We take your privacy seriously. This Privacy Policy describes PulseActiv’s policies and procedures on the collection, use, and disclosure of your information when you use the services, websites, and applications offered by PulseActiv (the “Services”) and tells you about your privacy rights. By using the Services, you consent to our use of your information in accordance with this Privacy Policy. We will not use or share your personal information with anyone except as described in this Privacy Policy. Capitalized terms that are not defined in this Privacy Policy have the meaning given them in our Terms of Service.

This Privacy Policy is intended to meet our duties of transparency under the “Personal Data Protection Act” or “PDPA”. We will post any modifications or changes to this Privacy Policy on this page and notify you explicitly.

1. Who We Are and How to Contact Us

Who we are.

PulseActiv is the Controller (for the purposes of the PDPA) of your Personal Data (referred to as “PulseActiv”, “we”, “us”, or “our” in this Privacy Policy). Our address is 44 Kallang Place #05-07, Four Star Building, Singapore.

How to contact us.

For any request, question, comment, or action you have in connection to this Privacy Policy, please contact us at [email protected].

2. Your Rights Relating To Your Personal Data

You have the right under this Privacy and Cookies Policy, and by law to:
• Request access to your Personal Data. This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
• Request correction of the Personal Data that we hold about you. This enables you to have any information we hold about you corrected.
• Request erasure of your Personal Data. This enables you to ask to delete or remove Personal Data where there is no good reason for us to continue to process it.
• Object to processing of your Personal Data. This enables you to object to processing your Personal Data where we are relying on legitimate interest as the legal basis for doing so. You also have the right to object to where we are processing your Personal Data for direct marketing purposes.
• Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example, if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your Personal Data. This enables you to get your Personal Data in a structured, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent. This right only exists where we are relying on consent to process your Personal Data (“Consent Withdrawal”). If you withdraw your consent, we may not be able to provide you with access to certain specific functionalities of our Site.

How to exercise your rights.

To exercise any of the rights described above, please contact us using the contact details in Who We Are and How to Contact Us. Typically, you will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, except in relation to Consent Withdrawal, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive, or, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one week.

3. Marketing Communications Preferences

You can ask us to stop sending you marketing messages at any time by:
• following the opt-out links on any marketing message sent to you; or
• contacting us at any time using the contact details in Who We Are and How to Contact Us.
Please note that you can not opt-out from Automatic system messages, like resetting your account password.

4. What Personal Data Do We Collect

PulseActiv uses Personal Data to provide the Services, remember information to help you efficiently access your account, analyze how the Services are used, diagnose service or technical problems, maintain security, monitor aggregate metrics such as the total number of visitors, traffic, and demographic patterns, and track users.

Information You Provide to Us Directly.

The Personal Data we may collect from you is outlined below.

• Identity Data: Full name
• Contact Data: Email address, telephone number, company information, and billing data
• Online presence: Link to your company website
• Transaction Data: Any details about payments to and from you and other details of subscriptions and services you have purchased from us.
• Content Data: Any content you post to the Services, including game content (questions, media, etc), preference settings, messages, and other contributions to the Services, ( “Content”).
• Marketing and Communications Data: Your preferences in receiving marketing from us and our third parties and your communication preferences. If you correspond with us by email or messaging through the Services, we may retain the content of such messages and our responses.
• Technical Data: Internet protocol (IP) address, your login data, browser type, and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website or use our services.
• Aggregated Data: We may also collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Data, but once in aggregated form, it will not constitute Personal Data for the purposes of the GDPR as this data does not directly or indirectly reveal your identity.
• No Special Categories of Personal Data: We do not collect any “Special Categories of Personal Data” about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.

5. Personal Data Collected in Games

Games and Players

PulseActiv allows Users (Game Creators) to create out- and indoor games and quizzes for Players. Players are individual players or teams. Players are not required to have a registration or subscription and do not need to provide any personal information to play games. To play the game the Players need to provide a name for the playing entity (team or person, real or fictional). This provided name is used only within the specific game and is not used anywhere else.

Do not request personal data in games

We advise against asking for any kind of Personal Data within games, but it is possible that Game Creator has built the game in a way that asks for Personal Data from the Players. It is also possible that players will need to take photos or shoot videos about themselves, other players, or their teams. Game results (answers, tracks, photos, and videos) are public and therefore it is not a suitable channel for collecting any Personal Data from the Players.

Players’ rights to their data

Game creators should not set up the questions and games in a way that asks for Players’ personal data or puts Players in a position where they need to provide information potentially embarrassing or harmful to them. If you as a Player feel that the information you provided during the game (including your name, email, any answers to questions, photos, or videos) should be removed from the results pages you should turn to the person that provided or conducted the game you participated in. The Game Creator has the right and responsibility to remove the content about the participant or delete the full data set about the game.

If the Game Creator can not be contacted or is not willing to cooperate then the Player is advised to contact PulseActiv directly at [email protected] specifying exact information that should be removed and the URL where it is accessible. PulseActiv will first contact the account owner for the removal of this info. If the account owner fails to do this PulseActiv will remove the information from the database.

Using Data Provided by Players for Marketing Purposes

Information provided by the Players belongs to the Account under which the Game was run. PulseActiv will never rent or sell data provided by the Players. PulseActiv will not use photos or videos created by the Players in any marketing or sales activities without explicit written consent from the account owner. We advise account owners to get explicit written consent in case they are planning to use any information provided by the Players for Any Purposes.

6. How We Use Your Personal Data and Why

We generally use Personal Data for the following: to deliver and improve our Services; to manage your account and provide you with customer support; website or mobile application analytics; to diagnose or fix technology problems; to verify your identity and prevent fraud or other unauthorized or illegal activity; to enforce or exercise any rights in our Terms of Service;
In respect of each of the purposes for which we use your Personal Data, the PDPA requires us to ensure that we have a legal basis for that use if you are within Singapore. The legal bases depend on the Services you use and how you use them.

This means we collect and use your Personal Data only where:

• We need it to provide you the Services, including to operate the Services, provide customer support and personalized features, and protect the safety and security of the Services;
• It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the Services and protect our legal rights and interests; or
• We need to process your data to comply with a legal or regulatory obligation.

We may also rely on your consent as a legal basis for using your Personal Data where we have expressly sought it for a specific purpose. If we do rely on your consent to the use of your Personal Data, you have the right to change your mind at any time (but this will not affect any processing that has already taken place). We have set out below more detailed examples of relevant purposes for which we may use your Personal Data.

• Providing, updating, and maintaining our Services, Site, and business: To deliver the Services you have requested, including, for example, registering you as a user, managing your account and profile, and authenticating you when you log in.
• Processing payments: To process payment for any purchases, subscriptions, or sales made on our Site,
• Research and development: To enable us to improve the Services and better understand our users and the markets in which we operate. For example, we may conduct or facilitate research and use learnings about how people use our Services and feedback provided directly to us to troubleshoot and identify trends, usage, activity patterns, areas for additional features and improvement of the Services, and other insights. We also test and analyze certain new features with some users before introducing the feature to all users.
• Communicating with users about the Services: To send communications via email and within the Services, including, for example, responding to your comments, questions, and requests, providing customer support, and sending you technical notices, product updates, security alerts, and administrative, billing and account management related messages. We may also provide tailored communications based on your activity and interactions with us.
• Providing customer support: To resolve technical issues you encounter, respond to your requests for assistance, comments, and questions, analyze crash information, repair and improve the Services and provide other customer support.
• Marketing: To send promotional communications that may be of specific interest to you, including, for example, blog updates by email
• To protect Players: It is very important to us that Players’ rights are protected, so we may process your individual or account data if any are contacted by Players about the possible Personal Data violations.
• Displaying game results: Data from the games is displayed on the results pages. If within a game personal data is asked then it may be displayed on results pages.

What happens when you do not provide necessary Personal Data?

Where we need to process your Personal Data to perform the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract. In this case, we may have to stop you from using our Services.

7. Who We Share Your Personal Data With

We may share your Personal Data with third parties in the ways that are described below. We consider this information to be a vital part of our relationship with you.

• Our Affiliates: Our affiliates may access your Personal Data to help us develop, maintain and provide our Services and help manage our customer relationships (including providing customer support, customer liaison, etc).
• Service Providers (Subprocessors): Our service providers provide us support for our Services, including, for example, website and application development, hosting, maintenance, backup, storage, virtual infrastructure, payment processing, analysis, identity verification, background and compliance reviews, fund administration, banking services, and other services for us, which may require them to access or use Personal Data about you.
• Researchers: To enhance the public understanding of patterns and trends in the markets served by our Services, we may provide Personal Data to third parties under confidentiality obligations such as for example, academics or contractors for research purposes.

If you request that we remove your Personal Data as described in Your Rights Relating to Your Personal Data, we will convey that request to any third party with whom we have shared your data. We are not, however, responsible for revising or removing your Personal Data obtained by any third party who has previously been provided your information by us in accordance with this policy or any third party to whom you have provided such information (whether by sharing your login and password, or otherwise).

In addition, Data generated by Players is public on result pages. We can not guarantee or limit access to it as it can be shared by anybody having an active link. If the Game Results contain data that is a safety concern or violates somebody’s rights then the right action is to remove the data (photos or videos) or to delete the full data set as described in „Personal Data Collected in Games”

8. How Long Do We Store Your Personal Data

We will retain your information for as long as your account is active or it is reasonably needed for the purposes set out in How We Use Your Personal Data and Why unless you request that we remove your Personal Data as described in Your Rights Relating to Your Personal Data. We will only retain your Personal Data for so long as we reasonably need to use it for these purposes unless a longer retention period is required by law (for example for regulatory purposes).

9. How We Protect Your Personal Data

PulseActiv uses industry-standard physical, managerial, and technical safeguards to preserve the integrity and security of your personal information. We limit access to your Personal Data to those employees and other staff who have a business need to have such access. All such people are subject to a contractual duty of confidentiality. We cannot, however, ensure or warrant the security of any information you transmit to PulseActiv or guarantee that your information on the Services may not be accessed, disclosed, altered, or destroyed by a breach of any of our physical, managerial, or technical safeguards.
We have put in place procedures to deal with any actual or suspected Personal Data breach. In the event that personal information is compromised as a result of such a breach of security, PulseActiv will promptly notify those persons whose personal information has been compromised, in accordance with the notification procedures set forth in this Privacy Policy, or as otherwise required by applicable law.

PulseActiv cannot ensure that your Personal Data will be protected, controlled, or otherwise managed pursuant to this Privacy Policy if you share your login and password information with any third party, including any third party operating a website or providing other services.

10. Children’s Privacy

Protecting the privacy of children is especially important. The Services are not intended for children below 16 and Loquiz does not knowingly collect or solicit personal information from anyone under the age of 16 or knowingly allow such persons to register with the Services.
However, children might engage with PulseActiv Services as Players. It is first and foremost the Game Creators’ responsibility to ensure that the game is set up in a way that does not collect any personal or potentially harmful information from the children playing the game.
Furthermore, it is the Game Creators’ responsibility to actively monitor results pages for the game and take necessary steps to remove personal content that is potentially harmful to Players. PulseActiv does not monitor the result pages of individual games. If you find that the result page includes information that should be removed please contact us at [email protected]. We will contact the account owner for action and if this is not possible will remove the content ourselves.

11. Links To Other Websites

This Privacy Policy applies to the online services offered by PulseActiv at www.pulseactiv.com.sg as well as accompanying PulseActiv mobile applications. The Services may contain links to other websites not operated or controlled by PulseActiv. We are not responsible for the content, accuracy, or opinions expressed on such websites, and such websites are not investigated, monitored, or checked for accuracy or completeness by us. Please remember that when you use a link to go from the Services to another website, our Privacy Policy is no longer in effect. Your browsing and interaction on any other website, including those that have a link on our Site, is subject to that website’s own rules and policies. Such third parties may use their own cookies or other methods to collect information about you.

12. Changes to Our Privacy Policy

We reserve the right, in our sole discretion, to change, modify, add, or remove portions of this Privacy Policy at any time. Any changes or updates will be effective immediately upon posting to this page. We will notify you additionally about such a case. You should review this Privacy Policy regularly. You can determine if changes have been made by checking the Effective Date below. Your continued use of our Site following the posting of any changes to this Privacy Policy means you consent to such changes.