PRIVACY POLICY

Introduction

This Privacy Policy (together with our End-User Licence Agreement and the User Agreement and any additional terms of use incorporated by reference into the End-User Licence Agreement and the User Agreement, collectively referred to as Terms of Use) applies to your use of:

• the YourPulses mobile application (Mobile App) that is available to download and/or install from the Apple App Store and Google Play Store (each and/or collectively Mobile App Store), once you have downloaded or streamed a copy of, or installed the App onto your mobile telephone or handheld device (Device),
• the web version of the YourPulses application (Web App), on the www.yourpulses.com (Website)
• any of the services accessible through the App (Services).

The term “App” is used for both or either of the Mobile App and Web App anywhere in this privacy policy.

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.

By proceeding and continuing to use the App you agree to this Privacy Policy and the applicable Terms of Use which will bind you.

In case you do not agree with this Privacy Policy and the applicable Terms of Use, please do not access, download, install, stream, or use the App or Services in any way.

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.

• Important information and who we are

  YourPulses is the controller and is responsible for your personal data (collectively referred to as "Company", "we", "us" or "our" in this policy).

  Contact details

  Our full details are:

  • Full name of legal entity: YourPulses ΙΚΕ (Company Number: 158436201000)
  • Email address: hello@yourpulses.com
  • Registered office/Postal address: Dimitriou Gounari 96, 15125 Amarousio, Attiki, Greece

  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:

  Website: www.dpa.gr
  Postal Address: 1-3 Kifissias Avenue, 115 23 Athens
  Telephone: +30 210 6475600
  Fax: +30 210 6475628
  Email: complaints@dpa.gr
  

  Changes to the privacy policy and your duty to inform us of changes

  We keep our privacy policy under regular review. This version was last updated on 09/04/2021. We reserve the right to periodically amend or revise this policy. This policy may change and if it does, the amended or revised policy will be published on this page and will be effective immediately upon publication. Your continued use of the App and the Services, following the publication of such amendments or revisions in this privacy policy constitutes your acknowledgment of the revised or amended privacy policy and your agreement and consent to be bound by the revised or amended privacy policy terms.

  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.

  Third party links, and third party products or services

  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.

• 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).

  We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, title, date of birth and gender.
  • Contact Data includes email address.
  • Device Data includes the type of mobile device you use, a unique device identifier, mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting, for the Mobile App.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Website for the Web App.
  • Transaction Data includes details of services, activities, or events that you participate in, perform, or carry out, or intend to or submit the willingness to participate in, perform, or carry out and details of such participation or performance, details of in-App transactions (meaning details on the redemption of pulse points, the issue of electronic coupons), details on the performance of on-your-own activities.
  • Profile Data includes your username and password, your interests, preferences, feedback, and survey responses, and information stored on your Device, including login information, photos, check-ins, or other relevant information.
  • Usage Data includes information about your use and visits to the App, the Website, and Services, including but not limited to traffic data and other communication data.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  • Location Data includes your location disclosed by GPS or other technology available on your Device for the Mobile App.

  We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App 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 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.

• How is your personal data collected?

  We will collect and process the following data about you:

  • Information you give us This is information (including Identity, Contact, and Marketing and Communications Data) you consent to giving us about you by filling in forms on the Website, the App, or by corresponding with us (for example, by email). It includes information you provide when you register to use the Web App, download, install, or use the Mobile App, subscribe to any of our Services, search for the App or Service, make an in-App transaction, such as the redemption of pulse points, submission of your interest in an action, submission of your performance of activities or participation in events, when you enter a competition, promotion or survey, and when you report a problem with the App, our Services, or the Website. If you contact us, we will keep a record of that correspondence.
  • Information we collect about you and your Device. Each time you visit the Website or use the App we will automatically collect personal data including Device, Technical, Profile and Usage Data. We collect this data using cookies and other similar technologies. Please see our cookie policy for further details.
  • Location Data. For the Mobile App, and specific in-Mobile-App Services or activities, we may use GPS technology to determine your current location. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings.
  • Information we receive from other sources including third parties and publicly available sources. Some third parties provide us with personal data about you, such as the following:
    • analytics providers (such as Google),
    • other service providers which you may interact with to sign up for or login to the App, or to use or when using the App or Website.

  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.

  Cookies

  We use cookies and/or other tracking technologies to distinguish you from other users of the App, the Services, or the Website and to remember your preferences. This helps us to provide you with a good experience when you use the App, Website or the Services and also allows us to improve the App, the Website and Services. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy.

• How we use your personal data

  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:

  • Where you have consented before the processing.
  • Where we need to perform a contract we are about to enter or have entered with you.
  • 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.

  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.

  Purposes for which we will use your personal data

  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.	Identity Contact Device	Your consent
  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 Contact Transaction Technical Device Marketing & Communications Location	Your consent 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 Contact Profile Marketing & Communications	Your consent 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 Contact Profile Usage 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 Contact Device Technical	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 Technical Usage	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)

  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 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.

• Disclosures of your personal data

  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:

  • Service providers who provide IT, system administration services and customer screening services.
  • Third parties to whom we outsource certain support services such as, without limitation, document processing and translation services, photocopying and document review, confidential waste disposal, IT systems and/or software and/or storage providers, IT Support service providers, document, and information storage providers.
  • Government or governmental agencies, regulatory authorities, courts and law enforcement agencies, registries. We may be required to disclose your information to comply with legal or regulatory requirements. We will use reasonable endeavours to notify you before we do this, unless we are legally restricted.
  • Advertising networks: to support and display ads on our App, and other social media tools.
  • Third party service providers to assist us with client insight analytics, such as Google Analytics.
  • Third party postal or courier providers who assist us in delivering our postal marketing campaigns to you, or delivering documents related to a matter.

  Please note the following:

  • This list is non-exhaustive and there may be other examples where we need to share with other parties to provide our services as effectively as we can.
  • We do not sell, rent, or otherwise make personal information commercially available to any third party, except with your prior permission.
  • 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.

• International transfers

  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.

• Data security

  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.

• Data retention

  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.

• Your legal rights

  Under certain circumstances you have the following rights under data protection laws in relation to your personal data.

  You have the right to:

  • Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
    • if you want us to establish the data's accuracy;
    • where our use of the data is unlawful but you do not want us to erase it;
    • where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
    • you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
  • You also have the right to ask us not to continue to process your personal data for marketing purposes.
  • You can exercise any of these rights at any time by contacting us at our postal address OR by email at support@yourpulses.com.