Pulsar Group PlcLSE: PULS

Privacy Policy

May 15, 2024 at 10:00 PM UTC · MarketScreener

DocuSign Envelope ID: 07A7DBEE-ACE9-4901-B7E5-FA39A739865A

Pulsar Group Privacy Policy

Classifcation: PUBLIC

Pulsar Group Privacy Policy

Last updated: May 2024

Content

Who we are

What is this policy?

The type of personal data we collect and hold How we collect Personal Data

Why we collect, hold, use and disclose your Personal Data Disclosure of Personal Data to third parties

How we hold Personal Data, and quality and security of Personal Data How long will we store your personal data?

Your rights Marketing Cookies

Who can you speak to about this policy? Changes to this policy

Appendix A: Additional privacy requirements

A.1 For individuals based in the UK and the EU Where we are a data controller

Our basis and interests in processing of your Personal Data Your additional rights under the EU and UK GDPR

How we approach transferring and processing your Personal Data internationally

A.2 For individuals based in California Collection and use of personal information Recipients of personal information California privacy rights

How to Exercise Your California Consumer Rights A3 For individuals based in Australia

Australian privacy laws

What is "personal information"? Employee records exemption

Disclosure of personal information to overseas recipients Complaints

Appendix B: Pulsar Group and its privacy/data officer contact details

Appendix C: Regulatory authority per jurisdiction

Document Version Control

DocuSign Envelope ID: 07A7DBEE-ACE9-4901-B7E5-FA39A739865A

Pulsar Group Privacy Policy

Classifcation: PUBLIC

Who we are

Pulsar Group Plc (formerly Access Intelligence Plc) and its subsidiaries operating the Pulsar, Isentia, ResponseSource and Vuelio brands globally (collectively, Pulsar Group, company, we, us or our), are a global group of technology companies, which together deliver high-quality SaaS products for leading global organisations in the marketing and communications industries.

The evolving Pulsar Group portfolio includes:

Pulsar, the audience intelligence and social listening platform, which combines conversational and behavioural signals from the world's leading digital sources to help organisations understand their audiences and create messages that matter to them;
Isentia, the market-leading media monitoring, intelligence and insights company headquartered in Sydney, Australia, operating in Australia, New Zealand and parts of South-East Asia; 
Vuelio, which provides monitoring, insight, engagement and evaluation tools for politics, editorial and social media in one place; and 
ResponseSource, the network that connects journalists and infuencers to the PR and communications industry.

The Pulsar Group includes those companies that operate the above portfolio globally. A full list of the companies currently part of the Pulsar Group is set out in Appendix B.

What is this policy?

The Pulsar Group is committed to protecting your personal data in accordance with all applicable data protection laws (Data Protection Law). The purpose of this policy is to provide you with transparency about our collection, usage, disclosure, maintenance, storage, retention and destruction of personal data.

This policy serves as a privacy policy and privacy notice that applies to all Pulsar Group entities - whether related to our website, marketing activities, products or services etc., and whether we act as a controller (i.e. an entity that determines the purpose and means for processing personal data) or a processor (i.e. an entity that processes personal data on behalf of the data controller).

This policy sets out the minimum requirements for all of the Pulsar Group for the protection of personal data in accordance with Data Protection Law. Where a jurisdiction in which we operate has regulatory obligations over and above the minimum requirements set out in this policy, for that jurisdiction these additional requirements are included in the Appendix A.

DocuSign Envelope ID: 07A7DBEE-ACE9-4901-B7E5-FA39A739865A

Pulsar Group Privacy Policy

Classifcation: PUBLIC

In most jurisdictions where we operate, the protections set out in this policy also apply to the personal data of our employees (however, this may not be the case in every jurisdiction we operate in, such as Australia - see Appendix A for further details).

The type of personal data we collect and hold

Personal data is information that relates to an identifed or identifable individual, or otherwise as that term or similar terms are defned under Data Protection Law (Personal Data).

The kinds of Personal Data we collect and hold about you depends on the nature of your dealings with the Pulsar Group and the circumstances of collection. This includes whether we collect the information from you as a customer, supplier, contractor, job applicant, infuencer or in some other capacity. The types of Personal Data we collect might include names, address, email, telephone numbers, job title and industry. We may also collect other information you choose to provide us and details of the interactions that you have with us.

For example, we currently collect and process the following information:

Public information - We may collect Personal Data from the public domain and social media sites and from other providers for the purposes of our research and analytics services. Further, our services collect and process information from a range of publicly available online sources, such as social networking sites and blogs. This content is only information that has been made publicly available, which can include Personal Data. We may also collect your details from publicly available sources such as LinkedIn and Google, as well as lead generation providers, in order to send you information about our services;
Infuencers - If you have infuence over an audience (e.g. journalists, subject/domain experts, bloggers etc.), we may collect your professional information which may include personal data, including: your full name, company name, job title, email address, telephone number, postal address/location, social handles/IDs, publicly available social media content, biography and work history. Infuencers are sent a privacy notice email that references this Privacy Policy to ensure they are aware of our processing and their rights;
Contact information - We collect your information when you contact us (whether in writing, electronically or by telephone) or use our websites and products (including when you use our websites to login, register for a webinar, download whitepapers or complete surveys), which may include: your full name, company name, job title, industry, email address, telephone number, postal address/location, IP address and social handles/IDs;
Job applicant information - As a job applicant, we may also collect your C.V. and cover letter;
Survey information - We may also ask you to complete surveys that we use to help us improve our software and services, although you do not have to respond to them;
Behavioural information - In addition to the above, we collect information automatically about your visit to our website. Please see our Cookies Section for more details; and

DocuSign Envelope ID: 07A7DBEE-ACE9-4901-B7E5-FA39A739865A

Pulsar Group Privacy Policy

Classifcation: PUBLIC

Sensitive Personal Data - Includes information relating to your health, genetic or biometric data, sexual orientation, racial or ethnic origin, political opinions, religious or philosophical beliefs and trade union membership, amongst other things, depending on how that term or similar terms are defned in the relevant Data Protection Law (Sensitive Personal Data). We do not expect any sensitive personal data in our processing, but in certain circumstances, e.g. it is publicly available online, it may be included in our processing. The only exception is related to UK political contacts where we include which political party they are affliated with.

How we collect Personal Data

We may collect Personal Data directly from you as described above.

Our in-house Research Teams also contact media outlets to collect accurate professional information of individuals working there. However, we may also collect contact details and other information about you from our affliates and from third parties, including:

Service providers that help us identify individuals and companies interested in our products;
Businesses with which we offer co-branded services or engage in joint marketing activities; and
Publicly available sources and data suppliers from which we obtain data to validate or supplement the information we hold.

In relation to the above mentioned service providers, we may receive data - including Personal Data

from third-party social media platforms and other online sources in order to provide our services (for example, Meta and X). We work in accordance with their individual privacy policies and our contracts with them. We only receive and process Personal Data that has been made publicly available by the individual data subject. This could include Sensitive Personal Data, or other special category information as defned under current Data Protection Law. For example, in relation to the YouTube Services API, we process the following YouTube user information: subscriber count, views, video title, video description, video 'like' count and viewer demographics. We use this data to help provide insights from across different audiences including analytics information and visualisations for owned content performance and benchmarking. We can also gain insights into individual data subjects to help organisations and brands understand the individuals' interactions with them. The data we obtain depends upon the source and what individuals have chosen to make available. We may analyse the information published to gain additional insights such as gender, interests and geographic location.

Individuals can change their privacy settings at any time to alter the way they share their information publicly. We only have access to this data for as long as the individual makes it publicly available.

Why we collect, hold, use and disclose your Personal Data

We collect, hold, use and disclose Personal Data for the following purposes:

DocuSign Envelope ID: 07A7DBEE-ACE9-4901-B7E5-FA39A739865A

Pulsar Group Privacy Policy

Classifcation: PUBLIC

Responding to your enquiries as a data subject;
Dealing with enquiries and requests about our services submitted to us via email or call;
Requesting information about your services which are applicable to you, your company, our company and our clients;
Deliver the contracted services and allow full use of the application functionality as purchased by the clients;
Deliver training and support to our application end users and/or carry out the transactions you have requested;
To communicate with you directly through emails, calls, chats, video conferencing;
Process payments for application subscriptions;
Carry out market research to understand how to improve our services and their delivery;
Create and manage marketing campaigns;
Generate sales leads and increase our market share;
Analyse user clicks and usage of the application and website to improve user experience and maximise usage of our services;
Prevent fraud and other prohibited or illegal activities;
Protect the security or integrity of the website, application, our business or services; and
Otherwise, as disclosed to you at the point of collection or as required or permitted by law.

Please note that sometimes we may record the video conferencing call in which you participate to analyse and improve our staff's communication skills. If we do so, we will be announcing it at the beginning of the conference call and in the meeting invite, and we will be providing a link to this policy in the meeting invites and on the registration page.

We may use and disclose your information for other purposes required or authorised by or under law (including purposes for which you have provided your consent).

If we are unable to collect Personal Data from or about you, we may not be able to respond to your requests or enquiries or engage in other dealings with you.

Disclosure of Personal Data to third parties

We will only disclose your Personal Data in accordance with applicable laws and regulations. In some instances, this will include sharing your Personal Data with third parties such as:

DocuSign Envelope ID: 07A7DBEE-ACE9-4901-B7E5-FA39A739865A

Pulsar Group Privacy Policy

Classifcation: PUBLIC

Applications and services - If you are a data subject in our platform, your Personal Data may be viewed by our clients' users with access to the platform; and
Service providers - We use third parties to help us provide our products and services. They may have access to your information as collected by the website or the platform, as reasonably necessary to perform the contracted tasks on our behalf. We sign contractual agreements to obligate them to protect the Personal Data, only use it to deliver the contracted services to us, prohibit them from selling it and not disclose it without our knowledge and permission. A list of our processors and sub-processors is available here.
Group companies - your personal data may be shared with other companies in the Pulsar Group.

We may also disclose your personal information for the following: (1) to comply with applicable law, regulation, court order or other legal process; (2) to enforce your agreements with us, including this Privacy Policy; or (3) to respond to claims that your use of the Service violates any third-party rights. If the Service or our company is merged or acquired with another company, your information will be one of the assets that is transferred to the new owner.

How we hold Personal Data, and quality and security of Personal Data

We adopt appropriate data collection, storage and processing practices and security measures to protect against misuse, interference and loss, as well as unauthorised access, modifcation or disclosure of your personal or transactional information stored on our website and systems. The security of your information is important to us, and we are committed to protecting the security of all of the personal information we process. Pulsar Group uses a variety of physical, administrative and technical safeguards designed to help protect it from unauthorised access, use and disclosure. We have implemented best-practice standards and controls in compliance with internationally recognised security frameworks, including:

Data Encryption
The Principle of Least Privilege
Staff security awareness training
Vulnerability scanning and penetration tests
Endpoint Detection and Response

All Personal Data and other Information within Pulsar Group is governed by a management system which has been certifed as ISO 9001 and ISO 27001 compliant. These certifcations provide interested parties with assurance of the quality and security of Pulsar Group's technical and organisational controls. For more details, please refer to our Trust Centre.

DocuSign Envelope ID: 07A7DBEE-ACE9-4901-B7E5-FA39A739865A

Pulsar Group Privacy Policy

Classifcation: PUBLIC

How long will we store your personal data?

We typically keep client account Personal Data for up to 7 years after the creation date to operate the service in accordance with legal requirements and tax and accounting rules or as otherwise permitted by applicable law.

Where you are an Infuencer, we will retain your personal information until either (a) you request us to cease processing such information in accordance with your data protection rights or (b) you cease to be professionally active for a signifcant period of time.

In addition, Pulsar Platform keeps Personal Data of social media users for up to 2 years. Where any Personal Data is no longer required or is no longer relevant, we will ensure it is disposed of in a secure manner.

Your rights

Each jurisdiction grants individuals certain legal rights in respect of their Personal Data. No matter where you are resident, you have the following rights in relation to how the Pulsar Group processes your Personal Data:

Right to lodge a complaint - You have a right to lodge a complaint to us at any time if you object to the way in which we have processed or managed your Personal Data (see Appendix B). Where you are dissatisfed with our response, you also have the right to escalate your complaint to the relevant regulator in your jurisdiction. Further information can be located on the applicable regulator's website (see Appendix C);
Right of access - All individuals have a right to access their Personal Data held by an organisation. We will generally provide you with access to your Personal Data (subject to some exceptions permitted by law), but may charge an access fee to cover the cost of retrieving the information and supplying it to you. Please contact us (using the relevant contact details set out in Appendix B) if you would like to access the Personal Data we hold about you;
Right of rectifcation/correction - We take reasonable steps to ensure that the Personal Data we collect and hold about you is accurate, up-to-date and complete. Please contact us (using the relevant contact details set out in Appendix B) if you would like to correct the Personal Data we hold about you; and
Right to opt-out from receiving any direct marketing - You can ask us to stop sending you marketing messages at any time. Please see the Marketing section below for instructions on how you can do this.

Additional rights or exceptions apply to individual's resident in the EU, UK and Australia, which are outlined in Appendix A of this policy.

DocuSign Envelope ID: 07A7DBEE-ACE9-4901-B7E5-FA39A739865A

Pulsar Group Privacy Policy

Classifcation: PUBLIC

Marketing

We believe in being open, honest and transparent with our clients and suppliers and want you to feel comfortable about how we collect your Personal Data and how we process it. We may use your Personal Data to communicate with you about our products and services, special offers, promotions and events that may be of interest to you, or other information which may help you in your role or help your company achieve its objectives.

You have the right to opt-out from receiving any direct marketing messages. You can ask us not to send you marketing messages by following the unsubscribe instructions that appear in our communications. Alternatively, you can let us know at any time that you no longer wish to hear from us by contacting us using the relevant contact details set out in Appendix B.

In certain instances, we collect and use your Personal Data by relying on the legitimate interest legal basis where available under Data Protection Law. This is because when you, for example, request to receive services or products from us, we have a legitimate organisational interest to use your Personal Data to respond to you and there is no overriding prejudice to you by using your Personal Data for this purpose. However, we will always provide you with the option to opt out of hearing from us.

We will only communicate to you in the way you have told us. For example:

Email/text marketing - In accordance with applicable law, where you provide us with your email address and/or mobile phone number, we may contact you for marketing purposes by email or text message; and
Post/telephone marketing - If you have provided us with your postal address or telephone number, we may send you direct mail or telephone you about our work unless you have told us that you would prefer not to receive such information.

Our websites use a software technology called "cookies". A cookie is a small data fle that contains information about a visit to a website. This information is provided by an individual's computer the frst time it visits a web server. The server records this information in a text fle and stores this fle on the hard drive. When that individual visits the same web site again the server looks for the cookie and structures itself based on the information provided. Most browsers are initially set up to accept cookies, but they can be reset to refuse all cookies or to warn you before accepting cookies.

Cookies enable us to identify your device. We use cookies that are strictly necessary to enable you to move around the site or to provide certain basic features. We use cookies to enhance the functionality of the website by storing your preferences, for example. We also use cookies to help us to improve the performance of our website to provide you with a better user experience. We also allow cookies that may be served where we embed social media links such as Twitter, YouTube and LinkedIn.

DocuSign Envelope ID: 07A7DBEE-ACE9-4901-B7E5-FA39A739865A

Pulsar Group Privacy Policy

Classifcation: PUBLIC

The following types of cookies may be used when you visit the site:

Strictly necessary cookies - These cookies are essential in order to enable you to move around our website and use its features. Without these cookies, services you have asked for cannot be provided. They are deleted when you close the browser;
Performance cookies - These cookies collect information in an anonymous form about how visitors use our website. They allow us to recognise and count the number of visitors and help us understand which pages are the most popular and where visitors spend most of their time;
Functionality cookies - These cookies allow our website to remember choices you make, such as your name, the region you are in or the pages you have viewed. They are used to provide enhanced and more personal features. If you personalise our pages, or register with our website or services, a persistent cookie helps us to recall your specifc information on subsequent visits. This simplifes the process of recording your personal information, such as billing addresses, shipping addresses, and so on. When you return to our website, the information you previously provided can be retrieved, so you can easily use the features that you customised. Persistent cookies will be kept on your device until their expiry or manual deletion;
Targeting or advertising cookies - The Pulsar Group does not sell Personal Data to advertisers. These cookies allow us and our advertising partners to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of advertising campaigns. They remember that you have visited our website and may help us in compiling your profle; and
Social Media cookies - These cookies allow you to connect with social media networks such as Facebook, LinkedIn, X, Pinterest. If you do not want us to use cookies in your browser, you can remove cookies from your computer's hard drive, or set your browser to block cookies or to send a warning notice before a cookie is stored on your computer. However, please note that you may not be able to use many of the services on our website or other websites without cookies.

More detailed information on cookies can be found at www.allaboutcookies.org.

Who can you speak to about this policy?

If you would like more information about our approach to privacy, or if you wish to contact us regarding the information set out in this policy, please refer to Appendix B of this policy for details of relevant local contact(s) in your jurisdiction.

Please contact us (using the contact details in Appendix B) if you have any concerns or complaints about the manner in which we have handled your Personal Data. We may ask you to put your concern or complaint in writing and provide details about it. You also have the right to complain to the relevant regulator in your jurisdiction, and in certain circumstances, to lodge an appeal if you are not happy with the outcome of a complaint. Please refer to Appendix C of this policy for details.