TABLE OF CONTENTS
- 1. The Scope
- 2. What Personal Data Do We Have on You
- 3. No Requirement to Disclose Personal Information
- 4. What Personal Data We Collect
- 5. Legal Basis and Reasons for Processing of Personal Data
- 6. Transfer of Personal Data to Third Party
- 7. Cookies and Services from Third Parties
- 8. Retention of Personal Data
- 9. International Transfers
- 10. Security of Personal Data
- 11. Hyperlinks to Third Party Websites
- 12. Modifications to This Policy
- 13. Your Rights
Privacy Policy
We (also known as "We", "Us" or "Our") are committed to protecting your Personal Data and your privacy. This Privacy Policy is designed to inform you about how we collect and store the information you provide through the website Pulse Kapitium (the "Website").
We want you to be well-informed about how your Personal Data is used and processed. We use various methods to ensure you receive relevant information. When we determine that specific details are necessary, we will provide them to you at the appropriate time. We are also happy to address any questions you may have regarding any limitations imposed by law.
1. The Scope
1.1 This policy describes the types of Personal Data the Company collects from individuals, and how it processes, shares with third parties, and secures that data.
1.2 This Policy covers information relating to an identified or identifiable natural person. An identifiable natural person is someone who can be directly identified, or identified through a combination of additional information we hold or are able to access.
1.3 The Policy defines "processing" as any activity that involves the use or collection of Personal Data, including its management, organization, and storage.
1.4 Our services are intended for general audiences and are not designed for anyone under the age of 18. We do not knowingly seek or collect information from individuals younger than 18 years old. We do not knowingly permit such individuals to use our services. If we become aware of any information collected from minors, we will delete it as promptly as possible.
2. What Personal Data Do We Have on You
2.1 When you access our services and channels or visit our website, we collect Personal Data. We may request your Personal Data in certain circumstances.
2.2 In other instances, we collect your Personal Data by analysing how our Services and service channels are used, or by receiving your information from our third-party partners.
3. No Requirement to Disclose Personal Information
3.1 You are not required to provide Us with any Personal Data. However, in certain circumstances, choosing not to do so may prevent Us from delivering the Services or restrict access to the website.
4. What Personal Data We Collect
4.1 This includes information about your online activity log and traffic data, such as:
- IP address
- Date of access and time of access
- Language you used
- Software crash logs
- Type of browser used
- Information regarding the device that you utilised
4.2 The information collected is not private and cannot be used to identify you.
4.3 Personal Data we receive from you: any personal data you voluntarily provide to Us when you connect to a third-party online trading platform through Us.
4.4 Personal information you provide directly to third-party platforms to facilitate trades: this includes your full name, address, phone number, and email address.
5. Legal Basis and Reasons for Processing of Personal Data
5.1 Your personal data is processed by the company for the purposes described in this section, in accordance with the applicable legal basis.
5.2 Without a legal basis, the Company cannot use your Personal Data. The following are the legal grounds upon which the Company may process your Personal Data:
- You have given your consent to the processing of your Personal Data for one or more purposes. This applies when you submit personal information through the Website so that we may transfer it to a third-party trading platform.
- The Company or a third party may need to process your data to pursue legitimate interests — for example, to improve Our Services or to defend legal claims.
- Processing must meet an obligation of law.
5.3 Contact us via email for more details on the processing required to protect legitimate interests.
5.4 Below is a list of reasons and legal grounds on which we may use the information you provide us:
Scope
Legal Basis
1. To share your personal information with third parties upon your request to gain access to digital trading
If you request it, we may collect your Personal Data to forward it to third-party companies.
You have given your consent to the processing of your Personal Data for one or more reasons.
2. To address your requests, questions, or concerns
Personal Data is necessary to respond to any questions you may have regarding the Services.
Processing is necessary to serve the legitimate interests of the Company or a third party.
3. To meet any legal obligation or administrative, judicial, or regulatory requirement, Personal Data is processed in compliance with applicable legal obligations.
To ensure compliance with legal obligations, processing is required.
4. To Enhance Our Services Personal
Data may be used by us to improve Our Services. This includes, among other things, crash reports and malfunction data we collect in relation to the Services.
Processing is necessary to serve the legitimate interests of the Company or a third party.
5. To stop fraud and misuse of Our Services.
Processing is necessary to serve the legitimate interests of the Company or a third party.
6. To perform and manage actions in accordance with the requirements of Our Services
These activities include back-office functions, business development, strategic decision-making, oversight mechanisms, and more.
Processing is necessary to serve the legitimate interests of the Company or a third party.
7. To conduct analysis, such as statistical analysis
To make informed decisions on various matters, we apply a range of analytical techniques, including statistical methods.
Processing is necessary to serve the legitimate interests of the Company or those of a third party.
8. To safeguard our assets, rights, and interests as well as those of third parties
Personal Data may be processed by us to protect our rights, interests, and assets, or those of third parties, in accordance with applicable laws, regulations, agreements, and any related conditions, terms, or policies.
Processing is necessary to serve the legitimate interests of the Company or a third party.
6. Transfer of Personal Data to Third Party
6.1 The Company may also share Personal Data with third-party companies that provide services to us, such as hosting and storage providers, IP address information, and user experience analysis.
6.2 You may also request that we share specific Personal Data about you with third-party trading platforms. In such cases, we will provide the Personal Data you have submitted to us directly to those third-party platforms. Please note that the use of your Personal Data will be governed by their respective privacy policies. Your Personal Data may be shared with multiple trading platforms.
6.3 The Company may share Personal Data with related entities or business partners. This allows the Company to access the resources needed to enhance and improve the products and services it provides to its customers.
6.4 If necessary to protect the rights of third parties or their assets, the Company may disclose Personal Data to regulatory, local, or other official authorities.
6.5 We may also share your Personal Data with potential investors or buyers, or with lenders to the Company or any other company within the group, in the event such a transaction takes place (including the transfer or sale of assets belonging to the Company or any other company within the group), or as part of any merger, restructuring, consolidation, or bankruptcy involving the Company or any other business within the group.
7. Cookies and Services from Third Parties
Third-party services, such as advertising providers and analytics companies, may be used on our website. These companies may also make use of cookies or similar technologies.
7.2 Cookies are small text files placed on your device each time you visit or access the website. They are used to collect information about your preferences and browsing habits in order to improve your experience, remember your settings, and personalize the products and services most relevant to you. Cookies are also used for statistical and analytics purposes.
Some cookies we use are session cookies, which are temporarily stored on your device and expire once you close your browser. Others are persistent cookies, which remain on your device for a period of time after your browser is closed. These are used to help the Website recognize you as a returning user and allow you to resume your visit seamlessly.
The type of cookie
Cookies are absolutely necessary
Scope
These cookies are necessary to access the features you've requested and to navigate our website. They are used to deliver the information, products, and services you've asked for.
They are also required for your device to download and stream data, allowing you to browse the website, use its features, and return to pages you've previously visited.
Additional Information
Cookies collect Personal Data, such as your username and last login date, to confirm that you are logged in to the site. They are deleted once you close your web browser (session Cookies).
The type of cookie
Functionality Cookies
Scope
Cookies allow us to recognize you each time you visit our site and to save your settings and preferences.
Additional Information
They remain active until their expiry date and are retained even after the browser is closed.
The type of cookie
Cookies for performance
Scope
Cookies are used to collect statistical data on the site's performance and to help improve it. They also allow us to carry out analysis on our website.
Additional Information
Cookies store anonymous data that is not linked to any identified or identifiable individual. Some cookies are removed when you close your browser, while others remain valid indefinitely.
7.4 Cookies are blocked or removed. To block or remove cookies, you will need to adjust your browser settings. Below are links to guide you through the process for some of the most popular browsers:
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
7.5 However, please be aware that some or all of the Website's functions and features may not work as expected if this happens.
Online Tracking Notice: This service does not currently support do-not-track signals.
8. Retention of Personal Data
8.1 The Company will retain your Personal Data for as long as necessary to fulfill the purposes described in this Policy, or for longer periods as permitted by applicable laws, regulations, policies, and orders.
8.2 We will share your information with third-party trading platforms for a period of 12 months. If you agree, we will continue sharing your data for an additional 12 months.
8.3 We regularly review the Personal Data we retain to ensure it is no longer needed.
9. International Transfers
9.1 Your personal information may be transferred to other countries (i.e. your personal data may be transmitted to a third country or to international organizations). The Company takes all necessary steps to safeguard the personal data you provide and to ensure that users can assert their rights and access effective legal recourse.
These protections and safeguards are available to all individuals residing in the EEA (European Economic Area):
- Transfer to a third country or international organisation that the EU Commission has determined provides an adequate level of protection for Personal Data, in accordance with Article 45(3) of Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 (the "GDPR")
- The transfer is made pursuant to a legally binding and enforceable agreement between public entities or authorities under Article 46(2)(a)
- The transfer was carried out in accordance with standard data protection clauses adopted by the EU Commission under Article 46(2)(c) of the GDPR
9.3 The Company can provide information about the security measures it uses to protect your Personal Data when transferred to third-party countries or international organisations. Send an email to: support@pulsekapitium.com
10. Security of Personal Data
10.1 We have implemented appropriate organizational and technical measures to protect Personal Data, including safeguards against accidental or unlawful destruction, loss, or alteration of Personal Data.
10.2 We cannot guarantee that the security of your Personal Data will be maintained without error. We are also not liable for any indirect, incidental, or consequential damages arising from the use or disclosure of Personal Data. This includes, but is not limited to, Personal Data disclosed due to transmission errors, unauthorised access by a third party, or any other cause beyond our control.
10.3 In cases where legal or other obligations beyond our control require us to disclose your Personal Data to third parties, such as public authorities, we may be required to do so. In such situations, we cannot control how those third parties handle the security of your Personal Data.
10.4 Personal Data cannot be transmitted over the internet in a completely secure manner. The Company cannot guarantee the security of any Personal Data you send to Us online.
11. Hyperlinks to Third Party Websites
11.1 The website may contain links to third-party sites and applications. These sites and applications are not under the supervision of the Company. We are not responsible for how these sites or apps collect or process Personal Data. This Policy does not apply to any actions carried out through such sites or apps.
11.2 When visiting any third-party websites or apps, we recommend that you read their privacy policies before choosing to access or use them. We also suggest that you carefully consider what Personal Data you share with them.
12. Modifications to This Policy
12.1 This Policy may be updated at any time. If changes are made, we will notify you by posting the revised Policy on our website.
12.2 In addition, when we make significant changes to this Policy, we will notify you through appropriate channels and publish an announcement on our website.
12.3 Unless otherwise specified, any amendments will take effect upon publication of the revised Policy.
13. Your Rights
13.1 You have the right to request verification of the accuracy of your Personal Data that we collect, to have any errors corrected, and to have Personal Data that we no longer require deleted. You may also restrict the types of processing applied to your personal information.
13.2 If you are a resident of the EEA, please refer to this page. These rights apply to the personal data you provide to us. To exercise any of these rights, you may send a written request to the email address below.
13.3 Access rights The Company is able to verify the accuracy of Personal Data being processed about you. If applicable, you are able to access your Personal Data. The Company will provide an electronic copy of the Personal Data currently being processed and may charge a reasonable fee for any additional copies. The data will be made available electronically upon request. The right to access Personal Data must not conflict with the rights and freedoms of others. If a request is detrimental to the rights and freedoms of another person, the Company may refuse to comply with the request or limit its ability to fulfill it.
13.4 Right to rectification The Company has the right to correct any inaccurate Personal Data. You may request that any incomplete Personal Data relating to you be corrected, taking into account the purpose of processing.
13.5 Right to Erasure The following reasons apply: (a) Personal Data are no longer needed for the purpose for which they were collected or processed; (b) You withdraw consent and there is no legal basis to continue processing; (c) You object, based on reasons specific to your situation, to the processing of Personal Data about yourself where such processing is based on legitimate interests pursued by Us or by a third party; (e) Personal Data are unlawfully processed; or (f) Personal Data must be removed to fulfill a legal obligation of the company. This right does not apply where processing is necessary (a) to fulfill an obligation required under European Union law or Member State law; or (b) to establish, exercise, or defend legal rights.
13.6 Processing restrictions If you have concerns about the accuracy of your Personal Data, you may ask the Company to limit its processing. If you request a restriction, your Personal Data may only be retained with your consent, to establish, exercise, or defend legal rights, to protect the rights of another individual, or for reasons of significant public interest within the European Union or a Member State.
13.7 Right to data portability If the processing is carried out by an automated system and is based on your consent or a contract you are party to, you have the legal right to access and review the Personal Data you have provided to the Company. You are entitled to request that your Personal Data be transferred directly from the Company to another controller, where technically feasible. Your rights under the right to erasure remain unaffected by the exercise of your right to data portability. The right to data portability does not infringe upon the rights or freedoms of any other person.
13.8 Right to challenge You have the right to object, at any time, to any use of your Personal Data that is based on legitimate interests pursued by the Company or a third party. This right is not limited to profiling based solely on such legitimate interests. If we are able to establish compelling legitimate grounds for processing your Personal Data, we may continue to do so unless you can demonstrate that your rights, freedoms, or interests outweigh ours, or that processing affects the exercise, establishment, or defense of legal rights. Regarding direct marketing, you have the right to object at any time to the processing of your Personal Data.
13.9 Right to refuse consent You may revoke your consent for Us processing Personal Data about you at any time. This will not affect the legality or lawfulness of any processing that was carried out based on your consent prior to its withdrawal. You are entitled to lodge a complaint with your supervisory authority. You may also appeal to a supervisory authority established by a member state to protect the fundamental rights of individuals in relation to the processing of Personal Data within the European Union. The laws of the European Union and its Member States may limit your rights regarding Personal Data concerning you, as detailed in this section 13.
13.10 We will provide you with the requested information in accordance with the rights outlined in section 13 of this agreement within one month of receiving your request. This timeframe may be extended by up to two additional months if necessary, depending on the nature and volume of requests received. We will notify you of any such extension, along with the reasons for it, within one month of receiving your request.
13.11 Unless otherwise restricted under section 13 of the law, information requested in accordance with your rights under section 13 will be provided at no cost. If a request is found to be unjustified or excessive, particularly if repeated, we may charge a reasonable fee to cover the administrative costs of fulfilling the request or notifying you of the action taken. We may also choose not to act on such requests.
13.12 If we have doubts about the identity of the person who submitted your request, we may ask them to provide reasonable proof of identification.
This Privacy Policy should be read alongside our Term Of Use and Risk Disclosure.
Pulse Kapitium 59-60 Grosvenor Street, Mayfair, London, W1K 3HZ | support@pulsekapitium.com