Bluck Szolgáltató és Kereskedelmi Korlátolt Felelősségű Társaság
PRIVACY POLICY
Last updated on June 17, 2025
1. INTRODUCTION
Bluck Szolgáltató és Kereskedelmi Korlátolt Felelősségű Társaság, a company duly incorporated, organized and existing under the laws of Hungary, Hungarian company number: 01-09-414868, having its registered address at Futó utca 37-45, Magyarország, Budapest, 1082, Hungary (hereinafter referred to as "BLUCK" or “Company”).
BLUCK respects your privacy and is committed to protect your personal data.
This Privacy Policy informs you about how we care about your personal information and tell you about your privacy rights and how the law protects you, when you:
·   Visit our mobile application available at: http://carepulse.co.il// or its subdomains (collectively “Website”);
·   Complete surveys and subscribe for the newsletters, communicate with our team ("Voluntary provision of data"); and/or
·   Use our Services.
We provide Services through the use of our Website, progressive web and mobile applications.
BLUCK is the data controller responsible for the collection and processing of your personal data in accordance with the EU General Data Protection Regulation (“GDPR”).
2. PURPOSE AND PRINCIPLES OF THIS PRIVACY POLICY
This Privacy Policy aims to give you information on how BLUCK collects and processes your personal data through your use of the Website and/or Services and/or Voluntary provision of data, including any data:
1. you may provide; and/or
2. we may collect through your use of the Website and/or the Services; and/or
3. when you sign up to our newsletters, complete our surveys and/or communicate with our support service.
It is important that you read this Privacy Policy, so that you are fully aware of how and why we use your data.
This Privacy Policy is in addition to the other policies and is not intended to cancel them. BLUCK is responsible for your personal data (collectively referred to as "we", "us" or "our" in this privacy policy).
In any its activities regarding processing Personal Data (Personal Information) of its Users, BLUCK will comply with the following principles:
· Lawfulness: Any Processing of Personal Data carried out by BLUCK as a Controller has a legal basis under the GDPR, as well as compliant with the requirements of the GDPR and other applicable AML/CFT laws (see, in particular, Articles 6, 7, 8, and 9 of the GDPR), and not involve any otherwise unlawful processing or use of personal data.
· Fairness: Any Processing of Personal Data carried out by BLUCK as a Data Controller is fair towards the Users whose personal data are concerned, and avoid being unduly detrimental, unexpected, misleading, or deceptive.
· Transparency: BLUCK as a Data Controller ensures that processing of personal data is clear and transparent to Users and regulators.
· Purpose limitation: Personal data is collected by the BLUCK as a Data Controller for specified, explicit and legitimate purposes, which are determined at the time of the collection of the personal data, and not further processed in a manner that is incompatible with those purposes.
· Data minimisation: BLUCK as a Data Controller only collects and processes personal data that are adequate, relevant, and limited to what is necessary for the purposes for which they are processed.
· Accuracy: BLUCK as a Data Controller ensures Personal Data (Personal Information) are accurate and, where necessary, kept up-to-date.
· Storage limitation: BLUCK as a Data Controller holds personal data, in a form which permits the identification of Users, for no longer than is necessary for the purposes for which the personal data are processed.
· Integrity and confidentiality: Personal Data (Personal Information) is processed by BLUCK as a Data Controller only in a manner that ensures the appropriate level of security and confidentiality for the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction, or damage.
· Accountability: BLUCK as a Data Controller takes responsibility for, and will be able to demonstrate compliance with the other principles of data processing, specified herein.
In the case of any data processing activities regarding any AML/KYC procedures, the BLUCK’s AML/KYC Policy will be applicable mutatis mutandis.
3. CHANGES TO THE PRIVACY POLICY AND OUR DUTY TO INFORM YOU ABOUT THEM
We may update this Privacy Policy from time to time. We may update this Privacy Policy periodically to reflect changes in our data practices or legal requirements. The updated version will be indicated by the date of the last update above. If we make material changes to this Privacy Policy, we may notify you by posting a Policy on the website, or by sending a Policy directly to you (for example, by e-mail). We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information.
4. WHAT DATA WE COLLECT ABOUT YOU
In accordance with the Article 4(1) of the GDPR, personal data any information which are related to an identified or identifiable natural person (“data subject”). It does not include data whose identity has been deleted (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows.
The information you provide to us: This is your personal information that you provide to us by filling out forms and all KYC information. We may receive information from you by correspondence with you by mail, phone, e-mail, mobile application(s), and our website available at http://carepulse.co.il/. This includes personal data that you enter on our website, provide to us through Services or through Voluntary Provision of Data, or provide to us in any other way. You provide such information when you:
1) Use our Website and Services;
2) Fill out KYC forms and requests;
3) Subscribe to our newsletters;
4) Fill out a survey;
5) Participate in (sign up to) any contest, promotional activity, giveaway, events, education, career, partnership offers;
6) Communicate with our support service, give us feedback (for example, when you communicate with us by customer support form, e-mail, phone, mail or otherwise).
As a result of these actions, you can provide us with information such as:
1) Proof of identity in the form of a photo (which will be in the form of a "selfie" in an approved format);
2) Date and place of birth (if you are an individual);
3) Date and place of registration or registration (if you are a legal entity) (Please note: using http://carepulse.co.il/, you agree not to hide your real location. You agree not to use a vpn, proxy, tor browser or other methods of hiding your real location);
4) Primary citizenship;
5) Email address;
6) Residential address;
7) Confirmation of the current residential address or confirmation of the current address of a registered legal entity (for example, a bank statement, electricity or water bill issued within the last three months);
8) Phone number;
9) Other data, documents and/or information necessary for compliance with the applicable AML/CFT laws and regulations.
Data for KYC is provided by contractors providing services in the financial sector. All users are checked for compliance with AML/CFT. If you do not pass the AML/CFT check, you will be refused to work with http://carepulse.co.il/.
We may also collect technical data about your equipment, browser features, browsing actions and patterns. For example, like many websites, at the Website and Services we use "cookies" and other similar tools and identifiers for analytics and marketing (like web beacons and pixels), and we obtain certain types of information when you access our Website and/or our Services (access log records such as date, IP address, user agent). However, aggregated data is not considered personal data, as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.
We may also receive information about you from other sources (such as public databases, marketing partners and other third parties) and add it to our account information (this concerns technical data from the following parties: analytics providers such as Google; advertising networks; and search information providers).
In accordance with the GDPR, we will inform you about the source of information and the type of information we have collected about you within a reasonable period after obtaining the personal data, but at the latest within a month.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data), unless it is explicitly necessary for the Services we provide, and you have given your explicit consent. Nor do we collect any information about your criminal convictions and offences.
If we need to process special categories of personal data, we will provide you with a clear justification and obtain your explicit consent before processing such data in accordance with Article 9 of the GDPR.

5. LEGAL BASIS FOR USING YOUR PERSONAL DATA
We will use your personal data only in cases where it is permitted by law. In accordance with Article 6 of the GDPR, we will use your personal data if one of the following legal grounds applies:
1) Your consent: We may process your data when you consented for the use of such data by us.
2) Legitimate Interests: We may process your data where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override them. For instance, for provision of Website and Services to you, for the development of business, to procure compliance with our terms and policies. We can also conduct KYC of each user to counter money laundering and terrorist financing.
3) Legal obligation: Where we need to comply with a legal or regulatory obligation (for example, to comply with applicable law, governmental requests, a judicial proceeding, court order, legal process, enforcement requirements). We may also disclose your information where it is necessary to investigate, prevent or take action regarding potential or suspected fraud, illegal activities, situations involving potential threats to safety.
4) Performance of contract: Our processing is necessary for the performance of a contract to which you as a data subject is party or in order to take steps at your request prior to entering into a contract with us.
We are responsible for verifying your identity. For our internal purposes, we identify all persons (whether an individual or a legal entity) with whom we establish or intend to establish business relations with.
We undertake to take reasonable measures to verify the identity of the beneficial owners (UBO) of legal entity, including the main investors and/or controllers of the legal entity, or, if the legal entity is a fund, a party that acts as a fund manager.
Our Website uses technologies of our Third-Party Service Providers to help us recognize your device and understand how you use our Website so that we can improve our products and/or services to reflect your interests and serve you advertisements about our products and/or services that are likely to be of more interest to you.
We also utilize services, which may include the collection of hashed identifiers derived from email addresses for cross-device tracking and targeted advertising purposes. By using our services, you acknowledge and consent to this data processing. We may share data, such as hashed email derived from emails or other online identifiers collected on our site(s) with our advertising partners. This allows our partners to recognize and deliver you ads across devices and browsers.
6. PURPOSE OF COLLECTING AND PROCESSING YOUR PERSONAL DATA
We collect and process your personal data for the following purposes:
1) To comply with anti-money laundering and counter-terrorism financing regulations (“AML/CFT laws”);
2) To ensure the security and prevent fraud, unauthorized access, and other illegal activities;
3) To meet other legal and regulatory requirements applicable to our business;
4) To respond to requests from law enforcement and regulatory authorities;
5) To verify your identity and provide you with our Services;
6) To communicate with you about our Services;
7) To provide customer support and respond to your inquiries;
8) To monitor, analyse, and improve our Services and website performance;
9) To send you promotional materials and updates about our services, provided you have given us your consent to do so.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for a reason compatible with the original purpose.
If we need to use your personal data for a purpose not related to the purposes stipulated here, we will notify you and we will explain the legal basis which allows us to do so.
7. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in this Privacy Policy.
Business Transfers. Third Parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
Affiliates. We may share your information with our affiliates (including parties that we control, controlled by or under common control with us). We require all third parties to respect the security of your personal data and to treat it in accordance with the law and this Privacy Policy. We do not allow our third-party service providers to use your personal data for their own purposes, share it with third parties and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Third-Party Service Providers: We may share your personal data with third-party service providers who assist us in providing our Services. These third parties are contractually obligated to use your data solely for the purposes specified by us and to protect your personal data in accordance with this Privacy Policy and applicable data protection laws. We require all third-party service providers to implement appropriate technical and organizational measures to ensure the security and confidentiality of your personal data and to notify us immediately in case of any data breaches or security incidents. You have the right to obtain information regarding the third-party service providers with whom we share your personal data, as well as the specific data that these third parties process. For these purposes, please send your requests to our DPO to the following e-mail address: dpo@carepulse.co.il, and our DPO will provide you with all the necessary information in accordance with this Privacy Policy.

8. INTERNATIONAL TRANSFERS
Please note that your information may be transferred, stored and processed by us and by those third parties with whom we may share your information in various countries, including outside Hungary.
We will take all necessary measures to protect your personal information in accordance with this Privacy Policy and applicable laws and require all our contractors to follow the same rules when processing your personal data. Moreover, we also take into account the best industry standards for securing your data processing.
If we transfer your personal data outside the EU/EEA, Switzerland, or the UK, we ensure that appropriate safeguards are in place to protect your personal data. These safeguards will include:
1. Standard Contractual Clauses (SCCs): We use standard data protection clauses approved by the European Commission.
2. Adequacy Decisions: We transfer your data to countries that have been recognized by the European Commission as providing an adequate level of data protection.
9. DATA SECURITY
We have put in place appropriate technical and organizational security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.
In addition, we limit access to your personal data to those employees, agents, contractors and other third parties. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
However, please remember that the transmission of data over the Internet (including e-mail) is never completely secure. Therefore, while we use appropriate measures to try to protect your personal data, we cannot guarantee the security of the data transmitted to us or by us. You must access the Website and Services and/or otherwise transmit your data in a secure environment.
10. DATA RETENTION
We will only retain your personal data for as long as is necessary to achieve the purposes for which we collected it, unless a longer retention period is required or permitted by law (for example, any legal, accounting or reporting requirements).
When we do not have an ongoing legitimate business need to process your personal information, we will either delete it or anonymize it, or, if this is not possible (for example, if your data is stored in backup systems), we will securely store it until it is deleted.
If in some circumstances we anonymize your personal data (so that they can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice.
11. YOUR LEGAL RIGHTS
Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:
As a data subject under GDPR, you have the following rights:
1) Right to Access: You have the right to request access to your personal data.
2) Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data.
3) Right to Erasure: You have the right to request the deletion of your personal data under certain conditions.
4) Right to Restriction of Processing: You have the right to request the restriction of processing your personal data under certain conditions.
5) Right to Data Portability: You have the right to request the transfer of your personal data to another organization, or directly to you, under certain conditions.
6) Right to Object: You have the right to object to the processing of your personal data under certain conditions, including processing for direct marketing purposes.
7) Rights Related to Automated Decision-Making: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or significantly affects you.
We must respond to your request within 30 calendar days. In serious cases, we can extend that deadline, but in any case, we will notify you in advance. If you submitted a request to correct and have not received any response within the timeline, make sure you duly submitted your request. Please send all your requests to our DPO to the following e-mail address: dpo@carepulse.co.il.
If we are relying on your consent to process your personal data you have the right to withdraw your consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide you with certain services.
We will inform you about it when you withdraw your consent. Please note that under certain circumstances it may be lawful for us to continue processing your information even if you have withdrawn your consent if one of the other legal grounds applies. No fee usually required. You will not have to pay a fee to access your personal data (or to exercise any of the other rights).
If you believe that your data protection rights have been violated, you have the right to lodge a complaint with the Hungarian National Authority for Data Protection and Freedom of Information (Nemzeti Adatvédelmi és Információszabadság Hatóság). The contact details to the Office are as follows: 
Falk Miksa utca 9-11, H-1055 Budapest
Postal address: Falk Miksa utca 9-11, H-1055 Budapest, HUNGARY

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