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Privacy Policy of PULS GmbH

Welcome and thank you for visiting our website; we appreciate your interest in our company. We take the protection of your personal data very seriously. We process your data in accordance with the relevant legislation on personal data protection, in particular the EU General Data Protection Regulation (GDPR) and the applicable local implementation laws. This privacy policy provides comprehensive information relating to how we process your personal data at PULS GmbH, and the rights you have in relation to this data.

Personal data is the information that permits the identification of a natural person. This includes in particular name, date of birth, address, telephone number, email address but also your IP address.

Anonymous data exists where no personal reference to the user can be made.

1. Responsible authority and Data Protection Officer

Elektrastrasse 6
81925 Munich

Phone: +49 89/9278-0
Fax: +49 89/9278-299


Company registration: 64293
Munich Registry Court
VAT ID no.: DE 129702224

Managing Director: Bernhard Erdl

Responsible person in accordance with para. 55 section 2 of the Rundfunkstaatsvertrag (Interstate Broadcasting Agreement):

Bernhard Erdl
Elektrastrasse 6
81925 Munich

Contact for data protection

2. Your rights as a data subject

Firstly we would like to inform you of your rights as an affected person. These rights are standardised in Articles 15 – 22 EU-GDPR. These cover:

  • The right of access (Art. 15 EU GDPR),
  • The right to be forgotten (Art. 17 EU GDPR),
  • The right to rectification (Art. 16 EU GDPR),
  • The right to data portability (Art. 20 EU GDPR),
  • The right to restriction of processing (Art. 18 EU GDPR),
  • The right to object to data processing (Art. 21 EU GDPR).

To exercise these rights, please contact our Data Protection Officer. The same applies if you have any queries on data processing at our company. You also have the right to lodge a complaint directly with the Data Protection Supervisory Authority.

3. Right to object

Please note the following in connection with your right to object:

if we process your personal data for the purpose of direct marketing, you have the right to object to this form of data processing at any time without giving reasons. This also applies to profiling insofar as it is associated with direct marketing.

If you object to data processing for direct marketing purposes, we will no longer process your personal data for these purposes. Exercising your right to object is free of charge and can be carried out informally, ideally via email to:

In the event that we process your data to protect legitimate interests, you may object to this type of processing at any time for reasons relating to your particular situation; this also applies to profiling based on these provisions.

We will then no longer process your personal information unless we can demonstrate compelling legitimate grounds that outweigh your interests, rights and freedoms, or the data processing is being used to assert, exercise or defend legal claims.

4. Purposes and legal bases of data processing

The processing of your personal data complies with the provisions of EU GDPR and all other applicable data protection regulations. Legal bases for data processing arise in particular from Art. 6 EU GDPR.

We use your data to initiate a business relationship, fulfil contractual and legal obligations, conduct the contractual relationship, to offer products and services, and to strengthen the customer relationship, which may include marketing and direct marketing.

Your consent also represents a permission requirement in terms of data protection law. In this context, we provide you with information on the purposes of data processing and your rights to opt out. If such consent also relates to the processing of special categories of personal data, we will expressly inform you in the consent request.

The processing of special categories of personal data in the context of Art. 9, para. 1 EU GDPR is only carried out if required on the basis of legal regulations and if there is no reason to assume that your legitimate interest in exclusion from data processing takes priority.

5. Forwarding to third parties

We will only pass on your data to third parties within the scope of the statutory provisions or with the appropriate consent. Otherwise, it will not be passed on to third parties unless we are obliged to do so due to mandatory legal regulations (disclosure to external bodies such as supervisory authorities or law enforcement authorities).

6. Recipients of the data

Within our organisation, we ensure that only the individuals receive the data that require that data to fulfil their contractual and legal obligations.

In many cases, our specialist departments are supported by service providers to fulfil their tasks. The necessary data protection agreements have been concluded with all service providers.

7. Data transfer to third countries

In principle, data will only be transferred to third countries (outside the European Union or the European Economic Area) if this is necessary for the performance of the obligation, is required by law or if you have given us your consent to do so. In the case of (sales) enquiries (see point 11), contact details can be forwarded to the corresponding foreign distributors in third countries (e.g. in Singapore or the USA).

8. Data retention period and data security

We store your data as long as it is needed for the processing purpose in question. Please note that a number of legally imposed retention periods require data to be stored for extended periods. This relates in particular to commercial or fiscal retention obligations (for example, arising from the German Commercial Code, Tax Ordinance, etc.). Unless there are further retention requirements, the data will be routinely deleted after use.

In addition, we may retain the information if you have given us your permission to do so, or in the event of legal disputes and we use evidence within the statutory limitation period which may be up to thirty years; the regular limitation period is three years.

The exchange of data from and to our website takes place in encrypted form. The transmission protocol we provide on our website is HTTPS, in all cases using the latest encryption protocols.

9. Obligation to provide data

A variety of personal data is necessary for the establishment, implementation and termination of the obligation and the fulfilment of the associated contractual and legal obligations. The same applies to the use of our website and the various functions it provides.

The details on this are summarised for you in the section above. In certain cases, data is also required to be collected or made available due to legal regulations. Please note that it is not possible to process your request or execute the underlying obligation without providing this information.

10. Categories, sources and origin of the data

The data we process is determined by the context in question: For example, it may vary depending on whether you have submitted an enquiry via our contact form, registered for our newsletter, sent us a job application or submitted a complaint.

Please note that we may also make information available separately to a suitable location for specific processing where appropriate, e.g. when uploading job application documents or when submitting a contact request.

When you visit our website, we collect and process the following data:

  • Name of the internet service provider
  • Information on the website you have visited us from
  • Web browser and operating system used
  • The IP address assigned by your internet service provider
  • Requested files, amount of data transferred, downloads/file export
  • Information on the pages of our website(s) that you visit, including date and time
  • For reasons of technical security (in particular to defend against attempted attacks on our web server), these types of data are stored in accordance with Art. 6 (1) lit. f EU GDPR. After 7 days at the latest, anonymisation is carried out by shortening the IP address so that no reference is made to the user. To achieve this, the last three digits are removed; in other words, becomes 127.0.0.*. IPv6 addresses are also anonymised. The anonymised IP addresses are kept for 60 days.

11. Contact form / contact via e-mail / arrange online meeting (Art. 6, para. 1 lit. a, b EU GDPR)

A contact form is provided on our website that can be used to make contact with us electronically. If you write to us via the contact form, we will process the data you have provided in the contact form to contact you and answer your questions and requests.

In doing so, we follow the principle of data minimisation and data avoidance by requesting only the information we need to contact you. These are your first name, last name, postcode, country and your email address, as well as the message field itself. Using the postcode and country, we can forward your request straight away to the responsible regional employees. All other data are voluntary fields and completion is optional (e.g. so we can answer your queries more accurately).

To participate in an online meeting, the name of the company is requested in addition as a compulsory field.

If you contact us by email, we will process the personal information provided in the email solely for the purpose of processing your request.

To answer your request, we will – if necessary – forward your contact request to the relevant persons at the responsible PULS company. A list of the relevant responsible PULS companies and distributors can be found here: Puls worldwide. If you contact us from a country where PULS does not have its own office, your enquiry will be passed to our local distribution partner. If any (sales) enquiries for these countries are received by us instead of by the local distributor, we will forward them to the relevant distributor with the request to make contact. This will be carried out on the basis of the legitimate interest pursuant to Art. 6 para. 1 lit. f EU GDPR for us to contact you quickly and easily. You have the right to object to this.

If you contact us, we will keep your enquiries until they have been fulfilled and no follow-up enquiries are expected.

12. Newsletter (Art. 6 para. 1 lit. a EU-GDPR)

Our website offers the option to subscribe to a complimentary newsletter. The email address provided during the newsletter subscription process, and your name where applicable (optional information), are used to send the personalised newsletter.

In this process, we follow the principle of data economy and data avoidance only the email address and your agreement to this data protection declaration are marked as compulsory fields. Due to technical necessity as well as legal security, your IP address will be processed when subscribing to the newsletter.

Our newsletter is sent via a newsletter service provider. For this purpose, your data will be stored by us with this service provider. The company’s servers are located in Europe. The processing of the data is carried out in accordance with the European General Data Protection Regulation.

For our account used to send the newsletter, we use the integrated data protection conformity function. Our reports evaluating the newsletter include anonymous data relating to recipients who open and click on the newsletter. Data protection compliance also prevents the collection and processing of complete IP addresses. Your data will not be passed on to other third parties in relation to the newsletter and the service provider does not receive any right to transfer your data.

Naturally you can cancel your subscription at any time using the unsubscribe link provided in the newsletter, thus opting out from permission. It is also possible to unsubscribe from the newsletter at any time via our website.

13. Automated case-by-case decisions

We do not use any purely automated processing facilities to make decisions.

14. Cookies (Art. 6 para. 1 lit. a, f EU GDPR, §25 para. 1 of the Telekommunikation-Telemedien-Datenschutzgesetz (Telecommunications and Telemedia Data Protection Act, TTDSG))

15. Links to social media (Art. 6 para. 1 lit. a GDPR)

Our website contains links to our corporate websites on the platforms Facebook, YouTube, XING, Twitter and LinkedIn. By clicking on these links, the respective social network receives the information about which website you have come from as a user.

In addition, further data is transmitted to the provider of the respective social media service (Facebook, YouTube, XING, Twitter and LinkedIn). These are, for example:

  • Address of the website where the activated link is located
  • Date and time of accessing the website or activating the link
  • Information on the browser and operating system used
  • IP address

If you are already logged into the corresponding social media service at the time of activating the link, the provider of the social media service may be able to determine your user name and possibly even your real name from the transmitted data and assign this information to your personal user account with the social media service. You can exclude this possibility of assignment to your personal user account if you log out of your user account beforehand.

The servers of the social media services are located in the USA and other countries outside the European Union. The data can therefore also be processed by the provider of the social media service in countries outside the European Union. Please note that companies in these countries are subject to a data protection law that generally does not protect personal data to the same extent as is the case in the Member States of the European Union.

Please note that we have no influence on the scope, type and purpose of data processing by the provider of the social media. Further information on the use of your data by the social media integrated on our website can be found in the privacy policy of the respective social media.

16. YouTube plug-in (Art. 6 para 1 lit. a EU GDPR, §25 para 1 TTDSG)

To display the videos contained on our website, we use an offering from YouTube LLC, 901 Cherry Ave, San Bruno, CA 94066, USA, represented by: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.  If you do not play these videos, no data about you as a user will be transmitted to YouTube. Your data will not be transferred until you have given your consent (Art. 6 I 1 a EU GDPR). When you visit our website, we display what is known as a “banner”. You already have the option of consenting to the data processing there. If you have not done so, the display area of the video will show you information on the processing of your data if you play a video. You can then use this to activate the videos and thus consent to the data processing. You can revoke your consent at any time here under “Marketing”.

YouTube will only receive the information that you have accessed the corresponding content on our website if you consent to data processing. If you have a Google account and are logged in to Google while you are playing the video, this can be assigned directly to your account. If you do not want this to happen, you must log out before opening the video sequence. YouTube may store your data and, in particular, process it for the purposes of advertising and market research. However, this type of evaluation for displaying targeted advertising can also be carried out if you have a Google account but are not currently logged in. Please note that when using YouTube, data may also be transferred to the USA.

17. Google Maps plug-in (Art. 6 para 1 lit. a EU GDPR, §25 para 1 TTDSG)

On our website we use Google Maps (API) from Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”). To ensure data protection, Google Maps is disabled when you first enter this website. A direct connection to Google’s servers will only be established if you activate Google Maps independently or have given your consent via our cookie banner (consent pursuant to Art. 6 I 1 a EU GDPR). You can revoke your consent at any time here under “Marketing”. This prevents your data from being transmitted to Google when you first enter the site.

After activation, Google Maps will save your IP address. This is then normally transmitted to a Google server in the USA and stored there. Additional information on the handling of user data can be found in Google’s privacy policy:

18. LinkedIn conversion tracking (Art. 6 para. 1 lit. a EU GDPR, §25 para. 1 TTDSG)

This website uses conversion tracking and the retargeting function of the LinkedIn business network. This allows website visitors to have personalised advertisements displayed on LinkedIn. In addition, PULS has the option of creating anonymous reports on the performance of advertisements as well as information on interactions on the website. For this purpose, the LinkedIn Insight Tag is integrated into this website via the Google Tag Manager. The Insight Tag establishes a connection to the LinkedIn server, assuming that you visit this website and are logged into your LinkedIn account at the same time.

LinkedIn’s Privacy Policy at provides further information on data collection and use in connection with the Insight Tag. You will also learn all about the options and rights to protect your privacy. If you are logged in to LinkedIn, you can also deactivate data collection at any time via the following link:

You can revoke your consent at any time here under “Marketing”.

19. Google Analytics and Hubspot for web analysis (Art. 6 para. 1 lit. a EU GDPR, §25 para. 1 TTDSG)

We use Google Analytics, a web analytics service provided by Google Inc. (“Google”) as well as technologies from Hubspot, Inc. Google and Hubspot use cookies to track user behaviour.

The information generated by the cookie about the use of the online offering by users is usually transmitted to a server in the USA and stored there.

Google will use this information on our behalf to evaluate the use of our online offering by users, to compile reports on the activities within this online offering and to provide us with other services related to the use of this online offering and internet usage. In this case, pseudonymous usage profiles of the users may be created from the processed data.

We only use Google Analytics with activated IP anonymisation. This means that the IP address of the users will be shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. The full IP address be sent to a Google server in the US and shortened there only in exceptional cases. The IP address sent by the user’s browser will not be merged with other data provided by Google.

Revocation options:

You can revoke your consent at any time here under “Marketing”.

Users can also opt out of the storage of cookies by setting their browser software accordingly; users may also prevent the collection by Google of the data generated by the cookie and related to their use of the online offering and the processing of such data by Google by downloading and installing the browser plug-in available at the following link:

20. Google Tag Manager (Art. 6 para. 1 lit. a EU GDPR, §25 para. 1 TTDSG)

This website uses Google Tag Manager. This service allows website tags to be managed via a single interface. Google Tag Manager only implements tags. This means that no cookies are used and no personal information is collected. Google Tag Manager initiates other tags, which in turn may collect data. Google Tag Manager does not access this data, however. If deactivated at the domain or cookie level, it will remain in effect for all tracking tags as far as they are implemented with the Google Tag Manager.

21. Google Display & Video 360 (formerly Doubleclick Bid Manager) (Art. 6 para. 1 lit. a EU GDPR, §25 para. 1 TTDSG)

On this website, we use the Display & Video 360 tool from Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, which collects data for analysis, marketing and optimisation purposes and thereby helps us improve our marketing measures to improve our website. The collected data is used by Display & Video 360 to link advertising contacts and clicks on advertisements with a resulting use of our website. In this way, we can determine whether Internet users who have seen our ads visit our website or what products they are interested in. This helps us to use our advertising budget more efficiently. The collected data can also be used by us to deliver advertising based on your interests (e.g. viewed products).

Pseudonymous online identification numbers (such as cookie IDs or IP addresses) are used for data collection. No unique user-related data such as name or address is stored here. All IDs used by us only allow the recognition of your device and your Internet browser. The data collected will not be used by us to personally identify you as a user of our website without your explicit consent.

We would like to point out that for users who have registered with Google, Google may link the visit to this website with the registered data. You can find out how Google processes your data on Google’s privacy pages by clicking on the following link:

You can opt out at any time here under “Statistics”.

At the following link, you will find an explanation of how you can deactivate data collection by Google on your computer or mobile device:

22. Campaign Manager (formerly DoubleClick by Google) (Art. 6 para. 1 lit. a EU GDPR, §25 para. 1 TTDSG)

This website continues to use Google’s online marketing tool Campaign Manager. Campaign Manager uses cookies to serve ads relevant to users, to improve campaign performance reports, or to prevent a user from seeing the same ads multiple times. Google uses a cookie ID to record which ads are displayed in which browser and can thus prevent them from being displayed multiple times. In addition, Campaign Manager can use cookie IDs to record what are known as conversions that relate to ad requests. This is the case, for example, if a user sees a Campaign Manager ad and later visits the advertiser’s website and buys something there using the same browser. According to Google, Campaign Manager cookies do not contain any personal information.

Due to the marketing tools used, your browser automatically establishes a direct connection to the Google server. We have no influence on the scope and further use of the data collected by Google through the use of this tool; this is our current understanding: By integrating Campaign Manager, Google receives the information that you have accessed the corresponding part of our website or clicked on an ad from us. If you are registered with a Google service, Google can assign the visit to your account. Even if you are not registered with Google or have not logged in, it is possible that the provider may find out and store your IP address.

In addition, the Campaign Manager (DoubleClick Floodlight) cookies used enable us to understand whether you perform certain actions on our website after you have accessed or clicked on one of our display/video ads on Google or on another platform via Campaign Manager (conversion tracking). Campaign Manager uses this cookie to understand the content you have interacted with on our websites to be able to send you targeted advertising later.

There are several ways you can prevent participation in this tracking process:

You can opt out at any time here under “Statistics”.

Alternatively, by setting your browser software accordingly, in particular by suppressing third-party cookies, you will not receive ads from third-party providers.

23. Online offerings for children

Persons under the age of 16 are not permitted to submit any personal data to us without the consent of the legal guardian or a declaration of consent. We encourage parents and guardians to actively participate in the online activities and interests of their children.

Notes on data protection in social media

PULS GmbH maintains a presence on “social media”, in this case on Facebook, Instagram, Twitter, YouTube, Xing and LinkedIn. Insofar as we have control over the processing of your data, we ensure that the applicable data protection regulations are observed.

Below you will find the most important information on data protection law in relation to our online presence.

Name and address of the persons responsible for operation

In addition to PULS GmbH, the following organisations are responsible for the company’s websites within the context of the EU General Data Protection Regulation (EU GDPR) and other data protection regulations:

  • Facebook
    (Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland)
  • Instagram
    (Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland)
  • LinkedIn
    (LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland)
  • Twitter
    (Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland)
  • Xing
    (New Work SE, Am Strandkai 1, 20457 Hamburg, Germany)
  • YouTube
    (Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland)

However, the use of these platforms and their functions is your own responsibility. This applies in particular to the use of interactive functions (e.g. commenting, sharing, rating). We would also like to point out that your data may be processed outside the territory of the European Union.

Purpose and legal basis

We ourselves maintain the social media pages to communicate with the visitors of these sites and in this way to keep them informed of our offerings.

In addition, we collect data for statistical purposes to be able to further develop and optimise the content and to make our offering more appealing. The data required for this (e.g. total number of page views, page activities and data provided by visitors, interactions) are processed by the social networks and made available to us. We have no influence on the production and presentation.

In addition, your personal data will be processed by the providers of social media, but also by PULS GmbH, for market research and advertising purposes. It is possible, for example, that user profiles may be created based on your usage behaviour and the interests arising from this. This means, among other things, that advertisements can be placed inside and outside the platforms that match your interests. For this purpose, cookies are usually stored on your computer. Regardless of this, data that is not collected on your devices can also be stored in your user profiles. Data storage and analysis is also carried out across devices; this applies in particular, but not exclusively, if you are registered as a member and logged in to the respective platforms.

We do not collect or process any data beyond this.

The processing of your personal data by PULS GmbH takes place on the basis of our legitimate interests in effective information and communication in accordance with Art. 6 para. 1 sentence 1 lit. f. EU GDPR.

If you are asked for consent to data processing, i.e. if you declare your consent by confirming a button or similar (opt-in), the legal basis for the processing is Art. 6 para. 1 clause 1 lit. a., Art. 7 EU GDPR.

Your rights / right to object

If you are a member of a social network and do not want the network to collect data about you via our website and link it to your stored member data for the respective network, you must

  • log out of the respective network before visiting our page,
  • delete the cookies located on the device and
  • close your browser and restart it.

After logging in again, however, may still be recognised as a specific user for the network.

For a detailed description of the respective processing types and the options to object (opt-out), we refer to the following linked information:

Overall, you have the following rights regarding the processing of your personal data:
the right to be informed; the right of access; the right to rectification; the right to erasure; the right to restrict processing; the right to data portability; right to complain about unlawful processing of your personal data with the responsible data protection authority.

However, as PULS GmbH does not have full access to your personal data, you should contact the providers of social media directly when asserting your claim, because they have access to the personal data of their users and can take appropriate measures and provide information.

If you still need help, we will of course try to assist you. Please get in touch with our Data Protection Officer.

Additional information on the Facebook page:

When you visit our Facebook page where we present PULS GmbH as a company, inform you about our products and communicate with our customers and interested parties, certain information about you is processed.

The responsible body and the data protection officer are the persons mentioned in point 1 of this privacy policy.

Processing of page insights

Facebook provides us with anonymised statistics for our Facebook page, which we use to obtain insights into user behaviour (known as “page insights”). These page insights are created based on information about people who have visited our site. This processing of personal data is carried out by Facebook and us as joint controllers. The data processing serves our legitimate interest to evaluate the types of actions taken on our site and to improve our page on the basis of these findings. The legal basis for this processing is Art. 6 para. 1 lit. f EU GDPR. More information on Facebook page insights is available here.

In running our Facebook page, we have concluded an agreement with Facebook on data processing as a joint controller, and this agreement sets out the distribution of data protection obligations between us and Facebook. Details of the agreement concluded between us and Facebook can be found here.