Effective Date: May 11, 2026

1. Identity of the Data Controller 

Imppulsor Limited is a company incorporated under the laws of Ireland and acts as the data controller of the personal data collected through its website, forms, contact channels, and associated digital tools. 

2. Scope of This Policy 

This Privacy Policy explains how Imppulsor Limited collects, uses, retains, discloses, and protects personal data when a person: 

a) visits the website www.imppulsor.com;
b) completes contact, inquiry, or referral forms;
c) requests information about diagnostics, services, or consulting solutions;
d) communicates with Imppulsor by email, chat, or other digital means;
e) interacts with site features, including analytics, usage measurement, and chat tools; or
f) maintains a pre-contractual, contractual, or professional relationship with Imppulsor in connection with its services. 

This policy does not govern the processing of data carried out by third-party websites or services linked from this site, which are governed by their own policies. 

3. Types of Personal Data We May Process 

Imppulsor may process, as applicable, the following categories of data: 

a) Identification and Contact Data
First and last name, email address, telephone number, company, job title, country, and other information voluntarily provided by the user.
b) Professional and Commercial Data
Information related to the user’s organization, business needs, industry, stage of development, interest in consulting services, and any other information submitted in forms, meetings, messages, or business processes.
c) Browsing and Site Usage Data
IP address, online identifiers, browser information, operating system, language, time zone, device type, pages visited, browsing times, entry and exit pages, browsing behavior, and other technical or analytical data associated with use of the site and cookies or similar technologies.
d) Digital Interaction Data
Information generated by interactions with chat tools, forms, browsing events, scrolling, clicks, selected elements, digital experience metrics, optimization testing, heat maps, or other site measurement and improvement tools.
e) Content of Communications
Messages sent by email, forms, chat, or any other channel provided by Imppulsor. 

Imppulsor does not deliberately request sensitive personal data through its website. If a person voluntarily submits information of that nature where it is not necessary, Imppulsor may delete it or limit its processing. 

4. How We Obtain Data 

Personal data may be obtained: 

a) directly from the data subject;
b) automatically when browsing the site and using its features;
c) through technological tools integrated into the site;
d) from legitimate business referrals, when a person is referred to Imppulsor by a third party; or
e) in the context of a pre-contractual or contractual relationship. 

5. Purposes of Processing 

Imppulsor processes personal data for the following purposes: 

a) responding to inquiries, requests, and messages received through the site or by digital means;
b) managing meetings, proposals, diagnostics, referrals, and business opportunities;
c) providing consulting services and managing relationships with clients, leads, business contacts, or prospects;
d) operating, administering, protecting, and improving the website and its user experience;
e) analyzing site performance, understanding user interaction, and optimizing content, structure, and usability;
f) enabling and managing chat features, digital support, and follow-up on user-requested interactions;
g) maintaining the security of the digital environment, preventing fraud, abuse, unauthorized access, or technical incidents;
h) complying with legal, regulatory, tax, accounting, or legal-defense obligations; and
i) sending professional or commercial communications where there is a lawful basis to do so under applicable law. 

6. Lawful Basis for Processing 

Imppulsor will process personal data on one or more of the following lawful bases, as applicable: 

a) pre-contractual measures, when the person requests information, a proposal, a meeting, or the initiation of a business relationship;
b) performance of a contract, when processing is necessary to provide services or manage a contractual relationship;
c) compliance with legal obligations, when Imppulsor must retain or disclose information as required by law;
d) legitimate interest, to operate the site, protect its security, manage B2B professional relationships, respond to inquiries, improve services, and defend rights, provided that such interest is not overridden by the rights and freedoms of the data subject;
e) consent, where required by applicable law, particularly for cookies that are not strictly necessary, non-exempt analytics or tracking tools, or certain electronic communications. 

7. Cookies and Similar Technologies 

The website uses cookies and similar technologies for technical, functional, analytical, and digital-experience-improvement purposes. Cookies that are not strictly necessary will only be activated where the user has given valid consent through the site’s cookie preference tool. 

For detailed information about the cookies used, categories, purposes, duration, and how to manage preferences, please consult Imppulsor’s Cookie Policy. 

8. Third-Party Tools Used on the Site 

Depending on the site’s effective configuration, Imppulsor may use third-party tools for specific support and analytics functions, including: 

a) Zoho SalesIQ, to enable chat features, visitor interaction, and digital support management;
b) Zoho PageSense, to measure site usage, analyze behavior, improve digital experience, evaluate interaction, and optimize performance. 

These tools may process technical and browsing data in accordance with the site’s configuration, the user’s preferences, and the applicable lawful basis. 

9. Recipients and Categories of Recipients 

Imppulsor may disclose or make personal data available to: 

a) technology, hosting, support, security, email, analytics, CRM, or digital infrastructure providers;
b) providers of chat, measurement, and site-improvement tools;
c) professional advisors, including attorneys, auditors, or consultants, where necessary;
d) financial, administrative, or accounting entities, where applicable;
e) public authorities, courts, regulators, or competent bodies, where there is a legal obligation or valid request;
f) third parties involved in a corporate transaction, reorganization, or due diligence process, under appropriate guarantees of confidentiality and lawfulness. 

Imppulsor does not sell the personal data of site visitors. 

10. International Data Transfers 

Given Imppulsor’s international character and use of global technology providers, some personal data may be processed in or accessed from outside the European Economic Area. 

Where international data transfers occur, Imppulsor will adopt the legally required safeguards under applicable law, including, where appropriate, adequacy decisions, standard contractual clauses, additional contractual measures, or equivalent mechanisms. 

In territories where Imppulsor conducts business outside Ireland or the European Union, this policy will be interpreted and applied together with the specific obligations enforceable in each jurisdiction. 

11. Data Retention 

Imppulsor will retain personal data only for as long as necessary to fulfill the purposes for which it was collected and, thereafter, for the retention periods required by applicable law or necessary for the establishment, exercise, or defense of claims. 

As a general rule: 

a) contact and business-inquiry data will be retained as long as necessary to manage the interaction and, thereafter, for a reasonable period of business follow-up or legal defense;
b) contractual data will be retained for the duration of the contractual relationship and subsequent legal periods;
c) data associated with cookies, analytics, or preferences will be retained according to the duration of each technology and the applicable configuration;
d) consent records will be retained for as long as necessary to demonstrate compliance. 

12. Data Subject Rights 

Where applicable, the data subject may exercise the rights recognized under data protection law, including: 

a) right of access;
b) right to rectification;
c) right to erasure;
d) right to object;
e) right to restriction of processing;
f) right to data portability, where applicable;
g) right to withdraw consent at any time, without affecting the lawfulness of processing prior to its withdrawal; and
h) right not to be subject to decisions based solely on automated processing, where legally applicable. 

Requests may be sent to: data protection@imppulsor.com 

Imppulsor may require reasonable information to verify the requester’s identity before responding. 

13. Complaints to the Competent Authority 

If a person considers that the processing of his or her personal data infringes applicable law, he or she may lodge a complaint with the competent supervisory authority. In the case of Imppulsor, the principal authority of reference is the Irish data protection authority, without prejudice to the data subject’s right to contact the authority corresponding to his or her place of residence or under applicable law. 

14. Minors 

The Imppulsor website and services are intended for professional and business relationships. They are not deliberately directed to minors. If Imppulsor detects that it has received personal data of a minor without sufficient lawful basis, it may delete such data or take measures to limit its processing. 

15. Security 

Imppulsor applies reasonable and proportionate technical, organizational, and security measures to protect personal data against loss, alteration, unauthorized access, improper disclosure, or destruction, taking into account the nature of the data and the risks of the processing. 

16. Changes to This Policy 

Imppulsor may modify this Privacy Policy to adapt it to legal, regulatory, technological, operational, or business changes. The current version will be the version published on the website at any given time.