Privacy policy

Privacy statement Pulse4all 

Protection of personal data

Below you will find the Privacy Statement of defibswap Holding B.V. (hereinafter:
"Pulse4all"). In this Privacy Statement, we inform you about the purposes for
which Pulse4all processes personal data and what your rights are as a data
subject. Pulse4all only processes personal data that is necessary for the purposes
described in this Privacy Statement. This Privacy Statement applies to defibswap
Holding B.V. and its affiliated entities: Pulse4all B.V., Pulse4all Finance I B.V.,
Pulse4all Finance II B.V., Pulse4all FR S.A.S., Pulse4all Sweden AB, Defibswap UK
Ltd, and Pulse4all DE GmbH (collectively referred to as "Pulse4all"). This includes
all entities established in the European Economic Area and the United Kingdom.

The Privacy Statement below applies to the personal data of data subjects who are
in any way related to Pulse4all. The terminology used in this Privacy Statement is
taken from applicable data protection legislation, including the General Data
Protection Regulation (EU) 2016/679 (“EU GDPR”), the UK GDPR and the UK Data
Protection Act 2018. Cas Bierkens has been appointed as Privacy Officer within
Pulse4all. If you have any questions about your privacy, please contact him at
legal@pulse4all.com .

Personal data we process:

Pulse4all only processes your personal data if there is a legitimate purpose for
doing so and the processing can be based on a legal basis. The personal data we
process about you, the purpose for which we process it and the legal basis for
doing so depend on your relationship with Pulse4all.
The overviews below detail which personal data Pulse4all processes in which
cases, broken down by category. They also include the legal basis on which the
processing is based and the retention periods we apply to the personal data.

Explanation of base for consent

If consent is required from the data subject for the processing of his/her personal
data, this consent is granted for a specific purpose. If you wish to withdraw your
consent at a later date, this is possible. You can send an email to our Privacy
Officer at legal@pulse4all.com. It is possible that we will no longer be able to
provide certain services due to the withdrawal of your consent.


Explanation of job application data storage

When you apply for a job at Pulse4all, we collect and process your personal data
solely for the purpose of handling the application procedure. The data we process
may include your name, contact details, CV, cover letter, education and work
history.

This data is stored in our systems and is only accessible to employees involved in
the recruitment process. We do not store this data for longer than necessary. As
standard, we store application data for four (4) weeks after completion of the
application procedure.

With your consent, we may store the data for up to one (1) year for future
vacancies.

Your data will not be shared with third parties, unless this is necessary for the
application process or we are legally obliged to do so. If we use external parties to
support our recruitment process (such as a recruitment system), we ensure that
these parties comply with the applicable privacy legislation and that appropriate
processing agreements have been concluded.

Special and/or sensitive personal data that we process:

Our website and/or service does not intend to collect data about website visitors
who are younger than 16 years of age. Unless they have permission from their
parents or guardian.

However, we cannot verify whether a visitor is over 16 years of age. If you are
convinced that we have collected personal data from a minor without consent,
please contact us at legal@pulse4all.com so that we can delete this information.

Retention period for personal data

Pulse4all retains your personal data in accordance with the statutory retention
periods. Your personal data will not be retained for longer than is necessary to
achieve the purposes for which the data was collected. The above overviews
indicate the retention periods that apply to the relevant purposes.

Collection of personal data

Pulse4all obtains your personal data in various ways:

  • When you wish to use Pulse4all’s services and enter into an agreement
    with it;
  • When you contact us by telephone;
  • When you contact us via the website (contact form).

As the data subject, you decide whether to provide your personal data to
Pulse4all. If you have provided your personal data to Pulse4all in the past but no
longer wish to do so, you can contact our Privacy Officer at any time.

Pulse4all cannot offer or provide certain services without being in possession of
your personal data.

Sharing personal data with third parties

We do not sell your data to third parties and will only provide it if this is necessary
for the execution of our agreement with you or to comply with a legal obligation.
We enter into a processing agreement with companies that process your data on
our behalf to ensure the same level of security and confidentiality of your data. We
remain responsible for these processing operations.

Rights of data subjects

If Pulse4all processes your personal data, you have a number of rights as a data
subject that you can invoke. If you wish to invoke any of your rights, please send
your request to our Privacy Officer at legal@pulse4all.com.
As a data subject, you have the following rights:

  • Right of access: As a data subject, you have the right to access the personal
    data processed by Pulse4all. If you wish to do so, you can submit a request
    for access.
  • Right to rectification: You have the right to rectify and supplement
    incorrect data if necessary. If you wish, we can remove incorrect information
    and, if necessary, restore it with correct information.
  • Right to object: In certain situations, you may object to the processing of
    your personal data.
  • Right to data portability: You have the right to transfer data or have it transferred. You can request your personal data from Pulse4all. We will ensure that you receive your data in a digital and structured format.
  • Right to be forgotten: In certain situations, you have the right to be “forgotten”. This means that we will delete all (possible) personal data about you.
  • Right to restriction: In some situations, you have the right to (temporarily) restrict data processing.

Exceptions and explanations of the above rights are included on the website of
the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) and the UK
Information Commissioner’s Office (ICO).

If we receive a request from you via the designated channel, we will contact you
within four weeks to verify your identity, assess your request and, where relevant,
implement your rights.

For identity verification purposes, we may request additional information to
confirm your identity.

Security of your personal data

In order to protect your personal data as effectively as possible, Pulse4all takes
appropriate technical and organisational measures.

Pulse4all ensures that your personal data can only be viewed by a limited number
of authorised persons and that the data is adequately secured. These security
measures prevent misuse, loss, unauthorised access, unwanted disclosure and
unauthorised modification of your personal data. If you have the impression that
your personal data is not properly secured or there are indications of misuse,
please contact our Privacy Officer.

Automated decision-making

Pulse4all does not use automated decision-making.

International transfers of personal data

If it is necessary for the performance of our services to transfer personal data
outside the European Economic Area (EEA) or the United Kingdom, Pulse4all
ensures that appropriate safeguards are implemented in accordance with
applicable data protection legislation.

Transfers of personal data between the EEA and the United Kingdom are currently
permitted on the basis of adequacy decisions issued by the European Commission
and the UK Government.

Where personal data is transferred to countries that do not benefit from an
adequacy decision, Pulse4all will ensure that appropriate safeguards are in place,
such as:

  • Standard Contractual Clauses (SCCs)
  • other legally approved transfer mechanisms

Cookies, or similar techniques:

A cookie is a small text file that is stored in the browser of your computer, tablet or
smartphone when you first visit this website.

Defiswap uses the following cookies on its website:

  • Functional cookies;
  • Analytical cookies;
  • Personalisation.

Website reviews

The reviews on our site are provided by customers, collected and checked for
authenticity. All reviews collected come from someone who has made a purchase
from us. If this is not the case, for example because products or services were
provided free of charge or there was a paid collaboration, this is clearly stated in
the review.

Changes:

The way in which we process personal data, and the composition or quantity of
data we process, may change. We therefore reserve the right to amend this
privacy statement. You will be notified of any changes if necessary. This Privacy
Statement always states the date of the most recent amendment. Previous
versions can be consulted below:

This statement was last revised in March 2025.

Contact details:

If you have any questions about the processing of your personal data or about
your privacy, you can contact us using the following contact details:

defibswap Holding B.V.
Fred. Roeskestraat 115
1076 EE Amsterdam
+31 85 401 42 46
www.pulse4all.nl


Privacy Officer: Cas Bierkens, legal@pulse4all.com