Privacy Policy

This privacy policy will explain how our organization uses personal data that we collect from third parties when we do business together.

1.1 Topics

• Who Are We?
• What Data Do We Collect?
• How Do We Collect Your Data?
• How Will We Use Your Data?
• How Will We Share Your Data?
• How Do We Store Your Data?
• Marketing Using Your Data
• What Are Your Data Protection Rights?
• What Are Cookies?
• How Do We Use Cookies?
• What Types of Cookies Do We Use?
• How to Manage Your Cookies
• Security
• Other Purposes
• Privacy Policies of Other Websites
• Changes to Our Privacy Policy
• How to Contact Us
• How to Contact the Appropriate Authorities

2 Who Are We?

PulseLearning Ltd. Barrow, Tralee, County Kerry, V92 C859, Ireland Telephone: +353 66 714 4600 Email: DPO@pulselearning.com

3 What Data Do We Collect?

PulseLearning collects the following data: Personal Data:

• Information about your location when you access the website
• Information that you provide to us through our websites when expressing an interest in obtaining additional information about our service, registering to use our service, or registering for an event. This includes data such as name, company name, email address, phone number, and other contact details.
• Information that you provide to us when applying for a job with our company, such as a resume or cover letter containing other details about your employment history
• Information that we may receive from a third party (such as LinkedIn or a recruiter) if you apply for a job with us. This will include your name, contact details, and any information contained in a resume, such as employment history.
• Information collected from cookies in your web browser. This information includes standard information from you (such as browser type and browser language), your Internet Protocol (IP) address, and the actions you take on the company website (such as the web pages viewed and links clicked). Our use of cookies to process information is explained in Section 14 of this policy.

In addition to Personal Data, PulseLearning may also collect Special Category (Article 9(1)) Data.

4 How Do We Collect Your Data?

You directly provide PulseLearning with most of the data we collect. We collect and process data when you do any of the following:

• Register online or place an order for any of our products or services.
• Register for the I Am Here mental health and wellbeing program.
• Voluntarily complete a customer survey or provide feedback on any of our message boards or through email.
• Use or view our websites with your browser’s cookies.
• Work as a collaborator in the delivery of our products or services.

PulseLearning may also receive your data indirectly from the following sources:

• Third-party companies acting on our behalf, such as recruitment companies
• Companies with whom we work to provide products or services

5 How Will We Use Your Data?

We will use your data to do the following:

• Process your order and manage your account.
• Communicate with you to deliver our products and services.
• Communicate with you to provide marketing information, if you opt in to allow us to do that.
• Communicate with you to deliver valuable resources to your role as an I Am Here Tribe Member and Ambassador.
• Communicate with you to provide notification of upcoming webinars and events.

6 How Will We Share Your Data?

PulseLearning will not share your data with any third party without your written consent.

7 How Do We Store Your Data?

PulseLearning securely stores your data in Microsoft 365, Pressidium, and Zoho. For all three, the data is held in the European Union. PulseLearning will keep your data for potentially up to six years. When this time period has expired, the data will be purged based on its creation date. This is covered by the PulseLearning policy document OP48 GDPR.

8 Marketing Using Your Data

PulseLearning would like to send you information about products and services of ours that we think you might like. If you have agreed to receive marketing, you can always opt out later. You have the right at any time to stop PulseLearning from contacting you for marketing purposes or giving your data to other members of the PulseLearning Group. If you no longer wish to be contacted for marketing purposes, you can unsubscribe on Mailchimp or send an email to DPO@pulselearning.com.

9 What Are Your Data Protection Rights?

You have the following rights in respect to the personal data that PulseLearning and I Am Here hold on you. Please contact us at this address to exercise any of the following rights:

9.1 The Right to Be Informed

9.1.1 Who Are We?

PulseLearning Ltd. and I Am Here, Sandy Lane, Barrow, Tralee, County Kerry, V92 C859, Ireland Telephone +353 66 714 4600 Email DPO@pulselearning.com

9.1.2 Where Do We Process Personal Data?

PulseLearning and I Am Here store and process personal data in miscellaneous documents and spreadsheets on local file servers hosted in our office in Ireland. Email-related personal data is processed in Ireland on the Microsoft 365 platform. For current and former Clients, accounting records are processed in a local instance of Sage hosted in our Irish office. The remaining Client data is processed on Microsoft Dynamics. Personal data on our website will be processed by Pressidium on EU-based servers. Some client personal data may be processed in our office in Canada on Microsoft Dynamics and is protected by appropriate access controls in line with our QP06 IT Policy. There is an adequacy decision in place between the EU and Canada for the protection of personal data.

9.1.3 Recipient(s) of the Personal Data

We are ISO 9001:2015 certified and an auditor from the British Assessment Bureau may need to examine our records as part of the regular recertification process.

9.1.4 Details of Personal Data Processed

9.1.5 The Right of Access

You have the right to obtain the following:

• Confirmation of your personal data being processed
• Access to a copy of your personal data
• Any other supplementary information

9.1.6 The Right to Rectification

You have the right to have your personal data corrected if it is inaccurate or incomplete.

9.1.7 The Right to Erasure (Includes Withdrawal of Consent)

You have the right to have your personal data erased in the following circumstances:

• You withdraw consent.
• The personal data must be deleted to comply with a legal obligation.
• The personal data was unlawfully processed.
• The personal data is no longer necessary in relation to the purpose for which it was originally collected.
• You object to the processing and there is no superseding legitimate requirement to continue the processing.
• The personal data is processed in relation to the offer of “information society services” to a child.

9.1.8 The Right to Restrict Processing

You have the right to ‘block’ or suppress processing of personal data.

9.1.9 The Right to Data Portability

You have the right to obtain and reuse your personal data for your own purposes across different services.

9.1.10 The Right to Object

You have the right to object to any of these:

• Processing based on legitimate interests or the performance of a task in the public interest or exercise of official authority (including profiling)
• Direct marketing (including profiling)
• Processing for purposes of scientific or historical research and statistics

9.1.11 Rights in Relation to Automated Decision-Making and Profiling

You have the right not to be subject to a decision under these circumstances:

• When it is based on automated processing
• When it produces a legal effect or a similarly significant effect on the data subject

9.1.12 The Right to Complain

If you feel that PulseLearning and I Am Here have not fulfilled their obligations under the GDPR or the Data Protection Act 2018, you have the right to lodge a complaint with the Data Protection Commission (DPC). The DPC offers guidance on how to make a complaint here: https://forms.dataprotection.ie/contact. If you make a request, we will respond to you within one month. If you would like to exercise any of these rights, please contact us at our email: DPO@pulselearning.com

9.1.13 Automated Decision-Making, Including Profiling

PulseLearning and I Am Here do not use any automated decision-making or profiling.

10 What Are Cookies?

Cookies are text files placed on your computer to collect standard internet log information and visitor behavior information. When you visit our websites, we may collect information from you automatically through cookies or similar technology.

11 How Do We Use Cookies?

PulseLearning uses cookies in a range of ways to improve your experience on our websites, including the following:

• Keeping you signed in
• Understanding how you use our websites

12 What Types of Cookies Do We Use?

View our Cookie Policy

13 How to Manage Your Cookies

On the Accept/Reject pop-up, there is a link to Cookie settings where you can set your cookie preferences directly.

14 Security

We take appropriate measures to ensure the security of personal data under our control and to prevent unauthorized access, disclosure, modification, or destruction of data. We have defined procedures and protocols for processing personal data, within QP06 IT Policy. All data stored on devices belonging to PulseLearning are encrypted with 128- or 256-bit AES encryption.

15 Other Purposes

Other purposes for which PulseLearning might process personal data can include the following:

15.1 Legal Action

Where necessary, we will process personal data provided to us for the purposes of seeking legal advice or other legal purposes. Examples of such processing would include providing information to debt collection agencies in the event of persistent nonpayment for products or services by an individual or sole trader. Also, where we receive a formal request under Article 23 of the GDPR, we may be required to disclose personal data of individuals to An Garda Síochána, the Revenue Commissioners, or other relevant organization.

15.2 System Logs, Maintenance, and Investigation of Data Security Breaches

We process certain data, including IP addresses, as part of our internal system logging on the PulseLearning websites to support the diagnosis of issues and maintenance of the websites. In addition, we will make use of detailed system logs on our web-hosting platform and within our Content Management System to support investigations of data security breaches.

16 Privacy Policies of Other Websites

The PulseLearning websites may contain links to other websites. Our privacy policy applies only to our websites, so if you select a link to another website, you should read their privacy policy.

17 Changes to Our Privacy Policy

PulseLearning keeps its privacy policy under regular review and places any updates on this web page. This privacy policy was last updated on 06-Oct-2020.

18 How to Contact Us

If you have any questions about the PulseLearning privacy policy or the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact the Data Protection Officer (DPO), Seamus Hand. Email: DPO@pulselearning.com Address: PulseLearning Ltd., Sandy Lane, Barrow, Tralee, County Kerry, V92 C859, Ireland

19 How to Contact the Appropriate Authorities

If you feel that PulseLearning has not fulfilled its obligations under the GDPR and Data Protection Act 2018, you have the right to lodge a complaint with the DPC. The DPC offers guidance on how to make a complaint here: https://forms.dataprotection.ie/contact