PULSA S.à r.l, a marketing, communications and digital marketing agency, uses communication tools subject to the processing of personal data. In this context, and under the obligation of the General Data Protection Regulation of May 25, 2018, we undertake to treat the data as a good father and we underline your rights with respect to your personal data.
Legal Policy
Welcome to pulsa.lu ! In compliance with articles 13 and 14 of the European General Data Protection Regulation N° 679/2016 (hereiafter « GDPR »), this Privacy Policy is there to inform you of the data processing procedures and the protection of your personal data related to our website, its content and our services. By personal data, we mean all information related to an identifier or identifiable individual (one that can be directly or indirectly identified).
PULSA’s data processing controller or data protection officer:
- Data controller
PULSA S.à r.l
62B, Grand-Rue L-3394 Roeser Luxembourg
Trade register and number: B185248
Business licence number and trade: 10046386 / 4 / 5 / 6 / 7
VAT number: LU26796676
Tel: +352 28 83 66 1
E-mail: contact@pulsa.lu
- Data Protection Officer
If you have any questions about the processing of your personal or your rights to privacy, please contact our Data Protection Officer at the address indicated above, or at the following email address : moien@pulsa.lu
- Log-files
Every time you browse our website, the browser you are using on your end device will automatically send to our website’s server for storage in server log files. Such data consist in information related to an identifiable or identified individual. The information is saved in that process:
– your end device’s IP address
– time and date of the website call
– name and URL of the file called
– URL of the website from which you went on our website
– type and version of the browser you used
– operating system used and the name of your access provider
The aim of this data processing is to ensure that our website can be properly opened and displayed on your end device. The information will also be used to optimize our website and ensure the security and stability of our systems.
The legal basis for the processing is article 6(1)(f) of the GDPR.
You have the right to object to supplying such information but your failure to do so may prevent you from using our website in whole or in part. The processed data will be stored only as long as necessary for the intended purpose or for the statutory retention period.
What is a cookie?
A cookie is a small file of data or text placed by websites on your desktop. As in food, there a different digital cookies such as session cookies known as ‘temporary cookies’, helping websites recognize users and the information provided when they navigate through a website, as long as the customer navigates; permanent cookies, known as “persistent cookies”, used by third parties to target customers; flash cookies also known as “super cookies”, remaining in your desktop even after deleting the cookies from your web browser; last but not least zombie cookies, difficult to manage and detect (but do not worry, PULSA.lu is also fighting against these creatures).
What is the purpose of PULSA to use cookies?
PULSA S.à r.l-S has the duty to enlighten our customers regarding European directives on cookies that we use. The cookies we use help us to optimize your visit on our website and offer you hand-made services. Cookies are helpful to detect some issues.
Since PULSA hates cookies, we only use ones with no prior consent.
Which cookie do we use?
| Cookie Name | Provider | Purpose | Expiry |
| r/collect | Doublick.net | This cookie is used to send data to Google Analytics about the visitor’s device and behavior. It tracks the visitor across devices and marketing channels.
| Session |
| _ga | Pulsa.lu | Registers a unique ID that is used to generate statistical data on how the visitor uses thee website.
| 2years |
| _gat | Pulsa.lu | Used by Google Analytics to throttle request rate | 1day |
| _gid | Pulsa.lu | Registerds a unique ID that is used to generate statistical data on how the visitors uses the website | day |
| collect | Google-analytics.com | Used to send data to Google Analytics about the visitor’s device and behavior. Tracks the visitors across devices and marketing channels | Session |
| vuid | Vimeo.com | Collects data on the user’s visits to the website, such as which pages have been read. | 2 years |
Management of cookies
If by chance, a cookie is popping out, it is still under your prior consent.
Your choices on your navigation program
You can configure your web browser in order to accept and save cookies:
If your browser is set to accept the recording of cookies in your device, cookies embedded in the pages and contents you have viewed will be systematically stored in your device.
or refuse them:
You can set your browser software to:
- to punctually accept or refuse a cookie before its saved
- systematically refuse the registration of cookies in your device
Warning: Any setting that you can undertake on your browser regarding the acceptance or refusal of cookies may change your Internet browsing and your conditions of access to certain services that require the use of these cookies.
If you choose to refuse the registration of cookies in your terminal or if you delete them, we disclaim any liability for the consequences related to the degraded operation of our services resulting from the impossibility for us to register or consult the cookies necessary for their operations and that you have refused or deleted.
You can also instruct system to delete cookies automatically when you close the browser window.
How to apply your rights regarding your personal navigator?
The configuration of each browser is different. It is usually described in the help menu of your browser software. We invite you to read it. You will be able to know how to modify your wishes regarding cookies.
- For Internet Explorer™ support.microsoft.com
- For Safari™ support.apple.com
- For Chrome™ support.google.com
- For Firefox™ support.mozilla.org
For more information about how to delete cookies and/or change cookie settings in the most common browsers, check out the following links:
- Chrome: https://support.google.com/chrome/answer/95647
- Firefox: https://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websites-stored
- Safari: https://support.apple.com/kb/ph51411?locale=en_GB
- Microsoft Internet Explorer: https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies
When you return to our website, cookies let us recognize automatically that your IP address has already been on our website before. Third-party cookies may also be set by the service providers we use. We will inform you separately of our use of cookies associated with the individual services.
Which Analytics tools do we use ? Google Analytics
Google Analytics is a web analytics service from Google Inc. (https://www.google.com/intl/en-GB/about/) (hereinafter “Google”).
In that context, pseudonymised user profiles are created and cookies are used.
The information generated by cookies concerning your use of our website is transferred to one of Google’s servers in the USA for storage.
You can prevent the installation of cookies by choosing the appropriate setting in your browser software.
You can download and install a browser add-on to prevent Google from recording information generated by cookies concerning your use of our website (https://tools.google.com/dlpage/gaoptout).
For more information about data protection related to Google Analytics, see the Google Analytics support page (https://support.google.com/analytics/?hl=en#topic=3544906).
The integration of Google services sometimes allows Google to collect and process information (including personal data). We cannot control which information is collected and processed by Google itself. On that subject, please see the Google Privacy Policy (https://policies.google.com/privacy). For tips on Google privacy settings, see https://privacy.google.com/take-control.html?categories_activeEl=sign-in.
Third party website links
Our website may contain links to external third-party websites. Data processing on these websites is carried out under the sole liability of the relevant third party, and such processing is therefore beyond our control. For more information, please refer to the third party’s privacy and cookie policy.
Right to be forgotten?
Data subjects have certain rights subject to the conditions defined in the GDPR. Every data subject generally has the following rights:
- Right of access by the data subject (GDPR Art. 15): you have the right to obtain information about the processing of your personal data and its main components.
- Right to rectification (Art. 16 GDPR): you have the right to demand rectification of data concerning you and/or completion of incomplete data.
- Right to object (GDPR Art. 21): insofar as your personal data is processed on the basis of legitimate interests within the meaning of GDPR Article 6 (1) (f), you have the right to object to such processing on grounds relating to your particular situation (without prejudice to our compelling legally protected interests) and/or to object to direct advertising. If you wish to exercise your right to object, you may send us an e-mail at the following address: moien@pulsa.lu. We will keep a file in which the relevant information of the persons who have exercised their right to object will be processed in order to respect the data subject’s wishes. The information in the opt-out list will be stored for 3 years and then deleted.
- Right to erasure (GDPR Art. 17): under certain conditions, you have the right to erasure of your personal data stored by us, e.g., in case the personal data are no longer necessary in relation to the purposes for which they were collected or if you have made a legitimate objection to the data processing. The right to erasure is not always applicable, especially not if the processing is necessary for exercising the right of freedom of expression and information; for compliance with a legal obligation, for reasons of public interest or for the establishment, exercise or defense of legal claims.
- Right to restriction of processing (GDPR Art. 18 et seq.): you have the right to obtain the restriction of the processing of your personal data under certain conditions, in particular if you contest the accuracy of the data but you do not wish to obtain erasure of the data; the information is no longer needed by us but you need the information for the establishment, exercise or defense of legal claims, or you have made a legitimate objection to the data processing
- Right to data portability (GDPR Art. 20): in certain cases defined by law, you have the right to receive your personal data that you supplied to us, in a structured, commonly used and machine-readable format and you have the right to transmit those data to another controller.
In accordance with the regulations in force, any request for the exercise of your rights must be signed and accompanied by a photocopy of an identity card bearing your signature and specify the address to which the reply must be sent to you. An answer will be sent to you within 2 months of receiving the request.
Don’t hesitate to send us any requests or queries you may have concerning your rights to moien@pulsa.lu . If you believe that the processing of your data is not compliant with the GDPR, you have the right to file a complaint with the competent data protection authority (cf. www.cnpd.lu).
Data security
We protect our website and other systems by taking appropriate technical and organizational measures against loss, destruction, access, modification or dissemination of your personal data by unauthorized persons. Despite such measures, complete protection against all risks is not possible given the nature of the Internet.
In case of breach/loss of data
Any loss or violation of personal data will be notified to the CNPD within 72 hours and to the persons concerned in accordance with the law of 25 May 2018, Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and the free movement of such data.
Changes to the Privacy Policy
It may be necessary to adapt this Privacy Policy in case of changes in our company procedures or amendments of the applicable laws. You will be informed of such change in a reasonable time. Please examine the currently applicable Privacy Policy when you visit our website.
DISCLAIMER OF WARRANTIES AND LIMITATION OF LIABILITY
This site is provided by Pulsa S.à r.l “as is” and “as available” basis. Pulsa makes no representations or warranties of any kind, express or implied, as to the operation of this site or the information, content, materials, or products included on this site. You expressly agree that your use of this website is at your sole risk. To the full extent permissible by applicable law. Pulsa S.à r.l disclaims all warranties, express or implied, including but not limited to particular purpose. Pulsa S.à r.l does not warrant that this website, its servers, or email sent from Pulsa S.à r.l are free of viruses or other harmful components. Pulsa S.à r.l will not be liable for any damages of any kind arising from the use of this site.
APPLICABLE LAW
By visiting pulsa.lu, you agree that the laws of the Grand-Duchy of Luxembourg, without regard to principles of conflict of laws, will govern these Conditions of Use and any dispute of any sort that might arise between you and Pulsa S.à r.l or its associates.