This Privacy Notice explains how Mpulse S.A. (“Mpulse”) collects, uses, shares or otherwise processes your Personal Data in accordance with applicable privacy laws and regulations, which include the General Data Protection Regulation 2016/679 (“GDPR”), in the context of the mpulse.eu website.
1. Personal data we collect about you
When using the term “Personal Data” in our Privacy Notice, we mean information that relates to you and allows us to identify you, either directly or in combination with other information that we may hold, as defined by the GDPR.
From a general perspective, we base the processing of Personal Data that may be done in order for us to perform our contractual obligation(s) as the publisher of this Website (“Contractual Obligations”) and to enable us to be compliant with any legal or statutory obligations (“Legal Obligations”). We may also process Personal Data when we consider that such processing can be based on our legitimate interests (“Legitimate Interests”) and only when we have assessed that your interests and fundamental rights do not override our legitimate interests. For example, itmayt be in our Legitimate Interest to process certain Personal Data to continue to develop our business activities (quantitatively and qualitatively), to improve our business performance, etc.
Please note that we may also need to process Personal Data to respond to any legal claim that may arise.
Your data is used by Mpulse for the following purposes and on the following legal basis:
|For which purpose do we process your Personal Data?
||On what legal basis do we process your Personal Data?
|Providing you with the service you have requested while browsing our website
||Contractual Obligation, Legitimate Interest
|Providing you with information/resources (and related accesses), or any other services that you may have requested from us
||Contractual Obligation, Legitimate Interest
|Communicating / distributing to you communications related to our products and services (e.g. newsletter and email marketing)
||Legitimate Interest or consent
|Managing our website and displaying properly to your device(s), including generating and analyzing anonymized statistical usage data of our website
||Legitimate interest (monitoring and improving our website and service)
|Complying with any applicable rules, laws and regulations
The categories of data collected for the above purposes are the following:
- Personal identification information: name and surname, postal and e-mail address, phone number
- Content or messages you send to us or provide otherwise directly to us such as inquiries, questions, comments, answers to questions
- In the context of email marketing, certain additional data as further detailed in section 5 “Email Marketing” below.
Mpulse uses your Personal Data only for the purposes for which it was collected, unless we consider that we may need to use it for another purpose which is compatible with the original purpose. If a new purpose is unrelated to the original purpose, we will notify you and explain the new purpose together with the legal basis.
We may collect personal information through your use of our website, when you contact or request information from us or, when you subscribe to our newsletter/mailing list and, in the context of direct email marketing, through certain other means as detailed in section 5 (“Email Marketing”) below.
2. Recipients of your Personal Data
Your Personal Data is used by Mpulse as described above. In addition, we may share your Personal Data with the following third-party service providers:
- Google Analytics, only as described in paragraph 5 (‘Cookies”) below.
Your personal data will not be transferred to any other third party.
3. Processing of your Personal Data outside of the European Union
As described above, your data may be processed by (i) WordPress and (ii) Mailchimp, both of which host data outside of the European Union, including in the United States, which is not recognised by the European Commission of offering the same level of protection as the European Union. Please be ensured that we take all necessary steps in this respect to verify that your Personal Data receives an adequate level of protection, either by entering into data transfer agreements including standard data protection clauses adopted or approved by the European Commission or by otherwise ensuring appropriate safeguards and, where needed, by taking additional supplementary contractual, organisational or technical measures.
If you have questions about the means we implement to ensure adequate protection of your Personal Data transferred outside of the European Union or wish to obtain a copy thereof, please contact us via firstname.lastname@example.org.
4. Your rights in relation to your Personal Data
Under the GDPR you have various rights as an individual which you can exercise under certain circumstances in relation to your Personal Data that we hold. These rights are to:
- Request access to your Personal Data;
- Request rectification of your Personal Data;
- Request the erasure of your Personal Data;
- Request the restriction of processing of your Personal Data;
- Object to the processing of your Personal Data;
- Request data portability.
If you want to exercise one of these rights, please contact us via email@example.com.
You also have the right to lodge a complaint with the data protection supervisory authority in Luxembourg, the CNPD (Commission Nationale pour la Protection des Données), through their website: www.cnpd.lu.
5. Email marketing
As mentioned above, we may include you in our newsletter and/or marketing mailing list based on:
- Your consent by subscribing to our newsletter or marketing mailing list through Mpulse’s website;
- Our legitimate interest in the case of newsletter and/or marketing communications sent to you in the context of your professional activities. In this case and for this purpose only, data may be collected from you or through third parties, for example: when we interact with you in the context of our products and services, when you visit or contact us, or register to attend an event or appointment and, if and as appropriate and proportionate with your legitimate privacy expectations, through publicly available information.
In both cases, you can opt out of newsletter and marketing emails at any time by using the link sent in such communications or by contacting us as firstname.lastname@example.org.
Any email marketing messages we send are done so through an EMS, email marketing service provider. An EMS is a third-party service provider of software / applications that allows marketers to send out email marketing campaigns to a list of users.
We only collect certain data about you, as detailed above (personal identification data, content/messages you send to us). In addition, email marketing messages that we send may contain tracking beacons / tracked clickable links or similar server technologies in order to track recipients’ activity within email marketing messages. Tracking data may notably include: device data, IP address, forward/email open tracing, date/time/duration of recipient activity.
We will retain the data collected for email marketing purposes for a maximum of three (3) years from the date of the last communication with you.
6. Retention period
We will only retain your Personal Data for as long as we need to fulfil the purposes for which it was collected and processed, as well as to satisfy any legal, regulatory, accounting or reporting requirements which may apply to us.
In the context of email marketing, we will retain your Personal Data as explained in section 5 (email marketing) above.
What is a cookie?
A cookie is a small piece of data or message that is sent from an organisation’s web server to your web browser and is then stored on your hard drive. Cookies can’t read data off your hard drive or cookie files created by other sites, and do not damage your system.
We use the following third-party cookies for this purpose:
Google Analytics uses “cookies” to help the website analyse how users use the websites, applications or services. Google Analytics mainly uses first-party cookies to report on visitor (aka. user) interactions on Google Analytics customers’ websites.
By using our website, applications or services you consent to the processing of data about you by Google in the manner and for the purposes set out above.
To find out more, see “How Google uses data when you use our partners’ sites or apps”, (located at https://www.google.com/policies/privacy/partners/, or any other URL Google may provide from time to time).
To opt out of being tracked by Google Analytics across all websites visit: https://tools.google.com/dlpage/gaoptout.
To view Google Analytic’s data retention controls, visit: Data retention – Analytics Help (google.com).
If you have questions or concerns regarding this Privacy Notice or you wish to exercise your rights in relation to your Personal Data, please do not hesitate to contact us at email@example.com or send your request to the following address:
7, rue J. Fischbach,