Please read the following Privacy Policy to understand what personal information you provide us with, how this information is processed and the purposes for which such processing is undertaken by Pulse Motivation UK Ltd (“Pulse Motivation“, “our“, “we” or “us“).
Pulse Motivation UK Ltd is based in London, United Kingdom; and is covered by data protection legislation which refers to the UK Data Protection Act 1998; the EU General Data Protection Regulation (‘GDPR’) and any successor legislation relating to the Processing of Personal Data and privacy.
The person with responsibility for Pulse Motivation’s data protection compliance is the Data Privacy Manager and they can be contacted via email at: [email protected].
We will act in respect of Personal Data to comply with the six principles of the GDPR, which are:
We are the Data Processor of the Personal Data supplied to us by our clients as part of the Pulse Motivation Assessment, who remain the Data Controller in respect of their Personal Data. We are therefore responsible for making sure that our systems, processes and people comply with the relevant data protection laws as a Data Processor of that Personal Data.
All of our employees are required to abide by our Privacy Policy when handling Personal Data and will be provided with appropriate data protection training. Any breach of data protection will be taken seriously and may result in disciplinary action. Our Data Privacy Manager will provide advice and guidance to our people on data protection issues, as is required.
This Privacy Policy explains how we collect and process personal information when we provide our tools and reporting services (“Services“). The sale and provision of such Services are governed by our Standard Terms and Conditions.
We collect personal information about:
This Privacy Policy applies to any individual about whom we process personal information in the course of providing our Services (“you” or the “data subject“).
You may give us information about you by filling in forms on our website at www.pulsemotivation.com, (“Website“) , by corresponding with us by phone, email or otherwise, or through our Pulse Motivation platform as you may be invited by us or our Client to complete an assessment (“Pulse Motivation”).
You may provide personal information to us when you log an inquiry on our Website, use Pulse Motivation, complete one of our Pulse Motivation Assessment, subscribe to our information services, place an order on our site, ask to do a demo, post in discussion boards, enter a competition, promotion or survey, when you report a problem with our Website or Pulse Motivation or otherwise communicate with us.
Information We Collect from Participants when Participating in an Assessment
Clients may provide personal information about Participants that have been nominated to undertake an Assessment. This information may include the Participant’s name, ID number, employee number, email address and other contact details. Participants may also provide this information directly to us.
Participants may take part in Assessments through our Website, or Pulse Motivation.
When Participating in an Assessment, we will ask the Participant to provide responses that may constitute personal information. We categorise such personal information as follows:
You must provide Identification Data as this is required in order for us to administer the Assessment, provide the results to the Client who requested that the Assessment is made available to you for completion, and for the purposes set out in the section entitled “For what purposes do we process information about you?“
You will be required to provide a response to some (if not all) of the questions within the Assessments. If you do not provide a response to certain questions within the Assessment, you may not be able to proceed to the next section or complete the assessment.
You do not need to provide Demographic Data to us. This information is entirely voluntary but assists us in providing deeper insights at a business level on motivator trends.
Special Categories of Personal Data
Demographic Data may include personal data that reveals your racial or ethnic origin, which is classed as a “special category of personal data” under data protection law. Demographic Data is not included in the Assessment criteria and serves solely as a tool for clients to filter results at a team and organisation-wide level. Our confidentiality promise ensures that no individual can be identified through this data. Demographic data may also be used by Pulse Motivation for research purposes in order to monitor our tests and questionnaires for fairness and to maintain a high standard of Assessment.
Where an Assessment asks you to provide special category data, we will ask for your explicit consent to collect and process such information. Your ability to complete an Assessment will not be affected by your choice not to provide such data, nor will this choice affect your Assessment outcomes.
Any Demographic Data that we collect will be processed in accordance with this Privacy Policy and applicable data protection laws, and we shall ensure that it is treated securely.
From time to time, Participants may volunteer additional personal information about themselves to us, which may include special categories of personal data. For example, Participants may inform us about a health issue or disability which may impact the way in which they undertake the Assessment. We will obtain explicit consent before further processing any special categories of personal data that a Participant provides. With your consent, this information will be communicated to the Client requesting the Assessment whose responsibility it is to take any decisions regarding the impact on the Assessment process as a result of the information. Please note that without such consent, we may not be able to address the needs of individual Participants.
For What Purposes Do We Process Personal Information About You?
We are committed to keeping your personal information confidential and secure. The way in which we use your personal information will depend upon whether you are a Client or a Participant.
Personal Information About Clients When Using our Website or Ordering Services
We will use personal information about Clients in the course of providing Services for the following purposes:
Personal information provided by you in relation to each of your visits to our Website will be used:
This information is stored in log files and is used for aggregated and statistical reporting.
Personal information About Participants When Participating in an Assessment
We process Identification Data, Assessment Data and Demographic Data provided in relation to your Participation in Assessments for the purpose of providing Services to our Clients. This may include processing this data in order to:
We may also process Demographic Data for research purposes. We research responses to our Assessments in the light of areas such as gender, age and cultural background over the longer term; this is considered best practice and allows us to monitor our Assessments for fairness in use.
The Demographic Data that we collect goes through the process of aggregation and/or anonymisation. The Demographic Data that is personally identifiable to you is not individually disclosed to any Client or any third parties.
If you complete the Assessment in a jurisdiction that prohibits completion of such Demographic Data, you should not complete those details to the extent such law prohibits doing so.
We may also process your personal information for the purposes of using and refining Assessment tools, analysis, accounting, billing and audit, credit or other payment card verification, security, administration, enforcing and defending legal rights, systems testing, maintenance and product development, customer relations, performing our obligations to Participants and Clients whether under contract or otherwise, and to help us in future dealings with you.
We may also provide a copy of the Assessment Data to our Clients for use by them for their own internal human resource management purposes.
Clients are entitled to use the personal information that we provide to them as part of our Services for their own purposes; however, such Clients are obliged to process such personal information in accordance with their own obligations under applicable data protection laws. You will have rights with respect to the manner in which our Clients process such personal information provided by us to them.
When you provide us with personal information via one of our online touch points (such as a web form, platform input, lead form, social lead), you consent to our collecting it and using it only for the reason for which you sent us your information.
Where we ask for your personal information for a secondary reason, like marketing or research, we will either ask you directly for your expressed consent, or provide you with an opportunity to say no.
If you change your mind after you have opted in, you may withdraw your consent for us to contact you, collect more information, use, or disclose your information, at any time, by contacting us at:
Pulse Motivation UK
Email address: [email protected]
Address: 167-169 Great Portland Street, 5th Floor, London, W1W 5PF, UNITED KINGDOM.
Profiling
Our Assessments are conducted, in part, on the basis of profiling, which means that we process your personal information using software that is able to process your responses to questions and provide insights and perceptions of your own behaviours or those of people that you work with.
If you are a Participant, you should note that it is our Clients that make decisions on the basis of our Assessments. If you have any questions about how Assessment results will be used in their decision making process, you should ask the Client (i.e. your employer or potential employer) for further information.
If you are a Client, it is your responsibility to ensure that your decision making process including how you interpret the Assessment results complies with applicable laws.
We must have a legal basis to process your personal information. In most cases, the legal basis will be one of the following:
We shall not provide any vulnerable adult, or person under the age of 16 with access to the Services, unless otherwise permitted by applicable law.
We do not send marketing communications to Participants who are only registered as Participants; however, we may contact you if you have provided us with your contact details and are a Client or prospective Client of our Services.
For users who are not only registered as a Participant, we use cookies for advertising purposes as described in our Cookie Policy.
If you do not wish to receive any marketing communications we may send to you from time to time, please let us know at any time by emailing us at [email protected].
Information about Participants will be disclosed to our Clients in the context of the provision of Services to them in connection with the Assessment(s) undertaken. Individual responses may be disclosed to Clients, and an overall Assessment report will be provided to Clients, containing an overall Assessment score, insights into strengths and development areas and additional comments about the Participant’s.
We may also pass anonymised and/or statistically aggregated data to our approved agents as described above, and to current or future potential Clients or research institutions. Because this information cannot identify you as an individual, it does not constitute personal information.
We may disclose your personal information to third parties:
In respect of all disclosures of Personal Data, we will only share the personal information which is necessary for the particular purpose for which it is provided, or where we have another legitimate interest in doing so (weighed up against your rights to have your data protected), and we will ensure that the Personal Data is appropriately protected.
International Data Transfers
Due to the international nature of internet based Assessment and training services, we may from time to time appoint third parties to process data containing information about you on our behalf as a data processor, or store such information in, or transfer it to persons located in, countries outside of the UK. These countries may not have data protection laws equivalent to those which are in force in UK to protect your information. Where we transfer your information to such third party data processors and/or third parties outside of the UK, we shall ensure that an International Data Transfer Agreement (“IDTA”) is in place that will GDPR equivalent guarantees in respect of the technical and organisational security measures to ensure their compliance with those measures in order to ensure your information is adequately protected in accordance with applicable data protection laws. For more information on the appropriate safeguards in place, please contact us at the details below.
A cookie is a small information file that is sent to your computer and is stored on your hard drive. Our Website uses cookies to distinguish you from other users of our Website. This helps us to provide you with a better user experience when you use our Website. For detailed information on the cookies we use and the purposes for which we use them please see our Cookie Policy.
The transmission of information via the internet either by or to us can never be completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted to or from us via our Website or by email. If you use electronic means in order to transfer personal information to us, any such transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
To protect your personal information, we take reasonable precautions and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered, or destroyed.
We keep your information secure by taking appropriate technical and organisational measures against its unauthorised or unlawful processing and against its accidental loss, destruction, or damage. We do our best to protect your personal information, but we cannot guarantee the security of your information if it is transmitted to our website, applications, or services, or to other websites, applications, and services, via an internet or similar connection.
If you provide us with your personal information, the information is encrypted using secure socket layer technology (SSL). Although no method of transmission over the internet or electronic storage is 100% secure, we follow and implement additional generally accepted industry standards.
We retain Participants’ personal information (including assessment information) for a period of 24 months, after which time we may anonymise the data and use it for research purposes. We will also anonymise data at the request of the Client or the Participant. If the Participant requests their data to be anonymised, we will first inform the Client who requested the Assessment be made available to the Participant.
We retain Clients’ personal information for as long as we maintain a relationship with Clients, and then for a reasonable period of time that allows us to assist with any queries, requests or complaints regarding the Assessments and/or the Services, to commence or defend legal claims, and to comply with our regulatory obligations (including record retention obligations).
You are entitled to see the personal information that we hold about you. You may ask us to make any necessary changes to ensure that personal information about you is accurate and kept up to date. You will not have the right to make changes to the Assessment Data, however, as this would undermine the accuracy and value of the Assessment reports.
If you would like:
then please email us at [email protected]. Please note that we will likely require additional information from you in order to honour your requests. Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
We may update this Privacy Policy from time to time. The updated Privacy Policy will be published on our Website and, where appropriate, notified to you by email. You should refer to the Privacy Policy from time to time in order to keep yourself up to date with regard to the way we process your personal information.
If you would like to access, correct, amend, or delete any personal information we have about you, register a complaint, or simply want more information, contact our Privacy department as follows:
Privacy Department
Attention: Yael Rosen
Email address: [email protected]
Address: 167-169 Great Portland Street, 5th Floor, London, W1W 5PF, UNITED KINGDOM
We do not sell your personal information.
