Privacy Policy

1. Introduction

This privacy policy explains how Pulse Digital Ltd ("PULSE", "we", "us", "our") collects, uses, stores, shares and deletes personal data.

It applies to:

  • our website at pulsedigital.co.uk and its subdomains; and

  • the mobile applications we publish on the Apple App Store and Google Play, namely Heartbeat CLM, Heartbeat CLM Viewer and Neo Hypnobirthing (together, the "Apps").

Where we build, host or operate digital services on behalf of our clients, those services are governed by the privacy policy of the client concerned, who acts as the data controller. In those cases PULSE acts as a data processor and this policy does not apply.

If you have any questions about this policy, please contact us at legal@pulsedigital.co.uk.

2. Who we are

For the purposes of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, the data controller is:

Pulse Digital Ltd
A limited company registered in England and Wales, company number 10649542
Registered office: Office 7, 35–37 Ludgate Hill, London, EC4M 7JN, United Kingdom
Email: legal@pulsedigital.co.uk

Our Data Protection Officer can be contacted at the address above, marked for the attention of the Data Protection Officer, or by email at legal@pulsedigital.co.uk.

3. What personal data we collect

  • 3.1 Through our website

    • Information you provide directly — your name, email address, telephone number, employer, job title and any other information you enter into contact forms, enquiry forms, surveys or job applications.

    • Correspondence — a record of communications between you and us, including emails and support tickets.

    • Usage data — details of your visits to our site, the pages and resources you access, and the dates and times of access.

    • Technical data — your IP address, browser type and version, operating system, device type and referring website, collected for system administration, security and analytics purposes.

  • 3.2 Through our Apps

    • Account and identity data — where the App requires an account, the username, email address and organisation associated with that account.

    • Content you create or access — presentations, notes, form entries and other content you generate or view within the App.

    • Device and diagnostic data — device model, operating system version, App version, unique device identifiers, crash reports and performance logs.

    • Usage data — features used, content viewed, session duration and interaction events, used to operate and improve the App.

    The Apps do not collect precise location data, contacts, photos, health data or advertising identifiers.

  • 3.3 Special category data

    We do not seek to collect special category personal data (such as data concerning health) through our website or Apps.

4. Cookies and similar technologies

We use cookies and similar technologies to distinguish you from other users, to operate our website and to improve it. Our Apps may use local storage and similar device-based technologies to hold session information and preferences.

Full details are set out in our Cookie Policy at pulsedigital.co.uk/cookie-policy.

5. How we use your data, and our lawful bases

Under the UK GDPR we must have a lawful basis for processing your personal data. Our bases are as follows.

Purpose Lawful basis

Responding to enquiries and providing the services you request

Performance of a contract, or steps taken at your request prior to entering a contract

Operating, maintaining and supporting the Apps

Performance of a contract

Diagnosing faults, monitoring performance and improving our products

Legitimate interests (running and improving our services)

Securing our systems and preventing fraud or misuse

Legitimate interests (protecting our business and our users)

Sending marketing communications

Consent, or legitimate interests where you are an existing customer and the communication relates to similar services

Meeting legal, regulatory and accounting obligations

Legal obligation

You can ask us to stop sending you marketing at any time by using the unsubscribe link in any marketing email or by emailing legal@pulsedigital.co.uk. Withdrawing consent does not affect the lawfulness of processing carried out before the withdrawal.

6. Who we share your data with

We may share your personal data with:

  • Service providers acting on our behalf — including hosting, infrastructure, analytics, error reporting and customer support providers. These providers process data only on our documented instructions under a written contract.

  • Our clients — where you use an App in connection with a client's platform, data associated with that use may be shared with the client, who is the controller of that platform.

  • Professional advisers — including auditors, lawyers and insurers, where necessary.

  • Regulators and law enforcement — where we are under a legal obligation to disclose, or where disclosure is necessary to protect the rights, property or safety of any person.

  • A purchaser or successor — if we sell or transfer all or part of our business, your data may be disclosed to the prospective purchaser subject to appropriate confidentiality protections.

We do not sell your personal data, and we do not share it with third parties for their own independent marketing purposes.

7. Where we store your data and international transfers

We host our website, our Apps and the personal data associated with them in data centres located in the United Kingdom and the Republic of Ireland. Your data is not routinely stored anywhere else.

Ireland is a member of the European Economic Area. The United Kingdom has determined that the EEA provides an adequate level of protection for personal data, so transfers between our UK and Irish infrastructure take place on the basis of those adequacy regulations and no additional safeguard is required.

A limited number of our service providers, such as those supplying error reporting and analytics, may process data outside the UK and EEA. Where that happens, we ensure a comparable level of protection by relying on one of the following:

  • transfer to a country that the UK Government has determined provides an adequate level of protection; or

  • an International Data Transfer Agreement, or the UK Addendum to the European Commission's Standard Contractual Clauses, supported by a transfer risk assessment and any additional measures it identifies as necessary.

You can request details of where your data is held, and a copy of the safeguards we rely on, by contacting legal@pulsedigital.co.uk.

8. How long we keep your data

We keep personal data only for as long as we need it for the purposes set out in this policy, or for as long as we are required to keep it by law. When a retention period ends, we securely delete the data or irreversibly anonymise it so that it can no longer be linked to you.

  • 8.1 Retention periods

    Category of data Retention period

    Website enquiry and contact form submissions

    24 months from your last contact with us

    Email and support correspondence

    6 years from the end of the relationship, to meet contractual and limitation-period requirements

    Marketing contact details and consent records

    Until you unsubscribe or object, plus 24 months to evidence that your preference was honoured

    Website server logs and security logs

    12 months

    Website analytics data

    14 months, after which it is aggregated and no longer identifies you

    App account data

    For as long as your account remains active, and then 30 days after the account is closed or a deletion request is completed

    App content you have created

    For as long as your account remains active, unless you delete it sooner

    App usage and analytics data

    12 months, after which it is aggregated and no longer identifies you

    App crash reports and diagnostic logs

    90 days

    Accounting and transaction records

    6 years from the end of the relevant financial year, as required by UK tax law

    Job applications from unsuccessful candidates

    12 months, unless you ask us to keep your details for longer

  • 8.2 Backups

    Personal data deleted from our live systems may persist in encrypted backups for a further 35 days, after which those backups are overwritten on a rolling cycle. Data held in backups is not used for any operational purpose and is restored only in the event of a system failure.

  • 8.3 Data we are required to retain

    In a small number of cases we are legally required to keep data even where you have asked us to delete it. This includes:

    • financial and transaction records, which we must keep for tax and audit purposes;

    • records needed to establish, exercise or defend legal claims; and

    • pharmacovigilance and product safety records. Where information you submit relates to an adverse event or product complaint concerning a medicinal product, we and our clients are required by medicines regulation to retain that record, and it cannot be erased on request. Where possible, we will restrict the record so that it is used only for safety reporting purposes.

    Where this applies, we will tell you which data we have retained and why when we respond to your request.

9. Your rights, and how to delete your data

  • 9.1 How to request deletion of your data

    You can ask us to delete the personal data we hold about you at any time. There is no charge for this.

    To submit a deletion request, email legal@pulsedigital.co.uk with the subject line "Data Deletion Request".

    Please include the following so that we can locate your records:

    • your full name;

    • the name of the App or service concerned;

    • the email address or username associated with your account, if you have one; and

    • whether you want all of your data deleted, or only specific items.

    You may also write to us at Pulse Digital Ltd, Office 7, 35–37 Ludgate Hill, London, EC4M 7JN, United Kingdom, marked for the attention of the Data Protection Officer.

    If you use one of our Apps with a registered account, you can also delete your account directly within the Apps. Deleting your account through the App removes your account and associated content in the same way as a request made by email.

  • 9.2 What happens after you submit a request

    1. We will acknowledge your request, normally within 5 working days.

    2. We may ask you for information to verify your identity. We do this to make sure we do not disclose or delete data at the request of the wrong person.

    3. We will complete your request and respond to you within one month of receiving it. If your request is particularly complex, we may extend this by up to two further months, and we will tell you within the first month if that is the case, along with the reason.

    4. We will delete the relevant data from our live systems within 30 days of confirming your request. Copies held in encrypted backups are removed as those backups are overwritten, as described in section 8.2.

    5. Where we are legally required to retain some of your data, we will tell you which data has been retained and on what basis.

    Where you use an App in connection with a client's own platform, some of the data associated with your use may be controlled by that client rather than by us. If that applies to your request, we will tell you and, where we can, direct you to the right contact.

  • 9.3 Your other rights

    Under UK data protection law you also have the right to:

    • Be informed about how we use your data — which is the purpose of this policy.

    • Access a copy of the personal data we hold about you. There is no fee for this.

    • Rectification — to have inaccurate data corrected and incomplete data completed.

    • Restrict processing in certain circumstances, for example while we investigate a challenge to the accuracy of your data.

    • Object to processing based on our legitimate interests, and to object to direct marketing at any time.

    • Data portability — to receive certain data in a structured, commonly used and machine-readable format.

    • Withdraw consent at any time where we rely on consent.

    • Not be subject to automated decision-making producing legal or similarly significant effects. We do not carry out such decision-making.

    To exercise any of these rights, contact legal@pulsedigital.co.uk. We will respond within one month.

10. Security

We maintain appropriate technical and organisational measures to protect personal data against unauthorised or unlawful processing and against accidental loss, destruction or damage. These include encryption of data in transit and at rest, access controls on a least-privilege basis, logging and monitoring, and staff training.

If we give you a password or access credentials, you must keep them confidential and must not share them. No method of transmission or storage is completely secure, and while we take appropriate measures we cannot guarantee absolute security.

If a personal data breach occurs that is likely to result in a risk to your rights and freedoms, we will notify the Information Commissioner's Office within 72 hours and, where the risk is high, we will notify you directly.

11. Children

Our website and Apps are intended for business and professional users and are not directed at children. We do not knowingly collect personal data from anyone under the age of 16. If you believe a child has provided us with personal data, contact legal@pulsedigital.co.uk and we will delete it.

12. Links to other websites

Our website and Apps may contain links to third-party websites and services. This policy does not apply to those sites, and we are not responsible for their content or privacy practices. We encourage you to read the privacy policy of any site you visit.

13. Changes to this policy

We may update this policy from time to time. Any changes will be posted on this page with a revised "Last updated" date. Where changes are significant, we will notify you by email or through the App.

Previous versions of this policy are available on request.

14. How to complain

If you are unhappy with how we have handled your personal data, please contact us first at legal@pulsedigital.co.uk so that we can try to resolve it.

You also have the right to complain to the UK supervisory authority:

Information Commissioner's Office
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Helpline: 0303 123 1113
ico.org.uk/make-a-complaint

15. Contact us

PULSE
Office 7, 35–37 Ludgate Hill, London, EC4M 7JN, United Kingdom
Privacy and data protection enquiries: legal@pulsedigital.co.uk
General enquiries: enquiries@pulsedigital.co.uk