Privacy Policy/Notice

[21st July 2021]

Introduction

Keeping your Personal Data (the same as Personal Information) secure, while ensuring your Privacy is really a big deal for us at PPC Samurai.

PPC Samurai own the Adpulse.io brand and operates a service with the same designation which proceeds with the herein described Processing of Personal Data.

The goal of this text is to inform everyone of what Personal Data we (PPC Samurai and Adpulse.io) collect and why; how it is handled by us; what entitles us to process it; and your rights under the applicable Personal Data Protection laws.

Personal Data means any data that either on its own or if cross-referenced with other data allows the identification of one specific natural person.

We DO NOT, nor will ever sell Personal Data.

We will modify this Privacy Policy, from time to time, on a need basis, always posting a time-stamped updated version.

The Controller

PPC Samurai, owner of Adpulse.io
PO Box 3061
Norman Park QLD Australia 4170

Applicable Laws

This Privacy Policy is provided to you, in line with the following Personal Data Protection Legislation:

 

  • Primarily, the Regulation (EU) 2016/679, also known as the General Data Protection Regulation (GDPR), because at present date is the most comprehensive Personal Data Protection law enforceable around the Globe;
  • The (EU) ePrivacy Directive, which mainly focuses on the use of Cookies by us;
  • The California Consumer Privacy Act 2018, also known as the CCPA, now being replaced by the California Privacy Rights Act of 2020 (CPRA).
    Anyone who is identified as being under 18 years of age is not allowed to use our service, therefore if any Personal Data has been gathered pertaining to such a natural person, it shall be immediately erased from all repositories, and if a user, his/ her privileges will be revoked.

What We do With Personal Data

We do not process any data that is not required as an enabler for the delivery of our services to you.

The goal of Processing Personal Data consists of:

    1. Allowing registered users to operate our tool via the website; therefore, we exclusively process data pertaining to registered users (logged in users) towards us (PPCSamurai and Adpulse.io);
      These users have been “enrolled” at request of their employers/ hiring parties (our Corporate Client), to become users of our tools and services on behalf of their organization, hence our Legal Basis to Process their Personal Data consists of the fulfillment of Contractual Obligations towards our Corporate Client.
    2. Providing training actions towards users; These users may either fall in the same category as above mentioned, hence the same Legal Basis for processing applies from our side or, they have freely joined our training actions, hence our Legal Basis for Processing their Personal Data is Legitimate Interest.
      All natural persons maintain full control over the Personal Data pertaining to them which undergoes Processing by our side, since all are able to exercise their rights under the law (which are listed below in this document) at any time.
      We do not share any Personal Data with any 3rd party that is not involved in the delivery of our services (while acting either as Controllers or Processors), unless under a legal obligation.

Which Personal Data

The following list is an example of the type of Personal Data under Processing by us regarding “users”:

· Name
· email
· Organization
· App usage
· Username
· Password
· Browser
· IP Address
· Phone (optional)
· Google Login credentials
· Training Actions
· Communications
· Training remarks

If you are a visitor, we will merely gather data via Cookies that allow us to “remember” you and ensure that our website content is delivered with quality towards your web browser. Nevertheless, this does not comprise the Processing of Personal Data… meaning you remain “anonymous” for us.

We do not use any type of Automated Processing of Personal Data in the sense of a decision-making process over Personal Data automatically taken by algorithms or other “logic mechanisms”, which includes (yet not exclusively) “Profiling” activities.

Cookies

When you use our service you can disable non-necessary Cookies via the popup banner at the bottom of the login page, clicking the option “Cookies Settings”.

“Necessary Cookies” are session cookies which gather Login Data to enable providing access to registered users and the IP addresses plus browser versions to optimize the user experience, as well as Cookies that enforce security and enable load balancing to optimize our service delivery. We only use secure Cookies, in the sense that they do not share your Personal Data with any 3rd party; and which are essential, in the sense that if not in place, you may not be able to Log-in.

For additional detailed information and the chance of disabling the other Cookies in use please read the description under “Analytics”; “Advertisement” and “Functionality” after you click on “Cookies Settings on the banner at the bottom of your Landing Page.

DPO contacts

We have someone in our team who is responsible for ensuring our ongoing compliance towards applicable Personal Data Protection laws (our Data Protection Officer) and here is his identification and contacts:

Mr. Rui Serrano
Country: Portugal, European Union
email – rui.freitas.serrano@ppcsamurai.com

Data Retention

We will maintain your Personal Data for the duration of the service contract with our Corporate Client (where that is the case) or until you ask us to erase it by exercising your Rights under the law.

Note that if you have been enlisted towards us by our Corporate Client and you ask for your Personal Data to be erased, we will inform our Corporate Client of that request, since our contractual obligation is to assure the service towards all of its registered users and the Corporate Client is the Controller under the Law.

The erasure of your Personal Data takes place over both “live repositories” as well as backups as determined under the law upon 30 days of either your valid request for it to be erased (if you have enrolled yourself towards our services), the confirmation from our Corporate Client of the request for erasure (is you have been enrolled by a Corporate Client) or after termination of the service contract with our Corporate Client or with you if that is the case.

Ensuring The Security And Confidentiality Of Your Data

We resort to secure and encrypted hosting environments to host and process your Personal Data, observing by the highest market standards and operated under market best practices, and all transfer of Data from and to your browser is also encrypted.

Regardless of the potential need of transferring your Personal Data to other countries (so our partners may provide their component of our service) we have in place all required by law technical and legal measures/ commitments.

Our partners (in the delivery of our service) consist of:

    • LogRocket – user experience and troubleshooting platform
    • Hubspot – CRM, Email, Knowledge Base
    • Google Cloud – hosting of service
    • Stripe – management of payment services
    • Profitwell – reporting
    • Mixpanel – reporting
    • WordPress – user registration for Online Learning Platform
    • Google Ads – primary function of the platform
    • Microsoft – primary function of the platform
    • Google Analytics – reporting
    • Segment – data synchronization
    • Google Authentication – allows for registered users to operate functionalities;
    • Facebook Authentication – allows for registered users to operate functionalities;

Your Rights Under The Law

You may exercise the following Rights where these apply to you:

( GDPR ) Right of access – The right to obtain from us confirmation as to whether your Personal Data is being processed by us, and where that is the case, access to such Personal Data. To prevent violating your Privacy there may be the need to identify you prior to sharing the Personal Data with you.

( CCPA ) Right to know and access your personal information – similar to the Right of Access under the GDPR, California resident natural persons have the right to:

    • Know the categories of personal information we collect and the categories of sources from which we got the information;
    • Know the business or commercial purposes for which we collect and share personal information;
    • Know the categories of third parties and other entities with whom we share personal information; and
    • Access the specific pieces of personal information we have collected about you.

( GDPR ) Right to rectification – you can ask for the update of inaccurate Personal Data pertaining to you. You may directly amend existing information while logged-in towards us or by submitting a request as herein defined ahead.

( GDPR ) Right to erasure – you can ask us to erase your Personal Data, which will be done unless there is a legal obligation or Legitimate Interest from our side to maintain it.

( CCPA ) Right to deletion – again in a similar manner to what the GDPR rules, natural persons who reside in the state of California may ask us to delete their Personal Data.

( GDPR ) The right to restrict processing – you may request of us to have in place specific processing restrictions. If you exercise this right make sure to explain which are those restrictions and the reason for the request and we will provide you a reply, either acknowledging your request or denying it and explaining why.

( GDPR ) The right to object to processing – you may object to processing activities that occur under our Legitimate Interest, however we may refuse to comply if that means no longer being able to deliver our services.

( CCPA ) Right to opt-out of sales – As previously informed we do not “sell “ Personal Data

( GDPR ) Right to data portability – you may ask us to provide all the Personal Data that we have pertaining to you or just some that you specifically ask us for.

( GDPR ) Right to be informed about a Personal Data Breach – in case of an incident that breaches your Privacy (in the sense that your Personal Data under Processing by us has been/ or even potentially has been exposed to unauthorized 3rd parties) you have the Right to be informed within 72 hours of such incident.

( GDPR ) Right to lodge a complaint with a supervisory authority – you have the right to lodge a complaint regarding our Processing activities over your Personal Data towards any of the EU Member States data protection Supervisory Authorities.

( CCPA ) Right to be free from discrimination – You may exercise any of the above rights without fear of being discriminated against.

For any of the above-mentioned CCPA related rights, you may designate an authorized agent to submit a request on your behalf. In the request, you or your authorized agent must provide sufficient information for us to confirm the identity of such authorized agent as well as your own. We are also required to verify that your agent has been properly authorized to request information on your behalf and this may represent additional time to fulfil your request.

Exercising Your Rights

You may exercise your Rights towards us by sending us an email to rui.freitas.serrano@ppcsamurai.com

Final Note

Our service may include links to other websites whose privacy practices may differ from our own. If you submit personal data to any of those sites, your information is governed by their privacy policies, hence we strongly encourage you to carefully read the privacy policy of any website you visit.