We attach great importance to protecting your privacy and your personal data at PulseLife.
This privacy policy applies when you connect to our website available at: https://pulselife.com/ or use our services, such as our mobile application and our Google Chrome extension.
We detail how we use your personal data in accordance with:
- Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the “GDPR”)
- The French Data Protection Act (Loi Informatique et Libertés), as amended
- Any other applicable data protection laws in your jurisdiction”
This policy may be updated at any time, following changes in legal, technical or commercial matters. We will inform you of any substantial modification. We nonetheless recommend that you consult this policy regularly to become aware of its latest version in force.
WHO ARE WE?
PulseLife services are provided by 360 MEDICAL, a company with its registered office at 2 avenue Lacassagne, 69003 Lyon, France.
360 MEDICAL is the controller of your personal data, meaning we determine why and how your data is used.
You can contact us by sending an email to: privacy@pulselife.com
WHY AND HOW ARE MY PERSONAL DATA USED?
We ensure that we collect and use your personal data in a manner that is adequate and necessary for our objectives when you use our services.
Below you will find a table listing several key pieces of information about your personal data:
- Why we use your personal data (the “purpose”)
- Which personal data we use about you
- The legal reason that authorises us to use your data (the “lawful basis”)
- The periods during which we retain your personal data
¹ WHY? (Processing purposes)
² WHAT? (Personal data)
³ HOW? (Lawful basis)
⁴ FOR HOW LONG? (Retention period)
SECTION 1
- ¹ Enable you to access the website of the Platform and use the different features via the placement of strictly necessary cookies.
- ² Data relating to the device used to access and use the website: IP address, technical information concerning the characteristics and operating data of the user’s device, operator, operating system, device model, IP address, language choices, date and time of access.
- ³ Our legitimate interest in ensuring that our website, application and Chrome extension function correctly.
- ⁴ Cookies deposited have a lifespan of 13 months from their placement; information collected via these cookies is retained for 25 months from their collection. Your cookie preferences are valid for 6 months from when you expressed them.
SECTION 2
- ¹ Perform statistical analyses on the performance of our services in order to be able to improve and optimise their features, content and your navigation. More information in the “Cookies” section.
- ² Data relating to the device used, actions performed on the website, visit frequency, referring website and more generally, your interactions with our services.
- ³ Your consent.
- ⁴ Same as section 1
SECTION 3
- ¹ Create and manage your user account, and verify your status as a healthcare professional.
- ² Email address, password, name, surname, profession, specialty, postcode, country. To verify your status as a healthcare professional, you have the choice of providing us with: Your professional registration number; A copy of your qualification; A copy of your professional ID card.
- ³ Performance of our contract (the Terms of Use) under which access to our services is conditional on your status as a healthcare professional.
- ⁴ We retain this data for the entire duration of our relationship, that is, until you delete your account or until we delete it for you after 2 years of inactivity. In any case, we will retain this data securely for a further period of 5 years, for evidential reasons.
SECTION 4
- ¹ Support you during your use of our services, with the help of our dedicated customer service.
- ² All information you deem useful to communicate to us should you contact our customer service available via this contact form.
- ³ Performance of our contract (the Terms of Use) under which we provide support.
- ⁴ Same as section 3
SECTION 5
- ¹ Provide our services accessible via our website, application and Google Chrome extension.
- ² Data linked to your user account. Your requests, searches performed via our tools, etc.). The content (prescription templates, etc.) that you generate using our tools.
- ³ Performance of our contract (the Terms of Use) under which we provide our Services to you.
- ⁴ Same as section 3
SECTION 6
- ¹ Process online transactions, manage payment incidents and debt recovery.
- ² Data relating to the payment method you have chosen (card number, your account with a payment service provider such as PayPal, etc.) and your order history.
- ³ Performance of our contract (the Terms of Use) under which we offer you various payment methods to subscribe to our paid offerings.
- ⁴ Our payment service providers retain your banking data for a period of 13 months from your payment.
SECTION 7
- ¹ Provide you with a personalised browsing experience in the content accessible via our services, as closely aligned as possible with your practice.
- ² Your browsing and usage history of our services (requests, searches performed via our tools, etc.).
- ³ Our legitimate interest in improving our services so that they are as relevant as possible for your practice.
- ⁴ This data is retained for the entire duration of our relationship, that is, until you delete your account or until we delete it for you after 2 years of inactivity.
SECTION 8
- ¹ Communicate to you commercial information about our offerings, events, services. We may send you, if you have not objected, commercial emails to the email address you provided when creating your account.
- ² Email address.
- ³ Our legitimate interest in promoting our offerings.
- ⁴ 3 years following our last contact with you/termination of the contract concluded.
SECTION 9
- ¹ Manage any complaint, grievance or pre-dispute and dispute.
- ² The nature of the data processed depends on the dispute but may include any data relevant to the resolution of the dispute.
- ³ Our legitimate interest in protecting and defending our rights and interests.
- ⁴ Once we have resolved your complaint, we retain this data for the duration of our contractual relationship, plus a period of 5 years for evidential reasons. Where it is a dispute, we retain this data until all remedies have been exhausted.
SECTION 10
- ¹ Manage your requests to exercise your rights.
- ² Name, surname, contact details, any other personal data targeted by your request.
- ³ Compliance with our legal obligations under the GDPR.
- ⁴ Regarding proof of identity (if required): deleted once the request is processed (it may however be retained longer, for 6 years from closure of the request, if there is a high risk of dispute). Regarding data collected to manage the request: until management/closure of the request. Regarding the response provided to you: 6 years from closure of the request. If your request concerns deletion of your data / objection to their processing as part of our marketing activities, we will retain your data for 3 years to keep our opt-out list up to date.
Cookies
Cookies are small text, image or software files that may be placed and/or read on your device when you access our website and application or when you use our Chrome extension. We may place cookies or use other similar technologies that pursue the same objective.
We use cookies (i) strictly necessary for the functioning of our services and (ii) for audience analysis. Thus, information stored by cookies placed on your device may relate to the adverts you have clicked on, the type of browser you use or your IP address.
Where cookies are subject to your consent, you are free to withdraw it at any time via the dedicated cookie banner or in the application interface, without this having any consequence for your use of the services.
Cookies strictement nécessaires (obligatoires)
These cookies are necessary for the website to function and cannot be disabled – services cannot function correctly without them. The User can configure their browser to block or warn of the existence of these cookies, but in that case certain parts of our services will not function.
These cookies are necessary to use the services, to administer our system, to prevent fraudulent acts, to maintain login from one page to the next, or to retain your cookie preferences.
Audience Analysis Cookies (Subject to Your Consent)
These cookies allow us to better understand how our users behave when they use our services. They allow us to count visits and traffic sources in order to measure and improve the performance of our services.
List of audience measurement cookies:
– ga, gat, _gid and mixpanel
Am I Obliged to Provide You with My Personal Data?
To create a user account, a prerequisite for any use of our services, you must provide us with a certain amount of personal information. We provide services reserved for healthcare professionals. If you decide not to provide us with the elements allowing you to attest to your status as a healthcare professional, you will only have access to certain features of the services.
To Whom Can We Transfer Your Personal Data?
We position ourselves as the trusted intermediary of your personal data and we oppose the sale of your data to third parties.
However, certain obligations may require us to do so; we therefore commit to only sharing your personal data with recipients and for legitimate purposes, namely:
- The technical team, for the maintenance of our information system and for cybersecurity purposes;
- The commercial team, to improve our offerings and communicate about their existence.
- Other departments (accounts, customer service), when necessary
External recipients and notably:
- To authorities and public bodies to whom we must communicate certain of your personal data to comply with legal obligations, to protect the rights and/or safety of 360 MEDICAL or an individual;
- To our service providers and notably:
- Hosting service providers, of which you will find a detailed list in our Terms of Use.
- Payment service providers, when you subscribe to our paid offerings.
- Mailing service providers, to send you the information necessary for the use of our services.
- To partners, for the purpose of enriching statistical data on the use of our services.
What Rights Do You Have Over Your Personal Data?
You have rights over your personal data, and we commit to respecting them:
- Withdraw your consent. If your personal data has been processed with your consent, you are entitled to withdraw your consent at any time. Withdrawal applies only for the future (we are not required to delete data used whilst you had given us your consent).
- Access and obtain a copy of your personal data. Subject to the request not being manifestly unfounded or excessive.
- Rectify your data. If you have a user account, it is simpler to modify your own data directly from the PulseLife application. If you are unable to do so, you can request to rectify your personal data if it is inaccurate or obsolete and/or request that it be completed (subject to the request not being manifestly unfounded or excessive, in particular due to its repetitive nature).
- Erase your data. This is not an absolute right as we may be required to retain your personal data for legal or legitimate reasons.
- Restrict our use of your data, without deleting it. This right means that we retain your data on our servers but we can no longer use it.
- Obtain portability of your data. You can receive the personal data concerning you that you have provided to us in a structured, commonly used and machine-readable format. This applies only when we use your data as required by our Terms of Use or when you have given your consent.
- Object to our use of your data. Where we use your data on the basis of our legitimate interests (for example when we send you commercial communications), you can object and we will stop using your data for this purpose.
- Give instructions regarding the fate of your data in the event of death. You can send us instructions on the fate of your personal data in the event of your death.
You have the right to lodge a complaint with your competent data protection authority.
We nonetheless invite you to contact us at privacy@pulselife.com to exercise your rights before filing a complaint with your data protection authority.