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Data Protection Regulations

These data protection regulations provide an overview of what personal data is collected by Pulse and the companies affiliated with Pulse, how this personal data is processed, and to whom it may be disclosed. It also explains what rights you have under data protection laws and how you can exercise these rights.

By using a website or mobile application operated by Pulse or a Pulse-affiliated company, you agree that your personal, as well as non-personal data, may be processed according to the terms in these data protection regulations and accept the following data protection regulations.

Please review these data protection regulations at regular intervals so that you are always informed about how your personal data is being used and can exercise your rights.

What you need to know about us:

1. What data does Pulse and companies affiliated with Pulse generally process?

Essentially, there are two categories of data that are processed when you contact us: personal data (4.1) and non-personal data (4.2).

1.1 What is personal data and what is the definition of “processing”?

Personal data refers to any information relating to you and that reveals something about you as an individual, such as your first name and surname, postal address, email address, date of birth, phone number and similar information.

Information that cannot be associated with you, i.e. with your identity as an individual, is non-personal data.

Processing encompasses any handling of your personal data, for example, the entry, collection, anonymisation, saving, management, use, transfer, disclosure or erasure of your personal data.

1.1.1 How do we process your personal data and what is the legal basis for doing so?

Your trust in us when it comes to protecting your personal data and your privacy is important to us, which is why we want you to know that:

We adhere to the basic principles set out in data protection laws where applicable. This means that we are transparent concerning which of your personal data we process and how. We only process personal data that we have obtained by legal means and, when required, with a legal basis for doing so. A legal basis may take the form of a contract, your consent, a law or a public interest that allows us to process data or a legitimate interest on our part.

We will notify you whenever we process your personal data. If we no longer need your personal data and are no longer legally required to retain it, or you no longer want us to keep and process it, then we will cease to do so.

Your rights in relation to your personal data and how you can exercise these rights are explained later in Section 5.

1.1.2. What personal data does Pulse process, and when and why does it do so (purpose)?

Essentially, we process your personal data each time you contact us. In the case of Pulse products, for example, this happens when you:

  • purchase a subscription for a product (newspaper or e-paper) and enter a contract with us for that reason or when you already have a subscription;
  • participate in a competition, contest, draw, crossword puzzle (online, via SMS or entry form);
  • have signed up for an email newsletter;
  • receive advertising about our media products and services (direct marketing);
  • register online so that you can comment on content in newspaper articles;

a) Subscription for Pulse products (newspaper or e-paper)

If you want a subscription and have entered into a contract with us for that reason, we collect the following personal data from you along with your order:

  • Gender (Mr/Ms)
  • First name
  • Surname
  • Address, including house number, postal code and place of residence
  • Phone number (landline and mobile number)
  • Email address
  • Payment information

We process this personal data for the duration of the subscription for the following purposes:

  • to fulfil and handle contractual and legal obligations;
  • to manage and maintain the customer relationship (e.g. change of address);
  • to verify access authorisation and administration of the user account (if available);
  • to issue invoices.

If you select an online payment option such as a credit card when purchasing a subscription, payment will be processed using the online payment system of the respective provider. In such cases, personal data and payment details are processed directly by the provider of the respective payment system. We are not privy to nor do we save your payment details. Please note the data protection regulations of the respective online payment system provider in such cases.

In order to provide you with additional offers on products and services from Pulse, we also process personal data in the following ways:

  • for marketing purposes, i.e. we advertise additional products from Pulse by post, phone, email or SMS. You have the option to object to this processing at any time.

b) Competitions, contests, draws, crossword puzzles

If you participate in a competition, contest or draw via an entry form or online, or if you solve our crossword puzzle and send in the answer, we normally collect the following personal data:

  • Gender (Mr/Ms)
  • First name
  • Surname
  • Address, including house number, postal code and place of residence
  • Phone number (landline or mobile number)
  • Email address

We process this personal data for the following purposes:

  • to draw the winner;
  • to announce who the winner is

In order to provide you with additional offers on products and services from Pulse we also process personal data in the following ways:

  • to develop and manage the relationship with you;
  • for marketing purposes, i.e. we advertise additional products from Pulse by post, phone, email or SMS. You have the option to object to this processing at any time.

c) Email newsletter

If you have agreed to let us use your email address for advertising purposes, we will send you newsletters at regular intervals to inform you about the Pulse’s additional offers and services.

You can object to the processing of your email address at any time by clicking the unsubscribe link found at the bottom of each newsletter.

d) Advertising about our media products and services (direct marketing)

In order to provide you with additional offers on products and services from Pulse, we and the companies belonging to the Pulse also process your personal data for marketing purposes. This means that we advertise additional products and services from the Pulse by post, phone, email or SMS.

For the purposes of customer acquisition, we also obtain personal data (addresses) from publicly available as well as professional third-party sources.

You always have the option to object to the processing of your personal data for these purposes in general or for a specific product or service.

e) Online registration for comments function

When you register to use the comments function on the Pulse website, we collect the following personal data:

  • First name
  • Surname
  • User name
  • Gender
  • Email address
  • Address, including house number, postal code, place of residence, and country
  • Phone number (landline and mobile number)

We process this personal data for the following purposes:

  • to fulfil and carry out legal obligations;
  • to verify access authorisations and administration of the user account.

In order to provide you with additional offers on products and services from Pulse, we also process the personal data mentioned above:

  • to develop and manage the relationship with you;
  • for marketing purposes, i.e. we advertise additional products Pulse by post, phone, email or SMS. You have the option to object to this processing at any time.

All content that you have uploaded using the comments feature is publicly visible and can be reused for editorial purposes, e.g. published as a letter to the editor.

1.1.3 Disclosure of personal data to third parties

All personal data collected when you contact Pulse can be processed for the purposes mentioned above, in particular for marketing purposes. You have the option to object to this transferring and processing at any time.

Your personal data can also be shared with third parties that are not part of Pulse and who provide technical or organisational services on behalf of Pulse or companies belonging to Pulse and that we require for the purposes mentioned above or to carry out their general business activities. Examples include hosting partners, printers or supplier organisations. These service providers are contractually bound to process your personal data exclusively on our behalf and as instructed by us, and to guarantee that the appropriate technical or organisational security measures are in place to guarantee your personal data is protected.

When you post comments on an article on a website or in a mobile application and log into a Pulse user account via Facebook or Twitter, you are also agreeing to the publication of your surname and first name and potentially your place of residence (as provided by you in your user account, Facebook account or Twitter account) together with your comments. Your comments, including personal data, can be further shared on third-party websites and indexed by search engines.

Your personal data shall not otherwise be passed on, transmitted or sold to third parties outside the Pulse unless required to manage a contract that you have concluded with Pulse or a company belonging to the Pulse, or unless you have expressly consented to it.

This notwithstanding, Pulse may disclose personal data for legal reasons; for example, to law enforcement agencies for the purpose of prosecuting and detecting illegal activities or to tax authorities.

1.2 Non-personal data

When you contact us, our websites and applications use various technologies provided by us and by third parties to collect non-personal data.

1.2.1 What constitutes non-personal data and why do we process it?

Non-personal data is information that cannot be traced back to your identity. As a matter of principle, we do not combine this data with your personal data, meaning that this data is anonymous to us.

We collect and process this data so that we can continually improve our products and services and tailor them to your needs, to identify trends as well as to generate and evaluate statistics about the usage of our digital products and services. This data is also used to provide you with positive advertising experience. That is to say, it is our basic assumption that you appreciate our informative and entertaining media products and are also willing to pay for them. Our products and services are therefore either financed through paying users (subscribers) or advertising. This is why you will find advertising both in our print media and especially in our free online products.

You have the option at any time to opt-out of the processing of non-personal data.

1.2.2 What technologies do we use and why?

We use the following technologies:

a) Cookies

We use our own as well as third-party cookies on our websites and in our mobile applications. A cookie is a small text file that is saved on your device when you visit one of our websites.

Cookies fall into two categories: session cookies and permanent cookies.

Session cookies can be used to track the websites you visit and to save your user options. A session cookie is only saved for the duration of your site visit, i.e. a single web session. This means that when you close your web browser, the session is ended and the cookie is deleted.

Permanent cookies can be used along with other items in order to identify you again the next time you visit our website and, for example, to detect your reading preferences. A permanent cookie is saved for a longer duration than a single session.

Cookies can also be divided into functional and non-functional cookies. Pulse uses both functional as well as non-functional cookies on its websites.

Functional cookies are required to offer the functions used on our websites or services. Non-functional cookies are not necessarily required for the functionality of the websites. This type of cookie is used to collect and analyse data about how websites or mobile applications are used (language preference, duration of a single user session, etc.) so that we can improve your reading and advertising experience. Such cookies include the following:

In order to provide you with tailored direct marketing and therefore to reduce unnecessary advertising and tailor our products and services to your interests, the following cookies are used to analyse your behaviour, for example:

We use our own cookie technology to collect non-personal data on our websites and in our mobile applications. This data is not combined with your personal data. We do not create any personal profiles or carry out any profiling as defined by data protection laws.

We use this data to analyse our users’ behaviour in relation to our individual products and services, to identify interest groups that are not tied to any specific individual and to better tailor advertising and content to these interest groups.

Our websites also use Google Analytics, which is a web analytics service provided by Google Inc (1600 Amphitheatre Parkway Mountain View, CA 94043, USA). Use includes it's Universal Analytics’ set of features. When a user is logged into a Google service, this makes it possible to associate data, sessions and interactions across multiple devices with a pseudonymous user ID so that a user’s activities can be analysed across multiple devices. Google Analytics cookies. The non-personal information generated by the cookies about your use of our website is generally sent to and stored on a Google a server located in the USA. The IP addresses are anonymised first, however. The anonymised IP address sent by your browser for the purposes of Google Analytics is not combined with other Google data. Google uses this information on our behalf to analyse how you use our websites, to generate reports on website activities, and to provide us with additional services associated with the use of the website and the Internet. More detailed information on the terms of use and data protection can be found here: https://toolsiehegoogle.com/dlpage/gaoptout/.

b) Log files

When using websites or mobile applications, the web servers record non-personal usage data in what is known as log files. Log files provide information about your IP address, the operating system you are using, the web pages you visit, browser type and version, date, time, and the requested file. This information is required for technical purposes in order to correctly provide the website content you have requested and are generated whenever a person uses the Internet. This anonymous data is saved separately from any personal data you provide and therefore cannot be traced back to your identity.

We evaluate this non-personal data for statistical purposes in order to optimise our website and the technology used to operate it, to identify trends, as well as to improve offers and products and/or to tailor it to your needs in the best way possible.

c) Third-party website elements, e.g. plugins

Elements from third-party providers (e.g. social networks such as Facebook, Twitter, Google+ and YouTube) may be used on our websites or in our mobile applications. If you click on an element from a third-party provider (e.g. the Like plugin from Facebook), a connection to the servers of that third-party provider may be established automatically. This may result in the transmission of information about your visit to our websites or a mobile application to the third-party provider. In some cases, it may be possible to associate this data with your user account with the third-party provider (e.g. your Facebook or Twitter account). Furthermore, the third-party provider may share personal data (surname, first name and email address) from your Pulse user account, insofar as you have authorised the third-party provider to carry out this function. Information about the collection and use of your data by third-party providers can be found in the data protection information of the relevant third-party provider.

1.3 How can I disable cookies?

a) Cookie settings

By using our websites and applications, you agree to the processing of your personal data in the manner described and for the aforementioned purposes. However, you can control and/or delete cookies at any time using the opt-out links listed above.

Most web browsers are set to automatically accept cookies. It is up to you, however, to configure your browser so that it rejects cookies as a rule by selecting the ‘do not accept cookies’ setting in your browser or so that it prompts you to accept cookies whenever you visit a website.

You also have the option to delete cookies stored on your computer or mobile device by using the function provided for this purpose in your browser. Remember that you will have to disable or delete the cookies on all of your devices.

Please note that deleting cookies in the browser will also cause an opt-out cookie. This means that if you want to keep an opt-out cookie enabled and have deleted all cookies, you must enable the opt-out cookie again when you revisit the website. Otherwise, you will be identified as a new user and the collection of your data will resume. Please also be aware that you will have to disable the cookies on all of your devices.

If you choose one of the options described, you may not be able to fully use all of the functions of this website. Please note that there is no option to opt-out of general advertising on our websites or in our applications.

5. What are your rights with respect to your personal data?

Your personal data belongs to you. You, therefore, have the right to control what happens with your personal data and are permitted to find out at any time how your personal data is being handled.

5.1 How you can protect your children

We all need to work together to ensure that future generations become responsible citizens of the digital world.

Because children are less cognisant of the risks and consequences of the processing of their personal data and are unlikely to know their rights in this regard, special protections should be in place when it comes to their personal data. In particular, this, of course, applies to the use of such personal data for advertising purposes, which is why you will also find the relevant age limits in our terms of use as well as information about the legal age of consent.

6. Data security

Pulse operates secure data networks which meet the relevant technical standards. All necessary and reasonable technical and organisational precautions are taken to protect your data against loss, destruction, falsification, manipulation and unauthorised access.

Although Pulse has taken every necessary step to prevent data from being disclosed through data transfer errors and/or unauthorised access by third parties, it cannot accept any liability for such unwanted incidents.

7. Who can you contact?

There are various ways to contact us:

If you have a legal question regarding data protection, and your subscription or other customer relationship with us, please contact us here.

8. Legal basis

When processing your personal data, we observe the Act on Data Protection along with its regulations where applicable.

9. Changes to and acceptance of these data protection regulations

Pulse modifies these data protection regulations as appropriate according to new or changing requirements. The latest version of this data privacy statement can always be found in the appropriate place.

The data protection regulations in their latest amended versions shall apply. By continuing to use Pulse’s website or mobile applications, the user agrees to the current data protection regulations in their most recently amended versions.