Last Updated (effective date): July 13, 2021
Why do we process information?
|Personal information we process|
|We process personal information you provide us freely and knowingly.
It is important to stress that you are not legally required to provide such personal information to us.
|Sign up. To sign up for a newsletter to receive updates about the Service, we may ask you to provide your name, contact information, the information you would like us to share with you, and how you heard about us.
Account information. To register and create a user account, we will ask you to provide your full name, email address, billing information, and password.
Transactions. We may process information about your investment and lending transactions, if you wish to record such transactions on pulsehound. Such information may include identifying documents, records related to such transactions (such as agreements, ledgers and certificates, etc.). We may also process information concerning actions on these resources such as disposal of assets, returns, interest accrued, etc.
To clarify, the information above is being processed to operate and provide the Service, and only for limited purposes described under “how and why we use personal information”.
Inquiries and Notifications. You can send us your inquiries or ask us to notify or contact you through any of our contact methods. In such, we may ask you to provide information such as your name, email address, the topic of your inquiry, and the text of your message. Our business providers or we may process and process this information.
You do not have a legal obligation to provide any of the above information to us. However, you will not be able to interact with our Services, receive updates, or submit inquiries, without providing the required information.
|We obtain information from third parties.||We may obtain information from third parties to enhance or supplement the information we processed from you. We may also process information about you that is publicly available. We may combine this information with the information we process from you directly. For example, we may obtain information when you log in through a third-party social network or authentication service, such as Facebook or Google, or demographic information from Google Analytics when you directly interact with our Services.
Information provided by social networks. When we make social networks available on the Service, if you connect a social network, such as Facebook, so our Services we may process personal information from the social network in accordance with your privacy settings on that social network. These services will authenticate your identity and provide you the option to share certain personal information with us, which could include your name, email address, address book, and contacts, or other information.
Similarly, when you interact with us through a social media site or third-party service, such as when you like, follow, or share our content on Facebook, or other sites, we may receive information from the social network, including your profile information, user ID associated with your social media account, picture and any other information you permit the social network to share with third parties.
The data we receive is dependent on your privacy settings with the social network. You should always review and, if necessary, adjust your privacy settings on social network websites before linking or connecting them to our Services.
|We also process analytics information about your use of the Service.||When you interact with our Service, we may process information about your visit and use of the Service and your interaction with our email messages and notifications. Analytical information we process includes your IP address, the general location corresponding to your IP address, time and date of access, type of browser used, language used, links clicked, and the features, functions, and components you used.|
|Category of personal information (PI)||Specific pieces of PI processed||Sources of PI processed|
|(A) Identifiers||A real name, photo, alias, unique personal identifier, online identifier, identification documents, Internet Protocol address, and email address.||From you or social networks such as Facebook or Google.|
|(B) Personal information categories||A real name, entities names, registration or identification numbers, photo, unique personal identifier, online identifier, identification documents, address, telephone number, credit card number, debit card number, or any other financial information.||From you.|
|(D) Internet or another network activity||Browsing history, search history, information on a consumer’s interaction with a service, website, application, or advertisement.||We may automatically process from your devices, from social networks or through information we process from our service providers.|
|(E) Inferences and profiling||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||Indirectly from you. For example, through information we process and process about you in the course of providing Services to you.|
|How and why we use personal information
We will never use your information for any purpose, other than the purposes listed below.
|To provide our Service and promote our Service.||We will process the information you provided us or information we have processed from social networks or information we automatically process about your preferences to:
|To notify you and update you about the Service.||If you sign up to receive our notifications or updates, we then process your email address to send you our periodic marketing updates and update you about our Services. We may send you marketing materials by email, text, push notification, depending on the operating system or means of communication you use. Each time we send you marketing materials, we give you the option to unsubscribe.
If we process your contact information in the course of using the Services, we will allow you to refuse or opt-out of our notification or Service emails at any time by sending an email to [email protected]. As long as you have not opted-out, we will send you these communications.
|To authenticate your identity.||If you log in through a third-party service such as email or social network, we use your information to authenticate your identity, allow you to access and use certain features of the Service.|
|To provide you the Service, and for reporting and business planning.||If you use our Services, we will process your information to fulfill your registration, charge you for the Service price and associated fees, and keep you informed about the status of your registration. We process your information for accounting and financial record-keeping purposes. We may also process your information to adapt the Service and its content to your preferences and to the preferences of future users, to understand better the market demand in which we operate and for reporting and business planning purposes.|
|To respond to your inquiry, question or request.||If you submit an inquiry to us, we will use the information you provide in your request or question to process, handle, and contact you about the inquiry.|
|We use analytics information to improve and enhance the Service, and for our business administration.||We use analytics information to improve the Service and the content on the Service, our email communications, and the tools we offer to users. We also use the analytics information to adapt the Service and its content to users’ preferences. Finally, we will use the analytics information to understand how we operate and for reporting and business planning purposes.|
|We use anonymized information to improve our Service.||We may anonymize and aggregate the personal information we process. We may use anonymized data for improving our Service and developing new tools and features. We may also share such anonymized data with others.|
|Category of (PI)||Business or commercial purpose for processing and selling personal information.|
|(A) Identifiers||To recommend to you Services and tools; To provide you the Service; To fulfill your registration, reporting, and business planning; To respond to your inquiry, question, or request.|
|(B) Personal information categories||To fulfill your request for Service; For reporting and business planning.|
|(C) Protected classifications||To contextualize and personalize your experience with our Services.|
|(F) Internet or another network activity||We use analytics information to improve and enhance the Service and our business administration and promote our Services to you.|
|(K) Inferences and profiling||To promote our Services to you and fulfill our Services by contextualizing and personalizing your experience with our Services.|
|How we share personal information|
|We share your information with other users when you have asked us to do so.||We will share your personal information with other users to the extent you have asked or authorized us to do so, such when you use the community feature on our Service.|
|We share your information with our service providers to help us operate our business and Services.||We will share your personal information with our service providers (SiteGround, Glide, Microsoft, Google and Upay, MailChimp), who help us perform certain Service-related functions. These include, Service registration, payment processing, mailing information, maintaining databases, hosting services, internal website operations, Service fulfillment, and applying updates and modifications to the Service. These companies are authorized to use your information only as necessary to provide their specific relevant services to us and not for their purposes. Our Service runs on Glideapp, and uses Google Apps, Google Firebase, Sheets and Drive.|
|We will share your information if we are legally required.||We will share your personal information if we are required to disclose it by a judicial, governmental, or regulatory authority, if the appropriate law enforcement authority asking for such information has a warrant, criminal subpoena or court order requiring we share information. In such events, we have to comply. Unless we are legally prevented from doing so, we will try to inform you when such requests are made. We have never received a National Security Letter or Foreign Intelligence Surveillance Act (FISA) order.|
|We will share your information with a third-party in the event of a change in our structure.||We will share your information to enable structural change if we reorganize our business, merge, consolidate or resolve to operate in any different framework or legal structure or entity, for example, due to a merger or acquisition.|
|We will share your information in case of an emergency concerning you.||We will share your information if we need to act to protect the personal safety of our users or the public.|
We do not and will not provide your personal information in direct exchange for money. Therefore, in the literal sense, we do not sell your data. However, the CCPA requires us to disclose if we sell personal information, and under the CCPA’s expansive definition of “sell”, the following activities may constitute a CCPA sale of data.
|Category of personal information (PI)||Categories of Third Parties to whom we share PI.||Categories of Service Provides to whom PI was disclosed.|
|(A) Identifiers||Other users, Social networks sites, Advertisers and Advertising Networks.||Social network sites, Service providers who help us perform certain Service-related functions.|
|(B) Personal information categories||Social networks sites, Advertisers and Advertising Networks.||Service providers who help us perform certain Service-related functions.|
|(C) Protected classifications||Social networks sites, Advertisers and Advertising Networks.||Service providers who help us perform certain Service-related functions.|
|(F) Internet or another network activity||Advertisers and Advertising Networks, Business partners, Social networks sites.||Service providers who help us perform certain Service-related functions.|
|(K) Inferences and profiling||Service providers who help us perform certain Service-related functions.|
In the preceding twelve (12) months we have not sold any personal information.
|How we transfer personal information internationally|
|We will transfer your information internationally in accordance with applicable data protection laws.||We will internationally transfer information in accordance with applicable data protection laws. If we transfer your personal information for processing at locations outside your jurisdiction, we will abide by data transfer rules applicable to these situations. If you are a user in the EU, we may transfer your information from within Europe to other jurisdictions outside Europe, we will do so by using the adequate safeguards determined by the EU Commission.|
|Automatic data processing tools|
|What are automatic data processing tools?||Cookies are text files that include a small amount of data we store on your computer, tablet, or smartphone when you use the internet and visit our Service. It allows us or a third party to recognize you. We may use both Session Cookies and Persistent cookies as described below.
Session cookies data is read by a website you visit, during the session of your visit. Session cookies expire when you close your browser. Persistent cookies data is read by a website you visit when you return to revisit it. A persistent cookie remains on your computer until it expires, or you delete your cookies.
Necessary cookies are those that are strictly necessary for the functioning of our Service. Our Service cannot operate properly without these cookies. You can block or receive an alert about these cookies by setting your browser configuration. Still, some parts of our Service may not function properly without these cookies.
Preferences cookies are those that remember your choices when you use our Service and allow the site to react by reflecting your preferences.
Statistics cookies help us to discern how you and others interact with our Service by processing data that does not directly identify you.
Marketing cookies track your use of our Service and allow us to tailor content and deliver you ads, both on and off the Service, that we believe is relevant to you.
|Do Not Track Signals. California law requires us to let you know how we respond to web browser “Do Not Track” (DNT) signals. Because there currently isn’t an industry or legal standard to recognizing DNT signals, we do not respond to them currently. We await the result of work by the privacy community and industry to determine when such a response is appropriate and what form it should take. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.|
|We implement technical and organizational measures to secure your personal information.||We implement safeguards to reduce the risks of damage, loss of information, and unauthorized access or use of information we process and maintain. However, these measures do not guarantee absolute information security. Therefore, although we take reasonable precautions and make reasonably appropriate efforts to secure your information, you cannot expect that the Service will be immune to information security risks.|
|We will retain your personal information for as long as we need it to operate the Service and interact with customers, and after that, as required for record-keeping matters.||We keep your personal information for the duration of our business relationship with you, interacting with you as a customer, to the extent permitted by applicable laws. We may keep your information for as long as necessary to administer our business, our bookkeeping requirements, resolve disputes, establish and defend legal claims, and enforce our agreements. When we no longer need your data, we will delete it from our systems (using reasonable means) and records or take steps to anonymize the data.|
|Glide’s practices||Glide explains how what practices it uses to secure information being processed by it. Please refer to this article for additional information.
We implement the following Glide techniques referred in the article:
|You have certain rights subject to possible restrictions under the law to access, obtain a copy, or update your data.||You have the right to:
Access your personal data that we process and have about you and receive a copy of it.
Rectify incorrect, inaccurate, or incomplete personal data we have about you.
|If you are a resident of California you have certain rights subject to possible restrictions under the law to know, request deletion, opt-out of the sale of personal information and protect against discrimination.||If you are a resident of California, you have the following rights:
Right to Know. Subject to a verifiable request you have the right to know: The categories of personal information we have processed about you; The categories of sources from which we are processing the personal information; Our business or commercial purpose for processing personal information; The categories of third parties with whom we share personal information; and the specific pieces of personal information we have processed about you.
Right to Request Deletion. You have the right to request the deletion of your personal information from our records and direct us to ask any of our service providers to delete your personal information from their records. Such is subject to receipt of a verifiable request from you and subject to certain exceptions set out below.
Please note that we may not delete your personal information if it is necessary to complete the transaction for which the personal information was processed, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us; Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity; Debug to identify and repair errors that impair existing intended functionality; Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law; Comply with the California Electronic Communications Privacy Act; Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent; Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us; Comply with an existing legal obligation; or Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Right to Opt-Out. We do not sell personal information for monetary consideration. However, we may share certain personal information with third parties under circumstances which might be deemed a “sale” under the California Consumer Privacy Act. In such a case, you have the right at any time to request to opt-out of the “sale” or sharing of your personal information. If you wish to exercise opt-out right, you can exercise this right by sending us an email to [email protected]. We will comply with your request as soon as possible, but no later than 15 business days from the date we received your request.
Right to Non-Discrimination. You have the right not to be discriminated against by us because you exercised any of your rights under the CCPA. It means we cannot, among other things: Deny goods or services to you; Charge different prices or rates for products or services, including through the use of discounts or other benefits or imposing penalties; Provide a different level or quality of goods or services to you, or suggest that you will receive a different price or rate for products or services or a different level or quality of goods or services.
We may charge a different price or rate or provide a different level or quality of goods or services to you if that difference is reasonably related to the value provided to our business by your personal information.
If you would like to exercise any of your CCPA rights as described above, you should email us to: [email protected].
|You have the right to designate an authorized agent to submit a request on your behalf.||You may designate an authorized agent to make a request under the CCPA on your behalf. To do so, you need to provide the authorized agent written permission to do so and the agent will need to submit to us proof that they have been authorized by you. We will also require that you verify your own identity, as explained below.|
|Verification of Requests.||We may ask you for additional information to confirm your identity and for security purposes, before disclosing the personal information requested to you or delete the personal information about you.
For Password Protected Accounts. We will verify your identity through our Service existing authentication practices for your account. We will also require you to re-authenticate before disclosing or deleting your information.
For Non-Account Holders.
We will verify your identity by using two or three points of the information verification process, or together with a signed declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request depending on the type of information you require.
|Timing Format and Fees.||Except as otherwise provided herein, we endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by email. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. For information portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
|If you are a resident of the EU, you have additional rights, subject to possible restrictions under the law, to delete, restrict processing, withdraw your consent and object to our processing of your personal data for our legitimate interests.||If you are a resident of the EU, you have the following additional rights to:
Object to the processing of your personal data for marketing purposes or for our other legitimate interests. However, we may override your objection if we demonstrate compelling legitimate grounds, or for the establishment, exercise or defense of legal claims. At any time, you can also object to our processing of your personal data for direct marketing (newsletter) purposes, by simply opting out of our newsletters.
Restrict the processing of your personal data for the duration we require to verify its accuracy. You have the right to restrict the processing of your personal data if you consider it an unlawful processing. You can also restrict the deletion of your data if you need it for the establishment, exercise, or defense of legal claims. You can also request the restriction of the processing during the time we review your objection to our legitimate interest.
Erase your personal data when it’s no longer needed. For example, when you withdraw your consent to our newsletters, you have the right to ask us to erase your data relating to that. However, we may still process your personal data if we need to in order to comply with a legal obligation, or if we are subject to do so under the law, or for the establishment, exercise, or defense of legal claims.
Data Portability You have the right to receive the personal data that you provided to us in a structured, commonly used, and machine-readable format and to send that information to other businesses. Where technically feasible, you also have the right to have your personal data transmitted directly from us to another business you designate.
If you wish to exercise any of these rights, contact us at [email protected].
We have the right to ask for reasonable evidence to confirm your identity before we provide you with the data. Where we are not able to provide you with the data that you have requested, we will explain the reason for our inability to do so.
|ADDITIONAL INFORMATION FOR USERS IN THE EU|
|We are data controllers of the personal data we process about you through our Service.||Pulsehound Ltd. is the data controller for the personal data we process through our Services and the tools offered on our Services. Our registered address is at 11 Menachem Begin Rd., Ramat Gan, Israel. You can contact us by email at [email protected].|
|You have a right to complain to the relevant supervisory data protection authority.||Subject to applicable law, you have the right to complain to your local data protection authority. If you are in the EU, you can complain to the supervisory authority, particularly in the Member State of your residence, place of work, or place of an alleged infringement of the GDPR. For a list of data protection authorities in the EU, click here.|
|Legal bases for processing your data.||The legal basis for processing, processing, and profiling the information you volunteer to provide when using our Services is your consent.
The legal basis for processing and sharing the information you volunteer to provide using our Services is your consent.
The legal basis for our processing, processing, and profiling your Service preferences is our legitimate business interest in offering you products that are suitable to your interests.
The legal basis for processing and processing your email address to send you marketing emails is either our legitimate interest in offering further Services to existing customers if you’ve previously commercially engaged with us or your consent in other cases.
The legal basis for our processing and processing your registration for the fulfillment of Service and billing, is the performance of the contract for providing a Service to you.
The legal basis for processing your inquiry information is our legitimate interest in responding to your question or request.
The legal basis for keeping your interactions for Service adaptations, and business planning, is our legitimate business interest in enhancing our Service and our business development and planning.
The legal basis for processing analytics information about you is our legitimate interest in managing our Service and our business development and planning.
The legal basis for sharing your data with others if you breached our terms is our legitimate interest in protecting ourselves from abuses.
The legal basis for disclosing your data to a judicial, governmental, or regulatory authority is our compliance with our legal obligation to do so.
The legal basis for sharing your data to enable a structural change of Pulsehound Ltd. is our legitimate business interests in our business continuity following any structural change.
|Our Service is not intended for anyone under 13.||Our Services are not intended for—and we don’t direct them to—anyone under 18. And that’s why we do not knowingly process personal information from anyone under 18. If we need to rely on consent as a legal basis for processing your information and your country requires consent from a parent, we may require your parent’s consent before processing and using that information.|
|Last update: July 13, 2021
|You can contact us at [email protected]||If you have any questions, complaints, or suggestions, you may contact us at [email protected]. We will do our best to resolve your issue promptly.|