Privacy Policy

We are very pleased about your interest in our company. Data protection holds a particularly high priority for the management of pulse publishing GmbH. The use of the pulse publishing GmbH website is generally possible without providing any personal data. However, if a data subject wishes to use special services of our company via our website, the processing of personal data may become necessary. If the processing of personal data is required and there is no legal basis for such processing, we generally obtain the consent of the data subject.

The processing of personal data, such as the name, address, email address, or telephone number of a data subject, is always carried out in accordance with the General Data Protection Regulation (GDPR) and in compliance with the country-specific data protection provisions applicable to pulse publishing GmbH. Through this privacy policy, our company aims to inform the public about the nature, scope, and purpose of the personal data we collect, use, and process. Furthermore, this privacy policy seeks to inform data subjects of their rights.

As the controller responsible for processing, pulse publishing GmbH has implemented numerous technical and organizational measures to ensure the most complete protection possible for personal data processed via this website. Nevertheless, internet-based data transmissions can generally have security vulnerabilities, meaning that absolute protection cannot be guaranteed. For this reason, every data subject is free to transmit personal data to us via alternative means, such as by telephone.

Definition of terms
The privacy policy of pulse publishing GmbH is based on the terminology used by the European legislator when adopting the General Data Protection Regulation (GDPR). Our privacy policy is intended to be easy to read and understand for both the general public as well as our customers and business partners. To ensure this, we would like to explain the terms used in advance.

In this privacy policy, we use, among others, the following terms:

Personal data
Personal data refers to any information relating to an identified or identifiable natural person (hereinafter referred to as the "data subject"). A natural person is considered identifiable if they can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

Data subject
A data subject is any identified or identifiable natural person whose personal data is processed by the controller responsible for the processing.

Processing
Processing is 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.

Restriction of processing
Restriction of processing refers to the marking of stored personal data with the aim of limiting its future processing.

Profiling
Profiling is any type of automated processing of personal data that involves using this personal data to evaluate certain personal aspects related to a natural person, particularly to analyze or predict aspects regarding their work performance, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.

Pseudonymization
Pseudonymization is the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that this additional information is kept separately and is subject to technical and organizational measures that ensure that the personal data is not assigned to an identified or identifiable natural person.

Controller or controller responsible for processing
The controller or the controller responsible for processing is the natural or legal person, authority, organization, or other body that alone or jointly with others determines the purposes and means of processing personal data. If the purposes and means of processing are determined by Union law or the law of the Member States, the controller or the specific criteria for their designation may be provided for by Union law or the law of the Member States.

Processor
A processor is a natural or legal person, authority, organization, or other body that processes personal data on behalf of the controller.

Recipient
A recipient is a natural or legal person, authority, organization, or other body to whom personal data is disclosed, regardless of whether they are a third party or not. Authorities that may receive personal data in the context of a specific investigative task under Union law or the law of the Member States are not considered recipients.

Third party
A third party is a natural or legal person, authority, organization, or other body, other than the data subject, the controller, the processor, and the persons who, under the direct authority of the controller or the processor, are authorized to process the personal data.

Consent
Consent is any freely given, specific, informed, and unambiguous indication of the data subject's wishes, in the form of a statement or any other clear affirmative action, through which the data subject signifies their agreement to the processing of personal data concerning them.

Name and address of the controller responsible for processing
The controller within the meaning of the General Data Protection Regulation, other applicable data protection laws in the Member States of the European Union, and other provisions with data protection legal character is the:

pulse publishing GmbH
Lokstedter Weg 50
20251 Hamburg
Phone: +49 40 5700267 20
E-Mail: info@pulsepublishing.de
Website: www.pulsepublishing.de

Cookies
The websites of pulse publishing GmbH use cookies. Cookies are text files that are stored and saved on a computer system via an internet browser.

Many websites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a string of characters that can be used by websites and servers to assign it to the specific internet browser in which the cookie was stored. This enables the visited websites and servers to distinguish the individual browser of the data subject from other internet browsers that contain different cookies. A specific internet browser can be recognized and identified through the unique cookie ID.

By using cookies, pulse publishing GmbH can provide users of this website with more user-friendly services that would not be possible without setting cookies.

Through a cookie, the information and offers on our website can be optimized in the interest of the user. As mentioned earlier, cookies allow us to recognize the users of our website. The purpose of this recognition is to make it easier for users to use our website. For example, the user of a website that uses cookies does not have to enter their login details again on each visit to the website because they are retrieved from the cookie stored on the user's computer system.

The data subject can prevent the setting of cookies by our website at any time by making the appropriate setting in the internet browser they use, thereby permanently objecting to the setting of cookies. Furthermore, already set cookies can be deleted at any time through an internet browser or other software programs. This is possible in all common internet browsers. If the data subject disables the setting of cookies in their internet browser, some functions of our website may no longer be fully usable.

Collection of general data and information
The website of pulse publishing GmbH collects a series of general data and information with each visit to the website by a data subject or an automated system. This general data and information is stored in the server's log files. The following data may be collected: (1) the types and versions of browsers used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrer), (4) the subpages that are accessed on our website by an accessing system, (5) the date and time of access to the website, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system, and (8) other similar data and information used to prevent risks in the event of attacks on our information technology systems.

When using this general data and information, pulse publishing GmbH does not draw any conclusions about the data subject. Rather, this information is required to (1) deliver the content of our website correctly, (2) optimize the content of our website as well as the advertising for it, (3) ensure the permanent functionality of our information technology systems and the technology of our website, and (4) provide law enforcement authorities with the necessary information for prosecution in the event of a cyber attack. These anonymously collected data and information are therefore analyzed by pulse publishing GmbH for statistical purposes and also to increase data protection and data security within our company, ultimately ensuring an optimal level of protection for the personal data we process. The anonymous data in the server log files is stored separately from all personal data provided by a data subject.

Contact possibility via the website
The website of pulse publishing GmbH contains information required by law that enables quick electronic contact with our company and direct communication with us, including a general address for so-called electronic mail (email address). If a data subject contacts the controller responsible for processing via email or through a contact form, the personal data transmitted by the data subject is automatically stored. Such personal data voluntarily provided by a data subject to the controller for processing will be stored for the purpose of processing or contacting the data subject. These personal data will not be passed on to third parties.

Routine deletion and blocking of personal data
The controller responsible for processing processes and stores personal data of the data subject only for the period necessary to achieve the storage purpose, or as required by European or other legislative bodies in laws or regulations to which the controller is subject.

If the storage purpose no longer applies or a storage period prescribed by the European legislator or another competent legislator expires, the personal data will be routinely blocked or deleted in accordance with the legal regulations.

Rights of the data subject
Right to confirmation
Every data subject has the right granted by the European legislator to request confirmation from the controller responsible for processing as to whether personal data concerning them is being processed. If a data subject wishes to exercise this right to confirmation, they can contact our data protection officer or another employee of the controller at any time.

Right to access
Every data subject affected by the processing of personal data has the right granted by the European legislator to obtain, at any time, from the controller responsible for processing, free of charge, information about the personal data stored concerning them, as well as a copy of that information. Furthermore, the European legislator has granted the data subject the right to be informed about the following information:
  • the purposes of the processing
  • the categories of personal data being processed
  • the recipients or categories of recipients to whom the personal data has been or will be disclosed, especially recipients in third countries or international organizations
  • if possible, the planned duration for which the personal data will be stored, or, if not possible, the criteria used to determine that duration
  • the existence of the right to rectification or deletion of personal data concerning them, or the restriction of processing by the controller, or the right to object to such processing
  • the existence of the right to lodge a complaint with a supervisory authority
  • if the personal data is not collected from the data subject: all available information about the source of the data
  • the existence of automated decision-making, including profiling, as referred to in Articles 22(1) and (4) of the GDPR, and — at least in these cases — meaningful information about the logic involved, as well as the scope and the intended consequences of such processing for the data subject
  • Furthermore, the data subject has the right to inquire whether personal data has been transferred to a third country or an international organization. If this is the case, the data subject also has the right to obtain information about the appropriate safeguards related to the transfer.
If a data subject wishes to exercise this right to access, they can contact our data protection officer or another employee of the controller at any time.

Right to rectification
Every data subject affected by the processing of personal data has the right granted by the European legislator to request the immediate correction of inaccurate personal data concerning them. Furthermore, the data subject has the right to request the completion of incomplete personal data — including by providing a supplementary statement — taking into account the purposes of the processing.

If a data subject wishes to exercise this right to rectification, they can contact our data protection officer or another employee of the controller at any time.

Right to erasure (Right to be forgotten)
Every data subject affected by the processing of personal data has the right granted by the European legislator to request the controller to erase personal data concerning them without delay, provided that one of the following reasons applies and the processing is not necessary:
  • The personal data were collected for purposes that are no longer necessary.
  • The data subject withdraws their consent, on which the processing was based according to Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR, and there is no other legal basis for the processing.
  • The data subject objects to the processing under Art. 21(1) GDPR, and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing under Art. 21(2) GDPR.
  • The personal data have been unlawfully processed.
  • The erasure of the personal data is required to fulfill a legal obligation under Union law or the law of the Member States to which the controller is subject.
  • The personal data were collected in relation to services of the information society offered under Art. 8(1) GDPR.
  • If any of the above reasons apply and a data subject wishes to request the erasure of personal data stored by pulse publishing GmbH, they can contact our data protection officer or another employee of the controller at any time. The data protection officer or another employee will ensure that the request for erasure is promptly fulfilled.

    If the personal data have been made public by pulse publishing GmbH and our company is obligated as the controller under Art. 17(1) GDPR to erase the personal data, pulse publishing GmbH will take reasonable measures, including technical ones, to inform other controllers who process the published personal data, taking into account the available technology and the cost of implementation, that the data subject has requested the erasure of all links to these personal data or copies or replications of these personal data from these other controllers, insofar as processing is not required. The data protection officer of pulse publishing GmbH or another employee will take the necessary actions on a case-by-case basis.
Right to restriction of processing
Every data subject has the right, granted by the European legislator, to request the restriction of processing of their personal data by the controller if one of the following conditions is met:
  • The accuracy of the personal data is disputed by the data subject, for a period that allows the controller to verify the accuracy of the personal data.
  • The processing is unlawful, the data subject opposes the deletion of the personal data and instead requests the restriction of its use.
  • The controller no longer needs the personal data for the purposes of processing, but the data subject needs it for the assertion, exercise, or defense of legal claims.
  • The data subject has objected to the processing under Article 21(1) of the GDPR, and it is not yet clear whether the legitimate grounds of the controller override those of the data subject.
  • If one of the above conditions is met and a data subject wishes to request the restriction of personal data stored by pulse publishing GmbH, they may contact our data protection officer or another employee of the controller at any time. The data protection officer of pulse publishing GmbH or another employee will initiate the restriction of processing.
Right to Data Portability
Every data subject has the right, granted by the European legislator, to receive their personal data that has been provided to a controller, in a structured, commonly used, and machine-readable format. They also have the right to transmit these data to another controller without hindrance from the controller to whom the personal data were provided, provided the processing is based on consent under Article 6(1)(a) of the GDPR or Article 9(2)(a) of the GDPR, or a contract under Article 6(1)(b) of the GDPR, and the processing is carried out by automated means, unless the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Furthermore, when exercising their right to data portability under Article 20(1) of the GDPR, the data subject has the right to request that the personal data be transmitted directly from one controller to another, where technically feasible and provided this does not affect the rights and freedoms of other persons.

To exercise the right to data portability, the data subject can contact the data protection officer appointed by pulse publishing GmbH or another employee at any time.

Right to Object
Every data subject has the right, granted by the European legislator, to object at any time, on grounds relating to their particular situation, to the processing of their personal data that is based on Article 6(1)(e) or (f) of the GDPR. This also applies to profiling based on these provisions.

In the event of an objection, pulse publishing GmbH will no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing that override the interests, rights, and freedoms of the data subject, or the processing is necessary for the establishment, exercise, or defense of legal claims.

If pulse publishing GmbH processes personal data for direct marketing purposes, the data subject has the right to object at any time to the processing of their personal data for such marketing purposes. This also applies to profiling, insofar as it is related to such direct marketing. If the data subject objects to the processing for direct marketing purposes, pulse publishing GmbH will no longer process the personal data for these purposes.

Additionally, the data subject has the right to object, on grounds relating to their particular situation, to the processing of their personal data by pulse publishing GmbH for scientific or historical research purposes, or for statistical purposes, as per Article 89(1) of the GDPR, unless such processing is necessary for the performance of a task carried out in the public interest.

To exercise the right to object, the data subject may directly contact the data protection officer of pulse publishing GmbH or another employee. The data subject also has the right to exercise their right to object in the context of using information society services, notwithstanding Directive 2002/58/EC, through automated procedures that use technical specifications.

Automated Decisions in Individual Cases, Including Profiling
Every data subject has the right, granted by the European legislator, not to be subject to a decision based solely on automated processing— including profiling— that produces legal effects concerning them or similarly significantly affects them, unless the decision (1) is necessary for the conclusion or performance of a contract between the data subject and the controller, or (2) is authorized by Union or Member State law to which the controller is subject, and such law provides for appropriate measures to safeguard the rights, freedoms, and legitimate interests of the data subject, or (3) is based on the explicit consent of the data subject.

If the decision (1) is necessary for the conclusion or performance of a contract between the data subject and the controller, or (2) is based on the explicit consent of the data subject, pulse publishing GmbH will take appropriate measures to safeguard the rights, freedoms, and legitimate interests of the data subject, including at least the right to obtain human intervention from the controller, to express their point of view, and to contest the decision.

If the data subject wishes to assert rights related to automated decisions, they may contact our data protection officer or another employee of the controller at any time.

Right to Withdraw Data Protection Consent
Every data subject has the right, granted by the European legislator, to withdraw their consent to the processing of personal data at any time.

If the data subject wishes to exercise their right to withdraw consent, they may contact our data protection officer or another employee of the controller at any time.

Legal Basis for Processing
Article 6(1)(a) GDPR serves as the legal basis for processing activities where we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is a party, such as processing activities required for the delivery of goods or the provision of another service or benefit, the processing is based on Article 6(1)(b) GDPR. The same applies to processing activities necessary for the performance of pre-contractual measures, such as in cases of inquiries regarding our products or services. If our company is subject to a legal obligation that requires the processing of personal data, such as for the fulfillment of tax obligations, the processing is based on Article 6(1)(c) GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or another natural person. This would be the case, for example, if a visitor were injured at our premises and their name, age, health insurance details, or other vital information had to be passed on to a doctor, hospital, or other third parties. In such cases, the processing would be based on Article 6(1)(d) GDPR. Finally, processing activities may be based on Article 6(1)(f) GDPR. This legal basis applies to processing activities that are not covered by any of the above-mentioned legal bases if the processing is necessary for the purposes of legitimate interests pursued by our company or a third party, provided that the interests, fundamental rights, and freedoms of the data subject do not outweigh those interests. Such processing activities are permitted, especially because the European legislator explicitly mentioned them. In this regard, it is assumed that a legitimate interest may exist if the data subject is a customer of the controller (Recital 47, sentence 2 GDPR).

Legitimate Interests in Processing Pursued by the Controller or a Third Party
If the processing of personal data is based on Article 6(1)(f) GDPR, our legitimate interest is the conduct of our business for the benefit of the well-being of all our employees and shareholders.

Duration of Storage of Personal Data
The criterion for the duration of storage of personal data is the respective statutory retention period. After the period expires, the relevant data will be routinely deleted, unless they are still required for contract fulfillment or contract initiation.

Legal or Contractual Requirements for Providing Personal Data; Necessity for Contract Conclusion; Obligation of the Data Subject to Provide Personal Data; Possible Consequences of Non-Providing
We inform you that the provision of personal data is partly legally required (e.g., tax regulations) or may arise from contractual arrangements (e.g., information about the contractual partner). In some cases, it may be necessary for a contract to be concluded that a data subject provides us with personal data, which will then need to be processed by us. For example, the data subject is obligated to provide us with personal data when our company enters into a contract with them. Failure to provide the personal data would result in the inability to conclude the contract with the data subject. Before providing personal data, the data subject must contact our data protection officer. Our data protection officer will inform the data subject on a case-by-case basis whether the provision of personal data is legally or contractually required or necessary for the conclusion of the contract, whether there is an obligation to provide the personal data, and what consequences the non-provision of personal data would have.

Existence of Automated Decision-Making
As a responsible company, we refrain from automated decision-making or profiling.

Advertising and Marketing Services
When advertisements are displayed on the website, this is usually done with the involvement of third-party providers. Typically, this involves the transfer of users' personal data, such as the IP address, to the intermediaries. If the advertising is necessary for the financing of the website, a justification under Art. 6 para. 1 lit. f GDPR may be possible.

Changes to Our Privacy Policy
In order to ensure that our privacy policy always complies with current legal requirements, we reserve the right to make changes at any time. This also applies if the privacy policy needs to be adjusted due to new or updated services, such as new offerings. The new privacy policy will apply during your next visit to our platform.

This Privacy Policy has been generated in part by the Privacy Policy Generator of the DGD - Your External DPO that was developed in cooperation with German Lawyers from WILDE BEUGER SOLMECKE, Cologne, and the Privacy Policy Generator of activeMind AG.