Privacy Policy

Privacy Policy explained

We take your privacy extremely seriously. This policy describes what, why and how we collect and use your personal information, how we protect it and how you can contact us.

 Privacy Policy

Pulse Innovations Ltd.  ("Pulselive", "we" or "us") is the Sony group company responsible for data processing in connection with Pulselive consumer and professional electronics products, services and websites. We are registered in the United Kingdom.

This policy explains the types of information that we may collect and hold, how that information is used and with whom the data is shared (See section Sharing Information about you). It also sets out how you can contact us if you have any queries or concerns about this information. Some of our services also have their own privacy policy which provide details of the use of your information by that service.

Information that we collect

In short

What personal information does Pulselive collect and where does this information come from?

Pulselive may collect information about you in several different ways, for example: when you complete our survey, complete text fields or send documents.

Information that you provide us

Whenever you interact with Pulselive  you may be asked to provide us with information relating to you. For example:

• When you create an account with us, or correspond with us by phone, e-mail or otherwise, we may ask you to provide a range of information, such as your name, date of birth and contact details
• When you contact our customer service centres for assistance, we may keep information about the call, including your name, the reason why you contacted us and the advice we gave you
• When you participate in one of our prize draws or competitions, we may collect your name, address, age or artistic input,
• When you visit us at a public event, such as trade show or exhibition or participate in one of our surveys, we may ask for information, such as your business card, name, contact details, family situation, interests and preferences
• When you use our online services, we may receive content that you choose to upload, such as product reviews, comments, photos and forum posts, or details of your interests and preferences that you choose to tell us about when, for example, selecting the services that you wish to receive

Information we may collect from other sources

We may also collect information from publicly available sources and third parties, including:

• When carrying out business to business sales activities, we may use business contact details that are publicly available

Information we may collect in relation to social networks

If you use any of our social network applications, pages or plugins or you use one of our products or services that allow interaction with social networks, we may receive information relating to your social network accounts.

For instance:

• If you log-in to one of our websites or services using your social network account, we may receive basic details from your social network profile. The basic details we receive may depend on your social network account privacy settings, however, they might include your social network ID, name, profile picture, gender and locale. We may also receive additional information from your profile if you give us permission to access it
• If you click on a 'like', '+1' or 'tweet' or similar button in one of our websites or services, we may record the fact that you have done so. In addition, the content that you are viewing may be posted to your social network profile or feed. We may receive information about further interactions with this posted content (for example, if your contacts click on a link in the posted content), which we may associate with the details that we store about you
• If you 'like', '+1' or similar one of our pages on a social network site, we may receive information about your social network profile, depending on your social network account privacy settings

For more information and for details about how you can control access to your social network profile, you should view the privacy policy and other guidance available on your social network’s website.

Information we may collect when you use websites, products and services from Pulselive

Some of our websites, internet-enabled products and online services provide Pulselive with information about your use of them, including:

• Details of the content that you view and interact with. For example, when you use our website, we may collect information about your visit, such as your browser software, which pages you view and which items you ‘clicked’ on or added to your shopping basket
• Service, product or server logs, which hold information about your use of our service, product or websites, such as your IP address, browser information (including HTTP user agent strings), HTTP client request information and the time and location of your activities, domain, device and application settings, errors and hardware activity
• Device information such as your device ID(s) and/or information about where your device is physically located. For example, when you are using a geo-location service or application and you have provided consent to your location being shared
• Interests and preferences that you specify during setup of the Internet enabled product or service
• Emails communications that you have with Pulselive personnel may be monitored and logged.

In general, this information is collected using digital identifiers such as a device number, browser cookie or your IP address. These identifiers are used to distinguish the information provided by your browser or device from that of another user’s browser or device,

We may associate the collected information with one of your accounts, if for instance you are logged into a service when the information is collected. Please see our Cookie policy for further details.

How we use cookies

Cookies on our website are used for a variety of different purposes, but generally speaking their use breaks down into the following categories:

• Analytical/Performance Cookies: These allow us to recognise and count the number of users of our website and see how such users navigate through our website. This helps to improve how our website works, for example, by ensuring that users can find what they are looking for easily.

The following table lists the cookies used on our website: 

How Pulselive uses the information that it collects

In short

How Pulselive uses the information that it collects and what the legal basis for this is

Pulselive may use the information it collects for the following purposes:

Service provision

When we use personal information to offer our products and services to you, the processing is based on an agreement between you and Pulselive . In this context, we may use personal information to:

• Facilitate and process your searches and requests for information when you contact us about Pulselive and its products and services
• Analyse survey results in which you participated, create reports from them and use them for purposes for which they were designed

Product and service development

We work constantly to improve our products and services. We base this processing on our legitimate interests to develop our products and services to better meet customer requirements, to ensure data quality, to develop identity management, and to strengthen network and information security. In this context, we may use personal information:

• For staff training and quality assurance purposes
• To measure our performance or ask for your opinions on Pulselive products and services and conduct product surveys
• To develop and improve new and existing Pulselive products and services, recommendations, advertisements and other communications

Marketing

When we use personal information for marketing purposes, either, we base the processing on our legitimate interests to know our customers, keep you up-to-date about Pulselive 's latest products and services, and to personalise your customer experience, or on your prior consent, e.g. for sending marketing messages.

 In particular, we may collect, store, track and profile your information to:

• To provide you with newsletters and other communications by email, if you have provided your prior consent or we are otherwise permitted to do so under applicable law. See the Marketing communication section below for more details.
• Conduct prize draws, contests and other promotional offers
• Create anonymous, aggregated statistics about the use of our websites, products and services, which we may share with third parties and/or make available to the public.

Surveys

When we use personal information collected from a survey or research, the processing is based on your consent to participate in the survey or research which we conduct.

Security

We may use information collected from monitoring our websites, online services and emails for security purposes. This information may be passed to the police or to other appropriate authorities. We base this processing on our legitimate interests to protect you and our company, systems, employees and partners, or on a legal obligation to cooperate with competent authorities.  

Fraud prevention and investigation

Pulselive may use personal information to prevent fraud and to investigate violations or our policies. In this case, we base the processing of personal information on our legitimate interest to prevent fraud and to provide benefits only to our customers.

We may also use personal information to comply with applicable laws, regulations and court orders and to comply with valid legal information requests from such bodies. We may use your personal information to enforce or defend the legal rights of any or the terms and conditions of any Pulselive product or service. In this case, we base the processing on a legal obligation to which Pulselive is subject or on our legitimate interest to defend our legal rights.

Other purposes

Combining the information we collect

We may link or combine the information that we collect from the different sources outlined above in the “Information that we collect” section above. Information may be linked via a unique identifier, such as a cookie or account number Alternatively, we may decide to combine two or more databases into a single database of customer information.

We may do this for your and/or our convenience (for example, to allow you to more easily register for a new service), to allow us to provide a more seamless customer support whenever you contact us and to provide you with better, personalised services, content, marketing and adverts.

Sharing information about you

In short

How is information about you shared with 3rd parties?

Sharing of information by Pulselive

In general, Pulselive does not sell, rent or otherwise disclose information about you to third parties without your consent. However, there are exceptions:

Other Sony group companies

We may disclose information about you to other Sony group companies. They may combine this information with other details they hold about you. Unless they provide you with their own privacy policy, they may use your personal details for the purposes explained in this policy.

Our service providers

We may use third party service providers (either data processors or data controllers) to process your personal information for the purposes outlined above. For example, for managing survey tools, sending postal mail and emails, sending text messages (SMS), providing marketing assistance, providing fraud checking services and providing customer services.

Our data processors operate only in accordance with our instructions, in line with this policy, and are subject to appropriate confidentiality and security obligations.

When we are a service provider to a third party

We often conduct surveys and research on a third party’s commission in which case we may provide your personal information to them following your consent to it.

Third Party Advertising Partners
Where you download and/or use any of Sony applications and/or services that include third party advertisements (whether featured within the application or service itself or displayed to end users using a frame, wrapper, pop up or any other form of advertising functionality), we may share personal data we collect about your usage of the applications and services with our advertising partners so that they can better target and/ or personalise advertisements displayed within any Sony service, or any application used by you (whether Sony or not). Some of our third party advertising partners act independently, and thus will handle shared data under the terms of their own privacy policies. Additionally, you can control personalised ads in your browser’s cookie settings (for more information see our Cookie Policy).

 

Third party newsletters

If you request or agree to receive information or newsletters from one of our business partners, we may provide that third party with your details so that they can respond to your request.

Legal and business purposes

We may use and/or disclose to third parties information about you:

To government bodies and law enforcement agencies to prevent fraud, to comply with the law and to meet a reasonable request from such bodies

To third parties (including professional advisors) to enforce or defend the legal rights of any Sony group company or the terms and conditions of any Pulselive product or service

To a third party purchaser or seller, and its and our professional advisors, in connection with a corporate event such as a merger, business acquisition or insolvency situation

Anonymous statistics

We prepare anonymous, aggregate or generic data (including “generic” statistics) for a number of purposes as outlined above. As we consider that you cannot reasonably be identified from this information, we may share it with any third party (such as our partners, advertisers, industry bodies, the media and/or the general public).

Sharing of information by you

A number of our online services allow you to upload and share messages, photos, videos and other content and links with others and/or create a publicly accessible profile for your account. For example:

The communities and forums area of our website, allows you to post comments (with your account name), which are visible to other users of that service

Other services allow you to share a link which if clicked on may allow the recipient to access your uploaded content

You should not expect any information that you make available to others via Pulselive ’s online services to be kept private or confidential. Content and links that you share might, for instance, be forwarded by your recipients to others. You should always exercise discretion when using such services.

News, competitions and offers from Pulselive

You may be offered the opportunity to sign up to receive information about Pulselive group news, competitions and offers. If you do, companies in the Sony group may send you their news, competitions and offers and may use your linked Sony accounts details to make this information more relevant to you.

Use and disclosure for legal and corporate reasons

Pulselive may use and/or disclose the details of your linked Pulselive accounts:

To government bodies and law enforcement agencies to prevent fraud, to comply with the law and to meet a reasonable request from such bodies

To third parties (including professional advisors) to enforce or defend the legal rights of any Pulselive group company or the terms and conditions of any Pulselive product or service

To a third party purchaser or seller, and its and our professional advisors, in connection with a corporate event such as a merger, business acquisition or insolvency situation

International transfers of your information

In short

How does Pulselive  transfer information about you to other countries?

Pulselive  is part of the Sony group, which is a global organisation. For the purposes explained in this policy, your information  may be transferred to Sony group companies (including service providers operating on their behalf) and other third parties in countries which do not have the same level of data protection laws as those in the country where you are located.

Pulselive  uses a variety of legal mechanisms, including EU Standard Contractual Clauses, to help ensure that your rights and protections will travel with your data. This is why each of those Sony group companies (and their authorised data processors) will comply with Sony Europe’s internal policy relating to processing of personal information which complies with the key data protection principles of fair handling of personal information and ensuring adequate level of protection of personal information.

Please contact us if you want to receive further information regarding international data transfers. You will find contact information at the end of this policy.

Marketing communications

In short

How does Pulselive  use your personal information to send you marketing communications and how can you change your marketing preferences?

When you provide us with contact details, such as when you undertake a survey,  you may be given the opportunity to opt-in to (or in certain cases where applicable law allows, opt-out of) receiving various newsletters and other communications by post, email, telephone and/or text message (SMS) from Pulselive  and/or other Sony group companies. These communications may include, for instance, details about the latest Pulselive products and services in which you may be interested.

Pulselive may also use your information to personalise and to target more effectively its marketing communications as set out in this policy. When we use customer profiles for direct marketing purposes, you have the right to object to this kind of personal information processing at any time you wish to do so. You can contact us using the details in the “Contact us” section below to change your preferences.

You can change your marketing communication preferences at any time:

• If you would like to unsubscribe from an email sent to you, follow the ‘unsubscribe’ link and/or instructions placed (typically) at the bottom of the email. But note that:
• If you use more than one e-mail address to shop or contact Pulselive, you will need to unsubscribe separately for each email address
• This method will only unsubscribe for newsletter or other communication that you have received and you should use one of the other methods if you wish to opt-out of all our marketing communications
• You can contact us using the details in the “Contact us” section below in order to change your marketing communication preferences

Please note that we may occasionally send you important information about Pulselive products and services that you are using or have used. These emails are not affected by your marketing communication preferences.

Security of your information

In short

How does Pulselive  protect your personal information and what can you do to protect yourself?

What we do to protect your information

We take a number of steps to protect your information from accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access, including where appropriate:

• Limiting access to the information we collect about you (for instance, only those of our personnel who need your information to carry out our business activities are allowed access)
• Putting in place physical, electronic, and procedural safeguards in line with industry standards

What you should do to protect your information

As general best practice on the Internet, it is recommended that individuals take great care with user accounts, and follow some basic rules:

• Do not use trivial passwords (such as single dictionary words)
• Do not use the same password for multiple accounts
• Do use very long passwords (at least 10 characters, but preferably much longer)
• Do use passwords which contain a combination of upper and lower case letters, numbers and special characters e.g. $%^& etc.
• Do keep passwords securely (never written down, or shared with anyone) and changed periodically

Cookies and web beacons

In short

What are cookies and web beacons and how are they used?

Our websites use industry-wide technologies, such as “cookies” and “web beacons”, to collect information about the use of our websites and email communications. For instance, these technologies may tell us which visitors clicked on key elements (such as links or graphics) on a website or email and recognise your browser the next time you visit our websites. More information about our use of cookies and web beacons can be found in our Cookie policy.

Access to your information and your rights

In short

How can you access your personal information and what are your rights?

If you would like a copy of the personal information that we store about you in our customer databases, please contact us using the details given in the “Contact us” section below.

This is in addition to your legal rights, including the right to access a copy of your personal information, the right to request the deletion or updating of any inaccurate personal data and the right to object, in some cases, to our processing of your personal data. You can exercise these rights by contacting us using the details given in the “Contact us” section below.

Where we base processing on your consent, you have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

You may also have, for some data processed by us, a right to data portability, i.e. the right to receive your personal information in a structured, commonly used machine-readable format and transmit your personal information to another data controller.

You can exercise these rights by contacting us using the details given in the “Contact us” section below. You may be asked to provide some proof of identification so that we can verify that it is you making the request.

If you are concerned that we have not complied with your legal rights or applicable privacy laws, you may contact the Information Commissioner’s Office (www.ico.gov.uk) (which is the regulator responsible for data protection in the United Kingdom, where Pulselive  is located). Alternatively, if you are located outside of the United Kingdom, you may contact your local data protection authority.

Retention of personal information

We will only retain your personal information for as long as is reasonably necessary for the various purposes set out in this policy or to otherwise comply with any applicable laws and regulations concerning the mandatory retention of certain types of information.

Links to other sites

In short

Does this privacy policy extend to websites visited when following links on our website?

Some of our websites may contain links to other websites that are not operated by Pulselive , including websites operated by other Sony group companies.

While Pulselive  tries to link only to sites that share Pulselive ’s high standards and respect for privacy, we are not responsible for the content, security or privacy practices of those other websites. You should view the privacy and cookie policies displayed on those websites to find out how your personal information may be used.

Children’s privacy

In short

How does Pulselive  handle the personal information of children?

Pulselive considers a child to be anyone under the age of 16. We do not knowingly seek or collect personal information from or about children without the consent of a parent or guardian.

If Pulselive becomes aware that personal information that has been submitted to us relates to a child without the consent of a parent or guardian, Pulselive will use reasonable efforts to:

• Delete that personal information from its files as soon as possible
• Ensure, where deletion is not possible, that this personal information is not used further for any purpose, nor disclosed further to any third party

Any parent or guardian with queries regarding our processing of personal information relating to their child should contact us using the details provided in the “Contact us” section.

Contact us

In short

How can you contact Pulselive about your personal information?

You can contact us in the following ways:

1. By email

You can also contact us by emailing privacyoffice.SEU@sony.com.

2. By mail:

If you are in the EU

You can write to us at our business address above, or at The Privacy Office c/o Pulselive Legal Department, The Heights, Brooklands, Weybridge, Surrey KT13 0XW, United Kingdom.

If you are in the UK

You can write to Privacy Office c/o Pulselive Legal Department, The Heights, Brooklands, Weybridge, Surrey KT13 0XW, United Kingdom.

4. By telephone:

If you are calling from England, Wales & Scotland, please dial 07470770374, 9am to 6pm, Monday to Friday.