Effective Date: May 15, 2018
Your privacy is very important to us. Please read below to see how Pulson, Inc., creators of the Counterpace guidance system, handles information. Before we get to the details, here are a few of our fundamental privacy principles:
- Your privacy is critically important to us and we handle your information accordingly.
- We don’t share your personal information with anyone without your consent except to comply with the law, develop & operate our products and services, or protect our rights.
- Information you upload or post to the Pulson forums may be seen by others and may not be able to be truly deleted.
- We aggregate and de-identify information from our users to use for business and research purposes.
2625 Park Blvd.
Palo Alto, CA 94306
Information We Collect
Pulson collects information about you, including personally identifiable information, if you choose to share it with Pulson, register an account, or if you track activities using the Services. Pulson also collects information about how you use the Services. There are several opportunities for you to share information about yourself and your activities with Pulson, including your name, physical address, email address, gender, age, equipment usage, activities (including date and time as well as your heartrate, your pace, and their relative timing), profile photo and other pictures. You may also submit comments and other content to be shared. In addition, Pulson will collect your credit card or other payment information if you purchase goods or services from Pulson. If you are a user of our mobile application for researchers, then your research protocols are also collected by the Services.
We do not track or collect your location, direction, or speed when using the Pulson mobile application.
You may use the Services to access your contacts’ information, to connect with your contacts on the Services, or to send them your activity information while using the Services. If you choose to use these features, Pulson will access and store your contacts’ information. You may delete your contacts’ information by updating your account settings, by contacting us at email@example.com, or by updating your device’s permission settings.
Pulson may allow you to sign up and log in to the Services using accounts you create with third-party products and services, such as Facebook or Google (collectively, “Third-Party Accounts”). These Third-Party Accounts may ask your permission to share certain information from your Third-Party Account with Pulson. We use this information to verify your identity as well as to provide you with features of our products and services. This information may include your first and last name, email address, profile information and preferences with the applicable Third-Party Account. This information is collected by the Third-Party Account provider and is provided to Pulson under their privacy policies. You can generally control the information that we receive from these sources using the privacy settings in your Third-Party Account. You can deactivate your account at any time by contacting us at firstname.lastname@example.org.
When you make a payment through our payment page, we may collect information from you to properly process your payment. This personal information may include your name, address, phone, email address, the payment amount, and information about your desired payment method (e.g. credit card, online payment service, or any other payment method made available by us) (“Payment Method”). We use certified third-party payment services and we do not view or store your Payment Method information.
How Information is Collected and Stored
Pulson collects information you provide to us. When you register and agree to our Terms of Service, you must provide personal information such as your name and email address. You may post content, including photos, and communicate with other users. You may also provide additional personal information or payment information to complete your user profile or make purchases.
Pulson also automatically collects a variety of technical information, including location, device and network information, cookies, log files and analytics services.
Cookies and Similar Technologies
The Services use log files to store user interaction information. Stored information includes IP addresses, device identifiers, browser type and version, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks. This information is used to analyze trends, administer the Services, track users in the aggregate, and gather broad demographic information for aggregate use. IP addresses, etc., may be linked to session IDs, user IDs and device identifiers.
The Services and particularly the mobile application use log files to store activity information in Activity Logs. Stored information includes date/time stamp, movement timing, cardiac timing, guidance information, device identifier, and other related information. This information is used to provide analysis and graphing tools to users of the Services, provide support to users of the Services, do research on the efficacy of the Services, analyze trends, administer the Services, and gather broad demographic information for aggregate use. Session IDs, etc. may be linked to user IDs and device identifiers. If you are a user of our mobile application for researchers, then your research protocols are copied into your Activity Logs and subject to the same policies as the Activity Logs.
Pulson uses third party analytics providers to understand how the Services are used and to help us improve the Services.
Collection from Children
The Services are not intended for use by children under the age of 13. Pulson does not knowingly collect any information from children under the age of 13. If you believe we may have accidentally received such information, please contact us immediately via email@example.com.
Pulson may collect personally identifiable information about your activities over time and across third-party websites or online services when you use the Services. We may obtain additional information about you from third parties such as marketers, partners, researchers, and others. We may combine information that we collect from you with information obtained from such third parties and information derived from any other product or service we provide.
Pulson is committed to providing you choices to manage your privacy and sharing. However, Pulson does not recognize or respond to browser-initiated Do Not Track signals. To learn more about Do Not Track signals, you can visit https://allaboutdnt.com.
How Pulson Uses Information
Pulson primarily uses the information we collect to administer and operate the Services. We also use this information to analyze, develop and improve the Services. We may also use this information to market the services, accept payments, provide support related to the Services, protect users and enforce our Terms of Service, promote safety, pursue further research in order to improve the Services, and communicate with you. Additionally, your information may be shared with third parties, as set forth below.
How Information is Shared
Sharing Information and Activities
You may share your information, including your profile, username, photos, your activities, and comments you make. You may choose to invite your contacts to view your activities using the Services. If you link your Pulson account to other social networks and share your activities, they will be viewable outside the Services. If you choose to share or post your location information via such third parties, it is possible that unintended people could have access to such information. You should use caution when sharing information via third parties and you should carefully review the privacy practices of such third parties.
Publicly Available Information
Information and content that you share using the Services may be publicly accessible.
Sharing within Pulson
We may share your information and content within Pulson to operate, improve, or promote the Services.
We may share your information with third parties who provide services to Pulson such as supporting and improving the Services, promoting the Services, processing payments, or fulfilling orders. These service providers will only have access to the information necessary to perform these limited functions on our behalf and are required to protect and secure your information. We may also use service providers to collect information about your use of the Services over time so that we or they may promote Pulson or display information that may be relevant to your interests on the Services or other websites or services.
Affiliates and Acquirors of our Business or Assets
Aggregated and De-Identified Information
Pulson may de-identify Activity Logs and may modify, de-identify and aggregate the information, data, text, sound, photographs, graphics, video, or other materials you make available in connection with the Services, in ways that do not personally identify you or contain personally identifiable information. Examples of such aggregated information or statistical data include information about equipment and usage, demographic information and performance or biometric information. Pulson may use, sell, license, and share this information with third parties for research, business or other purposes. If you make information or content publicly available on the Services, such information, even when aggregated, is capable of being publicly viewed and possibly associated with you.
We may share your information if (i) you direct us to do so or (ii) you otherwise consent to such sharing.
We may share your information with third parties, including law enforcement, public or governmental agencies, or private litigants, within or outside your country of residence, if we determine that disclosure is reasonably necessary to comply with the law, including to respond to court orders, warrants, subpoenas, or other legal or regulatory process. We may also disclose your information if we determine that disclosure is reasonably necessary or appropriate to prevent any person from death or serious bodily injury, to address issues of national security or other issues of public importance, to prevent or detect violations of our Terms of Service or fraud or abuse of Pulson or its users, or to protect our operations or our property or other legal rights, including by disclosure to our legal counsel and other consultants and third parties in connection with actual or potential litigation.
We may share your information with third parties when we forward Digital Millennium Copyright Act (DCMA) notifications, which will be forwarded as submitted to us without any deletions.
Your personally identifiable information may be disclosed to third parties in unforeseeable situations that are not preventable even when commercially reasonable protections are employed, such as in the case that Pulson or the Services is subject to a hacking or other attack.
How We Protect Information
We take several measures to safeguard the collection, transmission and storage of the data we collect. These steps depend on the sensitivity of the data that we collect, process, and store. Although we strive to employ reasonable protections for your information that are appropriate to its sensitivity, we do not guarantee or warrant the security of the information you share with us and we are not responsible for the theft, destruction, loss or inadvertent disclosure of your information or content. No system is 100% secure. The Services use industry standard Secure Sockets Layer (SSL) technology to allow for the encryption of personal information and Payment Method information. The Services are registered with site identification authorities so that your browser can confirm Pulson’s identity before any personally identifiable information is sent. In addition, Pulson’s secure servers protect this information using advanced firewall technology.
To help ensure that these measures are effective in preventing unauthorized access to your private information, you should be aware of the security features available to you through your browser. You should use a security-enabled browser to submit your Payment Method information and other personal information at the Services. Please note that if you do not use a SSL-capable browser, you are at risk for having data intercepted.
Most browsers have the ability to notify you if you change between secure and insecure communications, receive invalid Services identification information for the Services you are communicating with, or send information over an unsecured connection. Pulson recommends that you enable these browser functions to help ensure that your communications are secure. You can also monitor the URL of the Services you are visiting (secure URLs begin with https:// rather than http://), along with the security symbol of your browser to help identify when you are communicating with a secure server. You can also view the details of the security certificate of the Services to which you are connected. Please check the validity of any Services you connect to using secure communications.
How to Opt Out or Adjust Notification and Email Preferences
Updating Account Information
You may correct, amend or delete submitted account information that is inaccurate at any time by adjusting that information in your account settings. If you need further assistance, please contact Pulson at firstname.lastname@example.org. Pulson will generally respond to your request within 7 business days.
Deleting Information and Deactivation of Accounts
You may request deletion of your personally identifiable information by contacting us at email@example.com to request account deletion. Once deactivated, your account and activities cannot be reinstated. Even after your account is deleted, Pulson may keep a copy of your de-identified Activity Logs in our records, and may continue to use your aggregated de-identified information indefinitely. If you purchased a product from us, the date, price, purchaser name, email address, and physical address specified in such transaction will be retained in our accounting records.
Note that content you have shared with others or that others have copied may also remain visible after you have closed your account or deleted the information from your own profile. In addition, you may not be able to access, correct, or eliminate any information about you that other users or third parties copied or exported out of our Services. Your public profile may be displayed in search engine results until the search engine refreshes its cache.
United States Operation
The Services are operated from the United States. If you are located outside of the United States and choose to use the Services or provide information to us, your information will be transferred, processed and stored primarily in the United States. United States privacy laws may not be as protective as those in your jurisdiction. You acknowledge and consent to this practice. For redundancy and efficiency, your information may be held on computer systems anywhere in the world.
While Pulson continues to work hard to protect your personal information, no data transmission over the Internet can be guaranteed to be absolutely secure, and Pulson cannot ensure or warrant the security of any information you transmit to Pulson. Transmitting personal information is done at your own risk.
Retention of Information
When you delete your user account, certain personal information will be immediately de-associated with the account and deleted, such as your e-mail, name, birth month, and profile photo (if applicable), if you had chosen to provide this information. Additionally, your Third-Party Account information will be immediately de-associated with your account. All of your activities will be de-identified, made private and no longer associated with your personal information. Your comments will be deleted. We may, however, keep a record of your deletion for up to 30 days following your deletion of an account. Additionally, we may keep system logs, which may be associated with your account for up to 90 days following your deletion of an account.