This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
If you do not agree with these terms, please do not access, download, install, or use the App or Services in any way.
This policy is provided in a layered format so you can click through to the specific areas set out below.
YourPulses is the controller and is responsible for your personal data (collectively referred to as "Company", "we", "us" or "our" in this policy).
Our full details are:
For any questions, clarifications or requests regarding the processing of your personal data, please contact us:
By letter to the above postal address, noted for: data privacy
By email to: DPO@yourpulses.com
In the event that you feel that your request has not been sufficiently dealt with or satisfied and that the protection of your personal data is in any way affected, you may contact the Hellenic Data Protection Authority, the Greek regulator, using the following contact details:
Postal Address: 1-3 Kifissias Avenue, 115 23 Athens
Telephone: +30 210 6475600
Fax: +30 210 6475628
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 our relationship with you.
The App or the Website may contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services. Please check these policies before you submit any personal data to these websites or use these services.
The purpose of the App involves the provision of redeemable pulse points upon the completion of eligible actions. These points may be used either via direct donations to certain third-party organisations participating in the App or via the issue of electronic coupons, uniquely identified by a QR code, used with, or against, the purchase of products or services by third-party entities participating in the App (online or in-person).
For the use of these coupons against the purchase of products or services by third-party entities, or for the redemption of the pulse points in connection with third-party entities you agree to be bound by the terms of these third-party entities, including their own privacy policies. We do not accept any responsibility or liability for these policies or for any personal data that may be collected by them in-person or through their websites or services. Please check these policies before you submit any personal data in-person, or to these websites or services.
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).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, 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.
We will collect and process the following data about you:
The provision of personal data about you from third parties may be subject to their policies and any applicable account settings you might have with them.
We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:
We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
|Purpose/activity||Type of data||Lawful basis for processing|
|To register you as a new App user.
For Mobile App, to register you as a new App user and install the App.
|To process in-App transactions and deliver Services, manage in-App submissions and requests, including your submissions regarding participation in events, performance of activities (including on-your-own activities), the issuance of coupons, the redemption of pulse points via donation or via coupons, to enable you to participate in in-App prizes, draws, competitions.||Identity
Marketing & Communications
Performance of our agreement with you
Necessary for our legitimate interests (to evidence the basis for issuing pulse points and allowing their redemption)
|To manage our relationship with you including notifying you of changes to the App, Website or any Services, or asking you to leave a review or complete a survey||Identity
Marketing & Communications
Performance of our agreement with you
Necessary for our legitimate interests (to keep records updated and to analyse how customers use our App/ Services)
Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)
|To enable you to partake in a prize draw, competition or complete a survey||Identity
Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our App/Services, to develop them and grow our business)|
|To administer and protect our business and this App and Website including troubleshooting, data analysis and system testing||Identity
|Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)|
|To use data analytics to improve our App, Website, Services, marketing, customer relationships and experiences||Device
|Necessary for our legitimate interests (to define types of users for our App and Services, to keep our App and Website updated and relevant, to develop our business and to inform our marketing strategy)|
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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
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 by law.
We may share personal information the following categories of third parties as necessary, only on a need-to-know basis, subject to the principle of data minimisation and all other applicable privacy principles:
Please note the following:
In order to provide our services, we may need to transfer your personal information to locations outside Greece. This may entail a transfer of your information from a location within the European Economic Area (the “EEA”) to outside the EEA, or from outside the EEA to a location within the EEA. For any transfer of data outside the EEA, we will implement appropriate measures to ensure that your personal information remains protected and secure in accordance with applicable data protection laws and the EU General Data Protection Regulation.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of Greece.
Where we have given you (or where you have chosen) a password that enables you to access the App, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
All of our partners, employees, consultants, workers and data processors (i.e. those who process your personal information on our behalf), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of such personal information, keep it secure and protect it.
Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.
We will retain relevant personal information for five (5) years from the date of our last interaction with you and in compliance with our obligations under the EU General Data Protection Regulation, or for longer if we are required to do so according to our legal, regulatory and/or compliance obligations or professional indemnity obligations. We may then destroy such files without further notice or liability.
In some circumstances you can ask us to delete your data: see "Your legal rights" below for further information.
In some circumstances we will 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.
In the event that you do not use the App for a period of 1 year then we will treat the account as expired and your personal data may be deleted.
Under certain circumstances you have the following rights under data protection laws in relation to your personal data.
You have the right to: