Privacy Policy

Last updated: September 2022

Introduction

Fenix Media Ltd T/A Pulsar is a technology company headquartered in London, UK.

Pulsar Platform is the leading AI-powered audience intelligence platform, combining conversational and behavioural signals from the world’s leading digital sources to help organisations understand their audiences and create messages that matter to them.

Pulsar is committed to protecting your personal data and this privacy policy states how we collect your personal data, how we store it and how we use it.

This privacy policy applies to Pulsar (“we”, “our” or “us”) as related to our website, marketing activities, products and services.

The purpose of this policy is to give you a clear explanation about how Pulsar (whether as a Controller in its own right or as a Processor for the “first party data” in our Pulsar tool) collects and uses the personal data you provide to us and that we collect.

We ensure that we use your information in accordance with all applicable laws concerning the protection of your personal data (Data Protection Law).

Information Collected

We collect personal data about you in three ways: directly from your input, from third-party sources, and through automated technologies.

• We collect your personal data from the public domain and social media sites and from other providers for the purposes of our research and analytics services;
• Our services collect and process information from a range of publicly available online sources, such as social networking sites and blogs. This content is only information that has been made publicly available, which can include personal information;
• We may also collect your details from publicly available sources such as LinkedIn, Winmo, GrowLabs and Google in order to send you information about our services.
• We collect your information, which may include: full name, company name, email address, telephone number, postal address/location, IP address, social handles/IDs, when you contact us or use the website
• You use the website to register for a webinar, download whitepapers or complete surveys
• As a job applicant, we may also collect your C.V. and cover letter
• We may also ask you to complete surveys that we use to help us improve our software and services, although you do not have to respond to them.
• In addition to the above, we collect information automatically about your visit to our website. Please see our Cookies Section for more details;

Information Collected from Other Sources

We also may obtain contact details and other information about you from our affiliates and from other third parties, including:

• Service providers that help us identify individuals and companies interested in our products;
• Businesses with which we offer co-branded services or engage in joint marketing activities; and/or
• Publicly-available sources and data suppliers from which we obtain data to validate or supplement the information we hold.

How we use personal information

The personal data we collect will be used for the following purposes:

• Responding to your enquiries as a data subject;
• Dealing with enquiries and requests about our services submitted to us via email or call;
• Requesting information about your services which are applicable to you, your company, our company and our clients.
• Deliver the contracted services and allow full use of the application functionality as purchased by the clients.
• Deliver training and support to our application end users and/or carry out the transactions you have requested.
• To communicate with you directly through emails, calls, chats, video conferencing.
• Process payments for application subscriptions.
• Carry out market research to understand how to improve our services and their delivery.
• Create and manage marketing campaigns.
• Generate sales leads and increase our market share.
• Analyse user clicks and usage of the application and website to improve user experience and maximize usage of our services.
• Prevent fraud and other prohibited or illegal activities.
• Protect the security or integrity of the website, application, our business or services.
• Or otherwise, as disclosed to you at the point of collection or as required or permitted by law.

Please note that sometimes we may record the video conferencing call in which you participate to analyse and improve our staff’s communication skills. If we do so, we will be announcing it at the beginning of the conference call and in the meeting invite, and we will be providing a link to our Privacy Policy in the meeting invites and on the registration page.

Provision of Services

We receive data – including personal data – from third party social media platforms and other online sources in order to provide our services. Examples of these third parties include Instagram, Facebook, YouTube API Services and Twitter. We work in accordance with their individual privacy policies and our contracts with them.

We only receive and process personal data that has been made publicly available by the individual data subject. This could include sensitive data, or special category information as defined under current Data Protection Law. For example, in relation to the YouTube Services

API, we process the following YouTube user information: subscriber count, views, video title, video description, video ‘like’ count and viewer demographics. We use this data to help provide insights from across different audiences including analytics information and visualisations for owned content performance and benchmarking. We can also gain insights into individual data subjects to help organisations and brands understand the individuals’ interactions with them.

The data we obtain depends upon the source and what individuals have chosen to make available. We may analyse the information published to gain additional insights such as gender, interests and geographic location.

Individuals can change their privacy settings at any time to alter the way they share their information publicly. We only have access to this data for as long as the individual makes it publicly available.

How we share information

Applications and services

If you are a data subject in our platform, your personal information may be viewed by our clients’ users with access to the platform.

Service providers

We use third parties to help us provide our products and services. They may have access to your information as collected by the website or the platform, as reasonably necessary to perform the contracted tasks on our behalf. We sign contractual agreements to obligate them to protect the personal information, only use it to deliver the contracted services to us, prohibit them from selling it and not disclose it without our knowledge and permission.

A list of our processors and sub-processors is available here: https://www.accessintelligence.com/trustcentre/sub-processors/

How we protect your information

We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal or transactional information stored on our website and systems.

The security measures we’ve put in place include:

• the encryption of client data;
• the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services;
• maintaining certifications with ISO 27001 and Cyber Essentials Plus
• the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident;
• a process for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures for ensuring the security of the processing

Your Rights

The right to access your personal data

You have a right to obtain confirmation that your personal data is being processed by us as a Controller. You also have the right to request a copy of your personal data we hold as a Controller.

Where applicable, we will provide a copy of your personal data within one month of receiving the written request. Should you wish to exercise these rights we require you to prove your identity with two pieces of approved identification (photo ID and proof of address such as utility bill).

The right to rectify and update your personal data

The accuracy of your personal data is important to us. You can rectify/update your personal data, including your address and contact details at any time.

The right to request to have your personal data erased

You have the right to request the deletion of your personal information at any time. We will communicate back to you within one month the result of your request. We may not be able to delete or erase your personal information, but we will inform you of these reasons and any further actions available to you.

The right to restrict processing of your personal data

You have the right to ‘block’ or suppress processing of your personal data. However, we will retain just enough of your personal data to ensure that the restriction is respected in the future.

The right to object

You have the right to object to our processing of your personal information for direct marketing purposes. This means that we will stop using your personal information for these purposes.

From the very first communication from us and every marketing communication we send after you will have the right to object to marketing.

Your right to lodge a complaint with a supervisory authority

The ICO is the UK’s independent body set up to uphold information rights in the public interest, promoting openness by public bodies and data privacy for individuals.

Keeping your personal data

We keep client account personal data for up to 7 years after the creation date to operate the service in accordance with legal requirements and tax and accounting rules or as otherwise permitted by applicable law. In addition we keep personal data of social media users for up to 2 years. Where any persona data is no longer required or is no longer relevant, we will ensure it is disposed of in a secure manner.

Marketing

We believe in being open, honest and transparent with our clients and suppliers and want you to feel comfortable about how we collect your personal data and how we process it. We will use the details you provide to us to communicate with you about how we can help you in your role and help your company achieve its objectives.

We promise that we will only communicate with you in the way you wish us to and we will always respect your privacy. You can change your mind at any time and it’s quick and easy to let us know that you no longer want to hear from us by contacting the Data Protection Officer.

In certain instances, we collect and use your personal data by relying on the legitimate interest legal basis. This is because when you, for example, request to receive services or products from us, we have a legitimate organisational interest to use your personal data to respond to you and there is no overriding prejudice to you by using your personal data for this purpose. However, we will always provide you with the option to opt-out of hearing from us.

We will only communicate to you in the way you have told us. For example:

Email/text marketing

In accordance with applicable law, where you provide us with your email address and/or mobile phone number, we may contact you for marketing purposes by email or text message. By subscribing to Fenix Media Ltd T/A Pulsar emails or opting in to email communication from Fenix Media Ltd T/A Pulsar, you grant us the right to use the email for email marketing.

Post/telephone marketing

If you have provided us with your postal address or telephone number, we may send you direct mail or telephone you about our work unless you have told us that you would prefer not to receive such information. We also actively check telephone numbers against the Corporate Telephone Preference Service (CTPS) and will only make telephone calls to you where your telephone number is listed on the CTPS if you have specifically told us that you do not object to such calls and have consented to receive them from Fenix Media Ltd T/A Pulsar.

Cookies Policy

A cookie is a piece of text that is stored on your computer by your web browser. We use cookies to monitor how people use our site so we can develop and improve the design, layout and function of the site.

Cookies enable us to identify your device. We use cookies that are strictly necessary to enable you to move around the site or to provide certain basic features. We use cookies to enhance the functionality of the website by storing your preferences, for example. We also use cookies to help us to improve the performance of our website to provide you with a better user experience. We also allow cookies that may be served where we embed social media links such as Twitter, YouTube and LinkedIn.

The following types of cookies may be used when you visit the Site:

Strictly necessary cookies

These cookies are essential in order to enable you to move around our website and use its features. Without these cookies, services you have asked for cannot be provided. They are deleted when you close the browser.

Performance cookies

These cookies collect information in an anonymous form about how visitors use our website. They allow us to recognize and count the number of visitors and help us understand which pages are the most popular and where visitors spend most of their time.

Functionality cookies

These cookies allow our website to remember choices you make, such as your name, the region you are in or the pages you have viewed. They are used to provide enhanced and more personal features.

If you personalize our pages, or register with our website or services, a persistent cookie helps us to recall your specific information on subsequent visits. This simplifies the process of recording your personal information, such as billing addresses, shipping addresses, and so on. When you return to our website, the information you previously provided can be retrieved, so you can easily use the features that you customized. Persistent cookies will be kept on your device until their expiry or manual deletion.

Targeting or advertising cookies

These cookies allow us and our advertisers to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of advertising campaigns. They remember that you have visited our website and may help us in compiling your profile.

Social Media cookies

These cookies allow you to connect with social media networks such as Facebook, LinkedIn, Twitter, Pinterest and Google+.

If you do not want us to use cookies in your browser, you can remove cookies from your computer’s hard drive, or set your browser to block cookies or to send a warning notice before a cookie is stored on your computer. However, please note that you may not be able to use many of the services on our website or other websites without cookies.

More detailed information on cookies can be found at www.allaboutcookies.org.

Appendix

A.1 For Individuals Based in the United Kingdom (UK), European Union (EU), European Economic Area (EEA) and Switzerland

If you are based in one of these jurisdictions, Pulsar is the controller of your personal data collected in the following instances:

• When you visit our website www.pulsarplatform.com
• When we process your personal data for sales and marketing purposes

Our legal basis for processing of your personal data is:

• Processing is necessary to meet contractual obligations entered into by us with our clients;
• Processing is necessary for purposes of our legitimate interests or our client in relation to goods and services when we process the names, contact details, job titles, companies of our existing and prospective clients for our marketing purposes, including market research and sales leads generation
• Processing is necessary to comply with a legal or administrative obligation.

The legitimate interests are as follows:

• Responding to your enquiry about our processing of your personal data;
• In response to an enquiry from you about our good and services;
• For the purpose of promoting our goods and service via direct marketing which are relevant to you in your role. We will always confirm how your personal data was obtained and always offer an opt out of direct marketing communications;
• Enquiring about your goods and services which are applicable to our company or our clients.

You have the following rights under the GDPR:

• Be informed about the collection and use of your personal data
• Access your personal data
• Correct errors in your personal data
• Object to the processing of your personal data.
• This right is also available to individuals whose personal data is processed by us for direct marketing purposes. If you object to the processing of your personal data for direct marketing purposes, we shall stop processing within one month of receipt of your request.
• Portability of your personal data
• Restrict our processing of your personal data for specific reasons, including any of the purposes supported by the legitimate interest legal bases (see the section above).

We process personal data in Ireland and share it with our service providers in EU, USA and other jurisdictions. We use standard contractual clauses as the data transfer mechanism of transferring UK/EU data to countries subject to data transfer requirements.

You may contact us at:

or you may contact our EU Data Representative at:

You may also lodge a complaint with your local supervisory authority, EU Data Protection Authorities (DPAs) or Swiss Federal Data Protection and Information Commissioner (FDPIC). See their contact details here National Data Protection Authorities: https://edpb.europa.eu/about-edpb/about-edpb/members_en

A.2 For Individuals Based in California

This section provides additional specific information for consumers based in California as required by the California Consumer Privacy Act of 2018 (“CCPA”).

A.2.1 Collection and Use of Personal Information

In the last 12 months, we have collected the following categories of personal information

• Identifiers, such as your name, mailing address, email address, zip code, telephone number or other similar identifiers
• California Customer Records (Cal. Civ. Code § 1798.80(e)), such as username and password, company name, job title, business email address and department
• Internet/network information, such as log and analytics data, information about the device(s) used to access the services and information regarding your interaction with our websites or services and other usage data
• Geolocation data, such as information about your location (at country and city level) collected from your IP address.
• Sensory Information, the content, audio and video recordings of conference calls between you and us that we record where permitted by you and/or the law
• Profession/employment information that you send to us when applying for a position included in your CV and cover letter
• Other personal information, such as personal information you provide to us in relation to a survey, comment, question, request, article download or inquiry and any other information you upload to our application

We collect personal information directly from you, from your browser or device when you visit our websites, from third parties that you permit to share your information or from third parties that share public information about you, as stated above.

A.2.2 Recipients of Personal Information

We share personal information with third parties for business purposes. The categories of third parties to whom we disclose your personal information may include: (i) our service providers and advisors, (ii) marketing and strategic partners; (iii) ad networks and advertising partners; (iv) analytics providers; and (v) social networks.

A.2.3 California Privacy Rights

As a California resident, you may be able to exercise the following rights in relation to the personal information about you that we have collected (subject to certain limitations at law):

• The right to know any or all of the following information relating to your personal information that we have collected and disclosed in the last 12 months (upon verification of your identity):
• The specific pieces of personal information we have collected about you
• The categories of personal information we have collected about you
• The categories of sources of the personal information
• The categories of personal information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed
• The categories of personal information we have sold and the categories of third parties to whom the information was sold, and
• The business or commercial purposes for collecting or selling the personal information.
• The right to request deletion of personal information we have collected from you, subject to certain exceptions.
• The right to opt-out of personal information sales to third parties now or in the future. However, we do not sell your personal information.

You also have the right to be free of discrimination for exercising these rights. Please note that if exercising these rights limits our ability to process personal information (such as a deletion request), we may no longer be able to provide you with our products and services or engage with you in the same manner.

Note that we will only be able to directly process the above requests in situations where we are the “business” under the CCPA, which refers to the entity that determines the purpose and means of information processing. This includes some situations where you provided the relevant information directly to us. However, in many cases we are instead a “service provider” under the CCPA, and are processing personal information on behalf of our customer or our client’s customer, who provided the information to us or on whose behalf we are collecting your personal information, and our customer or our client’s customer acts as the “business” under the CCPA. In those situations where we are acting as a service provider, we will refer your request to the applicable business instead.

A.2.4 How to Exercise Your California Consumer Rights

To exercise your right to know and/or your right to deletion, please submit a request by contacting us at [email protected]

We will need to verify your identity before processing your request. In order to verify your identity, we will generally require sufficient information from you so that we can match it to the information we maintain about you in our systems. Sometimes we may need additional personal information from you to be able to identify you. We will notify you.

We may decline a request to exercise the right to know and/or right to deletion, particularly where we cannot verify your identity or locate your information in our systems or as permitted by law.

Our application and services are intended for business use, and we do not expect them to be of any interest to minors. We do not intentionally collect any personal information of consumers below the age of 16. We do not sell the personal information of California consumers.