Privacy Notice

Pulso Europe BV is the Controller of the Personal Data you (Data Subject) provided to Pulso Europe BV for your Employee Assistance Programme.

1. What Personal Data do we collect?

Personal Data that we might collect are:

  • Demographic data such as your name, surname, gender, seniority, age, function, possible site/department, your relation to the organisation where EAP is applicable, your phone number and e-mail address;
  • Results of the questionnaires about psychosocial themes (if applicable);
  • Risk assessment;
  • Short description of the reason you asked for support and the topic;
  • Short explanation about content of the sessions and the recommendations.

2. What guarantees do we offer regarding the processing of Personal Data?

Pulso guarantees that it will process this Personal Data legally and compliant with applicable privacy laws and regulations:

  • Pulso processes your information after you have given consent to the processing of your data for the purposes described in the Informed Consent.
  • Pulso processes your information for the implementation of a contract in which the concerned party is involved or to take steps prior to entering into a contract at the request of the concerned party.
  • We process this information because it allows us to guarantee a good execution of the EAP service. We can also demonstrate the importance of processing this information on individual and organisational level.
  • We process this information to have a good exchange of data with the EAP experts. This way we can guarantee the continuity of care for your dossier.

You have the right not to give permission for the collection of Personal Data or revoke your consent at all times. Refusing or withdrawing permission may have certain consequences to the support provided by Pulso regarding EAP where the collection of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

3. What do we use your Personal Data for?

Your Personal Data is processed by Pulso Europe BV located in Kessel-Lo, Belgium.
Hosting and storage of your data takes place in the following locations:

  • Antwerp DataCenter BV in Antwerp, Belgium
  • Amazon Web Services EMEA SARL in Frankfurt, Germany
  • Combell NV in Ghent, Belgium

No third party providers have access to your data, unless specifically required by law.

Your Personal Data will only be used to produce statistical reports about the EAP. However, all information relating to you as a person is rigorously protected. This means that you will not be identified by name or in any other recognisable way in these reports.

4. How long do we keep your data?

According to European Legislation we are obligated to keep your information for a certain period. Within the EAP, the rule is that we keep your data for 30 years. After this period your personal data will be irreversibly anonymised or destroyed. For more information see our data retention policy: https://pulso-europe.eu/policies/data-retention-policy.

5. What are your rights?

Should you believe that any Personal Data we hold on you is incorrect or incomplete, you have the ability to request to see this information, rectify it or have it deleted. If the legal basis for the processing relies on consent you have the right to withdraw your consent at any time. You have the right to obtain from the controller restriction of processing, as well as the right to object to the processing of your personal data and automated individual decision-making and profiling. As the Data Subject you can exercise your rights through the Data Subject Access Request Form.

In the event that you wish to file a complaint about how we have handled your personal data, please contact the Data Protection Officer via d1604787467p636103662o1557492572@410207622p1023895488u338423676l2045813685s1104214510o343067471-1189031030g1309674016r786807960o1674191393u742468341p1967586921.194138841c1428462748o431258990m887953208 or by post

DPO
Pulso Europe BV
Diestsesteenweg 52 bus 0201
3010 Kessel-Lo

 Our Data Protection Officer will then look into your complaint and work with you to resolve the matter.

If you still feel that your personal data has not been handled appropriately according to the law, you have the right to lodge a complaint with the supervisory authority.