1. GDPR – EU General Data Protection Regulation

The EU General Data Protection Regulation (GDPR), is an article of legislation passed by the EU. Should the UK exit the union the UK will still be subject to the provisions of the GDPR. The GDPR to a large extent supersedes the provision of the Data Protection Act 1998 (DPA), by virtue of being more thorough and up to date in regard to the subject matter of the DPA and by being far reaching in that the DPA only covered personal information under restricted circumstances whereas the GDPR covers “ALL” personal information. This GDPR policy is specific to and limited to our website, and is therefore limited in it’s scope for our viewers ease of reference. Our business is committed to being GDPR compliant. Prior to the deadline for compliance with the GDPR, subjects may initiate a subject access request under either the DPA or under GDPR.

2. Privacy policy

Previously to the implementation of the GDPR it was ‘normal’ practice of website operators to maintain a ‘privacy policy’. We believe a ‘privacy policy’ is now best placed within the context of our GDPR policy; We take the privacy of the site users very seriously. We ask that you read this entire policy (‘the GDPR Policy for our website’) carefully as it contains important information about how we will use your personal data. For the purposes of the Data protection Act 1998 and the GDPR, PULSAR Development International Ltd (‘we’ or ‘us’) is the ‘data controller’ (i.e. the company who is responsible for, and controls the processing of, your personal data).

3. Personal data we collect about you when you visit our website

We may obtain personal data about you (such as your name, address, other contact details,) whenever you complete an online form or send us an email through the website. For example, we will obtain your personal data when you send us feedback, contact us for any reason, sign up to a service, enter a competition, purchase goods or services. We may also obtain sensitive personal data about you if you volunteer it during the completion of an online form or email us. If you volunteer such information, you will be consenting to our processing it for the purpose purpose you specify in the communication. Our servers passively monitor your usage of this Site. This may include monitoring how many times you visit, which pages you go to, traffic data, location data and the originating domain name of a user’s internet service provider. This is necessary for the technical delivery of our website to your browser/device.

4. Delivery of “web pages”/”the website” – implied consent

By visiting our website your web browser will submit requests to our server(s) for information required to deliver our ‘web pages’ to you. It is not possible to present our content in your web browser without this process happening. This process involves temporarily recording your web browsers/devices unique address (known as an IP address). Your IP address may be considered personally identifiable information and falls under the GDPR legislation.

5. Key Info: IP addresses & metadata collected by web servers

Personal information collected: IP-Address & List of data/files accessed
Method of collection: Automatically by servers receiving HTTP/HTTPS requests
Method of consent: Automatic & implied (An acceptable exception under GDPR)
Data anonymised: No, but not associated with any other information
Retention period: days (1-30 days depending on log file size)
Deletion policy: Automatically deleted
Who has access ?: We and our supplier of IT-Services
Risk: MINIMAL

6. Cookies policy

We do not currently employ any cookies on our website, it is our intention to employ various cookies as the site is developed, as we do so further information will be made available here.

7. Pages where cookies are never employed

The following pages do not use cookies and are coded to do so in compliance with the GDPR, to protect your individual rights while also allowing us to provide you enough information to satisfy our legal and regulatory requirements. Visiting the following pages will leave no permanent digital footprint on our systems (beyond the transient use of your IP-Address and Browser Metadata as per the previous section).

8. e-mail

If you as an individual choose to contact us by email, a person at our organisation will identify the purpose of your email broadly emails will fit into one of the categories below.
1. Enquiries with an intention to obtain a product or service from us
2. Enquiries that do not fit with our objectives or offerings of products and services
Given the nature of our business we may obtain sensitive personal data about you if you volunteer it in the content of your email or as an attachment.

9. Key Info: e-mails for per the normal course of business (1 above)

Personal information collected: IP-Address, e-mail address, Metadata, e-mail Content and Attachments
Method of collection: Automatically by e-mail servers
Method of consent: Automatic and implied per acceptance of website T&Cs and this GDPR-Policy
Data anonymised: No
Retention period: Months to years
Deletion policy: Automatically deleted after a maximum of 2 years unless subject our terms of business and full GDPR-Policy or the “Right to be forgotten”
Who has access ?: We and our supplier of IT-Services
Risk: LOW to HIGH depending on content

10. Key Info: e-mails that are not relevant to our objects or the provision of a service (2 above)

Personal information collected: IP-Address, e-mail address, Metadata, e-mail Content and Attachments
Method of collection: Automatically by e-mail servers
Method of consent: Automatic and implied per acceptance of website T&Cs and this GDPR-Policy
Data anonymised: No
Retention period: Months to years
Deletion policy: Automatically deleted after 1 year
Who has access ?: We and our supplier of IT-Services
Risk: LOW to HIGH depending on content

11. e-mail marketing

We do not operate any e-mail based marketing programs, if you have received what you believe to be an email from us that appears to be a marketing email please forward it to london@pulsar-development.com as it is likely to be unauthorised activity by another party.

12. Disclosure of your personal data

We may disclose your personal data to:

Our agents / staff / contractors if necessary to further the provision of a service to you at your explicit request
Related organisations to whom we have statutory obligations
Law enforcement agencies in connection with any investigation to help prevent unlawful activity
Third parties in relation to the provision of services that you require from us, including banks, lenders, investment providers, financial institutions and entities, and their agents or representatives

13. Keeping your data secure

We will use technical and organisational measures to safeguard your personal data, for example:

We store your personal data on secure servers
Related organisations to whom we have statutory obligations

Whilst we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data which are transferred from you or to you via the internet.

14. Information about other individuals

If you give us information on behalf of someone else, you confirm that the other person has appointed you to act on his/her behalf and has agreed that you can:

Give consent on his/her behalf to the processing of his or her personal data
Receive on his/her behalf any data protection notices
Give consent to the transfer of his/her personal data abroad

15. Your rights

You have the right to require us to correct any inaccuracies in your data free of charge. If you wish to exercise this right you should:

Put your request in writing
Provide us with enough information to identify you (e.g. account number, username, registration details)
Specify the information that is incorrect and what it should be replaced with

You have the “right to be forgotten”. If you wish to exercise this right you should:

Put your request in writing
Provide us with enough information to identify you

16. Changes to this policy

We may change this policy from time to time. You should check this policy occasionally to ensure you are aware of the most recent version which will apply each time you access this site.