Privacy Policy of PULS GmbH

Welcome and thank you for visiting our website; we appreciate your interest in our company. We take the protection of your personal data very seriously. We process your data in accordance with the relevant legislation on personal data protection, in particular the EU General Data Protection Regulation (GDPR) and the applicable local implementation laws. This privacy policy provides comprehensive information relating to how we process your personal data at PULS GmbH, and the rights you have in relation to this data.

Personal data is the information that permits the identification of a natural person. This includes in particular name, date of birth, address, telephone number, email address but also your IP address.

Anonymous data exists where no personal reference to the user can be made.

1. Responsible authority and Data Protection Officer

PULS GmbH
Elektrastrasse 6
81925 Munich
Germany

Tel: +49 89/9278-0
Fax: +49 89/9278-299

E-Mail

Company registration: 64293
Munich Registry Court
VAT ID no.: DE 129702224

Managing Director: Bernhard Erdl

Responsible person in accordance with para. 55 section 2 of the Rundfunkstaatsvertrag (Interstate Broadcasting Agreement):

Bernhard Erdl
PULS GmbH
Elektrastrasse 6
81925 Munich
Germany

Email our Data Protection Officer

2. Your rights as an affected person

Firstly we would like to inform you of your rights as an affected person. These rights are standardised in Articles 15 - 22 EU-GDPR. These cover:

• The right of access (Art. 15 EU-GDPR),
• The right to erasure ('right to be forgotten') (Art. 17 EU-GDPR),
• The right of rectification (Art. 16 EU-GDPR),
• The right to data portability (Art. 20 EU-GDPR),
• The right to restriction of processing (Art. 18 EU-GDPR),
• The right to object to data processing (Art. 21 EU-GDPR).

To exercise these rights, please contact our Data Protection Officer. The same applies if you have any queries on data processing at our company. You also have the right to lodge a complaint directly with the Data Protection Supervisory Authority.

3. Right to object

Please note the following in connection with your right to object:

If we process your personal data for the purpose of direct mail, you have the right to object to this form of data processing at any time without giving reasons. This also applies to profiling insofar as it is associated with direct mail.

If you object to data processing for direct marketing purposes, we will no longer process your personal data for these purposes. Exercising your right to object is free of charge and can be carried out informally, ideally via email to: DSK@pulspower.com.

In the event that we process your data to protect legitimate interests, you may object to this type of processing at any time for reasons relating to your particular situation; this also applies to profiling based on these provisions.

We will then no longer process your personal information unless we can demonstrate compelling legitimate grounds that outweigh your interests, rights and freedoms, or the data processing is being used to assert, exercise or defend legal claims.

4. Purposes and legal bases of data processing

The processing of your personal data complies with the provisions of EU-GDPR and all other applicable data protection regulations. Legal bases for data processing arise in particular from Art. 6 EU-GDPR.

We use your data to initiate a business relationship, fulfil contractual and legal obligations, conduct the contractual relationship, to offer products and services, and to strengthen the customer relationship, which may include marketing and direct mail.

Your consent also represents a permission requirement in terms of data protection law. In this context, we provide you with information on the purposes of data processing and your rights to opt out. If such consent also relates to the processing of special categories of personal data, we will expressly inform you in the consent request, Art. 88 para. 1 EU-GDPR.

The processing of special categories of personal data in the context of Art. 9, para. 1 EU-GDPR is only carried out if required on the basis of legal regulations and if there is no reason to assume that your legitimate interest in exclusion from data processing takes priority, Art. 88 para. 1 EU-GDPR.

5. Forwarding to third parties

We will only pass on your data to third parties within the scope of the statutory provisions or with the appropriate consent. Otherwise, it will not be passed on to third parties unless we are obliged to do so due to mandatory legal regulations (disclosure to external bodies such as supervisory authorities or law enforcement authorities).

6. Recipients of the data

Within our organisation, we ensure that only the individuals receive the data that require that data to fulfil their contractual and legal obligations.

In many cases, our specialist departments are supported by service providers to fulfil their tasks. The necessary data protection agreements have been concluded with all service providers.

7. Transfer to third countries

Data will only be transferred to third countries (outside the European Union or the European Economic Area) if this is required to fulfil our obligation, it is required by law or you have given us your consent. In the case of relevant (purchase) enquiries (see point 11), contact data may be forwarded to third countries to our corresponding foreign distributors (e.g. in Germany, Singapore or the USA).

8. Data retention period

We store your data as long as it is needed for the processing purpose in question. Please note that a number of legally imposed retention periods require data to be stored for extended periods. This relates in particular to commercial or fiscal retention obligations (for example, arising from the German Commercial Code, Tax Ordinance, etc.). Unless there are further retention requirements, the data will be routinely deleted after use.

In addition, we may retain the information if you have given us your permission to do so, or in the event of legal disputes and we use evidence within the statutory limitation period which may be up to thirty years; the regular limitation period is three years.

9. Obligation to provide data

A variety of personal data is necessary for the establishment, implementation and termination of the obligation and the fulfilment of the associated contractual and legal obligations. The same applies to the use of our website and the various functions it provides.

The details on this are summarised for you in the section above. In certain cases, data is also required to be collected or made available due to legal regulations. Please note that it is not possible to process your request or execute the underlying obligation without providing this information.

10. Categories, sources and origin of the data

The data we process is determined by the context in question: For example, it may vary depending on whether you have submitted an enquiry via our contact form, registered for our newsletter, sent us a job application or submitted a complaint.

Please note that we may also make information available separately to a suitable location for specific processing where appropriate, e.g. when uploading job application documents or when submitting a contact request.

When you visit our website, we collect and process the following data:

• Name of the internet service provider
• Information on the website you have visited us from
• Web browser and operating system used
• The IP address assigned by your internet service provider
• Requested files, amount of data transferred, downloads/file export
• Information on the pages of our website(s) that you visit, including date and time
• For reasons of technical security (in particular to defend against attempted attacks on our web server), these types of data are stored in accordance with Art. 6 (1) lit. F EU-GDPR. After 7 days at the latest, anonymisation is carried out by shortening the IP address so that no reference is made to the user. To achieve this, the last three digits are removed; in other words, 127.0.0.1 becomes 127.0.0.*. IPv6 addresses are also anonymised. The anonymised IP addresses are kept for 60 days.

As part of a contact request, we collect and process the following data:

• Salutation, last name, first name
• Contact data
• Details on your preferences and interests

As part of order processing, we collect and process the following data:

• Salutation
• Last name, first name
• Date of birth
• Delivery address
• Billing address
• Email address
• Telephone number
• Data that is permitted to be processed from other sources

With newsletters, we collect and process the following data:

• Salutation (optional)
• Last name, first name (optional)
• Company (optional)
• Email address (mandatory)
• Analysis data from newsletter evaluation (anonymised data)

11.Contact form / contact via e-mail (Art. 6, para. 1 (a), (b) of the EU GDPR)

A contact form is available on our website that can be used to contact us electronically. If you contact us via the contact form, we will process the data you provide via the contact form to contact you and answer your questions and requests. For this purpose, we will pass on your contact request to the relevant persons at the relevant PULS company. A list of the potentially relevant PULS companies and distributors is available here: https://www.pulspower.com/contact/puls-worldwide. If you contact us from a country where PULS does not have its own branch, your enquiry will be passed on to our relevant local distribution partner. Should (purchase) enquiries for these countries be received by us instead of by the local distributor, we will forward them to the relevant distributor with the request to make contact. This is carried out on the basis of the legitimate interest pursuant to Art. 6 para. 1 (f) of the EU GDPR for us to contact you quickly and easily. You have the right to object to this.

In the contact form, the principle of data minimisation and data avoidance is respected by requesting only the data we need to contact you. This data is your first name, last name and e-mail address as well as the message itself. All other data fields are voluntary and completion is optional (e.g. to enable us to answer your questions in a more individual way).

If you contact us via e-mail, we will process the personal information provided in the email solely for the purpose of processing your request.

12. Newsletter (Art. 6 para. 1 lit. a EU-GDPR)

Our website offers the option to subscribe to a complimentary newsletter. The email address provided during the newsletter subscription process, and your name where applicable (optional information), are used to send the personalised newsletter.

In this process, we follow the principle of data economy and data avoidance only the email address and your agreement to this data protection declaration are marked as mandatory fields. Due to technical necessity as well as legal security, your IP address will be processed when subscribing to the newsletter.

Our newsletter is sent via a newsletter service provider. For this purpose, your data will be stored by us with this service provider. The company's servers are located in Europe. The processing of the data is carried out in accordance with the European General Data Protection Regulation.

For our account used to send the newsletter, we use the integrated data protection conformity function. Our reports evaluating the newsletter include anonymous data relating to recipients who open and click on the newsletter. Data protection compliance also prevents the collection and processing of complete IP addresses. Your data will not be passed on to other third parties in relation to the newsletter and the service provider does not receive any right to transfer your data.

Naturally you can cancel your subscription at any time using the unsubscribe option provided in the newsletter, and therefore opt out. It is also possible to unsubscribe from the newsletter at any time via our website.

13. Automated by-case decisions

We do not use any purely automated processing facilities to make decisions.

14. Cookies

15. Social Media Widgets

We have added a "Twitter-Widget" to our homepage to display the tweets from our Twitter account. A connection to Twitter is established to achieve this. In this process, log data is sent to Twitter, and a cookie is set on your computer. More information on this can be found at: Twitter privacy policy

In addition, our website contains links to our company accounts on the Facebook, YouTube, XING and LinkedIn platforms. Clicking on these links means that the respective social network receives information on which website you came from as a user. It is also possible, if you are currently logged in to the network in question, that the social network links this information to your account.

16. Google Analytics

We use Google Analytics, a web analysis service provided by Google Inc. ("Google"). Google uses cookies. The information generated by the cookie on the use of the online offering by the users are usually transmitted to a Google server in the USA and stored there.

Google will use this information on our behalf to evaluate the use of our online offering by users, to compile reports on the activities within this online offering and to provide us with other services related to the use of this online offering and internet usage. In this case, pseudonymous usage profiles of the users may be created from the processed data.

We only use Google Analytics with activated IP anonymisation. This means that the IP address of the users will be shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. The full IP address be sent to a Google server in the US and shortened there only in exceptional cases. The IP address sent by the user's browser will not be merged with other data provided by Google.

Users can opt out of the storage of cookies by setting their browser software accordingly; users may also prevent the collection by Google of the data generated by the cookie and related to their use of the online offering and the processing of such data by Google by downloading and installing the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en

If your browser does not support the link to the Browser Add-On from Google (e.g. when using our website from your smartphone), you can also opt out of data collection by Google Analytics by clicking on the link below. An opt-out cookie is then stored that prevents the future collection of your data when visiting this website.

17. Google Tag Manager

This website uses Google Tag Manager. This service allows website tags to be managed via a single interface. Google Tool Manager only implements tags. This means that no cookies are used and no personal information is collected. Google Tool Manager initiates other tags, which in turn may collect data. Google Tag Manager does not access this data, however. If deactivated at the domain or cookie level, it will remain in effect for all tracking tags as far as they are implemented with the Google Tag Manager.

18. Online offerings for children

Persons under the age of 16 are not permitted to submit any personal data to us without the consent of the legal guardian or a declaration of consent. We encourage parents and guardians to actively participate in the online activities and interests of their children.

19. Links to other providers

Our website also contains links to the websites of other companies. Where links to websites of other providers are available, we have no influence as to their content. As a result, no guarantee and liability can be assumed for this content. The content of these pages is always the responsibility of the respective provider or operator of the pages.

The linked pages were checked for any legal violations and identifiable infringements at the time the link was created. No illegal content was identified at the time the link was created. However, continuous content checking of linked pages is not feasible without specific evidence of an infringement. Upon notification of infringements, such links will be removed promptly.