Effective Date: 3 September 2020
About this Notice
Thank you for downloading Pulse.
Your privacy and the security of your personal data is, and will always be, very important to us. So, we want to transparently explain how and why we gather, store, share and use your personal data.
This Notice sets out the details of your personal data relationship with Pulse Ecosystems Pte Ltd, a Singapore company (“PulseCo”) and its affiliates. This Notice applies to all services made available to you through Pulse App (the “Pulse Services”).
This Notice tells you:
From time to time, we may develop new or offer additional services. If the introduction of these new or additional services results in any material change to the way we collect or process your personal data we will provide you with more information or additional terms or policies. Unless stated otherwise, when we introduce these new or additional services, they will be subject to this Notice.
The terms governing your use of Pulse App are defined in our Pulse App Terms and Conditions.
Who are we?
Your Data Controllers
PulseCo and the Prudential insurance entity operating in your territory (see Appendix 2) (“Pru Local Entity”) are separate data controllers (in some territories, this is known as a data user or data operator) of the personal data collected or gathered through your use of the Pulse Services, although the Pru Local Entity only processes such data as is necessary to carry out the purposes described in the “Why do we need your personal data?” section below.
If you purchase any insurance products or register to utilise any insurance services provided by Pru Local Entity on Pulse, the Pru Local Entity will collect and process your data for such purposes in accordance with their own terms and conditions and privacy notices.
The Pru Local Entity does not gather, collect or process any Health Data (as defined below) from your use of Pulse. If you are a customer of the Pru Local Entity, the Pru Local Entity may collect health data as part of the underwriting process to provide you with an insurance product or service in accordance with their own privacy notices.
For the data controllers' contact information, please see the "Updating your details and contacting us" section below.
Pulse Partners are third party partners who contract with you directly under their own terms and conditions to provide services in their own name – these may include sellers who sell goods and services on the Pulse Marketplace, the Health Assessment and Symptom Checker services, telemedicine Services, pulse wallet in certain territories and other services that we may add to the Pulse App from time to time.
Pulse Partners collect, gather and process information arising from your use of those services as independent data controllers. Pulse Partners will process your personal information in accordance with their privacy notices which are made available to you prior to you using the relevant service.
PulseCo is also an independent data controller in relation to such data collected or generated from your use of the Pulse Partner services and PulseCo will process such data in accordance with this Privacy Notice.
What data do we collect and where do we collect it from?
Providing your personal data is voluntary. However, if you do not provide your personal data, we may be unable to register you for the Pulse App or provide the Pulse Services or your use of or access to the Pulse App may be otherwise limited.
These are the data and information we collect or gather about you:
(a) Personal data you provide:
(b) Personal data we collect from other sources:
(c) Personal data we collect automatically when you use Pulse Services:
(d) Personal data we collect through cookies or other similar technologies.
These items may include the following, for example (as may be applicable):
(e) Health Data
The Pru Local Entity is not a data controller with respect to your Health Data. PulseCo and where applicable, the relevant Pulse Partner, are separate data controllers of your Health Data.
To the extent required by applicable laws, PulseCo will ask for your specific consent to process the Health Data. PulseCo obtains this consent separately when you take actions leading to collection, gathering, use or disclosure of Health Data. You can withdraw your consent at any time by contacting the PulseCo Privacy Officer – see "Updating your details and contacting us" section below.
In addition, you always have the right to ask us to delete your Health Data regardless of whether local laws provide you with this right, unless we have a legal obligation or need to retain such data.
(f) Cookies, Beacons
If you decide not to have your personal data processed by us for advertising purposes via cookies (and similar technologies), this does not mean that we will not show you advertisements. It simply means that these advertisements will not be personalized for you using first-party or third-party cookies, web beacons, or similar technologies.
Why do we need your personal data?
Pru Local Entity:
What is our justification for using your data?
PulseCo and Pru Local Entity rely on one or more legal bases for processing your personal data, including:
Who do we share your information with?
Pulse App profile information
The following personal data will be publicly available on the Pulse App: your name and/or username, profile picture, and any other information on your profile page.
Personal data you may choose to share
The following personal data will only be shared with other Pulse App users as follows:
Who we may share your personal data with
We may share your personal data with the following transferees to the extent necessary for them to assist us with fulfilling the above purposes or in accordance with any consent you have given: service providers, accountants, auditors, IT service and platform providers, intermediaries, reinsurers/retakaful operators, investment managers, agents, pension trustees (and other stakeholders), scheme advisors, introducers, selected third party financial and insurance/takaful product providers, advertising providers and legal advisers.
We share your personal data when we in good faith believe it is necessary for us to do so in order to comply with a legal obligation under applicable law, or respond to valid legal process, such as a search warrant, a court order, or a subpoena. We also share your personal data where we in good faith believe that it is necessary for the purpose of our own, or a third party’s legitimate interest relating to national security, law enforcement, litigation, criminal investigation, protecting the safety of any person, or to prevent death or imminent bodily harm.
We may share your personal data with other PulseCo affiliates where it is needed to carry out our daily business operations and to enable us to maintain and provide the Pulse Services to you, as well as for marketing purposes as mentioned in the section "Why do we need your personal data?" above.
We may share your personal data with an actual or proposed purchaser or transferee if we are involved in a merger, acquisition, re-organisation, sale of assets, or other similar corporate transaction, including for the purpose of any due diligence exercise.
Where may we process your personal data?
We may process your personal data in a territory other than the one you are resident in. To the extent we transfer your personal data, we will use appropriate safeguards and comply with the laws of the territory from which your personal data is transferred.
How do we keep your data safe?
How long do we keep your data for?
We keep your personal data only as long as necessary to provide you with the Pulse Services and for legitimate and essential business purposes, such as maintaining the performance of the Pulse Services, making data-driven business decisions about new services and products, complying with our legal obligations, and resolving disputes.
We maintain your personal data for the following periods:
Your personal data will be deleted or anonymised after the relevant retention periods have expired.
What can you do?
Pulse App is not targeted at persons under the age of 18. We do not knowingly collect personal data from persons under the age of 18. While certain Pulse Services may ask parents to provide data of their children where required for the service, we do not knowingly collect personal data about persons under the age of 18 without a parent/legal guardian's consent (please see the “ Acting on someone else’s behalf?” section below). If you believe that we have collected personal data from a person under the age of 18, or we have collected personal data about a person under the age of 18 without a parent/legal guardian's consent, please inform us via the details in the "Updating your details and contacting us" section below.
Acting on someone else’s behalf?
Pulse App is primarily designed to be used by yourself only; however there may be limited circumstances where you may give us personal data about others. If you give us personal data about another person (or persons), we’ll take that to mean they have appointed and authorised you to act on their behalf. This includes providing consent to:
If you give us personal data about a person under the age of 18, you must either be the person's parent/legal guardian or have the consent of the person's parent/legal guardian before doing so.
Updating your details and contacting us
Please update your details as directed on the Pulse App if any details you have provided to us in your registration change (e.g., if you change your e-mail address, telephone number). Please use the details below to contact PulseCo with any requests to do with your data.
Title / Designation:
Attention: Privacy Officer, Pulse Ecosystems Pte Ltd, 1 Wallich Street #19-01 Guoco Tower Singapore 078881
We will respond to and action all requests within the time limits required by applicable law and regulation. We may refuse to action a request to correct or provide access to personal data where the law allows or requires us to do so. For security reasons, we may take steps to authenticate the identity of the requesting party before responding to a request.
In those countries where we are required to do so by law, we have appointed data protection officers to oversee the protection of your personal data. If you have any questions about this Privacy Notice or about data protection for the Pulse Services or have complaints regarding this Privacy Notice or our handling of personal data, you can contact PulseCo through the Pulse Helpdesk above. To contact a Pru Local Entity, please refer to the contact information on their own privacy notice which you may access via the websites indicated in Appendix 2.
About this notice
Language: To the extent there is any inconsistency between the English version and an official local translation of this Privacy Notice, the English version shall prevail.
Definitions: Capitalised terms not defined in this Privacy Notice shall have the meaning given to them in the Pulse App Terms and Conditions.
"Prudential Group" means Prudential Plc and any affiliates of Prudential Plc.
Amendments: We change this Privacy Notice from time to time. We will not reduce your rights under this Privacy Notice without informing you. We always indicate the date the last changes were published.
Appendix 1 – Territory Specific Information
If you are a user in one of the following countries or regions, the following information is relevant to you.
Pulse is operated by Pulse Ecosystems Pte. Ltd., an affiliate of Pru Life UK. Both companies are affiliates of Prudential plc, a company incorporated in the United Kingdom. Prudential plc, Pulse Ecosystems Pte. Ltd., and Pru Life UK are not affiliated with Prudential Financial Inc., Philippine Prudential Life Insurance Company Inc., Prudentialife Plans, Inc. or Prudential Guarantee and Assurance, Inc.
“Whenever the word ‘insurance’ appears, it shall also include takaful.”
In the Children’s Information and Acting on someone Else’s Behalf? sections, all references to ‘age of 18’ shall be replaced with ‘age of 21 or person under guardianship’.
Pulse is operated by Pulse Ecosytems Pte. Ltd., an affiliate of PCA Life Assurance Co., LTD (PCALT). Both companies are affiliates of Prudential plc, a company incorporated in the United Kingdom. Neither Prudential plc, Pulse Ecosystems Pte. Ltd., nor PCALT are affiliated with Prudential Financial Inc., a company whose principal place of business is in the United States of America.
In the Children’s Information and Acting on someone Else’s Behalf? sections, all references to ‘age of 18’ shall be replaced with ‘age of 20’
Specific Data Protection Notification from PCA Life Assurance Co, LTD (“PCALT”)
Pursuant to Taiwan (Republic of China) Personal Data Protection Act (“PDPA”), PCALT hereby notify you as follows with respect to our indirect collection, processing and use of the personal data provided or to be provided by you (“Personal Data”) to the Pulse App and its operator and provider, Pulse Ecosystems Pte. Ltd.:
1. Entity and Data Source. PCALT, a company incorporated in Taiwan, is collecting, processing and using the Personal Data received from the Pulse App operated by Pulse Ecosystem Pte. Ltd. or its successors.
2. Purposes. PCALT may indirectly collect your Personal Data, then process, use, transmit and disclose it for the following purposes:
(i) PCALT intends to use your name and contact details to send special promotions and/or materials regarding personalised or customised products and services and/or products and services from a PCALT’s partners (related to health, wellness, nutrition, lifestyle, finance and/or insurance) where you have provided your consent. And PCALT uses your name and contact details for marketing purposes only with your consent (your use of the Pulse App will be deemed as your consent referred here);
(ii) To personalise, customise and tailor your use and experience of PCALT’s products and offerings, including to provide personalised and customised promotions, product and service suggestions such as offerings combining insurance products and other Pulse Services, and tips;
(iii) For the improvement and development of new financial services or insurance products and services; and
(iv) To perform data analysis and to conduct profiling such as marketing profiling.
3. Categories. The categories of personal data may be collected, processed and used are as disclosed in Annex A. PCALT won’t indirectly collect any of your sensitive personal data from Pulse Ecosystem Pte. Ltd. and/or other Pulse Partners.
4. Period, Areas, Recipients and Methods.
(1) Period: The Personal Data may be used until the later of (i) the relevant purpose described above ceasing to be applicable/relevant, (ii) PCALT ceasing to be required by applicable laws, regulations or internal rules to retain such Personal Data, (iii) the Personal Data ceasing to be required by PCALT to conduct business, and (iv) PCALT won’t exist anymore subsequent to any merge and acquisition, bankruptcy or liquidation.
(2) Recipients: The Personal Data may be disclosed to and used by: (i) Advisors or others rendering services to PCALT; (ii) PCALT’s Business and Marketing Partners and the officers, agents, or employees thereof; and, (iii) Regulatory, judicial or other authorities of the Taiwan or of any other jurisdiction in which PCALT does business or maintains data processing facilities (Collectively, the “Recipients”). The Personal Data may be collected, processed, used, transmitted and disclosed by each Recipient within the scope of the activity for which PCALT has provided the Personal Data to the relevant Recipient.
(3) Areas: The Personal Data may be used in Taiwan and any territory/region in which any of PCALT or Recipient does business or maintains data processing facilities.
(4) Methods: Any methods that are in compliance with applicable Taiwan Laws.
5. Rights. To the extent provided in Article 3 of the PDPA, you may by request in writing to PCALT: (1) inquire or review the Personal Data (PCALT may collect reasonable fees); (2) make copy(s) of the Personal Data (PCALT may collect reasonable fees); (3) add or amend the Personal Data (with proper explanation); (4) terminate PCALT’s collection, processing and use of the Personal Data (to the extent that such Personal Data is not necessary for PCALT to conduct business or provide service to you); or (5) require PCALT to delete the Personal Data (to the extent that such Personal Data is not necessary for PCALT to conduct business, provide service to you or PCALT is otherwise legally entitled to retain same).
The Personal Data Genres may be indirectly collected, processed and used by PCALT：
Appendix 2 – Details of Prudential insurance entities in your territory
|Prudential insurance entity
Prudential (Cambodia) Life Assurance Plc
Prudential Hong Kong Limited
PT Prudential Life Assurance
Prudential Life Assurance (Lao) Company Limited
Prudential Assurance Malaysia Berhad
Prudential BSN Takaful Berhad
Prudential Myanmar Life Insurance Limited
Prudential Assurance Company Singapore (Pte) Ltd
PCA Life Assurance Co., Ltd.
Prudential Life Assurance (Thailand) Public Company Limited
Pru Life Insurance Corporation of U.K.
Prudential Vietnam Assurance Private Limited
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