Privacy Policy
This policy explains what personal data Pulse Call collects when you use this website or apply for a role, why we need it, who else sees it, how long we keep it and what you can ask us to do. It applies to every page, country section and language version of the site.
We collect only what you send us — your name, phone number and language level, plus anything you choose to add. We use it to consider you for a role. We do not sell it, do not use it for advertising, and we run no analytics or tracking on this site. The tests you can take here never leave your browser. You can ask us to delete everything at any time by writing to hr@pulse-call.com.
1. Who we are
Pulse Call is the recruitment brand of the company below, which is the controller of your personal data under the UK GDPR and, where you are in the European Union, under the EU GDPR.
| Legal entity | SEAWAY DRAGON LP |
| Registration number | LP020855 |
| Date of registration | 17 February 2020 |
| Country of registration | United Kingdom |
| Registered office | Suite 6032, 128 Aldersgate Street, Barbican, London, England, EC1A 4AE |
| Website | pulse-call.com |
| Contact for data matters | hr@pulse-call.com |
| Data Protection Officer | Not appointed. We have assessed that our processing does not meet the criteria in Article 37, because it involves neither large-scale monitoring nor large-scale special category data. Data protection questions go to the address above |
2. What this policy covers
It covers personal data processed through pulse-call.com, including every country section and language version, and any application you send us through the site, by email or by telephone. It does not cover:
- third-party websites and services we link to, which have their own policies — including WhatsApp, Telegram and Facebook;
- processing of employee data once you have been hired, which is covered by separate employment documentation;
- conversations you start with us through channels outside the site, although the same principles apply to what we then do with the data.
The operational detail behind this policy — lawful basis assessments, the full retention schedule, processor requirements, breach and request procedures — is published in our Personal Data Processing Policy.
3. What data we collect
| Category | Data | Source | Required? |
|---|---|---|---|
| Identity | Your name | You | Yes |
| Contact | Telephone number; the messenger or email account you write from | You | Yes |
| Professional | Language level; any experience, availability or preferred contact time you choose to add in the free-text comment | You | Language level yes, free text optional |
| Referral | Name and phone number of the referring person; phone number of the person referred | The person making the referral | Only if the referral programme is used |
| Recruitment | Notes our recruiters make during the conversation, and the outcome | Created by us | Arises after you apply |
| Technical | IP address, browser and device type, time of access and page requested — in the server logs of our hosting provider | Collected automatically | Created when you visit |
Giving us this data is not a legal requirement. It is simply the information we need in order to consider you; without a name and a contact number we cannot process an application, and that is the only consequence of not providing it.
We do not collect special category data — health, disability, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data, sex life or sexual orientation — and we do not ask about criminal records. We also do not ask for a photograph, date of birth, marital status or your current or previous pay. Please do not put any of this in the free-text field. If it reaches us anyway, we delete it without taking it into account.
4. How your application reaches us
The site has no server-side form. When you fill in the application block and press the button, your browser opens WhatsApp with a message prepared from what you entered.
- Nothing reaches us until you press send in WhatsApp. Until then the details stay on your device, and you can edit or discard them.
- Once sent, the message travels through WhatsApp, a service of Meta Platforms Ireland Limited. WhatsApp is not acting for us when it carries your message: it is an independent controller for its own service and processes your phone number and the fact of the exchange under its own privacy policy. Message contents are end-to-end encrypted between you and us.
- If you would rather not use WhatsApp, write to hr@pulse-call.com or call the number published on the site. Applications sent that way are treated identically, and this is the route to choose if you do not want a messaging platform involved.
- Once your message arrives, we copy the details we need into our recruitment record and handle them as described below.
5. Why we use your data, and on what basis
| What we do | Why | Lawful basis |
|---|---|---|
| Contact you, talk to you, assess your application, tell you the outcome | To consider you for a role | Art. 6(1)(f) — our legitimate interest in filling roles with suitable people, which runs alongside your own interest in being considered |
| Prepare a contract and onboarding once you accept an offer | To hire you | Art. 6(1)(b) — steps taken at your request before entering into a contract |
| Keep your details after an unsuccessful outcome, to tell you about later roles | To offer you other roles | Art. 6(1)(a) — your separate consent, which you can withdraw at any time |
| Run the referral programme and pay bonuses | To source candidates through people who already know us | Art. 6(1)(f) — legitimate interest, limited to a single contact attempt |
| Keep server logs, filter spam and investigate misuse | To keep the site available and secure | Art. 6(1)(f) — legitimate interest in protecting the service |
| Keep records of payments made | Accounting and tax | Art. 6(1)(c) — legal obligation |
| Deal with a dispute or a claim | To defend our position | Art. 6(1)(f) — legitimate interest in establishing or defending legal claims |
Where we rely on legitimate interests, we first weigh those interests against your rights and record the assessment; you can ask for a copy, and you can object at any time (section 12). We do not use consent as a substitute where you would have no real choice, and we do not use your data for advertising or profiling.
We tell you the pay or pay range for the role, and the criteria behind it, before your first interview, and we do not ask what you earn or have earned. This follows Directive (EU) 2023/970 on pay transparency, and we apply it everywhere we recruit. If nobody has given you a figure, ask us for it.
6. If you were referred, or refer someone
Under our "refer a friend" programme we sometimes receive a person's number from someone else rather than from that person.
If you refer someone
By giving us another person's telephone number you confirm that you told them and that they agreed to be contacted. You are responsible if that permission was not obtained. We keep your own name, number and the record of any bonus.
If someone referred you
When we first contact you, we tell you — as Article 14 requires — who we are and how to reach us, that we got your number through a referral and from whom if you ask, why we are calling and on what basis, how long we would keep your data, and where to read this policy. Our legitimate interest is limited to that one contact. If you ask us to stop, we delete your number immediately and do not call again; the only thing we may keep is a note that you do not want to be contacted, so that we can honour it.
7. Cookies and your device
This site stores one thing on your device: pc_lang, a cookie and a matching local-storage entry that remember which language you chose from the language switcher. It is written only when you make that choice, contains nothing but the choice, and expires after a year.
There are no analytics, advertising, social or fingerprinting technologies on this site, and nothing is shared with third parties for those purposes. Because the language preference exists solely to provide something you explicitly asked for, it is exempt from the consent requirement under PECR in the UK and under Article 5(3) of the ePrivacy Directive in the EU — which is why you see no cookie banner. Clearing your browser storage removes it.
If we ever add anything non-essential, we will ask for your consent first, everywhere — including in the UK, where the law has since February 2026 allowed some purposes without consent — and we will update this section before doing so.
8. Tests on this site
The five tests — the earnings estimate, the myths quiz, the sales knowledge test, the call simulator and the working-style questionnaire — run entirely in your browser. Your answers and results are not sent to us, not stored on our servers, and not linked to any application. Closing the page discards them. They require no registration and ask for no contact details, and they play no part in whether we hire you.
9. Who else sees your data
We do not sell your personal data and do not share it for third-party advertising. Access is limited to:
| Recipient | Role | What they get |
|---|---|---|
| Our HR staff and hiring managers | Internal access | Your application and the notes, only as needed to make a decision |
| WhatsApp (Meta Platforms Ireland Limited), Telegram — if you use them to contact us | Independent controllers for their own service | Your phone number and the fact and metadata of the exchange, under their own terms. Message content is end-to-end encrypted |
| Our CRM provider | Processor | Contact and professional data, notes |
| Our hosting provider | Processor | Technical data in server logs |
| Accountants, auditors, legal advisers | Processor or separate controller, depending on the engagement | Only what a specific matter requires |
| Public authorities and courts | Separate controllers | Only in response to a lawful, reasoned request |
Every processor works under a written contract meeting Article 28, which obliges them to act only on our documented instructions and to protect the data. We name the providers we currently use to anyone who asks — write to hr@pulse-call.com.
10. International transfers
We recruit in more than ten countries, so data moves between the United Kingdom and the European Economic Area. That flow needs no extra safeguard: the European Commission renewed its adequacy decisions for the UK on 19 December 2025, running to 27 December 2031, and the UK recognises the EEA in the same way.
If data has to go anywhere else, we use one of the mechanisms in Chapter V: an adequacy decision, the EU Standard Contractual Clauses, the UK International Data Transfer Agreement or Addendum together with a transfer risk assessment, or another appropriate safeguard. You can ask for a copy of the safeguards we rely on by writing to hr@pulse-call.com.
A message you send through a messaging platform may be routed through that platform's own infrastructure outside the UK and the EEA, under its arrangements rather than ours. Using email or a phone call avoids that.
11. How long we keep it
| Data | Period | Why |
|---|---|---|
| Application of a candidate we did not hire | 6 months from the last contact | The period in which a hiring decision might be challenged |
| Application kept with your consent for future roles | 1 year, or until you withdraw consent | Your consent |
| Messenger thread containing your application | 6 months, or until the record is deleted if sooner | It duplicates the record and must not outlive it |
| Number of a referred person who declines contact | Deleted at once | We only keep a suppression note if you ask not to be contacted again |
| Data of a hired candidate | Moves into employment records; the period is set by employment and tax law | Legal obligation |
| Referral and payment records | 6 years | UK accounting and tax record-keeping |
| Server and access logs | Up to 12 months | Security and incident investigation |
When a period ends, the data is deleted or anonymised so that it can no longer be linked to you.
12. Your rights
| Right | What it means | Article |
|---|---|---|
| Access | Find out whether we process your data and get a copy of it | 15 |
| Rectification | Have inaccurate data corrected or incomplete data completed | 16 |
| Erasure | Have your data deleted where there is no continuing reason to keep it | 17 |
| Restriction | Have processing paused while a dispute about accuracy or grounds is resolved | 18 |
| Portability | Receive the data you gave us in a machine-readable form, or have it sent on | 20 |
| Object | Object to processing based on legitimate interests, including the referral contact | 21 |
| Withdraw consent | Withdraw consent at any time, without affecting what was lawful beforehand | 7(3) |
| Not be subject to automated decisions | See section 16 — we do not take them | 22 (EU) / 22A–22D (UK) |
To exercise any of them, write to hr@pulse-call.com. No particular form or wording is needed — a plain message is enough, and a WhatsApp message counts.
- We reply within one month. If a request is complex or there are several, we may extend by two further months and will tell you why within the first month.
- There is no charge. We can only refuse, or charge a fee, if a request is manifestly unfounded or excessive, and we would explain why and tell you how to complain.
- We ask for proof of identity only where there is genuine doubt, and then only for the least we need.
- If a request under the UK GDPR is unclear, we may ask you to clarify it, which pauses the time limit until you reply — a rule introduced by the Data (Use and Access) Act 2025. We will say plainly when that has happened.
13. Complaints
If you think we have mishandled your data, you can complain to us directly — a statutory right in the United Kingdom since 19 June 2026 under section 103 of the Data (Use and Access) Act 2025. We give everyone the same route, wherever they live.
How to complain: email hr@pulse-call.com with "Data protection complaint" in the subject line, or write to us at the registered office in section 1. Tell us what happened and what you would like us to do. No form is required.
What happens next: we acknowledge your complaint within 30 days of receiving it, investigate, and tell you the outcome and our reasons without undue delay — we aim for 30 days and will tell you if it will take longer.
You do not have to come to us first. You can complain to a supervisory authority at any time:
- United Kingdom: the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF — ico.org.uk, helpline 0303 123 1113.
- European Union: the data protection authority of the country where you live or work, or where the problem arose. The list is published by the European Data Protection Board.
You also have the right to an effective judicial remedy against us or against a supervisory authority.
14. Security
The whole site is served over HTTPS. Access to candidate data is limited to named individuals who need it, protected by unique credentials and multi-factor authentication where the system supports it, and removed as soon as someone's role changes or ends. Everyone with access is under a written confidentiality obligation, and candidate data is not copied into personal spreadsheets, private messengers or personal cloud accounts. We review access rights regularly and review every incident after it is closed.
If a breach happens that is likely to put your rights at high risk, we will tell you without undue delay and explain what happened and what we have done. Breaches that meet the threshold are reported to the relevant supervisory authority within 72 hours.
15. Children
The site is for adults. We do not knowingly collect data from anyone under 18. If we learn that we have, we delete it. If you believe a minor has sent us data, write to hr@pulse-call.com.
16. Automated decisions and AI
We do not take decisions about you based solely on automated processing, and we do not profile candidates. Every decision — to call you, to interview you, to make an offer or not — is made by a person. The tests on this site are scored in your own browser and are never seen by us. We use no AI system in recruitment, and the site has no chatbot or AI assistant.
If that ever changes, we will update this policy and tell you before it applies to you, and you will have the safeguards the law requires: information about the decision, the ability to make representations, human intervention and the right to contest the outcome.
17. Changes to this policy
We may update this policy. The version number and date at the top show which version applies. If a change materially affects how we use data you have already given us, we will tell you directly where we can reach you.
| Version | Date | What changed |
|---|---|---|
| 2.0 | 19 August 2026 | Rewritten to describe how the site actually works: applications sent through WhatsApp rather than a server-side form, messaging platforms named as independent controllers, tests confirmed as browser-only, cookies section corrected to the single language preference and the removal of the cookie-banner text. Lawful basis for assessing applications changed from Article 6(1)(b) to Article 6(1)(f). Added the complaints route under section 103 of the Data (Use and Access) Act 2025, the clarification pause for UK access requests, the renewed UK adequacy decisions, and the pay transparency commitment. |
| 1.0 | 19 August 2026 | First published version. |