Privacy Notice

PULSE SMART HUB PRIVACY NOTICE

We respect the privacy of every person who visits Pulse Smart Hub’s website and/or uses the services made available by us from the Pulse Smart Hub website (the “Pulse Smart Hub Service”) and we are committed to ensuring a safe online experience.

1 PURPOSE OF THIS NOTICE
This privacy notice explains our approach to any personal information that you might supply to us (or that might be collected from you) in connection with your use of the Pulse Smart Hub Service and sets out your rights in respect of Pulse Smart Hub’s processing of your personal information.
This privacy notice will inform you how you can verify which of your personal information is collected by us through the Pulse Smart Hub Service and how you can request that we delete, update or transfer it.
This privacy notice is intended to assist you in making informed decisions when using the Pulse Smart Hub Service. Please take a moment to read and understand it. Please note that it should be read in conjunction with our Website Terms of Use.
Please also note that this privacy notice only applies to the use of personal information collected by us from your use of the Pulse Smart Hub Service or during your communications with us. It does not apply to personal information collected during your communications with third parties.

2 WHO ARE WE AND WHAT DO WE DO?
The Pulse Smart Hub Service is operated by Euro Payphone Ltd (“Euro Payphone”) whose principal activities include wired telecommunications activities.
Philip Allard is the data controller responsible for your personal information. Euro Payphone is a registered company with company number: NI020783 and whose principal address is 59 Royal Lodge Road, Belfast, B18 7HL

3 HOW TO CONTACT US?
If you have any questions about this privacy notice or want to exercise your rights, please contact us by:
• sending an email to hello@pulsesmarthub.co.uk;
• calling us on 020 7313 9571; or
• writing to us at 22 Berghem Mews, Blythe Road, marking your letter for the attention of Philip Allard, COO and Data Protection Officer.

4 WHAT PERSONAL INFORMATION DO WE COLLECT AND HOW DO WE COLLECT IT?
Our primary goal in collecting personal information from you is to give you a customised experience while allowing us to provide services and features that most likely meet your needs. In order to do so personal information may be collected from you in the following ways:
• Information you voluntarily provide to us.
We collect and maintain personal information that you voluntarily submit to us during your use of the Pulse Smart Hub Service (e.g. during the course of email exchanges with us or as part of any customer support interactions).
In particular, in order to sign up and create an account we require the following personal information from you:
• name;
• e-mail address;
• postal address;
• mobile number
You have the flexibility to provide us with as little or as much of this information as possible. However, the more information you provide, the more you will get out of the Pulse Smart Hub Service.
If you contact us, we may collect additional information from you.
• Information we collect through your use of the Pulse Smart Hub Service.
We may collect through our use of cookies, pixels, beacons, log files and other technologies personal information regarding your mobile device, computer hardware and software used to access the Pulse Smart Hub Service. This may include the following:
• IP address of device(s) used;
• browser type;
• operating system and device type;
• approximate location (e.g. London);
• access times and dates; and
• referring website addresses.
We may also collect personal information regarding your use of and activity on the Pulse Smart Hub Service.
This personal information allows us to deliver more helpful information, services and tools. Please see our cookie policy for further information.
• Information we collect from third parties.
We may also combine personal information that we collect through your use of the Pulse Smart Hub Service with personal information that: a) you have provided to third parties and in respect of which you have given the third party permission to share with Pulse Smart Hub; and/or b) we have obtained from a public record.
How do we use your personal information?
We collect and use your personal information to operate the Pulse Smart Hub Service efficiently and to deliver you the very best service. In particular, we may use your personal information for the following purposes:
• Provision of the Pulse Smart Hub Service.
to decide what information is provided to you via the website.
What is our legal basis?
Pulse Smart Hub’s legitimate interests
• Service administration.
We may use your personal information to:
o develop and improve the Pulse Smart Hub Service;
o send you administrative e-mails about the Pulse Smart Hub Service; and
o contact you to answer any queries you may have.
What is our legal basis?
It is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best service we can to you.
• Internal record keeping and legal compliance.
We may use your personal information for internal record keeping purposes and to check you comply with the Website and Portal Terms of Use.
What is our legal basis?
It is in our legitimate interest to ensure that we keep our records up-to-date in order to monitor who uses the Pulse Smart Hub Service, to comply with our legal obligations and to monitor your compliance with the Terms of Use.
• Marketing by us.
By email
By post
By phone
By text
What is our legal basis?
Your consent.
It is in our legitimate interest
•Sharing information with third party processors.

We may share your personal information with third party processors in order to provide the Pulse Smart Hub Service and associated products and services to you.

What is our legal basis?

It is in our legitimate interest to share your personal information in such a way to ensure that we provide the very best service we can to you. Where we share your sensitive personal data, we shall be relying on your consent to do so.

• Sharing information with professional advisors & potential purchasers.

We may share your personal information with professional advisers or regulatory authorities:
o to enable them to process your personal information on our behalf in a manner consistent with this privacy notice;
o to comply with our legal obligations;
o to enforce our legal rights; or
o protect rights of third parties.

Your personal information may also be shared with prospective buyers if we go through a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets.
What is our legal basis?
It is in our legitimate interest to share your personal information with such third parties to enable them to process your information on our behalf, to comply with and/or enforce our legal rights and obligations, to protect the rights of third parties and to facilitate business transitions. Where we share your sensitive personal data, we shall be relying on your consent to do so.

Any other purposes for which we wish to use your personal information will be notified to you either by updating our privacy notice or otherwise from time to time including the legal basis of such use.
5 HOW DO WE OBTAIN YOUR CONSENT?

Where use of your personal information by us requires your consent, you can provide such consent:
• at the time we collect your personal information following the instructions provided; or
• by informing Pulse Smart Hub by e-mail, post or phone using the contact details set out in this privacy notice.
6 USE OF COOKIES
The Pulse Smart Hub Service may use certain cookies, pixels, beacons, log files and other technologies of which you should be aware. Please see our Cookie Policy to find out more about the cookies we use and how to manage and delete cookies.
7 THIRD PARTY LINKS
The Pulse Smart Hub Service may contain links to third party websites and services. Please remember that when you use a link to go from Pulse Smart Hub to another website or you request a service from a third party, this privacy notice no longer applies.
Your browsing and interaction on any other website, or your dealings with any other third party service provider, is subject to that website’s or third party service provider’s own rules and policies.
We do not monitor, control, or endorse the privacy practices of any third parties.
We encourage you to become familiar with the privacy practices of every website you visit or third party service provider that you deal with and to contact them if you have any questions about their respective privacy policies and practices.
This privacy notice applies solely to personal information collected by us through the Pulse Smart Hub Service and does not apply to these third party websites and third party service providers.
8 TRANSFERS OUTSIDE THE EEA
We may transfer your personal data outside the EEA to servers in Ashburn Virginia, United States of America in connection with our business or for legal reasons. We will ensure that the transfer is lawful and that there are appropriate security arrangements.
The European Commission has decided that United States of America provides an adequate level of protection in relation to data that is transferred there.
9 HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION FOR?

We do not keep your personal data for any specific period but will not keep it for longer than is necessary for our purposes.
In considering how long to keep it, we will take into account its relevance to our business and our legal and regulatory obligations.
10 CONFIDENTIALITY AND SECURITY OF YOUR PERSONAL INFORMATION
We are committed to keeping the personal information you provide us secure and we will take reasonable precautions to protect your personal information from loss, misuse or alteration.
We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from:
o unauthorised access;
o improper use or disclosure;
o unauthorised modification; and
o unlawful destruction or accidental loss.
All our employees and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of the personal information of all users of the Pulse Smart Hub Service.

11 HOW TO ACCESS YOUR INFORMATION AND YOUR OTHER RIGHTS?
You have the following rights in relation to the personal information we hold about you:
• Your right of access.
If you ask us, we’ll confirm whether we’re processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.
• Your right to rectification.

If the personal information we hold about you is inaccurate or incomplete, you’re entitled to have it rectified. If we’ve shared your personal information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

• Your right to erasure.

You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or you withdraw your consent (where applicable). If we’ve shared your personal information with others, we’ll let them know about the erasure where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

• Your right to restrict processing.

You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or object to us processing it. It won’t stop us from storing your personal information though. We’ll tell you before we lift any restriction. If we’ve shared your personal information with others, we’ll let them know about the restriction where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

• Your right to data portability.

With effect from 25 May 2018, you have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or ask us to transfer this to a third party of your choice.

• Your right to object.
You can ask us to stop processing your personal information, and we will do so, if we’re:
o relying on our own or someone else’s legitimate interests to process your personal information except if we can demonstrate compelling legal grounds for the processing;
o processing your personal information for direct marketing; or
o processing your personal information for research unless such processing is necessary for the performance of a task carried out in the public interest.

• Your rights in relation to automated decision-making and profiling.

You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, and it produces a legal effect or similarly significantly affects you unless such profiling in necessary for entering into, or the performance of, a contract between you and Pulse Smart Hub.

• Your right to withdraw consent.
If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.
• Your right to lodge a complaint with the supervisory authority.
If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to the UK Information Commissioner’s Office (ICO). You can find details about how to do this on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.
12 CHANGE TO THIS PRIVACY NOTICE
We may make changes to this privacy notice from time to time.
To ensure that you are always aware of how we use your personal information we will update this privacy notice from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. We may notify you by e-mail of any significant changes. However, we encourage you to review this privacy notice periodically to be informed of how Pulse Smart Hub uses your personal information.

Last Updated January 2018