Privacy Policy

This Privacy Notice describes how Pulse Software, Corp. (“Pulse”, “we”, “us”, “our”) collects, uses and discloses information about you when you use our website, applications, services, tools, and features, or otherwise interact with us (collectively, the “Services”). For the purposes of this Privacy Notice, “you” and “your” means you as the user of the Services.

Please read this Privacy Notice carefully. By using any of the Services, you agree to the collection, use, and disclosure of your information as described in this Privacy Notice. If you do not understand or agree to this Privacy Notice, please do not use or access the Services.

1. SCOPE AND APPLICABILITY OF PRIVACY NOTICE

For the purpose of applicable data privacy laws, we are the “data controller” with respect to information we collect about you as a representative of one of our enterprise customers or a website visitor. Our representative in the European Economic Area (“EEA”) is Sid Manchkanti, and can be contacted at sid@trypulse.ai. Our representative in the United Kingdom (“UK”) is Ritvik Pandey, and can be contacted at ritvik@trypulse.ai.

Please note that when we process personal information that may be contained in documents or other materials uploaded to the Services by our enterprise customers, we act as a “data processor” and process such information on behalf of our customers in accordance with the terms of our agreement with the relevant customer. Please visit the relevant customer’s privacy policy for more information. Depending on the service tier and administrative settings applicable to the relevant customer’s account, we may also use such information to improve and develop the Services.

2. CHANGES TO THIS PRIVACY NOTICE

We may modify this Privacy Notice from time to time, in which case we will update the “Last Updated” date at the top of this Privacy Notice. If we make material changes to how we use or disclose information we collect, we will use reasonable efforts to notify you (such as by emailing you at the last email address you provided us, by posting notice of such changes on the Services or by other means consistent with applicable law) and will take additional steps as required by applicable law. If you do not agree to any updates to this Privacy Notice, please do not continue using or accessing the Services.

3. COLLECTION AND USE OF INFORMATION

When you use or access the Services, we collect certain categories of information about you from a variety of sources. In addition to the specific uses discussed below, we may use this information to provide and improve the Services and to maintain our business relationship, as a matter of our legitimate interests, including by enhancing the safety and security of our Services, providing customer support, complying with applicable legal obligations, enforcing any applicable terms of service, and protecting our rights and the rights of our employees, users, or other individuals.

Information You Provide to Us

Some features of the Services may require you to directly provide certain information, including information about yourself. You may elect not to provide this information, but doing so may prevent you from using or accessing these features. Information that you directly submit through our Services includes:

• Basic contact details, such as first and last name, phone number, and enterprise email address. We use this information to create and maintain your account and provide the Services, as required to perform our contract with you, and because it is in our legitimate interest to communicate with you. We may also use contact information you provided to us to send you marketing emails and other communications about our Services, promotions, or special offers, to the extent you have consented to receiving marketing communications from us.
• Account information, such as name, company, username and password. If you sign up for an account using a third-party account, such as Google or Apple, we may receive any information related to your use of such third-party account. We use this information to provide the Services, as required to perform our contract with you, and because it is in our legitimate interest to maintain and secure your account with us. If you choose to register an account, you are responsible for keeping your account credentials safe. We recommend you do not share your access details with anyone else. If you believe your account has been compromised, please contact us immediately using the information found in the “How to Contact Us” section.
• Payment information, such as bank account, credit or debit card information, and billing address, which we collect using a third-party payment processor. We use this information to process your payment and provide the Services, as required to perform our contract with you.
• Applicant details, such as information included in your resume or CV, references, and job history. We use applicant details to process your application for employment and because it is in our legitimate interest to evaluate your candidacy.
• Any other information you choose to provide us when communicating with us, including through our automated Customer Service chat portal, for example, when sending a message through the Services, because it is in our legitimate interest to be responsive to you.

Information Collected Automatically

We and third parties may also use cookies, pixels, or other tracking technologies to automatically collect certain information about your interactions with the Services. This information is collected and used because it is in our legitimate interests to tailor your experience with the Services, provide you with offers or promotions, run analytics, better understand user interactions with the Services, etc. Such information includes:

• Device information, such as device type, operating system, unique device identifier, and internet protocol (IP) address.
• Location information, such as precise geolocation location.
• Other information regarding your interaction with the Services, such as browser type, log data, date, and time stamps, interactions with marketing emails, and ad impressions. Most browsers accept cookies automatically, but you may be able to control the way in which your devices permit the use of cookies. If you so choose, you may block or delete certain of our cookies from your browser; however, blocking or deleting cookies may cause some of the Services, including any portal features and general functionality, to work incorrectly. You may also opt-out of the collection and use of information for interest-based advertising by advertisers that are part of certain industry alliances, including through tools offered by the National Advertising Initiative, the Digital Advertising Alliance or the European Interactive Digital Advertising Alliance.

Your browser settings may also allow you to transmit a “Do Not Track” signal when you visit various websites. Like many websites, our website is not designed to respond to “Do Not Track” signals received from browsers.

Information Collected From Other Sources

We may obtain information about you from outside sources, including information that we collect directly from third parties and information from third parties that you choose to share with us, and combine it with other information we have about you. Such information includes:

• Analytics data we receive from analytics providers, which we use in our legitimate interests to improve our website, communications, and the Services.
• Information we receive from career websites, such as LinkedIn, which we use in our legitimate interests to process your application for employment.
• Information we receive from business information providers or other data-enrichment service providers, which we use in our legitimate interests to support onboarding and better understand how organizations and customers use our Services.
• Information we receive when you choose to link any third-party platform to your account, which we use in our legitimate interests to maintain your account and login information.

Any information we receive from outside sources will be treated in accordance with this Privacy Notice. We are not responsible for the accuracy of the information provided to us by third parties and are not responsible for any third party’s policies or practices. For more information, see the section below, Third-Party Websites and Links.

Deidentified Information

Finally, we may deidentify or anonymize your information such that it cannot reasonably be used to infer information about you or otherwise be linked to you (or we may collect information that has already been deidentified/anonymized), and we may use such deidentified/anonymized information for any purpose.

4. DISCLOSURE OF YOUR INFORMATION

We may disclose your information for legitimate purposes subject to this Privacy Notice, including to the following categories of third parties:

• Our affiliates or others within our corporate group, as a matter of our legitimate interests to efficiently provide the Services.
• Vendors or other service providers who help us provide the Services, including for system administration, cloud storage, security, customer relationship management, marketing communications, web analytics, payment networks, and payment processing.
• Third parties for their own marketing purposes based on your consent.
• Third parties to whom you request or direct us to disclose information, such as through your use of login integration, with your consent or to perform our contract with you.
• Professional advisors, such as auditors, law firms, or accounting firms, as a matter of our legitimate interests to assess, protect, enforce and defend our rights and to comply with our legal and regulatory obligations.
• Third parties in connection with or anticipation of an asset sale, merger, bankruptcy, or other business transaction, as a matter of our legitimate interests to run a successful and efficient business.

We may also disclose your information as needed to comply with applicable law or any obligations thereunder or in our legitimate interests to cooperate with law enforcement, judicial orders, and regulatory inquiries, to enforce any applicable terms of service, and to ensure the safety and security of our business, employees, and users.

5. THIRD-PARTY WEBSITES AND LINKS

We may provide links to third-party websites or platforms. If you follow links to sites or platforms that we do not control and are not affiliated with us, you should review the applicable privacy notice, policies, and other terms. We are not responsible for the privacy or security of, or information found on, these sites or platforms. Information you provide on public or semi-public venues, such as third-party social networking platforms, may also be viewable by other users of the Services and/or users of those third-party platforms without limitation as to its use. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators.

6. CHILDREN’S PRIVACY

Our Services are not intended for children, and we do not seek or knowingly collect any personal information about children. If we become aware that we have unknowingly collected information about a child, in particular any child under 13 years of age, we will make commercially reasonable efforts to delete such information from our database. If you are the parent or guardian of a child under 13 years of age who has provided us with their personal information, you may contact us using the below information to request that it be deleted.

7. DATA SECURITY AND RETENTION

Despite our reasonable efforts to protect your information, no security measures are impenetrable, and we cannot guarantee “perfect security.” Any information you send to us electronically, while using the Services or otherwise interacting with us, may not be secure while in transit. We recommend that you do not use unsecure channels to send us sensitive or confidential information.

We retain your information for as long as is reasonably necessary for the purposes specified in this Privacy Notice. When determining the length of time to retain your information, we consider various criteria, including whether we need the information to continue to provide you the Services, resolve a dispute, enforce our contractual agreements, prevent harm, promote safety, security, and integrity, or protect ourselves, including our rights, property, or products. In particular, we retain certain of your information as follows:

• your account data for as long as you keep your account open or as needed to provide you with our Services;
• if you contact us, we will keep your data for 24 months after you contact us;
• your technical usage information for 12 months; and
• data on your use of our Services is retained for 12 months.

8. DATA TRANSFERS

We are based in the United States. If you are using the Services from outside the United States, please be aware that the information we collect from you may be transferred to, stored and processed in the United States or other countries outside your country of residence.

9. PRIVACY RIGHTS

Depending on where you live, you may have certain rights in relation to your personal information. These rights apply with respect to the personal information that Pulse processes in its capacity as a “controller,” such as the limited personal information we collect directly from our enterprise users. For personal information contained in documents or other materials uploaded to the Services by enterprise customers, Pulse acts solely as a “processor” and any rights requests relating to that information should be directed to the relevant customer. Note that a number of these rights only apply in certain circumstances, and all of these rights may be limited by law.

• Access / Know: You may have the right to request access to the personal information we hold about you, and to obtain information about how we use it, and with whom we share or have shared it in the past.
• Deletion / Erasure: You may have the right to request that we delete personal information we hold about you.
• Correction: You may have the right to correct inaccurate personal information we hold about you.
• Portability: You may have the right to receive a copy of the personal information we hold about you and to request that we transfer it to a third party.
• Restriction of Processing: You may have the right to require us to stop, suspend or restrict our processing of personal information we hold about you.
• Objection: You may have the right to object to our processing of your personal information.
• Opt-Out of Marketing: You may opt out of marketing communications (i.e., through email) at any time by using the unsubscribe / opt-out function displayed in our communications to you. Please note that if you opt out, we may still send you transactional or administrative messages, such as emails about your account.
• Withdrawal of Consent: Where we rely on consent to process your personal information, you may have the right to withdraw this consent at any time.

To make a request described in this Section, please contact us at the email address listed below.You may also have the right to complain to your local data protection authority about how we process your personal data. Of course, we hope you will contact us first so we can resolve any issues.

10. HOW TO CONTACT US

Should you have any questions about our privacy practices or this Privacy Notice, please email us at security@trypulse.ai or contact us at:

Pulse Software, Corp.465 California St #635San Francisco, CA 94104

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