Effective: 03.03.2025
WHO IS RESPONSIBLE FOR DATA PROCESSING AND WHO CAN I CONTACT?
1.1 Pulsec GmbH, Krugerstraße 2/10, 1010 Vienna (“Pulsec”, “we”, “us”) is the responsible entity in accordance with Art. 4 Para. 7 of the General Data Protection Regulation (“GDPR”) regarding the processing of your personal data in the context of using the website https://pulsec.at/ (hereinafter referred to as the “Website”).
1.2 Pulsec focuses on protecting our customers, their data, and their users. Domain knowledge in information security and proven methodologies, combined with innovative cybersecurity solutions, is our weapon to protect your business from cyber threats. Regardless of whether you are a government agency, a public or private company, or belong to a specific industry, we are your reliable partner in dealing with the security challenges you face daily in this interconnected world.
1.3 You can contact us as follows:
Pulsec GmbH
Krugerstraße 2/10
1010 Vienna
Phone: +43 676 967 20 70
Email: dragomir.janjic@pulsec.com
1.4 Pulsec takes the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the applicable data protection regulations, especially the GDPR and the Austrian Data Protection Act in the currently applicable version (“DSG”).
1.5 This privacy policy provides information about the data processing activities. The terms defined in the GDPR are used. To make it easier to understand, the key terms according to their legal definitions are explained below:
• Personal Data: Any information related to an identified or identifiable natural person (“data subject”); an identifiable person is one who can be identified directly or indirectly, particularly by reference to an identifier such as a name, identification number, location data, online identifier, or one or more specific characteristics that express the physical, physiological, genetic, mental, economic, cultural, or social identity of that person.
• Processing: Any operation or set of operations performed on personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment or combination, restriction, erasure, or destruction.
• Data Subject: The person whose personal data is being processed.
• Controller: The natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of processing personal data.
• Processor: The natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller.
• Consent (of the data subject): Any freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which they, by a statement or a clear affirmative action, signify agreement to the processing of personal data relating to them.
FOR WHAT PURPOSES AND ON WHAT LEGAL BASIS ARE YOUR PERSONAL DATA PROCESSED?
2.1 Operation of the Website
2.1.1 To provide the website to you and to detect, prevent, and investigate attacks on our website, Pulsec processes the following personal data based on our legitimate interests (Art. 6 Para. 1 lit. f GDPR): the URL visited; the date and time of access; the IP address of the computer or mobile device; the name and version of the web browser; the browser type and settings (screen resolution, color depth, time zone settings, browser extensions, fonts, language); the operating system; and the website (URL) from which you visit our website (“Referrer”). Processing this data is necessary to offer you our website with its features.
2.2 Request via Website, Email, Post, or Phone
2.2.1 If you send an inquiry via our contact form on the website, by email, or by phone, Pulsec processes the following personal data to respond to the inquiry, to fulfill pre-contractual measures, or to fulfill the contract (Art. 6 Para. 1 lit. b GDPR), or based on our legitimate interests in processing your inquiry (Art. 6 Para. 1 lit. f GDPR): first name, last name, email address, phone number, content of the inquiry, and any other information you voluntarily provide. Processing your contact data (at least email address or phone number) is necessary to process your inquiry.
2.3 Offering Pulsec Services and Products (including Customer Management)
2.3.1 In the context of our services and products, we process (i) personal data you provide to us, (ii) personal data provided to us by our clients as the contracting party for services and products, and (iii) personal data we collect ourselves while providing the services and products. For the aforementioned purposes, we process name, address, and other contact details, date of birth and place of birth, identification data (including identification documents and other personal data related to the specific order, including documentation, event documentation, billing data, bank details). Without processing this data, we cannot offer services and products or handle ongoing customer management. The legal basis for this processing is the performance of pre-contractual measures or the fulfillment of the contract (Art. 6 Para. 1 lit. b GDPR).
2.4 Marketing Communication, Newsletters, Event Participation
2.4.1 We send electronic mail (via email, SMS, MMS, or Messenger) to our customers for promoting our products or services (“marketing messages”). For this purpose, we process your first and last name, email address, phone number, and other information you voluntarily provide in connection with receiving marketing messages. The customer can object to receiving marketing messages at any time by sending an email to office@pulsec.at. We will also provide an option to opt-out of further marketing messages with each marketing message. The legal basis for sending marketing messages is § 174 Para. 4 TKG 2021.
2.4.2 We send postal communications with marketing content based on our legitimate interests in promoting products or services that may be of interest to you (Art. 6 Para. 1 lit. f GDPR). For this, we process your first and last name, address, and other information you provide in connection with receiving marketing messages. You can exercise your right to object to postal marketing communications by sending an email to office@pulsec.at.
2.4.3 If you voluntarily provide us with your contact details and other data for receiving newsletters, participating in events, or other informational transmissions, we process your data based on your consent (Art. 6 Para. 1 lit. a GDPR). You can withdraw your consent at any time by emailing office@pulsec.at.
2.5 Legal Prosecution
2.5.1 In the event of an administrative or judicial dispute, the data necessary for the appropriate legal prosecution will be processed and, if necessary, transmitted to legal representatives, courts, and/or administrative authorities. In this context, particularly your contact details (first and last name, address) and other data related to the legal dispute (your behavior regarding the use of the website) will be processed. The aforementioned personal data will be processed based on our legitimate legal interests in legal prosecution under Art. 6 Para. 1 lit. f GDPR and in accordance with Art. 9 Para. 2 lit. f GDPR.
TO WHOM WILL YOUR PERSONAL DATA BE DISCLOSED?
3.1 We will disclose your personal data to our cooperation partners for the respective services and products, as necessary to process your inquiry or to provide the requested services and products. When booking cooperation products, which are explicitly identified as such, the personal data will be forwarded to the respective partners.
3.2 We use processors in accordance with Art. 28 GDPR, who carry out services on our behalf. Processors may only process the data entrusted to them in accordance with our instructions and as necessary for the performance of services on our behalf. We contractually require these processors to ensure the confidentiality and security of personal data processed under the contract.
3.3 The data protection level in countries outside the EEA may not correspond to that within the EEA. However, we will only transmit your personal data to countries for which the European Commission has determined that they provide an adequate level of data protection or we will implement measures under Chapter V of the GDPR to ensure that all recipients in third countries guarantee an adequate level of data protection. For this purpose, we enter into standard contractual clauses issued by the European Commission with these recipients.
HOW LONG WILL YOUR PERSONAL DATA BE STORED?
4.1 Your personal data will be stored only as long as necessary to achieve the respective purpose.
4.2 Pulsec will store your data longer than the time specified in section 4.1 if and to the extent required by legal retention obligations (according to § 132 Para. 1 BAO; §§ 190, 212 UGB: 7 years) or for the enforcement or defense of legal claims (usually for a period of up to 3 years), with longer data processing required in the case of pending or ongoing proceedings.
4.3 If data processing is based on your consent, Pulsec will process your data until consent is revoked. Consent can be withdrawn at any time by emailing office@pulsec.at. Revoking consent does not affect the legality of the processing that occurred based on consent until the revocation.
WHAT RIGHTS DO YOU HAVE?
5.1 You have the right to access under Art. 15 GDPR, the right to rectification under Art. 16 GDPR, the right to erasure under Art. 17 GDPR, the right to restriction of processing under Art. 18 GDPR, the right to object under Art. 21 GDPR, the right not to be subject to automated decisions, including profiling, under Art. 22 GDPR, and the right to data portability under Art. 20 GDPR. Additionally, there is a right to lodge a complaint with a competent supervisory authority under Art. 77 GDPR. For more information on your rights, visit: https://www.dsb.gv.at/rechte-der-betroffenen.
5.2 If you have any questions regarding the processing of your personal data or wish to exercise any of your rights under the GDPR, such as accessing, rectifying, or erasing your data, please contact us via email at office@pulsec.at.
5.3 The competent supervisory authority is the Austrian Data Protection Authority, Barichgasse 40-42, 1030 Vienna (https://www.dsb.gv.at/).