Updated as of May, 2018
Our data collection, use, and disclosure practices are explained in more detail in the accompanying
Website Privacy Policy and
Platform Privacy Policy. The following supplements those privacy policies for our operations within the European Economic Area (EEA).
Your information will be held in a database within or outside the EEA. PulsePoint, Inc., with an office at 360 Madison Avenue, 14th Floor, New York, NY 10017, or one of its affiliates, including PulsePoint Ltd, located at 31-35 Kirby Street, London, EC1N 8TE, UK, will collect your information as controller of the database and your details may be accessible to and used by other PulsePoint group companies. PulsePoint provides services in the USA and EEA, and your information may be transferred within or outside of the EEA (including to the USA) where privacy laws may differ from those in the European Union (EU). However, we will employ technical security measures designed to protect your personal data as required by EU law.
Our legal basis for collecting and using the personal data described herein will depend on the personal data concerned and the specific context in which we collect it. We will normally collect personal data from you only where we have your consent to do so, where we need the personal data to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interest or fundamental rights or freedoms. In some cases, we may also have a legal obligation to collect personal data from you or may otherwise need the personal data to protect your vital interests or those of another person.
As explained in our
Platform Privacy Policy, our Platform may be used for online behavioral advertising (OBA) and/or interest based advertising (IBA) (collectively, “Targeted Advertising”). In operating our Platform, we may collect, use, and disclose for Targeted Advertising purposes personal datawhich may be considered to be more sensitive, including information which is considered under EEA data protection laws to be within a special category of personal data. Personal data may include information such as e-mail address, gender, IP address, location or certain specific demographic and other information, as well as the following information which is considered under EEA data protection laws to be a special category of personal data; data related to race or ethnicity, health conditions such as information on certain past, present, or future medical conditions and treatment of those conditions, prescriptions you have filled, laboratory results, information about your health or wellness, or information regarding sexually transmitted diseases. If personal data is used for Targeted Advertising purposes, we will obtain your consent or, if the data is acquired from a third party, we request in our contract with that third party that they obtain your consent.
In accordance with the Internet Advertising Bureau (IAB) Europe framework for OBA, we do not create segments for Targeted Advertising purposes that are specifically designed to target children age 13 and under.
If we ask you to provide personal data to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal data is mandatory or not (as well as of the possible consequences if you do not provide your personal data). Similarly, if we collect and use your personal data in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.
