Privacy Policy

Effective date: May 2021

Pulse Health Systems Ltd (“us”, “we”, or “our”) operates the Pulse Health mobile application and Pulse Health website ( (hereinafter referred to as the “Service”).

This page informs you of our policies regarding the collection, use and disclosure of personal data when you use our Service and the choices you have associated with that data.

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.



Service is the Pulse Health mobile application operated by Pulse Health Systems Ltd

Personal Data

Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

Usage Data

Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).


Cookies are small files stored on your device (computer or mobile device).

Data Controller

Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.

For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.

Data Processors (or Service Providers)

Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller.

We may use the services of various Service Providers in order to process your data more effectively.

Data Subject (or User)

Data Subject is any living individual who is using our Service and is the subject of Personal Data.

Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Service to you.

Types of Data Collected

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:

·         Email address

·         First name and last name

·         Phone number

·         Organisation Name

·         Designation (Job Title)

·         Ward

·         Department

·         Site (location)

·         Phone number – (not displayed within directory)

·         Bleep number

·         Professional registration number (including but not limited to General Medical Council, Nursing and Midwifery Council)

·         Professional Interests

·         Cookies and Usage Data

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or the instructions provided in any email we send.

Usage Data

When you access the Service with a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data (“Usage Data”).

Tracking & Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and we hold certain information. Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyse our Service. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service. Examples of Cookies we use:

·         Session Cookies. We use Session Cookies to operate our Service.

·         Preference Cookies. We use Preference Cookies to remember your preferences and various settings.

·         Security Cookies. We use Security Cookies for security purposes.

·         Advertising Cookies. Advertising Cookies are used to serve you with advertisements that may be relevant to you and your interests.

Use of Data

Pulse Health Systems Ltd uses the collected data for various purposes:

·         To provide and maintain our Service

·         To notify you about changes to our Service

·         To allow you to participate in interactive features of our Service

·         To provide customer support

·         To gather analysis or valuable information so that we can improve our Service

·         To monitor the usage of our Service

·         To detect, prevent and address technical issues

·         To provide a global address book

·         To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information

Legal Basis for Processing Personal Data under the General Data Protection Regulation (GDPR)

If you are from the European Economic Area (EEA), Pulse Health Systems Ltd legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it. Pulse Health Systems Ltd may process your Personal Data because:

We need to perform a contract with you

You have given us permission to do so

The processing is in our legitimate interests and it is not overridden by your rights

To comply with the law

Retention of Data

Pulse Health Systems Ltd will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies. Pulse Health Systems Ltd will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods.

Transfer of Data

Your information, including Personal Data, may be transferred to – and maintained on – computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside and choose to provide information to us, please note that we transfer the data, including Personal Data, to and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Pulse Health Systems Ltd will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.

Disclosure of Data

Legal Requirements

Pulse Health Systems Ltd may disclose your Personal Data in the good faith belief that such action is necessary to:

·         To comply with a legal obligation

·         To protect and defend the rights or property of Pulse Health Systems Ltd

·         To prevent or investigate possible wrongdoing in connection with the Service

·         To protect the personal safety of users of the Service or the public

·         To protect against legal liability

Security of Data

The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

Direct Care and Indirect Care

Direct Care

Explicit consent under the GDPR is distinct from implied consent for sharing for direct

care purposes under the common law duty of confidentiality. The GDPR creates a lawful

basis for processing special category health data when it is for the provision of direct care

that does not require explicit consent. Clients (data controllers) must establish both a lawful

basis for processing and a special category condition for processing:

  • The lawful basis for processing special category health data for direct care is that processing is: ‘necessary… in the exercise of official authority vested in the controller’ (Article 6(1)(e)).12. It is also possible for the client (data controller) to rely on ‘processing is necessary for compliance with a legal obligation to which the controller is subject’ (Article 6(1)(c).13
  • The special category condition for processing for direct care is that processing is: ‘necessary for the purposes of preventative or occupational medicine for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services…’ (Article 9(2)(h)).
  • In addition to a GDPR Article 9 condition for processing, it is also necessary to identify an additional condition in Schedule 1 of the DPA 2018. For the provision of direct care the relevant condition is ‘Health or social care purposes’ (Schedule 1, Part 1 (2)).

Under Articles 6(1)(e) and 9(2)(h) to share data for the provision of direct care,consent under GDPR is not needed. However, in addition to the GDPR, data controllersmust also satisfy the common law duty of confidentiality. In order to satisfy the commonlaw data controllers can continue to rely on implied consent to share confidential healthdata for the provision of direct care.14 The most common example of when consent can beimplied is when a patient agrees to a referral from one healthcare professional to another.In these circumstances, when the patient agrees to the referral this implies their consentfor sharing relevant information to support the referral (unless the patient objects).The referral information can then be disclosed under GDPR using articles 6(1)(e) and 9(2)(h) as above.

Indirect Care

For purposes other than the provision of direct care, GDPR sets out certain requirements in order forconsent to be valid.Consent must be ‘freely given, specific, informed and an unambiguousindication of the data subject’s agreement’. Consentmust meet the following four criteria:

  • Where there is a legal requirement to disclose, for example, a direction under the Health and Social Care Act 2012 or disclosures under public health legislation, the lawful basis for processing would be:‘… for compliance with a legal obligation…’ (Article 6(1)(c)). In the majority of cases, the most appropriate special category condition for processing in the face of a legal requirement to disclose will remain as:16 ‘for the purpose of preventative…medicine…the provision of health or social care or treatment or the management of health or social care systems and services…’ (Article 9(2)(h)).
  • When processing data for medical research the Article 6 lawful basis is 6(1)(e) ‘… for the performance of a task in the public interest…’ The special category condition is Article 9(2)(j) ‘…research purposes…’. Reliance on this Article 6 lawful basis and Article 9 condition means that explicit consent is not required for GDPR purposes, however, explicit consent or another legal basis is still required under common law – see section below on ‘dealingwith requests for confidential health data’.
  • In addition to a GDPR Article 9 condition for processing, it is also necessary to identify

an additional condition in Schedule 1 of the DPA 18. For medical research the relevant

condition is ‘Research etc’ (Schedule 1 Part 1 (4)).

  • Where there is a request for personal confidential data from an insurance company,

solicitor, or employer (or similar third party) the lawful basis and lawful conditionforprocessing will be explicit consent under both Articles 6(1)(a) and Article 9(1)(a).

Your Data Protection Rights under the General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Pulse Health Systems Ltd aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.

If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

We process your dataand any additional personal data you send us on the legal basis of legitimate interest.

In certain circumstances, you have the following data protection rights:

The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.

The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.

The right to object. You have the right to object to our processing of your Personal Data.

The right of restriction. You have the right to request that we restrict the processing of your personal information.

The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.

The right to withdraw consent. You also have the right to withdraw your consent at any time where Pulse Health Systems Ltd relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

Service Providers

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), provide the Service on our behalf, perform Service-related services or assist us in analysing how our Service is used. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.


We may use third-party Service Providers to monitor and analyse the use of our Service.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network.

You may opt-out of certain Google Analytics features through your mobile device settings, such as your device advertising settings or by following the instructions provided by Google in their Privacy Policy:

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page:


Firebase is an analytics service provided by Google Inc.

You may opt-out of certain Firebase features through your mobile device settings, such as your device advertising settings or by following the instructions provided by Google in their Privacy Policy:

We also encourage you to review the Google’s policy for safeguarding your data:

For more information on what type of information Firebase collects, please visit the Google Privacy & Terms web page:


We may use third-party Service Providers to show advertisements to you to help support and maintain our Service.

AdMob by Google

AdMob by Google is provided by Google Inc.

You can opt-out from the AdMob by Google service by following the instructions described by Google:

For more information on how Google uses the collected information, please visit the “How Google uses data when you use our partners’ sites or app” page: or visit the Privacy Policy of Google:

Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Children’s Privacy

Our Service does not address anyone under the age of 18 (“Children”).

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, please contact us:

·         By email:

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