This Personal Data Protection Notice (“this Notice”) was updated on: 16 June 2020.
The Pulsifi Group consist of the following legal entities:
a. Pulsifi Pte. Ltd. (Company No:201632137C-H); and
b. Pulsifi Sdn Bhd. (Company No: 1214546-H).
When we use the term “Pulsifi”, “we” or “us” in this Notice, we are referring to the relevant legal entity within the Pulsifi Group that processes your personal data. We will let you know which entity will be the controller for your data when you purchase or use a product or service from us.
Pulsifi Pte. Ltd. (Company No:201632137C-H) is the controller and responsible for the Portal (defined below).
From time to time, Pulsifi may be a joint data controller (pursuant to Art. 26 of the General Data Protection Regulation (“GDPR”)) when collaborating with certain third parties like employers (who are also data controllers). Please refer to the section Joint Controller below for more details.
The Pulsifi Group are committed to protecting the privacy of visitors and users of www.pulsifi.me and all related portals, sites and Apps (collectively referred to as the “Portal”) and our customers, candidates and partners. As a user of this Portal or our services, this Notice outlines what information we may collect about you, how we use and share that information, how you may access your information and your choices about the use and disclosure of your information. If you have any questions about this Notice, please contact us via the contact details below.
Collection of Personal Data
Personal data means any information about an individual from which that person can be identified. It excludes data where the identity of the individual has been removed (anonymous data).
When you use the Portal, we may collect, use, store and transfer different kinds of personal data about you. These include:
- Personal details (including your name, date of birth, gender, identification card/passport/birth certificate number, nationality);
- Qualification details (including education, qualifications, work history, training, occupation, job description, job history, curricular vitaes, competency profiles, psychometric reports, performance reviews and other data provided by your employer);
- Contact details (including as address, e-mail address, telephone number);
- Payment details (such as bank account, credit/debit card and other payment details);
- Technical details (including login data, IP address, browser type and version, time zone and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Portal);
- Profile details (including psychometric profiles, reasoning abilities, vocational interests, organizational values, interests, background, social profile links, news, posts, tweets, blogs, photos and other data publicly available on the internet or obtained with your expressed consent your username and password, preferences, feedback and survey responses);
- Marketing and Communications details (including your preferences in receiving marketing materials and communication preferences); and
any information which you have provided in registration/application forms or any other similar forms, any social networking information provided or to which we are given access, references and/or any information about you that has been or may be collected, stored, used and processed by Pulsifi from time to time, Pulsifi only collects, uses and discloses sensitive personal data with your explicit consent for the purposes for which your explicit consent has been obtained. This information may be collected when you use this Portal or our services, you sign up or contact us, you provide feedback, whether through this Portal or other social networking services such as Facebook, from the world wide web or social media, when you carry out any transactions with us, or from our partners, affiliates or associates, industry research or databases. In addition, we may from time to time request certain other personal information which may be relevant for the purposes of providing our services and which we will inform you of accordingly.
We also collect, use and share Aggregated Data. Aggregated Data is data that may be obtained from your personal data but is not considered personal data under the General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR”) law as this data will not directly or indirectly reveal your identity (e.g. demographic or statistical data). As an example, we may aggregate your Qualification details to calculate the percentage of users who are of the same professional in that accesses a specific Portal feature. If we combine or connect Aggregated Data with your personal data in a manner that allows you to be identified, we will treat the combined data as personal data which will be used in accordance with this Notice.
We do not collect any Special Categories of Personal Data unless you have given Pulsifi explicit consent and we will only use those data for the purposes for which your explicit consent has been obtained. They include your race or ethnicity, political opinion, religious or philosophical beliefs, sex life, sexual orientation, genetic and biometric data, criminal convictions, trade union membership and information about your health.
You will ensure that any personal data you provide (whether for yourself or another person) is accurate, complete, not misleading and up-to-date and you will update/correct such personal information in a timely manner if and when it becomes inaccurate, misleading, incomplete or outdated by informing Pulsifi. If you provide any personal data of any other person, you will ensure that such person has consented to the provision of such information and the terms of this Notice. If requested, you will provide the necessary written confirmation of such consent.
While the provision of personal data is not mandatory, it is required in connection with the purposes as stated below, and if we do not have this information we may not be able to carry out the purposes or provide our services.In such situation, we may have to cancel the products and/or service you have with us but we will notify you if this is the case at the time.
We use different means to collect your data. These means include the following:
- Direct interactions. You may give us your Personal, Qualification, Contact and Payment details by filling in forms or by corresponding with us. This includes personal data you provide when you purchase or use our products or services; create an account on the Portal; request marketing to be sent to you; and give us feedback or contact us.
- Automated technologies or interactions. When you use the Portal, we will automatically collect Technical details. This is done by using cookies and other similar technologies. Please see the cookie, analytics and automatic collection of information section of this Notice for further details.
- Publicly available and Third Parties sources. We receive personal data from a variety of publicly available and Third Parties (see glossary for meaning) sources. These are set out below:
a. Technical details: Google Analytics, Hotjar and Auth0.
b. Personal, Contact, Qualification and Profile details: your current employer, prospective employer, LinkedIn, Facebook, Twitter, other sources with your explicit consent and publicly available information.
Cookies, analytics and automatic collection of information
We may use and disclose aggregated and anonymised statistics about usage of this Portal or our services. We may also use research or marketing companies to gather such data and provide statistical information about visits to this Portal, data on visitors’ screen settings and other general information. We may also use in-house or third party services to collect and analyze the activities on our Portal and information on our visitors, users, candidates and customers, for system administration, reporting purposes or to improve the Portal or our services/products, and such third party may have access to your personal information on terms which are similar to this Notice.
Use of Personal Data
Pulsifi uses for personal data for various purposes and they are set out in the table below. To process your personal data, we must have a lawful basis to do so. We have set out those in the table below. Please note that we may have more than one lawful basis for using your personal data. For more information on the lawful basis, please see the glossary section to find out more about the different lawful basis that Pulsifi relies on to use your personal data.
Please note that we do not generally rely on consent as a legal basis for processing your personal data except in certain situations such as sending you third party direct marketing communications via SMS or email. You have the right to withdraw your consent to our marketing activities at any time.
|Purpose||Data Type||Basis for processing|
|To provide services or to perform any of Pulsifi’s obligations, including without limitation any services or obligations related to human resource, talent management, assessment, hiring and staffing.|
|To process, manage or verify requests or applications for any services or any subscription.|
|To validate and/or process payments, rebates, refunds and charges.|
|To send you alerts, updates, mailers, promotional materials and the like from Pulsifi, our partners, customers, advertisers or sponsors and to communicate with you about services, products, events or promotions that may be of interest to you or for registration or attendance at any event or activity.|
|For any other purpose that is ancillary to or in furtherance of these above purposes or which is required by law or any regulatory authorities or where we have your permission to do so.|
|To communicate with you for any of the purposes listed in this Notice.|
|To respond to questions, comments and feedback.|
|To perform functions described at the time of collection of the personal information.|
|To enforce our legal rights or obtain legal advice.|
|To comply with legal and regulatory requirements.|
|To facilitate or enable any checks, verification, testing and profiling as may be required.|
|To manage/operate our business and for internal purposes (such as auditing, data analysis, database records, focus groups, evaluating our services and effectiveness of our marketing efforts, research and development and risk management).|
|In the unlikely event of a sale of the Pulsifi Group or part thereof.|
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 consistent and compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is consistent and/or compatible with the original purpose, please contact us.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Who do we disclose personal information to?
In connection with the above use of your personal information, we may disclose such personal information to the following for the purposes set out in the table above:
- Employers, customers, and partners to whom we provide various services or products in connection with this Portal or our business or operations, or who have contractual arrangements with us (whether in relation to your transaction or requested service or otherwise).
- Service providers, contractors, agents and professionals who provide various services or facilities to us in connection with this Portal, our business or operations or who have contractual arrangements with us.
- Our employees, contractors, agents, and advisors.
- Certain third parties from whom we may obtain information relating to you (such as references) and where such disclosure is necessary to obtain the information.
- Financial institutions, third-party payors, credit card, and payment gateway companies.
- Any other person who may be an assignee, transferee or participant in some way in our rights or business (whether actual or proposed). If a change happens to the Pulsifi Group, then the new owners may use your personal data in the same way as set out in this Notice.
- Other parties authorized or consented to by you.
- Regulatory, enforcement and governmental authorities as permitted or any person as required by law or to comply with the directives of the authorities or any order of court or legal process.
- Any other person to whom disclosure is required in order to protect or defend our rights and/or property.
- Any of our subsidiary, parent, associated or affiliated companies.
- Any other person to whom we (and our subsidiary, associated or affiliated companies or representatives) have a duty of disclosure under applicable law, regulations or guidelines.
Pulsifi Group requires all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow any of our third-party suppliers or service providers to use your personal data for their own purposes. We will only permit them to process your personal data for specified purposes and in accordance with our instructions.
Transfer outside your country or the EEA
Please note that such disclosure or use may involve the transfer of your personal information to places outside of your local country/jurisdiction and by providing us with such information, you consent to such transfer in connection with your dealings with us, the requested services or for the performance of contractual obligations or for other legal or business purposes. Any such transfer will be pursuant to contractual arrangements and other safeguards to ensure the appropriate levels of protection equivalent to the protection granted under the Personal Data Protection Act 2012 of Singapore and in accordance with this Notice and applicable law. This includes ensuring that recipients of such transferred information are in a jurisdiction which has comparable data protection laws or are otherwise bound to protect the personal information, having appropriate security arrangements and processes to protect and manage the information and ensuring that the collection and use of the information is for the purposes(s) set out in this Notice.
We share your personal data within the Pulsifi Group and with some of our third-party suppliers and service providers. This will involve processing and transferring your data outside the European Economic Area (“EEA”).
Whenever we transfer your personal data out of the EEA, we will ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards are in place. In this regard:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- Where we use third party suppliers or services providers that are based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.
Please contact us if you would like further information on the specific mechanism used by us when we process or transfer your personal data out of the EEA.
By using our services and/or the Portal and/or providing your personal data, you consent to the collection, use and processing of such information in the manner explained in this Notice (and which is subject to change from time to time). If you do not consent or if you withdraw your consent, you will inform us accordingly. In the event you withdraw your consent, we will inform you of the likely consequences of such withdrawal of consent.
You further consent to your educational, qualifying, training and professional institutions/bodies, employers, customers and referees disclosing your personal information to us. In addition, certain institutions/bodies, employers, referees and customers may require your express consent or submission/confirmation of certain information or documents in connection with the provision of our services. If so, you will be requested to provide such express consent, forms or information (as the case may be) in order to proceed with the provision of the services.
Your Legal Rights
The GDPR gives you the right:
- To request correction of your personal data if it is incorrect or out of date. If the data we hold about you is out of date, incomplete or incorrect you can inform us and your data will be updated.
- To request access to the personal data we hold about you, without charge (certain exceptions apply and can be explained by contacting the subject access email below in more detail as needed).
- To request to withdraw consent for processing your data if that process relies on consent.
- The right to object to processing of your data. You may request that we stop processing information about you. Upon receiving your request, we will contact you and let you know if we are able to comply or if we have legitimate grounds to continue to process your data. Please note that even after you exercise your right to object, we may continue to hold your data to comply with your other rights or bring or defend legal claims.
- The right to data portability. You may request that we transfer your data to another controller if the data is processed by automated means (i.e. excluding paper files).
- The right to request restriction of processing of your personal data.
- To request that we delete your data and the right to erasure (the “right to be forgotten”). If you feel we should no longer be using your data, you can request that we erase the data that we hold.
If you wish to exercise your rights, please contact us using the details in the contacting us section below.
Please note that if you use the Pulsifi service as part of your company’s employee assessment activity or for a job application, be aware, the data controller would be your employer or potential employer and it is responsible for assisting you in exercising your rights. Therefore, we would recommend that you contact them in the first instance.
You will not have to pay a fee to access your personal data or to exercise any of your rights in this Notice. However, we may charge a reasonable fee if your request is unfounded, excessive and/or repetitive; or we may refuse to comply with your request in these circumstances.
In order for you to exercise your rights, we may request specific information from you to assist us in confirming your identity. This is a security measure to prevent personal data from being disclosed to unauthorised persons. Generally, we will respond to all legitimate requests within one month. There may be times when it takes us longer than a month e.g. your request is particularly complex or you have made numerous requests. In these situations, we will notify you and keep you updated.
In so far as we may be a joint controller in certain circumstances, we have an arrangement with such joint controllers which determines our respective responsibilities for complying with applicable law, but which does not affect data subjects’ rights against each controller. Pulsifi and the joint controller provide the necessary information about the processing of the personal data, and Pulsifi does so via this Notice. Pulsifi will assist a joint controller, so far as reasonably possible, to respond to requests in the exercise of data subjects’ rights. Please direct any questions about these arrangements to our contact details provided below.
Third-Party Portals or providers.
You may opt-out of receiving marketing communications from us and selected third parties and limiting the distribution of your personal information. You can do so by contacting us via the contact details below or so far as applicable, by accessing your registration/account with us or by clicking on the “unsubscribe” link in certain electronic communications we may send to you.
When we receive your request to opt-out from receiving marketing communication, it may take up to fourteen (14) working days for your opt-out to be updated in our records and systems. Accordingly, you may still receive marketing communication during this short period of time. Kindly be reminded that even if you opt-out from receiving marketing communication, we may still contact you for other purposes in relation to the transactions between us or the services you have requested from us.
Protection of Personal Data
We take the necessary security and technical measures to protect the security and confidentiality of personal data in compliance with applicable law. The transmission of payment information (such as credit card and account numbers) is protected through the use of encryption such as SSL (Secure Socket Layer) protection. However, as no means of Internet or mobile transmission or mode or digital transfer or storage is entirely secure, we cannot guarantee its absolute security.
Checking & Updating Your Details & Passwords
If you wish to access, verify or correct your personal data or obtain information about how your personal data may have been used or disclosed in the past year, you may do so by contacting us via the contact details below. Please note that depending on the request, we may charge a small fee. Please also note that in certain circumstances, we may be prevented by law from complying with your request and we may also decline the request if allowed to do so by applicable law or if the relevant records are no longer retained by us.
Our security procedures mean that we may request proof of identity before we reveal information or carry out the requests. This proof of identity may take the form of your username/e-mail address and password (or other sign-in information) submitted upon registration (so far as applicable). Therefore, you should keep this information safe as you will be responsible for any action which we take in response to a request from someone using your username/e-mail and password. If you have an account with us, you can also update your personal information by accessing your account. You undertake to keep safe and not disclose to third parties, your account information, including passwords and sign-in information. We are not responsible for any misuse or disclosure of access information or passwords.
Pulsifi will only retain your personal data for as long as reasonably necessary in order to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, accounting tax and reporting requirements. In the unlikely event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you we may retain your personal data for a longer period.
Changes to the Notice
We reserve the right to modify and change this Notice from time to time. Any changes to this Notice will be published at www.pulsifi.me and your continued use of the Portal or our services will constitute your acceptance of the modified Notice.
If there are any inconsistencies between this Notice and the terms and conditions of the services we provide to you, the latter shall prevail.
Consent. You have given your consent to the processing of your personal data for one or more specific purposes.
Performing the Contract. Processing your personal data is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract.
Comply with legal obligation. Processing your personal data where it is necessary for compliance with a legal obligation that Pulsifi is subject to.
Legitimate Interest. Processing your personal data in the interest of Pulsifi’s business to conduct and manage our business. We will not use your personal data for activities where our interests are overridden by the impact on you.
If you wish to contact us, you have any questions about this Notice or if you would like us to stop or limit the use/processing , request access to, update or correct your personal data within our possession and control, please contact us at firstname.lastname@example.org or
Pulsifi Pte. Ltd.,
Legal & Compliance,
150 Cecil Street,
#03-00, Singapore 069543
You have the right to complain to your supervisory authority although we would appreciate the opportunity to resolve any issues you have before you make your complaint.