Privacy Policy
Privacy Policy for Pulsec Website Visitors
Introductory provisions
The rules for privacy protection of Pulsec d.o.o., for clients and other participants (hereinafter: “Rules”) of Pulsec d.o.o. (hereinafter: “Pulsec”) explains how to process personal data of clients and other participants (hereinafter: “Data Holder”/ “Data Holders”, “You”) in accordance with the General Data Protection Regulation (EU) 2016/ 679 (hereinafter: “Regulation”), “das Bundesgesetz zur Änderung des DSG 2018”, “DSGVO”, “BDSG” and “TTDSG”.
With these Rules, Pulsec provides information about the controller of personal data processing, the personal data protection officer, data that Pulsec collects and processes, for what purpose and legal basis, personal data processors, the storage time of your personal data, data protection and the rights of the Data Holder. These Rules are available on the website of Pulsec (www.pulsec.at).
Who is responsible for processing your personal data?
The following is responsible for data processing:
Pulsec d.o.o.
Krugerstraße 2/7
Austria, Wien
Phone: +43 1 484 90 01
e-mail: info@pulsec.com
Regarding the processing of your data, you can contact the Personal Data Protection Officer (DPO): Milorad Zrnić
Phone: +381 66 8042810
Email: dpo@pulsec.com
Personal data we collect and process
We primarily process personal data that you provide us directly, when visiting our website and establishing a business relationship with Pulsec.
Furthermore, we process personal data, to the extent necessary for the provision of Pulsec services, as well as data generated by web cookies and for which you consent.
We also process personal data that we have collected from publicly available sources.
Personal data that Pulsec processes are: first name, last name, email address, position/function at the employer, name of the employer.
Purpose and legal basis of personal data processing
We process personal data on the basis and for the purposes of:
a. Execution of the contract and/or undertaking of actions at the request of the Data Holder prior to the conclusion of the contract
The processing of personal data takes place for the purpose of providing services for the performance of a contract to which you are a party or to take actions at your request before concluding a contract.
b. Legitimate interest of Pulsec or a third party
We also process your data if the processing is necessary for the legitimate interests of Pulsec or a third party.
For example:
• for advertising or market research purposes, except for the data for which you have lodged an objection (the right to lodge an objection is described in a separate part of these Rules),
• for the purpose of court disputes,
• ensuring IT security,
• implementation of measures for the protection of Pulsec facilities (e.g. checking access rights),
• implementation of measures for the improvement and development of Pulsec products and services,
• implementation of fraud prevention measures,
c. Consent
The legality of processing your personal data for one or more special purposes is based on your consent when entering into a business relationship with Pulsec.
You can withdraw/revoke your consent at any time. Withdrawal of consent does not affect the legality of processing based on consent that was carried out before its withdrawal. Withdrawing consent is as easy as giving it.
d. Respecting Pulsec’s legal obligations or fulfilling obligations in the public interest
As a socially responsible company, Pulsec is committed to fulfilling statutory obligations and regulations (e.g. GDPR).
Who has access to your personal data and to whom we deliver your data
Inside Pulsec
Within Pulsec, access to your data is given to those organizational units that process your data in order to fulfill our contractual and legal obligations and to achieve the legitimate interests of Pulsec and third parties. Pulsec does not deliver your data to third parties.
c. Service providers
For the performance of certain services, Pulsec has authorized other service providers (hereinafter: “Service Providers”) to whom it submits your data for the purpose of performing the contracted services. Service providers are first of all familiar with the fact that your personal data is a secret, and we allow access to your data only to executors, i.e. service providers, who guarantee us the protection of personal data in accordance with the provisions of the GDPR. Service providers are companies that provide high-tech IT services, support services, telecommunications services, etc.
d. Other recipients of data based on your request for the transfer of personal data
How we protect your data
The protection of your personal data is extremely important to us. Some of the protection measures we implement are as follows:.
• establishment of technical and organizational measures necessary for the processing of personal data to be carried out in a safe manner;
• control of physical and logical access to the information system and business premises of Pulsec;
• establishment of technical and procedural measures necessary for the IT infrastructure to be implemented in accordance with the highest international security standards;
• establishment of electronic and procedural safeguards related to the collection, storage and disclosure of personal data
How long is personal data kept?
We process and store personal data as long as it is necessary to fulfill contractual and legal obligations or for as long as the session on the website lasts.
If we no longer need your data after the expiration of the contractual obligation, we delete it, and at the latest after the expiration of all legal deadlines for storing personal data.
Your rights
As Data Subjects within the meaning of the GDPR, you have the following rights:
• The right to access information
You have the right to request confirmation of whether we are processing your personal data, as well as access to your personal data that we are processing. You can exercise the same rights by completing a request for exercise of rights (hereinafter: Request).
We will respond to your request as soon as possible, and at the latest within one month from the date of receipt of the proper request.
• Right to rectification
You have the right to request the correction or addition of your personal data by submitting a Request. We will respond to your request as soon as possible, without unnecessary delay.
• Right to erasure
You have the right to request the deletion of your personal data if:
(I) that data is no longer necessary in relation to the basis for which it was collected or otherwise processed;
(II) withdraw the consent on which the processing of your personal data is based, and if there is no other basis for the processing;
(III) file an objection to the processing and there is no stronger legitimate reason for the processing, i.e. if you file an objection to the processing of data that is processed for direct marketing purposes, which includes creating a profile to the extent that it is related to such direct marketing;
(IV) the data has been illegally processed;
(V) the data must be deleted in order to comply with the legal obligation defined by the Personal Data Protection Act.
You can exercise your right by submitting a Request. We will respond to your request as soon as possible, without unnecessary delay.
• The right to restriction of processing
You have the right to request that we do not delete your personal data, but that it continues to be processed on a limited basis (in accordance with the restrictions that you specify) if you need it to exercise your other rights.
You can exercise the aforementioned rights by submitting a Request. We will respond to your request as soon as possible, and at the latest within one month from the date of receipt of the orderly request.
In the case of a large number of requests, as well as in the case of the complexity of your query, it is possible that we will need additional time to respond. In that case, we will inform you in a timely manner and answer you no later than 3 months from the date of receipt of the proper Request.
• The right to transfer data
You have the right to request the transfer of your personal data. You can exercise the same right by completing the Request. On the Request, you need to select the categories of personal data that are of interest to you, as well as indicate the time period to which your request refers.
Submit the completed Request to Pulsec via email info@pulsec.com. We will respond to your request as soon as possible, and at the latest within one month from the date of receipt of the proper request. In the case of a large number of Requests, as well as in the case of the complexity of your query, it is possible that we will need additional time to respond. In that case, we will inform you in a timely manner and answer you no later than 3 months from the date of receipt of the proper Request.
• The right to object
A special instruction regarding the right to object is stated below in these rules.
• The right to complain
At any time, you have the right to file a complaint before the competent authority for the protection of personal data of the state of Austria, related to the processing and protection of your personal data.
Profiling - Automated individual decision-making
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects that relate to you or similarly significantly affect you.
In case of need to use these procedures in individual cases, we will inform you separately.
We process your data partially automatically with the aim of evaluating certain personal aspects (profiling).
For example, we use profiling in the following cases:
• in order to be able to inform and advise you about products, we use special programs for the purpose of better insight into your needs (eg certain products, marketing);
Instructions related to the right to object
1. The right to object based on the special situation of personal data processing
In the event that we process your data in accordance with the special regulations of the Austrian state adopted on the basis of Chapter IX of the Regulation, you have the right to object at any time to the processing of personal data relating to you, including the creation of a profile based on those provisions. In this case, we may no longer process your personal data unless there are compelling legitimate reasons for the processing that go beyond your interests, rights and freedoms or to establish, exercise or defend legal claims.
2. The right to object to the processing of personal data for direct marketing purposes
If personal data is processed for the purposes of direct marketing, you have the right at any time to object to the processing of personal data for the purposes of such marketing, which includes profiling to the extent related to such direct marketing.
In any case, you can send us a complaint directly at any branch or in writing:
Pulsec d.o.o.
Kruger str.2/7
Austria, Vienn
e-mail address: dpo@pulsec.com