PULSUS builds strong and lasting relationships with its clients, partners, users, and collaborators based on mutual trust. Therefore, ensuring that your Personal Data (as defined below) is secure and remains confidential is an utmost priority for PULSUS.

In compliance with LGPD (General Data Protection Law), PULSUS is committed to the security and privacy of data subjects, especially in meeting the requirements of LGPD that regulate the secure processing of data by providing appropriate technical and administrative measures for protection, as well as facilitating the exercise of the data subject’s rights.

The terms of this Policy apply to Users and/or Visitors of the website https://www.pulsus.mobi, hereinafter referred to as the “Site,” and/or the PULSUS mobile application (hereinafter referred to as the “App”), which for the purposes of this policy, shall be collectively referred to as “DIGITAL CHANNELS.”

By accepting the content of this Policy, you acknowledge that PULSUS is the Controller of the Personal Data collected and uses this Site to provide online access to information about the organization, descriptions of services and products offered, and career opportunities in the information technology sector. Therefore, the terms and conditions of this Privacy Policy and the Terms of Use below must be carefully read before using and accessing the content of the Site. This Policy also outlines your rights and how you can contact us to exercise them or ask any questions you may have regarding the protection of your Personal Data.

SCOPE AND MODIFICATIONS

All access to and use of this Site are subject to this Privacy Policy and the Terms of Use outlined in this document. By accessing and using the Site, the visitor accepts the version of the terms that is in effect. PULSUS reserves the right to modify its Privacy Policy and Terms of Use at its sole discretion and without prior notice. We strongly recommend that visitors and users stay informed about the currently effective versions of these documents.

ORIGIN OF PERSONAL DATA

PULSUS collects and processes your Personal Data so that you can register on the DIGITAL CHANNELS and utilize their functionalities. Such Personal Data may be provided:

a. When registering your data in our Partnership Form at the link https://pulsus.mobi/en/terms-of-use

b. When registering your data in our Request a Quote Form on the links in the “Solutions” from our website.

c. When registering your data in our Contact Form at https://pulsus.mobi/en/contacting-pulsus/.

d. When registering your data in our Request a Trial Form through the “Free trial” button on our website.

e. By the company that contracts PULSUS’s services on your behalf;

f. Through automatic collection while browsing the websites and/or the App; and

g. Through the collection of information from other reliable sources.

Personal Data is primarily collected through the submission of service requests by your employing company and/or the company that recommended your name for receiving PULSUS’s services, or provided by you in your registration.

The information collected by PULSUS includes:

a. For individuals: name, phone and mobile numbers, e-mail, position, company and country;

b. For legal entities: business name, organization tax id, email, phone, and the name of the contact person.

Personal Data marked with an asterisk (*) on data collection forms are mandatory in order to attend your requests and/or provide the requested services. If you do not provide this Personal Data, it may result in restricted or even impossible access to our services.

Automatically collected Personal Data: We collect some information automatically when you visit our sites to personalize and enhance your experience. We gather this information using various methods, such as:

Cookies

We may use the “Cookies” feature to automatically collect information that allows us to identify features you may be most interested in, aiming to improve the performance of our applications and provide you with a more personalized browsing experience.

However, please  note that disabling “cookies” in your browser may result in an incomplete experience on our sites. For instance, you may not benefit from automatic login and other customization features available on our sites.

Additionally, please ensure to configure all browsers on your different devices (tablets, smartphones, computers). As there are different methods for configuring browsers, refer to the “Help” section of the browser you are using to understand how to configure it and set your preferences.

You can also disable audience measurement cookies using the links below:

You can disable “Google Analytics” cookies by downloading the module available at the following address: https://tools.google.com/dlpage/gaoptout/

You can disable the LinkedIn Insight Tag by modifying user settings on LinkedIn: https://www.linkedin.com/psettings/

Internet Protocol (“IP”) Addresses

An IP address is a unique identifier used by some electronic devices to identify and communicate with each other on the Internet. When you visit our sites, we may use the IP address of the device you are using to connect to the sites.

We use this information to determine the general physical location of the device and to understand the geographical areas where visitors are located. You can decide whether to enable or disable location services on your electronic device.

Statistics

Our sites use Google Analytics, a web analytics service provided by Google, Inc. (“Google”), to generate statistical reports. These reports provide insights into various aspects such as the number of users who have visited the sites, the pages visited, and the geographical locations of the users.

The information collected through statistics may include, for example, your IP address, the originating sites through which you arrived at our sites, and the type of device you used. Your IP address is hidden in our systems and will only be used if necessary to resolve a technical issue, administer the sites, or gain insights into our users’ preferences.

Traffic information from the sites is only accessible to authorized personnel. We do not use any of this information to identify visitors, and we do not share it with third parties not directly or indirectly involved in service provision.

The sites use Google reCAPTCHA, a service designed to prevent software that scans the Internet from creating artificial traffic or overloading a PULSUS service, making access more difficult for real users.

Google’s policies are available below, and by accepting this Privacy Policy, you agree to them. Any use of Personal Data collected through these tools by Google or its partners will be solely and exclusively the responsibility of Google: https://www.google.com/intl/pt-BR/policies/privacy/partners/, https://policies.google.com/privacy/, and https://policies.google.com/terms/

PURPOSES FOR WHICH WE USE PERSONAL DATA

The Personal Data collected by PULSUS is used to provide its services, ensure they function as expected, improve them, and enhance the reliability and security of all our services.

Specifically, PULSUS may, when authorized, use your Personal Data for the following purposes:

• Attending to your inquiries/support requests, as well as services, password exchange, reset, or other content;
• Administering, providing clarifications, and fulfilling obligations arising from the services contracted with PULSUS;
• Informing you about news, services, features, content, benefits, promotions, and other relevant events and relationship-building activities with users;
• Informing you about relevant commercial events and relationship-building activities with legal representatives;
• Recording and managing operations carried out by users through the PULSUS portal;
• Conducting login and authentication control, as well as user registration on the sites or App;
• Personalizing and enhancing your experience on our sites;
• Offering you our products and services and/or the products and services of our franchised partners;
• Collaborating and/or complying with a court order or request by an administrative authority;
• Any other purpose that will be informed to you, if applicable, when we collect your data.

You are aware that PULSUS, when necessary, enriches its database by adding information from other legitimate sources.

You should be aware that for the purpose of anti-fraud monitoring and money laundering prevention, PULSUS extracts and uses Personal Data from public sources, as well as Personal Data provided by third parties (such as financial institutions), which may be associated with the Personal Data that PULSUS holds about you.

PULSUS does not sell and/or commercialize information that can identify you.

BASIS FOR THE PROCESSING OF PERSONAL DATA

PULSUS processes Personal Data in accordance with the Legal Bases established by LGPD and in a manner that is appropriate and compatible with the purpose of its collection. We process your Personal Data as part of the performance and management of our contractual relationship with you and/or the company contracting our services, in our legitimate interest or that of third parties, provided that the legal requirements for this are met, in compliance with certain legal or regulatory obligations, or when necessary for the regular exercise of rights in a judicial, administrative, or arbitral process.

Your Personal Data may also be processed based on your prior consent if, under certain circumstances, your consent is requested.

SHARING OF PERSONAL DATA

The security and confidentiality of your Personal Data are of great importance to us. That’s why we restrict access to your Personal Data only to our duly authorized professionals who need to be aware of such data to process your requests or provide the requested service(s).

We will not disclose your Personal Data to unauthorized third parties. However, we may share your Personal Data with entities within the PULSUS group and authorized service providers with whom we work (for example: Call Center; relationship agents; BackOffice services; consultants in the areas of technology and information technology; etc.), whom we may engage to provide our services. In these cases, we ensure that your Personal Data is processed only for legitimate, specific, explicit, and informed purposes, with no possibility of subsequent processing incompatible with the purpose informed.

If third-party companies carry out the processing of any data collected through our sites and/or App, they must comply with the conditions stipulated here and in accordance with the applicable current legislation, without exception.

We do not authorize our service providers to use and/or disclose your Personal Data except to the extent necessary to provide services on our behalf or to comply with legal obligations. Our service providers will only use your Personal Data in accordance with the instructions issued by PULSUS and in accordance with the purposes stated in this Policy.

Furthermore, we may share Personal Data about you when we believe, in good faith, that we have an obligation to:

I. Comply with a law, regulation, or court order;

II. Respond to information requests made by regulatory bodies, law enforcement, and other public authorities, including in cases related to national security;

III. Enforce and/or protect PULSUS’s property or rights, including investigating fraud and helping prevent security threats, including information security, or other criminal or malicious activities; or

IV. Protect the legitimate interests of third parties, including the personal safety of PULSUS employees.

ACTIVITY RECORD

For the execution of its activities, PULSUS may record, if applicable, the accesses made by users on our sites and/or App, including:

• IP address and Logical Origin Port of users;
• Actions performed by users on the sites and/or App;
• Screens accessed by users;
• Dates and times of each activity carried out, as well as user access on the sites and/or App;
• Data about the device used by the user, especially: operating system version, geolocation, and other installed applications, if necessary;
• Session ID of users;
• History of operations performed;
• Behaviors identified in interaction with the sites and/or App.

The process aims to collect and analyze access logs for internal controls, audit support, and traceability. Other technologies may be used to obtain user navigation data, always respecting the conditions of this Policy.

STORAGE OF YOUR PERSONAL DATA

We store your Personal Data in our databases, in a secure environment, ensuring confidentiality and confidentiality, only for the time necessary to fulfill the purposes for which they were collected, subject to any legal deadlines and the need for PULSUS defense in processes. However, occasionally, we may have to retain your Personal Data for a longer period due to applicable laws or regulations. Upon the expiration of the legal and necessary period, your Personal Data will be deleted using secure disposal methods or used in an anonymized form for statistical purposes.

The Personal Data obtained may be stored on PULSUS’s own server or on a third-party server hired for this purpose, whether located in Brazil or abroad. They may also be stored using cloud computing technology and/or other emerging technologies, always aiming to improve and enhance its activities, respecting security levels and market best practices.

SENSITIVE PERSONAL DATA

“Sensitive Personal Data” refers to any information related to racial or ethnic origin, religious beliefs, political opinions, union membership, or membership in religious, philosophical, or political organizations, as well as health data or data related to sexual orientation, genetic or biometric data, when linked to a natural person.

As a general rule, we do not collect Sensitive Personal Data through our sites and/or App.

If it is strictly necessary to collect such data to achieve the purpose for which the processing is carried out, we will do so in accordance with local legal requirements for the protection of Personal Data and, in particular, with your specific and explicit prior consent, for specific purposes under the conditions described in this Policy.

PROCESSING OF PERSONAL DATA OF CHILDREN AND TEENAGERS

PULSUS does not intentionally collect Personal Data from children and teenagers through the sites and/or the App. To use the sites and/or App, the user must be at least 14 (fourteen) years old and, if under 18 (eighteen) years old, be assisted by parents or legal guardians, as provided in the Terms of Use. Click here to view the Terms and Conditions of Use: Terms of use, and these individuals must be responsible for any and all actions taken by minors when using the sites and/or App. [link to the terms of use], and they should be responsible for any and all actions taken by minors when using the sites and/or App.

INTERNATIONAL TRANSFER OF PERSONAL DATA

As PULSUS operates in areas aligned with the field of action of its FRANCHISEES, occasionally, your Personal Data may be transferred to recipients located outside of Brazil and authorized to perform services on our behalf. Data protection laws vary from country to country, but in the event of an international transfer to recipients in other countries, we will take necessary measures to ensure the existence of adequate safeguards for the protection of your Personal Data in accordance with LGPD and in compliance with the protections described in this Policy.

Despite the existence of explicit legal provisions authorizing international transfers beyond those indicated here, PULSUS is more likely to transfer your Personal Data abroad in one of the following scenarios:

I. when it is made to countries or international organizations that provide a level of protection for Personal Data equivalent to that provided by LGPD;

II. the data subject has provided their specific and highlighted consent for the transfer; or

III. when there are contractual clauses subject to the approval of the National Data Protection Authority (ANPD).

EXERCISING YOUR RIGHTS UNDER LGPD

PULSUS respects the rights you have as the data subject and enables their exercise in accordance with applicable legislation. Below is a list summarizing your different rights:

1 and 2 – Right to confirmation of the existence of Processing and access

You have the right to confirm whether we process Personal Data concerning you and to access the Personal Data you have provided to us and/or that we hold about you.

3 – Right to rectification

You can request the correction of your Personal Data that is incomplete, inaccurate, or outdated, if provided directly by you through PULSUS applications or websites. If provided by the contracting entity of PULSUS (your employer and/or the company that appointed you to receive PULSUS services), requests for correction should be made directly to the PULSUS service contracting entity.

4 – Right to anonymization, blocking, or deletion

You can request the anonymization, blocking, or deletion of unnecessary, excessive, or data processed in violation of LGPD.

5 – Right to data portability

When applicable, you can request the portability of your Personal Data to another service or product provider, upon express request, in accordance with the regulations of the National Data Protection Authority (ANPD), respecting trade and industrial secrets. The portability of Personal Data does not include data that has already been anonymized and/or deleted by PULSUS.

6 – Right to deletion of Personal Data processed with consent

You can request the deletion of Personal Data processed based on your consent, except in the following situations provided for by LGPD: Compliance with a legal or regulatory obligation by the Controller;

Research study by a research entity, ensuring, whenever possible, the anonymization of Personal Data;

II. Transfer to a third party, provided that the data processing requirements stipulated in LGPD are respected; or

III. Exclusive use by the controller, prohibited from being accessed by a third party, and provided that the data is anonymized.

7 – Right to information about data sharing 

You can request information from public and private entities with which we have shared your Personal Data. This information on the sharing of personal data is detailed in item 7 of this Policy, involving companies inherent to the execution of services provided by PULSUS.

8 – Right not to provide consent and refusals

You can request information about the possibility of not providing consent and the possible consequences of your refusal.

9 – Right to revoke consent

You can request the revocation of your consent at any time through express manifestation, with all processing carried out under the previously given consent being ratified. The revocation can be done directly on the websites and applications.

SECURITY APPLIED TO THE PROTECTION OF PERSONAL DATA 

We have implemented the best technical and administrative security market practices to protect your Personal Data from unauthorized access and accidental or unlawful situations of destruction, loss, alteration, communication, or dissemination, as required by current legislation.

To this end, we take all necessary precautions given the nature of Personal Data and the risks associated with its processing, to maintain data security, and in particular, to prevent distortions, damage, or unauthorized access by third parties (physical protection of facilities, authentication procedures with personal access and secure through identifiers and confidential passwords, connection logs, encryption of certain data, etc.).

However, be aware that no company, including PULSUS, can completely eliminate the security risks associated with the processing of Personal Data. For your security, it is indispensable that you protect against unauthorized access to your password and your computer, as your access is for personal and non-transferable use, being your sole and exclusive responsibility. In the event of an attempt of unauthorized or improper access, you must notify PULSUS as soon as possible.

THIRD-PARTY APPLICATIONS

Occasionally, we provide links to other websites for practical and informational purposes. These sites are not PULSUS sites, and some of them operate independently and are not under our control. They are managed by third parties with their own privacy policies and terms of use, which we advise you to read to understand how they collect and use your data.

PULSUS is not responsible for the privacy policies, security, and content of such sites or for the products and services that may be offered there. It cannot be held responsible for any losses and damages suffered due to the use of such links or frames.

CONTACT US REGARDING YOUR RIGHTS UNDER LGPD

PULSUS has appointed Magno Castro Alves, a Certified Professional in Privacy and Data Protection, as the DPO – Data Privacy Officer overseeing this new process. He will lead the adoption of new practices by the company, which have been implemented since September 2023, always aiming to maintain the DATA SECURITY adopted by the company.

To exercise any of your rights mentioned in this Policy, such as the right to access or correct your Personal Data, you can submit your request through the Individual Rights Exercise Form or by emailing dpo@pulsus.mobi with the subject: “LGPD – DPO PULSUS.”