[{"data":1,"prerenderedAt":984},["ShallowReactive",2],{"content:legal:\u002Flegal\u002Fdpa":3,"content:legal:published":980},{"id":4,"title":5,"body":6,"canonical":965,"changelog":966,"description":967,"draft":968,"effective":969,"extension":970,"locale":971,"meta":972,"navigation":973,"noindex":968,"og":965,"path":974,"seo":975,"status":976,"stem":977,"updated":969,"version":978,"__hash__":979},"legal\u002Flegal\u002Fdpa.md","Data Processing Addendum",{"type":7,"value":8,"toc":939},"minimark",[9,14,57,61,65,86,89,124,136,140,147,154,161,168,178,185,189,192,196,207,210,213,217,227,234,245,255,262,269,276,280,287,330,337,344,351,358,365,369,380,387,394,404,408,415,425,432,439,442,446,449,452,456,463,473,480,487,490,494,504,511,518,525,528,532,535,538,542,545,548,552,555,559,566,573,580,587,598,611,614,618,737,741,835,839,842,926,930,936],[10,11,13],"h2",{"id":12},"in-plain-english","In plain English",[15,16,17,21,24,27,30,39,42,45,48,51,54],"ul",{},[18,19,20],"li",{},"You (the customer) decide why and how the personal data in Pulseri is used. We process it for you, only on your instructions.",[18,22,23],{},"We keep it secure and confidential. If there is a breach, we tell you without undue delay and no later than 72 hours after we become aware of it.",[18,25,26],{},"We store it with Google Cloud in Belgium. Our team works from the UAE, and some of our providers are in the US.",[18,28,29],{},"Because Pulseri is a UAE company, the EU Standard Contractual Clauses are built in. The UK and Swiss versions are built in too.",[18,31,32,33,38],{},"We use sub-processors, listed on our ",[34,35,37],"a",{"href":36},"\u002Fsecurity\u002Fsubprocessors","sub-processors page",". We tell you 30 days before adding or replacing one. You can object to a new one, and if we cannot resolve your objection you can cancel.",[18,40,41],{},"AI tags comments and writes weekly summaries on every plan. We remove email addresses and some phone numbers first, and neither we nor our AI provider train AI models on your data.",[18,43,44],{},"We do not sell your data. Where US state privacy laws apply, we act as your service provider.",[18,46,47],{},"We help you answer requests from the people whose data you hold.",[18,49,50],{},"When your account ends, you can read your data for at least 90 days. Then we delete it.",[18,52,53],{},"You can check that we keep these promises: we answer your reasonable questions, fill in security questionnaires for Business and Enterprise customers, and you can audit us once a year by document review.",[18,55,56],{},"This addendum applies automatically when you accept the Terms of Service. Enterprise customers can ask for a signed copy.",[58,59,60],"p",{},"This summary helps you read the addendum. The numbered sections and the annexes below are the agreement.",[10,62,64],{"id":63},"_1-scope-and-parties","1. Scope and parties",[58,66,67,68,72,73,76,77,81,82,85],{},"1.1 This Data Processing Addendum (the \"",[69,70,71],"strong",{},"DPA","\") is part of the agreement between STAFFINGG L.L.C-FZ, a company registered in the Meydan Free Zone, Dubai, United Arab Emirates, with its registered address at Meydan Grandstand, 6th floor, Meydan Road, Nad Al Sheba, Dubai, United Arab Emirates (\"",[69,74,75],{},"Pulseri","\"), and the customer that accepted the ",[34,78,80],{"href":79},"\u002Flegal\u002Fterms","Terms of Service"," or signed an Order Form (the \"",[69,83,84],{},"Customer","\"). It applies when Pulseri processes Customer Personal Data to provide the Service.",[58,87,88],{},"1.2 The Customer is the controller of Customer Personal Data and Pulseri is its processor. If the Customer itself processes the data for another business, as that business's processor, then Pulseri is the Customer's sub-processor. In that case the Customer confirms that it has the right to give the instructions in this DPA and to agree to it.",[58,90,91,92,95,96,99,100,103,104,107,108,111,112,115,116,119,120,123],{},"1.3 ",[69,93,94],{},"Definitions."," Words defined in the Terms of Service (for example Customer Data, People, Team Members, Service and Order Form) have the same meaning here. In this DPA:\n(a) \"",[69,97,98],{},"Data Protection Law","\" means all data protection law that applies to the processing, including the EU General Data Protection Regulation (Regulation (EU) 2016\u002F679, the \"",[69,101,102],{},"GDPR","\"), the UK GDPR and the UK Data Protection Act 2018, the Swiss Federal Act on Data Protection, UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (the \"",[69,105,106],{},"PDPL","\"), the California Consumer Privacy Act (the \"",[69,109,110],{},"CCPA","\") and similar US state privacy laws, each as amended;\n(b) \"",[69,113,114],{},"Customer Personal Data","\" means the personal data in Customer Data that Pulseri processes for the Customer;\n(c) \"",[69,117,118],{},"Sub-processor","\" means a provider that Pulseri uses to process Customer Personal Data;\n(d) \"",[69,121,122],{},"SCCs","\" means the EU Standard Contractual Clauses for transfers of personal data to countries outside the EU (Commission Implementing Decision (EU) 2021\u002F914);\n(e) \"controller\", \"processor\", \"personal data\", \"data subject\", \"personal data breach\", \"processing\" and \"supervisory authority\" have the meaning they have in the GDPR. A \"data subject\" is the person the data is about.",[58,125,126,127,130,131,135],{},"1.4 ",[69,128,129],{},"What this DPA does not cover."," Pulseri is a controller, not a processor, for account, billing, website and sign-in security data about the Customer's organisation and its Team Members. The ",[34,132,134],{"href":133},"\u002Flegal\u002Fprivacy","Privacy Policy"," covers that data, and this DPA does not apply to it. The account's audit log is different: Pulseri keeps it for the Customer, under this DPA, and the Customer sets how long it is kept.",[10,137,139],{"id":138},"_2-how-pulseri-processes-customer-personal-data","2. How Pulseri processes Customer Personal Data",[58,141,142,143,146],{},"2.1 The subject matter, duration, nature and purpose of the processing, the types of personal data, the data subjects and the retention periods are set out in ",[69,144,145],{},"Annex 1",".",[58,148,149,150,153],{},"2.2 ",[69,151,152],{},"Only on instructions."," Pulseri processes Customer Personal Data only:\n(a) to provide, secure and support the Service, in line with the Terms of Service, this DPA and the Customer's documented instructions; or\n(b) where EU, EU Member State or UK law requires it, or where other law that applies to Pulseri (including UAE law) requires it. For data covered by the SCCs, processing under other law is limited to what the SCCs allow: law that respects the essence of fundamental rights and freedoms and does not go beyond what is necessary and proportionate in a democratic society.\nIn case (b), Pulseri tells the Customer first, unless the law forbids that.",[58,155,156,157,160],{},"2.3 ",[69,158,159],{},"Instructions."," The Terms of Service, this DPA and the Customer's use of the Service's features and settings are the Customer's complete instructions. Further instructions must be reasonable and in writing. If Pulseri thinks an instruction breaks Data Protection Law, it will tell the Customer straight away and may pause that instruction until it is changed.",[58,162,163,164,167],{},"2.4 ",[69,165,166],{},"The Customer's duties."," The Customer is responsible for:\n(a) having a lawful basis to collect Customer Personal Data and use it in the Service;\n(b) giving data subjects the notices that Data Protection Law requires, and getting any consent it requires (for example to send survey emails);\n(c) the accuracy and quality of the data; and\n(d) choosing the Service settings that match its legal duties, for example the audit log retention period and when to delete People.",[58,169,170,171,174,175],{},"2.5 ",[69,172,173],{},"AI processing."," On every plan, the Service sends the text of written survey answers to an AI provider to tag them by sentiment and theme and to write weekly summaries. AI is part of the Service and cannot be switched off for an account. Before text is sent, Pulseri removes email addresses and some phone number formats from the copy that is sent. This will not catch everything: names and other personal details in comments can still reach the provider. The stored original is not changed. The AI provider is a Sub-processor listed in Annex 3, and its terms do not allow it to use the data Pulseri sends it to train its models. ",[69,176,177],{},"Pulseri does not use Customer Data to train AI models.",[58,179,180,181,184],{},"2.6 ",[69,182,183],{},"Usage counts."," Pulseri may use counts about how the Service is used (for example the number of surveys sent and which features are used) to run, secure and improve the Service. These counts do not identify the Customer or any individual and are not Customer Personal Data.",[10,186,188],{"id":187},"_3-confidentiality","3. Confidentiality",[58,190,191],{},"Pulseri makes sure that everyone it allows to process Customer Personal Data is bound by a duty of confidentiality. It gives access only to people who need it.",[10,193,195],{"id":194},"_4-security","4. Security",[58,197,198,199,202,203,146],{},"4.1 Pulseri uses appropriate technical and organisational measures to protect Customer Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. The measures at the date of this DPA are in ",[69,200,201],{},"Annex 2",". They are also summarised on the ",[34,204,206],{"href":205},"\u002Fsecurity","Security page",[58,208,209],{},"4.2 Pulseri may change the measures, as long as the overall level of protection does not go down.",[58,211,212],{},"4.3 The Customer is responsible for the security settings under its control, such as its Team Members' roles, sign-in methods and API keys.",[10,214,216],{"id":215},"_5-sub-processors","5. Sub-processors",[58,218,219,220,223,224,146],{},"5.1 ",[69,221,222],{},"General authorisation."," The Customer agrees that Pulseri may use Sub-processors. The Sub-processors in use are listed in ",[69,225,226],{},"Annex 3",[58,228,229,230,233],{},"5.2 ",[69,231,232],{},"Their duties."," Pulseri has a written contract with each Sub-processor that gives Customer Personal Data at least the same protection as this DPA. Pulseri stays responsible to the Customer for its Sub-processors' performance of those duties.",[58,235,236,237,240,241,146],{},"5.3 ",[69,238,239],{},"Notice of changes."," Pulseri gives at least 30 days' notice before a new or replacement Sub-processor starts to process Customer Personal Data. It does so by updating Annex 3 and emailing the Customer's account owners. Anyone who wants these notices at another address can ask at ",[34,242,244],{"href":243},"mailto:privacy@pulseri.com","privacy@pulseri.com",[58,246,247,248,251,252,254],{},"5.4 ",[69,249,250],{},"Objection."," The Customer may object to a new or replacement Sub-processor on reasonable data protection grounds by writing to ",[34,253,244],{"href":243}," within 30 days after the notice. The parties will then try in good faith to resolve the objection. If it is not resolved by the date the new Sub-processor is due to start, the Customer may cancel the Service as set out in the Terms of Service. Fees already paid are not refunded. Because the Service runs on one shared platform, Pulseri cannot keep a single customer's data away from a Sub-processor that the platform uses; cancelling is the remedy.",[58,256,257,258,261],{},"5.5 ",[69,259,260],{},"Urgent replacement."," If a Sub-processor must be replaced urgently for security or service-continuity reasons, Pulseri may do so before the 30 days end. It tells the Customer as soon as it can, and the objection right in 5.4 still applies.",[58,263,264,265,268],{},"5.6 ",[69,266,267],{},"Copies of contracts."," On request, Pulseri gives the Customer a copy of its data protection terms with a Sub-processor. It may remove commercial terms and confidential information first.",[58,270,271,272,275],{},"5.7 ",[69,273,274],{},"Not Sub-processors."," Two kinds of provider are not Sub-processors under this DPA:\n(a) integrations the Customer chooses to connect (for example Slack, Microsoft Teams, Zendesk, the Customer's own Stripe account, the identity provider it uses for single sign-on, or an AI assistant app it connects). The Customer instructs Pulseri to exchange data with them, and the Customer's own terms with them apply; and\n(b) providers that Pulseri uses for its own business as a controller (for example to take payments from the Customer). They are listed separately on the sub-processors page, and the Privacy Policy covers them.",[10,277,279],{"id":278},"_6-international-transfers","6. International transfers",[58,281,282,283,286],{},"6.1 ",[69,284,285],{},"Where data is processed."," Pulseri is a company established in the United Arab Emirates. It stores Customer Personal Data with Google Cloud in Belgium (EU). Pulseri's team accesses it from the UAE. Sub-processors process it in the countries listed in Annex 3, which include the United States.",[58,288,289,290,293,294,297,298,301,302,305,306,309,310,313,314,317,318,321,322,325,326,329],{},"6.2 ",[69,291,292],{},"EU Standard Contractual Clauses."," Where the Customer's processing of Customer Personal Data is subject to the GDPR, the parties enter into the SCCs, which are incorporated into this DPA by reference. Because Pulseri is established outside the EU, the SCCs apply to every transfer of that data to Pulseri, including when Pulseri's team accesses data stored in the EU from the UAE. Pulseri's onward transfers to Sub-processors follow section 6.5. The parties make these choices:\n(a) ",[69,295,296],{},"Modules."," Module Two (controller to processor) applies where the Customer is a controller. Module Three (processor to processor) applies where the Customer is a processor. The Customer is the \"data exporter\" and Pulseri is the \"data importer\".\n(b) ",[69,299,300],{},"Clause 7"," (the docking clause, which lets other parties join) applies.\n(c) ",[69,303,304],{},"Clause 9(a):"," Option 2 (general written authorisation) applies, with the 30-day notice period in section 5.3.\n(d) ",[69,307,308],{},"Clause 11(a):"," the optional wording does not apply.\n(e) ",[69,311,312],{},"Clause 13 (supervisory authority):"," where the Customer is established in an EU Member State, the competent supervisory authority is the one responsible for the Customer there. Where the Customer is not established in the EU but has appointed a representative under Article 27 of the GDPR, it is the authority of the Member State where that representative is established. Where the Customer does not have to appoint a representative, it is the authority of the Member State where the data subjects concerned are located, as Clause 13(a) provides.\n(f) ",[69,315,316],{},"Clause 17:"," Option 1 applies, and the SCCs are governed by the law of Ireland. ",[69,319,320],{},"Clause 18(b):"," disputes go to the courts of Ireland.\n(g) ",[69,323,324],{},"Annexes:"," Annex I of the SCCs is Annex 1 of this DPA, Annex II is Annex 2, and the Sub-processor list in Annex 3 is given for information under Option 2.\n(h) ",[69,327,328],{},"How some clauses work in practice:"," audits under Clause 8.9 are carried out as section 11 sets out; Pulseri confirms deletion in writing on request (Clause 8.5); and the Customer's acceptance of the Terms of Service, or its signature of an Order Form, counts as its signature of the SCCs, including Annex I.A.\n(i) If the SCCs conflict with this DPA or any other part of the agreement, the SCCs win.\n(j) If an adequacy decision or another lawful transfer tool later covers a transfer, the SCCs stop applying to that transfer to that extent.",[58,331,332,333,336],{},"6.3 ",[69,334,335],{},"UK."," Where the Customer's processing is subject to the UK GDPR, the parties also enter into the UK International Data Transfer Addendum to the SCCs (version B1.0, issued by the Information Commissioner under section 119A of the Data Protection Act 2018). Its Table 1 is completed from Annex 1, Table 2 from the choices in section 6.2, and Table 3 from Annexes 1 to 3. For Table 4, either party may end the Addendum as its Section 19 allows. The competent supervisory authority for UK data is the Information Commissioner's Office.",[58,338,339,340,343],{},"6.4 ",[69,341,342],{},"Switzerland."," Where the processing is subject to the Swiss Federal Act on Data Protection, the SCCs apply with these changes: references to the GDPR mean that Act; the Federal Data Protection and Information Commissioner is the competent supervisory authority for those transfers; \"Member State\" in Clause 18(c) includes Switzerland, so data subjects in Switzerland can bring claims where they normally live; and where a transfer is subject only to the Swiss Act, Clause 17 refers to Swiss law and Clause 18(b) to the Swiss courts.",[58,345,346,347,350],{},"6.5 ",[69,348,349],{},"Onward transfers to Sub-processors."," For each Sub-processor that processes Customer Personal Data outside the EU, the UK or Switzerland, Pulseri uses a valid transfer tool: the SCCs (Module Three, with the UK and Swiss versions where needed), an adequacy decision (including the EU-US Data Privacy Framework for certified providers), or another tool Data Protection Law allows. Annex 3 lists the safeguard for each.",[58,352,353,354,357],{},"6.6 ",[69,355,356],{},"Government requests and local laws."," For data covered by the SCCs:\n(a) Pulseri tells the Customer about any request or order from a public authority for Customer Personal Data, unless the law forbids it; challenges it where there are reasonable grounds; and discloses only the minimum the request requires (Clause 15); and\n(b) as Clause 14 requires, Pulseri assesses the laws and practices of the UAE and the other countries involved, documents that assessment, gives the Customer a summary on request, and tells the Customer if its view changes.",[58,359,360,361,364],{},"6.7 ",[69,362,363],{},"If a transfer tool stops working."," If a court or authority rules that a transfer tool used under this section is invalid, the parties will work together to put a valid one in place.",[10,366,368],{"id":367},"_7-help-with-data-subject-requests","7. Help with data subject requests",[58,370,371,372,375,376,146],{},"7.1 ",[69,373,374],{},"Tools."," The Service lets the Customer find, read, correct and delete Customer Personal Data, through the dashboard, the API and the assistant (MCP) connection. The Customer is responsible for using them. Single survey answers cannot yet be deleted in the Service; Pulseri deletes or redacts them on request at ",[34,377,379],{"href":378},"mailto:support@pulseri.com","support@pulseri.com",[58,381,382,383,386],{},"7.2 ",[69,384,385],{},"Requests that reach Pulseri."," If a data subject contacts Pulseri about Customer Personal Data, Pulseri will not answer the request itself, except to tell the person to contact the Customer. It will pass the request to the Customer without undue delay, unless the law requires otherwise.",[58,388,389,390,393],{},"7.3 ",[69,391,392],{},"Further help."," Taking into account the nature of the processing, Pulseri gives the Customer reasonable help to answer requests that the Customer cannot answer with the tools in the Service. Help with deleting or redacting answers (7.1) and with getting data out (section 10) is free. For other help that goes beyond what the Service provides, Pulseri may charge reasonable costs if it tells the Customer the cost first.",[58,395,396,397,400,401,403],{},"7.4 ",[69,398,399],{},"Deleting a Person."," When the Customer deletes a Person in the Service, Pulseri:\n(a) removes the Person's name, email address and traits, replaces the ID the Customer gave the Person with a meaningless label, and deletes the Person's profile picture;\n(b) scrubs the content of the events it stored about the Person;\n(c) deletes the Person's survey delivery records, after adding them to totals that contain no personal data;\n(d) keeps the Person's survey answers, including written comments and their sentiment and theme tags, linked to the now anonymous record, so the Customer's trend history is not broken. Weekly AI summaries that were already written also stay. Comments and summaries can still contain personal data. If the Customer needs specific comments removed, it can ask at ",[34,402,379],{"href":378},";\n(e) if the Person's email address was blocked (for example because they unsubscribed), keeps a one-way hash of the address (a scrambled code that cannot be turned back into the address), so that the address is never emailed again; and\n(f) records in the audit log that the Person was deleted and by whom, without any details about the Person.\nOther records that mention the Person, such as logs of alerts and webhook deliveries, expire on the schedule in Annex 1. Copies that have already left the Service, for example alerts the Customer had sent to Slack or email, are under the Customer's control.",[10,405,407],{"id":406},"_8-personal-data-breach","8. Personal data breach",[58,409,410,411,414],{},"8.1 ",[69,412,413],{},"Notice."," Pulseri will tell the Customer about a personal data breach affecting Customer Personal Data, including one at a Sub-processor, without undue delay and no later than 72 hours after becoming aware of it. An Order Form may set a shorter time. Pulseri \"becomes aware\" when it has a reasonable belief that a breach has happened.",[58,416,417,418,421,422,424],{},"8.2 ",[69,419,420],{},"Who is told."," Pulseri sends the notice to the email addresses of the Customer's account owners, and to any other address the Customer has asked Pulseri, by writing to ",[34,423,244],{"href":243},", to use for breach notices. The Customer keeps these addresses up to date.",[58,426,427,428,431],{},"8.3 ",[69,429,430],{},"What the notice says."," The notice includes, as far as then known: what happened; where possible, the categories and approximate number of data subjects and records concerned; the likely consequences; what Pulseri has done or proposes to do about it; and a contact point for more information. Where not everything is known at first, Pulseri sends what it knows and adds the rest as it learns it.",[58,433,434,435,438],{},"8.4 ",[69,436,437],{},"Containing the breach and helping the Customer."," Pulseri will take reasonable steps to contain the breach, reduce its effects and stop it happening again. It will help the Customer meet its own duties to notify supervisory authorities and data subjects. Pulseri will not notify them about the Customer's data on the Customer's behalf unless the law requires it or the Customer asks. A notice from Pulseri is not an admission of fault.",[58,440,441],{},"8.5 This section is how Pulseri meets its duty, under the GDPR, the PDPL and other Data Protection Law, to inform the Customer as controller.",[10,443,445],{"id":444},"_9-assessments-consultation-and-records","9. Assessments, consultation and records",[58,447,448],{},"9.1 Taking into account the nature of the processing and the information available to it, Pulseri gives the Customer reasonable help with data protection impact assessments and with prior consultation of supervisory authorities about the Service.",[58,450,451],{},"9.2 Pulseri keeps a written record of the processing it carries out for its customers, as Article 30(2) of the GDPR and the PDPL require, and makes it available to a supervisory authority on request.",[10,453,455],{"id":454},"_10-return-and-deletion","10. Return and deletion",[58,457,458,459,462],{},"10.1 ",[69,460,461],{},"During the term."," The Customer can read Customer Personal Data in the dashboard and through the API and the assistant (MCP) connection, and can delete it in the Service. Pulseri does not offer a bulk export tool. If the Customer needs help getting its data out, Pulseri gives reasonable help on request.",[58,464,465,466,469,470,472],{},"10.2 ",[69,467,468],{},"After the subscription ends."," The account becomes read-only for at least 90 days. During that time the Customer can still sign in and read its data in the dashboard and through the API. Pulseri also gives reasonable help getting the data out on request, including where the Terms of Service allow it to withhold access after a serious breach of the Acceptable Use Policy. Pulseri emails the Customer 30, 7 and 1 days before deletion. During this period Pulseri only stores the data and gives the Customer access to it. The Customer may ask at ",[34,471,244],{"href":243}," for its data to be deleted sooner.",[58,474,475,476,479],{},"10.3 ",[69,477,478],{},"Deletion."," At the end of the read-only period, or sooner on request, Pulseri deletes Customer Personal Data from its live systems, including the audit log. Copies in database backups are gone within 14 days after that, and copies in server disk snapshots within 7 days. Server logs are kept for up to 30 days.",[58,481,482,483,486],{},"10.4 ",[69,484,485],{},"Legal hold."," If the law, a court or a legal dispute requires Pulseri to keep some Customer Personal Data (a \"legal hold\"), Pulseri pauses deletion of that data only, keeps it protected, uses it only for that purpose and deletes it when the hold ends.",[58,488,489],{},"10.5 On request, Pulseri confirms the deletion in writing.",[10,491,493],{"id":492},"_11-information-and-audits","11. Information and audits",[58,495,496,497,500,501,503],{},"11.1 ",[69,498,499],{},"Information."," Pulseri makes available to the Customer the information needed to show that it meets this DPA and Article 28 of the GDPR. Normally it does so by providing this DPA's annexes, the ",[34,502,206],{"href":205}," and summaries of its relevant policies, and by answering the Customer's reasonable written questions. Business and Enterprise customers can also ask Pulseri to fill in their own security questionnaire. Pulseri does not currently hold third-party certifications such as SOC 2 or ISO 27001 and does not claim them.",[58,505,506,507,510],{},"11.2 ",[69,508,509],{},"Remote audit."," If that information is not enough to show compliance, the Customer (or an independent auditor that it appoints, that is bound by confidentiality and is not a competitor of Pulseri) may audit Pulseri's compliance with this DPA by remote review of documents. The Customer gives at least 30 days' written notice, may audit once in any 12 months, and pays its own costs.",[58,512,513,514,517],{},"11.3 ",[69,515,516],{},"On-site audit."," An audit at Pulseri's premises is available only where a supervisory authority requires it, or after a personal data breach at Pulseri where documents cannot show compliance. It takes place during normal business hours, on at least 30 days' written notice unless the authority requires less, without access to other customers' data, and without unreasonably disrupting Pulseri's business.",[58,519,520,521,524],{},"11.4 ",[69,522,523],{},"Costs if a breach is found."," If an audit finds that Pulseri has materially breached this DPA, Pulseri pays the reasonable costs of that audit and fixes the breach promptly.",[58,526,527],{},"11.5 Audit rights under the SCCs are exercised as this section sets out. Nothing in this section limits the powers of a supervisory authority.",[10,529,531],{"id":530},"_12-us-state-privacy-laws","12. US state privacy laws",[58,533,534],{},"12.1 Where the CCPA or a similar US state privacy law applies to Customer Personal Data, Pulseri acts as the Customer's service provider (or \"processor\" or \"contractor\", as that law calls it). The business purposes for which the Customer discloses the data to Pulseri are the purposes listed in Annex 1.",[58,536,537],{},"12.2 For that data, Pulseri will:\n(a) not sell it or share it (in the CCPA, \"sharing\" means passing it on for advertising based on a person's activity across different businesses' websites and services);\n(b) not keep, use or disclose it for any purpose other than the business purposes in Annex 1, or outside the direct business relationship between the Customer and Pulseri, except as the law allows;\n(c) not combine it with personal information that Pulseri receives from others or collects itself, except as the law allows;\n(d) comply with the law that applies to it as a service provider and give the data the same level of privacy protection that the law requires of the Customer;\n(e) tell the Customer if it decides it can no longer meet these duties;\n(f) let the Customer, after giving notice, take reasonable and appropriate steps to stop and fix any unauthorised use of the data, including the steps in sections 7, 10 and 11; and\n(g) pass these same duties on to its Sub-processors by written contract.",[10,539,541],{"id":540},"_13-uae-data-protection-law","13. UAE data protection law",[58,543,544],{},"13.1 Where the PDPL applies to Customer Personal Data, Pulseri, as processor:\n(a) processes the data only on the Customer's instructions, for the purposes in Annex 1 and for no longer than the periods in Annex 1 and section 10;\n(b) protects the data with the measures in Annex 2;\n(c) keeps a record of the processing it carries out for the Customer (section 9.2);\n(d) gives the Customer the information it needs to show compliance (section 11);\n(e) tells the Customer about a breach as section 8 sets out; and\n(f) deletes the data when the processing ends, or returns it as section 10 sets out.",[58,546,547],{},"13.2 Pulseri will tell the Customer about any PDPL requirement it learns of that affects transfers of Customer Personal Data into or out of the UAE.",[10,549,551],{"id":550},"_14-liability","14. Liability",[58,553,554],{},"Each side's liability under or in connection with this DPA, including under the SCCs as between the parties, is subject to the limits on liability in section 15 of the Terms of Service. Nothing in this DPA limits either side's liability to data subjects, or data subjects' rights, under the SCCs or Data Protection Law.",[10,556,558],{"id":557},"_15-term-order-of-priority-and-law","15. Term, order of priority and law",[58,560,561,562,565],{},"15.1 ",[69,563,564],{},"Term."," This DPA lasts as long as Pulseri processes Customer Personal Data for the Customer. Sections that by their nature should continue after it ends, such as confidentiality and deletion, do so.",[58,567,568,569,572],{},"15.2 ",[69,570,571],{},"Order of priority."," If documents conflict, this order applies, highest first, as in section 1.5 of the Terms of Service: a signed Order Form; the SCCs, where they apply; this DPA and the sub-processors page; the Terms of Service; the Billing and cancellation page and the pricing page; then the Acceptable Use Policy. An Order Form cannot change the SCCs or reduce the protection they give data subjects.",[58,574,575,576,579],{},"15.3 ",[69,577,578],{},"Law and courts."," This DPA is governed by the law and courts set out in the Terms of Service (the law of England and Wales and the courts of the Dubai International Financial Centre), unless a signed Order Form says otherwise. The SCCs are governed by the law and courts chosen in section 6, and any other choice that Data Protection Law requires also applies.",[58,581,582,583,586],{},"15.4 ",[69,584,585],{},"Changes."," Pulseri may update this DPA to reflect changes in law or in the Service by giving 30 days' notice. The SCCs cannot be changed this way. A change that the law requires may apply sooner. If the Customer objects on reasonable grounds within the 30 days, the parties will talk in good faith. If they cannot agree, the Customer may cancel without penalty before the change takes effect, and the old DPA then applies until the end of the period it has paid for.",[58,588,589,590,593,594,146],{},"15.5 ",[69,591,592],{},"Signing."," This DPA applies when the Customer accepts the Terms of Service. Enterprise customers can ask for a countersigned copy at ",[34,595,597],{"href":596},"mailto:legal@pulseri.com","legal@pulseri.com",[58,599,600,601,604,605,607,608,610],{},"15.6 ",[69,602,603],{},"Notices."," Notices to Pulseri about this DPA go to ",[34,606,244],{"href":243},", with a copy to ",[34,609,597],{"href":596}," for notices that end the agreement or claim a breach. Notices to the Customer go to the email addresses of its account owners. An email notice counts as received one business day after it is sent.",[612,613],"hr",{},[10,615,617],{"id":616},"annex-1-details-of-processing","Annex 1: Details of processing",[619,620,621,634],"table",{},[622,623,624],"thead",{},[625,626,627,631],"tr",{},[628,629,630],"th",{},"Item",[628,632,633],{},"Description",[635,636,637,646,657,665,673,681,689,697,705,713,721,729],"tbody",{},[625,638,639,643],{},[640,641,642],"td",{},"Data exporter (controller)",[640,644,645],{},"The Customer: the business that has the Pulseri account. Its name, address and contact person are taken from the account or the Order Form. Contact: the account owners. Activities: using the Service to store and survey its People. Signature and date: the Customer's acceptance of the Terms of Service or signature of an Order Form (SCC Annex I.A; UK Addendum Table 1).",[625,647,648,651],{},[640,649,650],{},"Data importer (processor)",[640,652,653,654,656],{},"STAFFINGG L.L.C-FZ, Meydan Grandstand, 6th floor, Meydan Road, Nad Al Sheba, Dubai, United Arab Emirates. Contact: ",[34,655,244],{"href":243},". Activities: providing the Pulseri survey platform.",[625,658,659,662],{},[640,660,661],{},"Subject matter",[640,663,664],{},"Providing the Pulseri survey platform to the Customer.",[625,666,667,670],{},[640,668,669],{},"Duration",[640,671,672],{},"The term of the agreement, plus the read-only period and the deletion periods in section 10.",[625,674,675,678],{},[640,676,677],{},"Nature and purposes",[640,679,680],{},"Hosting, storing, sending, displaying, analysing and deleting Customer Personal Data in order to: send survey emails and show in-app surveys; collect answers; compute scores and reports; match events sent by the Customer to its survey triggers; tag written answers by sentiment and theme and write weekly summaries with an AI provider; send alerts and webhooks to destinations the Customer chooses; process bounces, spam complaints and unsubscribes so that blocked addresses are not emailed; make the data available to the Customer through the dashboard, the API and the assistant (MCP) connection; keep the Service secure and prevent abuse; and give support.",[625,682,683,686],{},[640,684,685],{},"Data subjects",[640,687,688],{},"People the Customer chooses to store or survey: for example the Customer's own customers and their staff, and the Customer's employees or contractors (for employee surveys). Team Members, for the account's audit log (what they did, when, and the IP address and browser details used), and where the Customer also loads them as People.",[625,690,691,694],{},[640,692,693],{},"Types of personal data",[640,695,696],{},"Identifiers and contact details (the ID the Customer gives each Person, name, email address, group memberships); traits the Customer defines; audience type (customer or employee); profile picture, if the Customer adds one; email block status (unsubscribed, bounced, spam complaint); survey delivery history (sent, reminder sent, completed, dismissed, bounced, spam complaint; Pulseri does not track email opens or clicks); survey answers (scores and written comments) and their sentiment and theme tags; weekly AI summaries of answers; events sent by the Customer or its connected tools, and records of which events matched a survey trigger; page path, site address and referrer sent by the in-app widget; logs of alerts and webhook deliveries; technical request information (such as IP address and browser details) in server logs; for Team Members, the audit log of their actions in the account, with IP address and browser details.",[625,698,699,702],{},[640,700,701],{},"Special categories of data",[640,703,704],{},"Not intended. The Customer must not submit special-category data (for example health data) or other data that the Acceptable Use Policy forbids. A person may still write such data in a comment. The Customer is responsible for that risk and for asking questions in a way that does not invite it.",[625,706,707,710],{},[640,708,709],{},"Frequency",[640,711,712],{},"Continuous, while the Service is used.",[625,714,715,718],{},[640,716,717],{},"Retention",[640,719,720],{},"See the retention table below and section 10.",[625,722,723,726],{},[640,724,725],{},"Transfers to Sub-processors",[640,727,728],{},"To the Sub-processors in Annex 3, for the purposes listed there, for as long as the Service is provided.",[625,730,731,734],{},[640,732,733],{},"Competent supervisory authority",[640,735,736],{},"As set out in section 6.2(e). For UK data, the Information Commissioner's Office; for Swiss data, the Federal Data Protection and Information Commissioner.",[738,739,717],"h3",{"id":740},"retention",[619,742,743,753],{},[622,744,745],{},[625,746,747,750],{},[628,748,749],{},"Data",[628,751,752],{},"How long Pulseri keeps it",[635,754,755,763,771,779,787,795,803,811,819,827],{},[625,756,757,760],{},[640,758,759],{},"People, survey answers and comments, tags and weekly AI summaries",[640,761,762],{},"Until the Customer deletes them (see section 7.4 for deleting a Person), or until the account is deleted under section 10. A Person's profile picture is deleted when the Person is deleted or the picture is replaced.",[625,764,765,768],{},[640,766,767],{},"Content of events sent by the Customer or its tools",[640,769,770],{},"Scrubbed after 30 days, or at once when the Person is deleted. The rest of the record is deleted after 90 days, or up to 180 days if the event started a survey send.",[625,772,773,776],{},[640,774,775],{},"Records of events that matched a survey trigger",[640,777,778],{},"180 days.",[625,780,781,784],{},[640,782,783],{},"Survey delivery records (sent, reminder sent, completed, dismissed, bounced, spam complaint)",[640,785,786],{},"90 days, or longer until the billing period they count toward has been invoiced. They are then reduced to counts with no personal data. They are deleted at once when the Person is deleted.",[625,788,789,792],{},[640,790,791],{},"Webhook delivery logs",[640,793,794],{},"30 days, and no more than the latest 1,000 per webhook destination.",[625,796,797,800],{},[640,798,799],{},"Alert delivery records",[640,801,802],{},"The destination and error details are scrubbed after 7 days, once delivery has finished. The record is deleted after 60 days.",[625,804,805,808],{},[640,806,807],{},"Audit log",[640,809,810],{},"30, 90, 365 or 730 days, depending on the Customer's plan. The Customer can choose a shorter period, but not less than 30 days. Deleted with the account.",[625,812,813,816],{},[640,814,815],{},"Server logs",[640,817,818],{},"Up to 30 days.",[625,820,821,824],{},[640,822,823],{},"Backups",[640,825,826],{},"Database backups and recovery logs: copies are gone within 14 days after the data is deleted from live systems. Server disk snapshots: 7 days.",[625,828,829,832],{},[640,830,831],{},"Everything else in the account after the subscription ends",[640,833,834],{},"Read-only for at least 90 days, then deleted (section 10).",[10,836,838],{"id":837},"annex-2-technical-and-organisational-measures","Annex 2: Technical and organisational measures",[58,840,841],{},"These are the measures in place at the date of this DPA.",[843,844,845,851,857,863,873,879,885,891,897,903,909,914,920],"ol",{},[18,846,847,850],{},[69,848,849],{},"Hosting and location."," The Service runs on Google Cloud in Belgium (EU): the application server, the database, file storage and the secrets store. Database backups are kept in Google's EU locations.",[18,852,853,856],{},[69,854,855],{},"Customer separation."," Each customer's data sits in a separate logical tenant. Every database query is limited to one customer, and the database also enforces row-level security (rules that limit each query to one customer's rows) as a second safeguard. A request for another customer's item is answered as \"not found\". Automated tests check this separation against a real database.",[18,858,859,862],{},[69,860,861],{},"Network protection."," All traffic to the app and the API passes through Cloudflare, which provides a web application firewall, attack protection and rate limiting. To do this, Cloudflare decrypts the traffic it passes on. The server's firewall accepts web traffic only from Cloudflare. The database has no public internet address and is reachable only on Pulseri's private network.",[18,864,865,868,869,872],{},[69,866,867],{},"Encryption in transit."," Connections between browsers or API clients and Cloudflare use TLS 1.2 or higher. Connections from Cloudflare to the app and API servers are encrypted, and the server's certificate is checked. Connections from the application to the database are encrypted, and production refuses unencrypted database connections. ",[69,870,871],{},"One exception:"," the logo files that customers upload for their surveys and widget are public by design, and on the last step between Cloudflare and Google's file storage they travel without encryption. Profile pictures and other files are stored privately and are not served this way.",[18,874,875,878],{},[69,876,877],{},"Encryption at rest and secrets."," Google encrypts stored data by default, including the database, files and backups. Sensitive secrets (integration credentials, webhook signing secrets, single sign-on secrets and identity verification secrets) are encrypted again by the application before they are stored. Passwords and secret API keys are stored only as one-way hashes. Public widget keys are not secret by design: they appear on the Customer's website and can only send events. Application secrets are kept in Google Secret Manager, not in code.",[18,880,881,884],{},[69,882,883],{},"Access control for customers."," Role-based permissions that the Customer configures; optional two-step sign-in with an authenticator app; a check of new passwords against lists of passwords exposed in known breaches; signing in again before sensitive actions; API keys with defined scopes; and, on plans that include them, single sign-on (SAML and OIDC), SCIM user provisioning (automatic syncing of users from the Customer's directory) and session limits.",[18,886,887,890],{},[69,888,889],{},"Administrative access."," Pulseri staff reach the server only through Google's Identity-Aware Proxy, with their individual Google accounts. There is no public SSH access. Access is limited to the people who need it.",[18,892,893,896],{},[69,894,895],{},"Audit log."," The Service keeps an audit log of security-relevant actions, including the IP address and browser details of the person who acted. The database refuses changes to log entries; entries are removed only by the automatic retention purge at the end of the Customer's retention period (including after a downgrade grace period), or when the account is deleted. The Customer can read the log in the dashboard, and through the API on plans that include it.",[18,898,899,902],{},[69,900,901],{},"Backups and recovery."," The database is backed up daily; the last 14 backups are kept, and point-in-time recovery covers the last 7 days. The server disk is snapshotted daily and snapshots are kept for 7 days. The database runs in a single zone, without automatic failover to another zone, so an outage of that zone can make the Service unavailable until it is restored. Automated monitoring alerts Pulseri when the API stops responding.",[18,904,905,908],{},[69,906,907],{},"Webhooks and integrations."," Outgoing webhooks are signed so the receiver can check they came from Pulseri. Incoming messages from providers (for example email delivery events) are checked for a valid signature. Outgoing destination addresses are checked before data is sent.",[18,910,911,913],{},[69,912,173],{}," Before written answers are sent to the AI provider, email addresses and some phone number formats are removed from the copy that is sent. This does not remove all personal data. The stored original is unchanged.",[18,915,916,919],{},[69,917,918],{},"Development."," Automated tests run against a real database, including tests of customer separation.",[18,921,922,925],{},[69,923,924],{},"People and incidents."," Staff and contractors are bound by confidentiality duties. Personal data breaches are handled and notified as section 8 sets out.",[10,927,929],{"id":928},"annex-3-sub-processors","Annex 3: Sub-processors",[58,931,932,933,935],{},"The Sub-processors are the providers listed in the first section of the ",[34,934,37],{"href":36},": the providers that process Customer Personal Data. For each one, the page gives the legal entity, what it does, the data it receives, where it processes the data and the transfer safeguard. That section is part of this DPA and is updated under section 5.3.",[58,937,938],{},"The other sections of that page, listing the providers Pulseri uses for its own business and the integrations customers choose to connect, are not part of this Annex (see section 5.7).",{"title":940,"searchDepth":941,"depth":941,"links":942},"",2,[943,944,945,946,947,948,949,950,951,952,953,954,955,956,957,958,959,963,964],{"id":12,"depth":941,"text":13},{"id":63,"depth":941,"text":64},{"id":138,"depth":941,"text":139},{"id":187,"depth":941,"text":188},{"id":194,"depth":941,"text":195},{"id":215,"depth":941,"text":216},{"id":278,"depth":941,"text":279},{"id":367,"depth":941,"text":368},{"id":406,"depth":941,"text":407},{"id":444,"depth":941,"text":445},{"id":454,"depth":941,"text":455},{"id":492,"depth":941,"text":493},{"id":530,"depth":941,"text":531},{"id":540,"depth":941,"text":541},{"id":550,"depth":941,"text":551},{"id":557,"depth":941,"text":558},{"id":616,"depth":941,"text":617,"children":960},[961],{"id":740,"depth":962,"text":717},3,{"id":837,"depth":941,"text":838},{"id":928,"depth":941,"text":929},null,[],"The agreement under which Pulseri processes personal data for its customers as their processor.",false,"2026-10-26","md","en",{},true,"\u002Flegal\u002Fdpa",{"title":5,"description":967},"final","legal\u002Fdpa","1.0","sy28DdbVZinDCsNc3nhRTI9v_sx9vwWgPUlG5YP21YU",[981,982,983,974,133,79],"\u002Flegal\u002Facceptable-use","\u002Flegal\u002Fbilling","\u002Flegal\u002Fcookies",1793908072209]