Privacy Policy

Last updated 01/10/2026

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and what to do if you have a complaint.

This privacy policy does not apply to any third party websites that may have links to our own website.

1 Who are we and what do we do?

1.1 The Nova Ripples Group comprises a number of separate legal entities providing software, platforms, digital products and other services. Details of the companies within our Group can be found at novaripples.com.

1.2 This website is operated by Discover your PULSE Ltd, incorporated and registered in England and Wales under company number 17190330, whose registered office is at G8 Lynch Lane Offices, Lynch Lane, Weymouth, Dorset, England, DT4 9DN. Discover your Pulse Ltd trades as Discover your PULSE and is part of the Nova Ripples Group.

1.3 This Privacy Policy is issued on behalf of the Nova Ripples Group and is intended to apply across our Group where relevant. The Group Company responsible for your personal data will depend on the website, product, service or other activity through which your personal data is collected.

1.4 We will identify the relevant Group Company where appropriate, including when you purchase, register for or use a particular product or service.

1.5 In this Privacy Policy, references to “we”, “us” or “our” mean the relevant Group Company responsible for the processing activity described.

1.6 We collect, use and are responsible for certain personal data about you. When we do so, we must comply with the UK General Data Protection Regulation (UK GDPR) and other applicable data protection laws.

1.7 The age requirements applicable to each product or service will be identified in the relevant terms, product information or other notice provided to you.

1.8 Occasionally, a Group Company may use photographs or other information relating to children as part of its activities. Where this occurs, the relevant Group Company will ensure that it has an appropriate lawful basis and any permissions required by law.

2 Terminology

It would be helpful to explain some key terms used in this policy:

We, us, our	The relevant Group Company responsible for the processing activity described in this Privacy Policy.
Group / Nova Ripples Group	Nova Ripples Ltd and the other companies within the Nova Ripples Group identified at novaripples.com from time to time.
Group Company	Any company within the Nova Ripples Group.
Personal data	Any information relating to an identified or identifiable individual
Special category personal data	Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership Genetic data Biometric data (where used for identification purposes) Data concerning health, sex life or sexual orientation
Data subject	The individual who the personal data relates to As the context dictates, our customers and individuals associated with them, contacts, suppliers and any individuals whose personal data we receive in the course of providing our services

3 Personal data we collect

3.1 The personal data we collect depends on how you interact with us and the particular products or services you use. Depending on the circumstances, we may collect or use some of the following personal data:

your name and contact information, including email address and telephone number and company or organisation details;
your address, and property address;
Contact details and addresses of our customers and, where relevant to the services we provide, their own customers, users or other contacts;
information to enable us to check and verify your identity, eg your date of birth or passport details;
your gender and pronoun preferences, if you choose to give these to us;
occupation or job title;
location information, including information you choose to provide and approximate location derived from technical information where applicable;
your billing information, transaction and payment details (including card or bank information for transfers and direct debits);
your contact history, purchase and services history;
information to enable us to undertake credit or other financial checks on you;
information about how you interact with and use our website, products and services;
audio recordings, eg calls;
video recordings, eg of virtual meetings;
your responses to surveys, competitions and promotions;
registering for any events or activities that we are organising;
submitting CVs or work history information to us for recruitment purposes;
contacting us for further information;
providing us with business cards or other contact information.

3.2 The main purpose of collecting and using this information is to provide our software platform and other products and services to our customers. However, we may also collect and use the above information for the purposes set out in section 5.3 below.

3.3 If you do not provide personal data we ask for, it may delay or prevent us from providing our services to you.

4 How your personal data is collected

4.1 We collect most of the above information from you directly.

4.2 However, we may also collect information:

from publicly accessible sources, Companies House or HM Land Registry;
directly from a third party, eg credit reference agencies;
from a third party with your consent, eg your bank or building society, another financial institution or advisor, or from credit referencing agencies
via our website. We use cookies and similar technologies on our website (for more information on cookies, please see our cookie policy) below;
from our customers, employers, organisations or other users who provide your details to us, for example where they invite you to access or use one of our products or services;
via our security, information technology (IT) systems, eg:
- from door entry systems and reception logs;
- through automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems.

5 How and why we use personal data

5.1 Under data protection law, we can only use your personal data if we have a proper reason, eg:

you have given consent—where we need your consent, we will ask for it separately of this privacy policy and you can withdraw consent at any time;
to comply with our legal and regulatory obligations;
to fulfil our contract with you or take steps at your request before entering into a contract; or
for our legitimate interests or those of a third party.

5.2 A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. You have the right to object to processing based on legitimate interests. We must then stop the processing unless we can demonstrate compelling legitimate grounds which override your interests, rights and freedoms or the processing is required to establish, exercise or defend legal claims.

5.3 The table below explains what we use your personal data for and why.

What we use your personal data for	Our reasons
Creating and managing your account with us	To perform our contract with you or to take steps at your request before entering into a contract; and, where appropriate, for our legitimate interests in administering account access and security.
Providing our software and platform products and services to you	To perform our contract with you or to take steps at your request before entering into a contract
Preventing and detecting fraud against you or us	For our and/or your legitimate interests, ie to minimise fraud that could be damaging for you and/or us
To check whether there is any conflict of interest between us and you and/or between you and another customer	To comply with our legal and regulatory obligations
Conducting checks to identify our customers and verify their identity Screening for financial and other sanctions or embargoes Other activities necessary to comply with legal and regulatory obligations that apply to our business, eg under health and safety law	Depending on the circumstances: —to comply with our legal and regulatory obligations —for our legitimate interests
To enforce legal rights or defend or take legal proceedings	Depending on the circumstances: —to comply with our legal and regulatory obligations —for our legitimate interests, or those of a third party
Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies	Depending on the circumstances: —to comply with our legal and regulatory obligations —for our legitimate interests
Ensuring internal business policies are complied with, eg policies covering security and internet use	For our legitimate interests, ie to make sure we are following our own internal procedures so we can deliver the best service to our customers
Operational reasons, such as improving efficiency, training and quality control	For our legitimate interests, ie to be as efficient as we can so we can deliver the best service to our customers at the best price
Ensuring the confidentiality of commercially sensitive information	Depending on the circumstances: —for our legitimate interests, ie to protect trade secrets and other commercially valuable information —to comply with our legal and regulatory obligations
Statistical analysis to help us manage our business, eg in relation to our financial performance, customer base, services range or other efficiency measures	For our legitimate interests, ie to be as efficient as we can so we can deliver the best service to our customers at the best price
Protecting the security of systems and data used to provide services, prevent unauthorised access and changes to our systems	Depending on the circumstances: —for our legitimate interests, ie to prevent and detect criminal activity that could be damaging for you and/or us —to comply with our legal and regulatory obligations
Updating and enhancing customer records	Depending on the circumstances: —to fulfil our contract with you or to take steps at your request before entering into a contract —to comply with our legal and regulatory obligations —for our legitimate interests, eg making sure we can keep in touch with our customers about existing and new services
Statutory reasons	To comply with our legal and regulatory obligations
Ensuring safe working practices, staff administration and assessments	Depending on the circumstances: —to comply with our legal and regulatory obligations —for our legitimate interests, eg to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
Providing information updates and/or marketing our services and those of selected third parties to existing and former customers and third parties	Depending on the circumstances: —for our legitimate interests, ie to promote our business —consent (which you can withdraw at any time)
Credit reference checks via external credit reference agencies	For our legitimate interests, ie to ensure our customers are likely to be able to pay for our services
Dealing with complaints or claims	Depending on the circumstances: —to comply with our legal and regulatory obligations —for our or your legitimate interests, eg to make sure any potential claim is reported to our insurer
Customising our website and its content to your particular preferences based on a record of your selected preferences or on your use of our website	Depending on the circumstances: —your consent as gathered by the separate cookies tool on our website—see ‘Cookies and other tracking technologies’ below —where we are not required to obtain your consent and do not do so, for our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price If you have provided such a consent you may withdraw it at any time by contacting us (this will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn)
Retaining and evaluating information on your recent visits to our website and how you move around different sections of our website for analytics purposes to understand how people use our website so that we can make it more intuitive or to check our website is working as intended	Depending on the circumstances: —your consent as gathered by the separate cookies tool on our website—see ‘Cookies’ below —where we are not required to obtain your consent and do not do so, for our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price If you have provided such a consent you may withdraw it at any time by contacting us (this will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn)
External audits and quality checks, eg for ISO or Investors in People accreditation and the audit of our accounts to the extent not covered by ‘activities necessary to comply with legal and regulatory obligations’ above	Depending on the circumstances: —for our legitimate interests, ie to achieve and maintain relevant accreditations so we can demonstrate we operate at the highest standards —to comply with our legal and regulatory obligations
Sharing your personal data with members of our group or affiliated companies who have the same ownership of our company. Third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale or in the event of our insolvency In such cases information will be anonymised where possible and only shared where necessary	Depending on the circumstances: —to comply with our legal and regulatory obligations —in other cases, for our legitimate interests, ie to protect, realise or grow the value in our business and assets
Voluntarily sharing relevant personal data with public authorities, regulators or other bodies exercising official functions in response to written requests where we consider disclosure is necessary and appropriate	For a recognised legitimate interest, namely to respond to a request from another organisation that needs the personal data for the purposes of carrying out its task in the public interest or exercising its official authority

5.4 Where we process special category personal data (see section 2 ‘Terminology’), we will also ensure we are permitted to do so under data protection laws, for instance:

we have your explicit consent;
the processing is necessary to protect your (or someone else’s) vital interests where you are physically or legally incapable of giving consent;
the processing is necessary to establish, exercise or defend legal claims; or
the processing is necessary for reasons of substantial public interest.

6 Marketing

6.1 We may use your personal data to send you updates (eg by email, text message, telephone, post or social media channels) about our services, including exclusive offers, promotions or new services.

6.2 We have a legitimate interest in using your personal data for marketing purposes (see section 5 ‘How and why we use your personal data’). We may rely on our legitimate interests for marketing where permitted by law. Where consent is required, we will obtain your consent before sending you marketing communications.

6.3 In all cases, you have the right to opt out of receiving marketing communications at any time by:

contacting us at https://discoveryourpulse.com/
using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts.
By following the opt out instructions in any email.

6.4 Please note that you may opt out of receiving marketing emails but we may still need to contact you for the purposes of providing our services to you. Such as billing, account, legal or service messages.

6.5 We may ask you to confirm or update your marketing preferences if you ask us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

6.6 We will always treat your personal data with the utmost respect and never sell it to or share it with organisations outside the Nova Ripples Group solely for their own marketing purposes.

7 Who we share your personal data with

7.1 We routinely share personal data with:

companies within the Nova Ripples group who have the same ownership as our company;
third parties we use to help deliver our services, eg providers of our finance system, IT service providers including cloud service providers such as data storage platforms, shared service centres, technical support and financial institutions in connection with invoicing and payments;
companies providing services for money laundering checks and other crime prevention purposes and companies providing similar services, including financial institutions and credit reference agencies;
other third parties we use to help promote our business, eg marketing agencies;
third parties approved by you, eg social media sites you choose to link your account to or third party payment providers;
our banks;

7.2 We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We ensure all outsourcing providers operate under service agreements that are consistent with our legal obligations.

7.3 We or the third parties mentioned above may occasionally also share personal data with:

our and their external auditors, eg in relation to the audit of our or their accounts, in which case the recipient of the information will be bound by confidentiality obligations;
our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations;
law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations;
other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition or asset sale or in the event of our insolvency—usually, information will be anonymised but this may not always be possible and the recipient of any of your personal data will be bound by confidentiality obligations.

7.4 If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ at section 17).

8 AI Use

8.1 When we refer to AI Tools, we mean any form of artificial intelligence which we may use in order to provide our services to you. This may include machine learning, deep learning and other artificial intelligence technologies including statistical learning algorithms, models (including large language models), neural networks and other artificial intelligence tools or methodologies, all software implementations of any of the foregoing, and related hardware or equipment

8.2 Personal data may be contained within information submitted to or processed using our AI Tools. Depending on the circumstances, we may act as a controller or processor of that personal data. Where an AI supplier processes personal data on our behalf, it will act as a processor or sub-processor, as applicable. We have a signed agreement in place with each supplier/contractor to ensure that your personal data is protected. Users of our AI Tools know to process personal data in accordance with the UK GDPR.

8.3 We do not permit AI technology providers to use personal data submitted through our services to train, retrain or fine-tune their general-purpose AI models.

8.4 In most cases, we process your personal data using the AI Tools to improve the efficiency, quality, and speed of our business processes. A lot of these processes are already happening manually. Using AI Tools to automate these processes allows us to use resource where it is needed most.

8.5 Any supplier who has access to your data is assessed for compliance with Data Protection legislation before any information is processed by them.

8.6 We may use AI and other automated technologies to support or automate aspects of our services and business processes. We will not make decisions based solely on automated processing that produce legal effects or similarly significantly affect you unless this is permitted by applicable data protection law and appropriate safeguards are in place.

9 Where your personal data is held

9.1 Personal data may be held at our premises and those of our group companies, third party agencies, service providers, representatives and agents as described in section 7 ‘Who we share your personal data with’.

9.2 Some of these third parties may be based outside the UK. For more information, including on how we safeguard your personal data when this occurs, see section 11 ‘Transferring your personal data abroad’.

10 How long your personal data will be kept

10.1 We will not keep your personal data for longer than we need it for the purpose for which it was collected or as required by law.

10.2 The period for which we retain your personal data will depend on the relevant Group Company, the product or service concerned, the nature of the personal data and the purposes for which it is processed. We will retain personal data only for as long as reasonably necessary for those purposes, including to meet applicable legal, regulatory, accounting and reporting requirements.

10.3 Following the end of the relevant retention period, we will delete or anonymise your personal data.

10.4 Your personal information may be converted ('anonymised') into statistical or aggregated data in such a way that ensures that you cannot be identified from it. Anonymised data cannot, by definition, be linked back to you as an individual and may be used to conduct research and analysis, including the preparation of statistics for use in our reports.

10.5 If you would like further information about how long we keep your personal data, please contact us (see ‘How to contact us’ at section 17).

11 Transferring your personal data abroad

11.1 It is sometimes necessary for us to transfer your personal data to countries outside the UK. This may include countries which do not provide the same level of protection of personal data as the UK.

11.2 We will transfer your personal data outside the UK and EEA only where:

11.2.1 the UK government or European Commission has decided the recipient country ensures an adequate level of protection of personal data (known as an adequacy decision); or

11.2.2 there are appropriate safeguards in place (eg standard contractual data protection clauses published or approved by the relevant data protection regulator), together with enforceable rights and effective legal remedies for you; or

11.2.3 a specific exception applies under data protection law.

11.3 For more information please contact us (using the ‘How to contact us’ information at section 17).

12 Your rights

12.1 You have the following rights in relation to your personal data, which you can exercise free of charge. Your request will be handled by the Group Company acting as controller for the relevant processing:

Access	You have the right to ask us for copies of your personal data. You can request other information such as where we get personal data from and who we share personal data with. There are some exemptions which means you may not receive all the information you ask for.
Rectification	You have the right to ask us to correct personal data you think is inaccurate or complete personal data you think is incomplete.
Erasure (also known as the right to be forgotten)	You have the right to ask us to delete your personal data—in certain situations
Restriction of processing	You have the right to ask us to limit how we use your personal data—in certain situations, eg if you contest the accuracy of the data
Data portability	You have the right to ask that we transfer the personal data you gave us to another organisation or to you—in certain situations
To object	You have the right to object: —at any time to your personal data being processed for direct marketing (including profiling); —in certain other situations to our continued processing of your personal data, eg processing carried out for our legitimate interests unless we demonstrate compelling legitimate grounds for the processing which override your interests or for establishing, exercising or defending legal claims
Not to be subject to automated individual decision making	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
The right to withdraw consent	When we use your consent as our lawful basis, you have the right to withdraw that consent at any time. You may withdraw consents by contacting us – our details are at the bottom of this policy. Withdrawing consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn

12.2 If you make a request, we must respond to you without undue delay and in any event within one month.

12.3 If you would like to exercise any of those rights, please:

email, call or write to us—see section 17: ‘How to contact us’; and
provide enough information to identify yourself (eg your full name, address and customer or matter reference number) and any additional identity information we may reasonably request from you;

12.3.1 let us know what right you want to exercise and the information to which your request relates.

13 Keeping your personal data secure

13.1 We have implemented appropriate technical and organisational measures to keep your personal data confidential and secure from unauthorised access, use and disclosure. We limit access to your personal data to those who have a genuine business need to access it. Those processing your personal data will do so only in an authorised manner and are subject to a duty of confidentiality.

13.2 We require our business partners, suppliers and other third parties to implement appropriate security measures to protect personal data from unauthorised access, use and disclosure.

13.3 We also have procedures to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are required to do so.

14 How to complain

14.1 Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

14.2 You may also have the right to lodge a complaint with the Information Commissioner’s Office (the UK data protection regulator, also known as the ICO) and/or the relevant supervisory authority in your jurisdiction.

14.3 The contact details for the ICO are:

Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

Helpline number: 0303 123 1113

Website: https://www.ico.org.uk/make-a-complaint

14.4 Please contact us if you would like further information

15 Changes to this privacy policy

15.1 This privacy policy was published on 01/10/2026 and last updated on 01/10/2026.

15.2 We may change this privacy policy from time to time. When we do, we will publish the updated version on our website and draw your attention to any material changes.

16 Updating your personal data

We take reasonable steps to ensure your personal data remains accurate and up to date. To help us with this, please let us know if any of the personal data you have provided to us has changed, eg your surname or address—see below ‘How to contact us’.

17 How to contact us

17.1 Individuals in the UK

You can contact us by email if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

If you have queries about how we handle your data, please contact our team by:

Email: info@novaripples.com

18 Do you need extra help?

If you would like this policy in another format (for example audio, large print, braille) please contact us (see ‘How to contact us’ above).