At Pulse Concierge LLC (herein referred to as the Company), we recognise the importance of protecting your private and confidential information and operate in compliance with the UAE Federal Decree Law No. 45 of 2021 Regarding the Protection of Personal Data.
Given the nature of our business, we pledge to you to respect and store your data securely and confidentially, whether you use our services, sites, and platforms (website & apps) as a guest, or a registered user.
This Privacy Policy will inform you as to how we safeguard your personal data when you use our services, tell you about your privacy rights, and how the law protects you.
1.IMPORTANT INFORMATION AND WHO WE ARE
PURPOSE
This Privacy Policy aims to give you information on how the Company collects and processes your personal data through your use of any of our services, including any data you may provide when you register or sign in on any of our sites or platforms, purchase a product or service, or take part in a event.
It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements these other notices and is not intended to override them.
PERSONS UNDER AGE OF 16 YEARS
Our platforms and sites are not intended for children use and we do not knowingly collect data relating to children, except the minimum legally required information for our service providers. Our Sites are not intended for use by persons under 16 years of age without legal parental, or guardian consent. If we learn we have collected, or received personal information from a person under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from, or about a person under 16 for which there is no legal parental, or guardian consent, please contact us.
CONTROLLER
We have appointed a data protection officer ("DPO") who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below. Attention: Data Protection
You have the right to make a complaint at any time to the relevant supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the relevant supervisory authority, so please contact us in the first instance.
For any questions or comments relating to this Privacy Policy, or the manner in which we collect and use your personal data, please contact us.
CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
THIRD-PARTY LINKS
The Sites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our platforms and sites, we encourage you to read the privacy policy of every website or other site you visit.
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
Depending on which of our products and/or services you use and how you interact with our platforms and sites, we collect different kinds of information from or about you. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
• Identity Data: first name, last name, address, username or similar identifier, marital status, title, date of birth, and gender, passport, Emirates ID and Residence Visa.
• Financial Data: bank account and payment card details, payment history.
• Transaction Data: payments to and from you and details of products and services you have purchased from us.
• Technical Data: internet protocol (IP) address, your login data, browser type and version, make and model (mobile phones only), operating system, hardware version, platform, device settings and other technology identification on the devices used to access our platforms and sites, file and software names and types, device identifiers, time zone setting and location, device locations such as through GPS, Bluetooth or WiFi signals, browser plug-in types and versions, operating system and platform, connection information such as the name of your mobile operator or ISP, browser type, language and time zone, mobile phone number and IP address.
• Profile Data: username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data: information about how you use our platforms and sites, products and services including redemption of our offers, how you use your devices to access our platforms and sites, including the screens you visit and searches you make. • Special Categories: includes details about your race, ethnicity or religion.
• Other Data:
• Photos or other data uploaded onto any of our sites or platforms by you, or shared with other users of our sites or platforms by you
• Communications with us via social media platforms, email, electronic messages and other electronic and non-electronic communications;
• Third party partner information related to how you use our third party partners, such as your reviews of our merchant partners, or other service providers.
• Your networks and connections made available to us, depending on the permissions you have granted, from your mobile and desktop devices' address book contacts, and other social media such as Facebook, Instagram, Pinterest and Twitter etc
• Marketing and Communication Data: your preferences in receiving marketing from us and our third parties, and your communication preferences.
We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law, as this data does not directly or indirectly reveal your identity.
For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific site feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.
We do not collect the following Special Categories of Personal Data: your philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. Nor do we collect any information about criminal convictions and offences.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
Direct interactions: You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• apply for or purchase our products or services;
• create an account or register with us;
• subscribe to our service or publications;
• request marketing to be sent to you, or further services to be provided to you;
• enter a competition, promotion or survey;
• correspond with us (online or offline including via email addresses and phone numbers), if you contact us; post material on our platforms or sites; or give us some feedback.
You also may provide information to be published or displayed (hereinafter, "posted") on public areas of our platforms / sites or transmitted to other users of our platforms / sites or third parties (collectively, "User Contributions").
Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, you may set certain privacy settings for such information by logging into your account profile or by contacting us. Please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of our Sites with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorised persons.
Automated technologies or interactions: As you interact with our sites, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs, web beacons, and other similar technologies. We may also receive Technical Data about you if you visit other sites employing our cookies.
Cookies: We automatically capture some information through the use of cookies. A cookie enables certain features and functions of our platforms / sites. Cookies can be categorised into four types:, each:
• Category 1 : Strictly necessary cookies. These cookies are essential for us to provide our services to you in a seamless fashion.
• Category 2 : Performance cookies. Performance cookies collect anonymous information and will not include personal information that could identify you.
• Category 3 : Functionality cookies. These cookies retain choices you make such as member ID, email ID and other preferences in order to help you avoid having to re-enter the information and are designed to help you as a user.
• Category 4 : Targeting or advertising cookies. These cookies collect information about your browsing habits to allow us to provide advertising relevant to you and your interests. This information is shared with other parties such as advertisers on an anonymous basis.
Web beacons : Pages of our Sites and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an e-mail and collect other related website and app statistics (for example, recording the popularity of certain app content and verifying system and server integrity).
We do not collect personal information automatically, but we may tie this information to personal information about you that we collect from other sources or you provide to us.
Log files : We may use log files to capture your activities on our apps as they interact with our Sites. Information captured in such log files may include the types of content you view or engage with and the frequency or duration of your activities.
Third parties or publicly available sources : We may receive personal data about you from various third parties and public sources as set out below :
• Technical Data from the following parties:
• analytics providers based either inside or outside the UAE;
• advertising networks based either inside or outside the UAE; • search information providers based either inside or outside the UAE; or
• third parties we contract with and/or their subsidiaries and affiliates to provide you a service based either inside or outside the UAE
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services based either inside or outside the UAE.
• Identity and Contact Data from data brokers or aggregators based either inside or outside the UAE.
• Identity and Contact Data from publicly availably sources based either inside or outside the UAE.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where we need to perform a contract we have with a third party to provide you a product or service.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email, text message or other means. You have the right to withdraw consent to marketing at any time by contacting us.
5. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us.
6. MARKETING & ADVERTISING
At Pulse Concierge LLC we want to give you complete control regarding certain personal data uses, particularly around marketing and advertising.
If you do not wish to have your personal data used by the Company to promote our own, or third parties' products or services, you can opt-out by contacting us. However please keep in mind that by opting out of this, we are unable to tailor our offerings and services to you based on what we think you may need, or what may be of interest to you.
If we have sent you a promotional e-mail, you may send us a return e-mail asking to be omitted from future e-mail distributions. This opt out does not apply to information provided to the Company as a result of a product or service purchase, product service experience or other transactions.
If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers' target-audience preferences, you can opt-out by Contacting us.
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
THIRD PARTY MARKETING
Before we share your personal data with any company outside the Company for marketing purposes, will obtain your consent, however we do not control third parties' collection or use of your information. These third parties however, should provide you with opt-in or opt out options, as we have. On the rare occasion that data is not being used the way you have requested, with these third parties, please contact us at any time.
LOCATION INFORMATION
You can choose whether or not to allow our Sites to collect and use real-time information about your device's location through the device's privacy settings. If you block the use of location information, some parts of our platforms / sites may then be inaccessible, or not function properly.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
7. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
• Internal Third Parties as set out in Section 10 – Glossary below.
• External Third Parties as set out in Section 10 – Glossary below.
• Third parties listed in the table in Section 4 – How we use your Personal Data above;
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.
• To a third party you nominate to fulfil the purpose for which you provide it. For example, if you give us an e-mail address to use the "e-mail a friend" feature of our Sites or you nominate another person to become a secondary member in family account, we will transmit the contents of that e mail and your e-mail address to the recipients.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
8. PROTECTING YOUR DATA: WHERE, HOW AND FOR HOW LONG?
We share your personal data within the Company. This does not involve transferring your data outside the United Arab Emirates.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the following regarding the data we hold on you:
• Request data access
• Request data correction
• Request data erasure.
• Object to data processing
• Request data restriction
• Request data transfer
• Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us.
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10.OUR COMMITMENT TO YOU
At Pulse Concierge LLC, we firmly believe in protecting our members and adhere to the following:
1. Ensure confidentiality, integrity, preservation and security of all data we hold on you.
2. Take the necessary action to ensure that suitable controls and resources are in place to fulfil our commitment to you
3. Maintain effective Information Security Management System (ISMS) through the implementation of the appropriate policies, procedures, and controls. 4. Ensure that we as a Company review and develop our ISMS protocol
5. Promote awareness amongst internal and external parties by sharing knowledge and responsibility.
• Internal Third Parties include: Our companies, their subsidiaries and affiliates acting as joint controllers or processors who provide IT and system administration services and undertake reporting.
• External Third Parties include: • Service providers acting as processors who provide IT and system administration services, or who we use to support our business and who are bound by contractual obligations to keep personal data confidential and secure and use it only for the purposes for which we disclose it to them.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• Revenue & Customs, regulators and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances.
• Any other party, their subsidiaries and affiliates which we have contracted with to provide you with a service and/or product.
6. Ensure compliance with all of UAE governments laws and regulatory requirements.