Pulse Finance Technologies Ltd, (“Pulse” or the “Company”) recognises, respects and protects the personal privacy rights of all our customers and works diligently to safeguard your privacy. We are committed to providing security and privacy regarding the collection and use of our customers’ personal information, as well as the personal information of all consumers who visit our institution.
The types of personal information that we collect depends on the products and services you request and use. This information may include, for each Principal who is an individual:
We may also require written authorisation from each Principal to obtain consumer credit reports.
We may also require the business to provide its name, postal and email addresses, and telephone numbers; type of entity such as corporation, LLC, partnership, or sole proprietorship; Employer Identification Number; the date the business was started; its bank and routing number and account number; its bank statements and its management and/or audited accounts.
We may require the business to provide its acquirer Merchant ID(s), the purpose for which it is requesting funding, its current and historical card takings, and chargeback and refund data, as well as its Merchant Category Code(s) and/or industry type.
We may require other reports such as credit, fraud and Office of Foreign Asset Control (“OFAC”) reports on each Principal.
We may require confirmation that the business is continuing to take payments through the card terminal(s) provided to us.
We may collect any personal information that you provide to us voluntarily, for example by completing a form on any of our websites or in hard copy, by taking part in survey, a phone or social media conversation, or by emailing us, or by permitting us to obtain information about you from a third party.
Our systems may automatically record information about your website usage, such as your browser type (e.g. Internet Explorer), operating system (e.g. Microsoft Windows), IP address (a way of identifying your internet connection) and basic information about your internet service provider. This information does not require your intervention and is used to improve our services and enhance your user experience.
For security and audit control, and to help us understand your preferences, we may also keep a record of when you access the site, which pages you visit and the actions you take on each page.
We may also collect data contained in a credit report from a consumer reporting agency (“CRA”) or from other information databases such as fraud and OFAC reporting sources.
3.2 Reasons we can use your personal information:
For everyday business purposes:
To enhance your experience on our website by:
For marketing purposes:
For internal research purposes, general website administration, and demographic and statistical analysis of our service users.
3.3 We may use your personal information to generate non-personal statistical data, for example relating to the size of our customer base and the levels of site usage. This will only be group data, such as the age range of site users, and will not include any information that could personally identify you. This may then be shared with third parties.
4.1 Pulse shares your personal information with third parties as permitted by law, including in the following ways:
4.2 We may also share aggregated and anonymised data sets based on your personal information with third parties that does not reasonably identify you directly as an individual.
5.3 Most internet browsers accept cookies by default; however, you can usually change your browser settings to reject cookies if you would prefer not to receive them. If you choose not to receive our cookies you will not be able to receive any personalised features and you may not be able to benefit from all our services.
6.1 The security of your personal information is very important to Pulse. We use physical, electronic, and administrative safeguards that are designed to protect your Personal Information from loss, misuse and/or unauthorised access, disclosure, alteration and destruction.
We have several layers of security measures in place to protect your information, including:
In addition, Pulse uses standard security protocols and mechanisms to exchange the transmission of sensitive data such as credit card details and bank account numbers. When you enter sensitive Personal Information such as your bank account number on our site, we encrypt it using Secure Socket Layer (SSL) technology.
6.2 Pulse is also committed to reducing risks of human error, theft, fraud, and misuse of its facilities. The Company’s efforts include training employees on security policies and procedures as well as implementation of such policies and procedures. Pulse employees are required to maintain the confidentiality of services data. Employees’ obligations include written confidentiality agreements, regular training on information protection, and compliance with company policies concerning protection of confidential information.
7.1 Our websites may contain links to web sites which are owned or controlled by parties other than Pulse. These links are provided for your convenience and do not imply that we have reviewed or condone the third-party sites, their content, or their privacy policies.
7.2 When using other websites, you must be aware that any personal information you supply will be handled according to their privacy policies. We recommend that you read and consider these website’s privacy policies and terms and conditions before providing any of your personal information. Pulse is not responsible for privacy practices or content on third-party websites.
7.3 Our websites may also automatically transfer you to a third party site in order to fulfil the services we provide to you. In such cases, we will carry out due diligence to ensure third parties have the appropriate data protection requirements in place.
7.4 When you access the linked third party websites you do so at your own risk. These sites may place their own cookies or other files on your computer, or collect data or solicit personal information from you. Pulse is not liable for any misuse of your information or other misconduct by the third party.
8.1 We sometimes use computers to make decisions. We do this for things like deciding if we can make you a funding offer based on information we hold about you. This includes details on whether you’ve kept up to date with payments on any credit accounts, and if you’ve been to court. You can ask for a member of the team to review a decision by emailing firstname.lastname@example.org.
9.1 We keep most of your data as long as you’re using Pulse, and for 5 years after that to comply with the law and if we face a legal challenge. In some circumstances, like cases of anti-money laundering or fraud, we may keep data longer if it is in our legitimate interest and/or the law says we have to.
9.2 To work out how long we keep different categories of data, we consider why we hold it, how sensitive it is, how long the law says we need to keep it for, and what the risks are.
10.1 You have a right to:
10.2 To do any of these things, please contact us through the website or by emailing email@example.com. EU data protection laws, like the GDPR, give us one month to respond.
11.1 We may transfer and store the data we collect from you to organisations outside the European Economic Area (‘EEA’). When we do this, we make sure that your data is protected and that:
11.2 If you’d like a copy of the relevant data protection clauses, please send an email to firstname.lastname@example.org.
12.1 If you have a complaint about how we use your personal information, please send an email to email@example.com and we’ll do our best to fix the problem. You can also reach our Data Protection Officer in these ways.
12.2 If you’re still not happy, you can refer your complaint with a data protection supervisory authority in the EU country you live or work, or where you think a breach has happened. The UK’s supervisory authority is the Information Commissioner’s Office (ICO). For more details, you can visit their website at ico.org.uk.
For questions, contact us at firstname.lastname@example.org.