Pulseri In plain English
- Pulseri is a survey platform for businesses. Our customers load information about their own customers and employees into Pulseri and survey them.
- For that data, our customer decides what happens to it and we act on their instructions. We are the "processor" and they are the "controller". If a Pulseri customer surveyed you, please contact that organisation first (see section 3).
- For our own website, sign-ups, billing and support, we decide, and we are the "controller". That is what most of this policy covers.
- We store data with Google Cloud in Belgium. Our team works from the United Arab Emirates. Some of our providers process data in the United States: email delivery, AI, Cloudflare's global network, payments and Google (section 7).
- Survey comments are sent to our AI provider, Anthropic, in the United States, to tag them and to write weekly summaries. This is part of the service on every plan and cannot be switched off. Anthropic's terms with us do not allow it to train its models on this data, and we do not either (section 3.3).
- We use Google Analytics on our website and switch off its advertising features. In the EU, the EEA, the UK and Switzerland, Google Analytics sets no cookies until you accept in the cookie banner. Elsewhere, analytics start on and you can switch them off at any time.
- We do not sell personal data, and we do not share it for advertising.
- Our service providers are listed on the sub-processors page. Where data leaves your region, we use legal safeguards.
- You can ask us to access, correct or delete your data, and you can object to some uses (section 10). Write to [email protected].
1. Who is responsible
1.1 The controller of the personal data described in sections 4 to 9 is STAFFINGG L.L.C-FZ, 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 ("Pulseri", "we").
1.2 Privacy contact: [email protected]. We have not appointed a data protection officer; privacy questions go to [email protected].
2. What this policy covers
This policy covers: visitors to our website; people who contact us; people who register an account or are invited as Team Members of a customer (the people a customer lets use its Pulseri account); people who pay us or manage billing; and people who report security issues. It also explains, in section 3, how we handle the data our customers load into Pulseri.
It does not cover the websites, apps and services of others that we link to or that integrate with Pulseri.
3. Data our customers load into Pulseri (we are the processor)
3.1 Customers use Pulseri (the "Service", as defined in our Terms of Service) to store information about People (their own customers and employees), send them surveys, and analyse answers. Everything customers put into or collect through the Service is "Customer Data" (as defined in the Terms). The parts of it that relate to a person are "Customer Personal Data". It can include:
- identifiers and contact details a customer chooses to provide, such as an external ID, name, email address, picture and the groups the Person belongs to;
- traits a customer defines (for example plan, role, department, region or any other field they send);
- survey activity: whether a survey was sent, answered, dismissed or unsubscribed, and whether an email bounced or was marked as spam. We do not record whether an email was opened or whether a link in it was clicked;
- survey answers: scores, comments (open-text answers), sentiment and theme tags, and the weekly summaries described in 3.3;
- events a customer sends from its own systems or from connected tools (for example a ticket closing or a payment);
- page information from the in-app widget: the page path, the site address and the referrer (the page the visitor came from). The path and referrer are sent without their query strings, and the page title is not sent.
3.2 The customer decides which data goes in, why, and for how long it stays. We process it only on the customer's instructions to provide the Service, under our Data Processing Addendum (the "DPA"). We do not use it for our own purposes, except to keep the Service secure and to produce de-identified usage statistics (counts that do not identify anyone) that help us run and improve the Service. We do not sell it.
3.3 AI features. On every plan, survey comments are sent to our AI provider, Anthropic, PBC, in the United States. Anthropic tags each comment with sentiment and themes, and writes weekly summaries of a customer's feedback. For the summaries we also send the scores and tags that go with each comment, and the customer's organisation and campaign names. Before sending, we remove email addresses and some phone number formats from the text. This removal is limited: names, phone numbers in other formats and other details in a comment can still reach Anthropic. Customers cannot switch the AI features off. Anthropic's terms with us do not allow it to train its models on the data we send, and we do not use Customer Data to train AI models.
3.4 If you are a person a customer has surveyed, or whose data a customer holds in Pulseri: the customer is responsible for telling you what it does with your data and for answering your requests. Please contact the organisation that surveyed you; the survey email shows who sent it. Each survey email contains an unsubscribe link. If you write to us, we will tell you that we act for the customer and, where the law allows, pass your request to them or help them answer it.
3.5 As a processor, we take data from your browser only when a customer has installed our in-app widget on a page of its own site or product. The widget does not set cookies and does not store anything on your device. It sends the page information listed in 3.1, together with what the customer's site tells it about you.
4. Personal data we collect for our own purposes (we are the controller)
| Who | What we collect | Where it comes from |
|---|---|---|
| Website visitors | Page views and visit data counted by Google Analytics 4: pages, referrer, approximate location, operating system, device type, browser type and language, the events described in the Cookie and analytics notice, and a random identifier kept in two analytics cookies on your device. Google works out the approximate location from your IP address; Google states that Google Analytics 4 does not log or store IP addresses. Google receives this data. We do not send it your name or email. Where we ask for consent, none of this happens unless you accept (section 8.1). | Your browser |
| People who use the contact form | Name, work email, organisation (optional), the kind of enquiry, for enterprise enquiries an optional estimate of how many people you want to hear from, your message, the page you came from, campaign tags in the link (UTM tags), your language setting and the time we received the message. Cloudflare Turnstile checks your IP address and browser details to tell people from bots (section 8.2). We do not store the form in a database: it is sent to our inbox by email through Twilio SendGrid. | You |
| Account holders and Team Members | Name, work email, profile picture, password (stored hashed, never in clear text), a pending change of email address, two-step sign-in settings, role and permissions, directory groups if your organisation provisions users through SCIM, the time of your last sign-in, sign-in and security events with the IP address and browser details linked to them, your preferences and saved views, a linked Google or Microsoft account if you use one to sign in, and the AI assistant apps you connect to Pulseri. When you register, we record the version of the Terms shown to you and when you accepted them, where available. If you sign in with Google, Microsoft or your company's single sign-on, we receive your name and email from that provider. | You, your organisation's administrator, or your identity provider (including SCIM provisioning) |
| Billing contacts | Billing contact name and email, company name, billing address, country, VAT or tax ID and its verification status, invoices, and payment status. The IP address you use when you sign up, which we send to Stripe to work out your tax location. A one-way hash of the card used for a free trial (a code that cannot be turned back into the card number), so that each card gets one trial. Card details are entered directly with Stripe and stored by Stripe, not by us. We see the card brand, the last four digits and the expiry date. | You, and Stripe |
| Customers' systems | API keys (stored hashed), webhook endpoints, and records of calls to our API that we need to run and secure the Service. | Your organisation |
| Support and security reports | The content of your emails or reports to us and any attachments. | You |
4.1 We do not knowingly collect special categories of personal data (such as health data) for our own purposes. We ask customers not to put such data into Pulseri (see the Acceptable Use Policy).
4.2 We do not collect your data from data brokers.
4.3 We keep server logs of traffic to our systems (for example IP address, time, address requested and error details) to keep the Service secure and working. We keep them for up to 30 days. Cloudflare sits in front of our website, app and API. To provide security and routing, it sees the contents of the requests that pass through it.
5. Why we use personal data, and our legal basis
If the GDPR or UK GDPR applies, we need a legal basis. These are ours.
| What we do | Why | Legal basis |
|---|---|---|
| Create and run accounts; sign you in; keep the Service secure | To provide the Service you asked for | Contract (Art. 6(1)(b)); our legitimate interest in security (Art. 6(1)(f)) |
| Take payment, send invoices, work out your tax location, keep tax records, check VAT IDs | To charge for the Service and meet tax and accounting law | Contract; legal obligation (Art. 6(1)(c)) |
| Answer contact forms and support requests | To respond to you | Our legitimate interest in answering business enquiries, or steps you asked for before a contract (Art. 6(1)(b), (f)) |
| Send service emails (trial, billing, security, limit warnings, product changes that affect you) | To run the Service | Contract; legitimate interest |
| Count website visits with Google Analytics | To understand which pages help visitors | In the EU, the EEA, the UK and Switzerland: your consent through the cookie banner (Art. 6(1)(a)). Elsewhere: our legitimate interest in understanding how our website is used (Art. 6(1)(f)); analytics start on and you can switch them off at any time. See section 8.1. |
| Record which version of the Terms was shown and when; check that a card has not already been used for a trial; enforce our terms | To prove agreement and prevent repeated trials and abuse | Legitimate interest; contract |
| Prevent spam and abuse (the spam check on our contact form, bot checks on sign-in, sign-up and password reset, rate limits) | To protect the Service | Legitimate interest |
| Keep an audit log of security-relevant actions in a customer's account | We keep it for the customer, as its processor under the DPA; the customer sets how long it is kept | The customer's instructions (DPA) |
| Improve the Service using usage statistics that do not identify a person | To fix and improve it | Legitimate interest |
| Defend legal claims and comply with law | To meet legal duties | Legal obligation; legitimate interest |
5.1 Where we rely on legitimate interests, we have weighed them against your rights and expect the impact on you to be small. You can ask us about this balance at [email protected], and you can object (section 10.2).
5.2 We do not send marketing emails to people who have not asked for them. If we start a newsletter, we will ask for consent first.
5.3 We do not make decisions about you based only on automated processing that have legal or similarly significant effects. The AI features (section 3.3) tag comments and write summaries for the customer, who decides what to do with them.
5.4 Providing your data is voluntary, but without name and email we cannot create an account or answer you, and without billing details we cannot invoice you.
6. Who we share personal data with
6.1 Providers that process data for us. They act on our instructions and may not use the data for their own purposes:
- Google Cloud hosts the app, the database and file storage in Belgium, keeps backups in Google's EU locations, and stores our server logs.
- Cloudflare provides security, routing and delivery for our website, app and API, and sees the contents of requests to do so. It also runs the Turnstile spam check on our contact form and tells our website your country so that the cookie banner knows whether to ask (section 8).
- Twilio SendGrid sends our emails (account emails such as invitations and password resets, survey and alert emails for customers, and contact form messages to our inbox) and reports bounces and spam complaints.
- Anthropic tags survey comments and writes weekly summaries for customers (section 3.3).
- Google Analytics (Google) counts visits to our website (section 8.1).
6.2 Providers that act as their own controllers. They decide how they use the data they receive, under their own privacy policies:
- Stripe takes payments. It acts as its own controller for your card details and for its fraud checks. See Stripe's privacy policy.
- Google reCAPTCHA checks for bots on sign-in, sign-up and password reset in the app. Google receives your IP address and browser and device signals, and acts as its own controller for this data. See Google's privacy policy.
- Google and Microsoft receive the sign-in request if you choose to sign in with a Google or Microsoft account.
The current list, with each provider's legal entity, location and safeguard, is on the sub-processors page.
6.3 We also share personal data, as needed, with:
- Your organisation's administrators, who can see who your Team Members are and what they did in the account.
- Integrations you connect (for example Slack, Microsoft Teams, Zendesk or Stripe), when you tell us to exchange data with them.
- Advisers, auditors and insurers under confidentiality duties.
- Authorities, where the law requires it or to protect rights and safety, after checking that the request is valid.
- A buyer or successor if our business is sold or reorganised. We would tell you before your data becomes subject to a different privacy policy.
6.4 We do not sell personal data and we do not share it for third-party advertising.
7. Where personal data is processed, and international transfers
7.1 We store data with Google Cloud in Belgium, in the EU. Our team works from the United Arab Emirates and accesses the data from there. Some providers process data in the United States or on global networks, as shown in 7.3.
7.2 The UAE does not have an adequacy decision from the EU or the UK (a decision that a country protects data well enough). For Customer Data, the DPA includes the European Commission's Standard Contractual Clauses (standard contract terms approved by the EU to protect data that leaves Europe): Module 2, or Module 3 where the customer is itself a processor, with the UK Addendum and the changes needed for Switzerland. Data you give us directly, for example when you sign up or write to us, is collected by us as controller in the UAE.
7.3 Where our providers process personal data:
| Recipient | Where | Safeguard |
|---|---|---|
| Our team | United Arab Emirates | For Customer Data, the Standard Contractual Clauses in the DPA |
| Google Cloud | Belgium (EU) | Hosted in the EU. Google's data processing terms, with Standard Contractual Clauses for any access from outside the EU |
| Cloudflare | Global network, including the United States | Standard Contractual Clauses, or the EU-US Data Privacy Framework where the provider is certified |
| Twilio SendGrid | United States | Standard Contractual Clauses, or the EU-US Data Privacy Framework where the provider is certified |
| Anthropic | United States | Standard Contractual Clauses |
| Stripe | EU and United States | Standard Contractual Clauses, or the EU-US Data Privacy Framework where the provider is certified |
| Google (Analytics, reCAPTCHA, sign-in) | EU and United States | Standard Contractual Clauses, or the EU-US Data Privacy Framework where the provider is certified |
| Microsoft (sign-in) | United States | Standard Contractual Clauses, or the EU-US Data Privacy Framework where the provider is certified |
We also use extra safeguards such as encryption and access controls. You can ask us for a copy of the safeguards at [email protected].
7.4 UAE law. Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (the "PDPL") applies to us as a company established in the UAE. The legal bases in section 5 are written for the GDPR; the PDPL relies more on consent than the GDPR does. We follow its principles: lawful, fair and transparent processing, limited purposes, accuracy, storage limits, security, and respect for your rights.
8. Cookies, analytics and spam checks
8.1 Google Analytics on our website. We use Google Analytics 4 to count visits. It sets two analytics cookies (_ga, and _ga_ followed by our measurement id) and sends visit data to Google, which processes it on our behalf. Google may process the data in the United States and other countries (section 7). We switch off Google signals and ad personalisation, set advertising storage to "denied", and do not send Google your name or email.
- Where we ask. Visitors in the EU, the EEA, the UK and Switzerland see a cookie banner with equal "Accept" and "Reject" buttons. Until you accept, Google's script sets no cookies, but it may send Google basic visit information without cookies (Google's "consent mode"). See the Cookie and analytics notice.
- Elsewhere. Analytics start on. Anyone can switch them off with "Cookie settings" in the footer. If your browser sends a Global Privacy Control signal, analytics start off.
- Your choice is stored only in your browser, for 12 months. Outside the countries where we ask, the automatic setting is also kept for 12 months.
- How we know where you are. Our server reads the country from your connection only to decide whether to ask, and stores nothing. If we cannot tell where you are, we ask.
The cookies, their lifetimes and your choices are in the Cookie and analytics notice.
8.2 Contact form spam check. The contact form uses Cloudflare Turnstile. It loads only when you start using the form. It runs a short check in your browser and returns a result to us, which we confirm with Cloudflare. Cloudflare receives technical information such as your IP address and browser details for this check. We treat it as strictly necessary to protect the form.
8.3 Our application. When you open the Pulseri app or sign in, we set cookies that you need to stay signed in and for security (a session cookie, a cookie that protects against forged requests, and short-lived cookies used during sign-in). The app also keeps a few small items in your browser's storage, such as the page you were heading to before sign-in and your recent searches. Stripe's script loads in the signed-in app and on the registration page for payments and fraud prevention, and may set its own cookies. On sign-in, sign-up and password reset we use Google reCAPTCHA to stop bots (section 6.2). The full list is in the Cookie and analytics notice.
9. How long we keep personal data
| Data | How long |
|---|---|
| Website analytics | In Google Analytics: detailed visit data for 2 months; data tied to a browser's random identifier for 14 months after the last visit. |
| Your cookie choice | 12 months, in your browser only. |
| Contact form messages | We do not store form submissions in a database. They are emailed to our inbox, where we keep them while we deal with your enquiry and for 12 months after, then delete them. |
| Account and Team Member data | While the account is active. If payment fails, the account becomes read-only and is later cancelled, as set out in section 6 of the Billing and cancellation page. After a subscription ends, the account stays read-only for at least 90 days: you can still sign in and read your data in the dashboard and through the API. We email you 30, 7 and 1 days before deletion. Then we delete the account's data from our live systems. Backups expire within 14 days after that. |
| Team Members who are removed | Access ends at once: their sessions end, and their linked sign-in accounts, connected AI assistant apps and profile picture are removed. Their name and email stay on the removed account record, so the account's history still shows who did what, until the customer's account is deleted. Audit log entries follow the audit log period below. |
| Invitations | An invitation link stops working when it is accepted or expires. 7 days after that we remove the link, and after 30 days we delete the invitation. |
| Audit log of account events | 30, 90, 365 or 730 days, depending on the customer's plan (see the pricing page). The customer can choose a shorter period, but not less than 30 days. Entries include the IP address and browser details of the person who acted. Older entries are deleted automatically. After a downgrade, see section 3.5 of the Billing and cancellation page. |
| Billing and tax records | As long as tax and accounting law requires, currently up to 7 years. Stripe keeps its own payment and invoice records under its own policy. |
| Server logs | Up to 30 days. |
| Customer Data (People, answers) | For as long as the customer's account exists, under the customer's control, then deleted as described above. Customers can delete a Person at any time. This removes the Person's name, email, traits, picture and ID, and scrubs the events stored about them. Survey answers, including comments, stay, linked to the anonymous record, so that the customer's trends still add up. If the address was blocked from email (for example after an unsubscribe), we keep a one-way hash of it so that we never email it again. A customer can ask us to remove specific comments. |
| Survey delivery records (sent, answered, bounced, unsubscribed) | 90 days, or longer until the billing period they count toward has been invoiced. Then they are reduced to counts with no personal data. They are deleted at once when the Person is deleted. |
| Raw copies of events sent by customers | The content of each event is 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. |
9.1 What we keep after an account is deleted. A record that the account's data was deleted, the one-way hash of the card used for a trial (section 4), our own billing and tax records for as long as tax law requires, and Stripe's own records.
9.2 Legal holds. If we must keep data for a legal claim, an investigation or an authority's request, we pause its deletion until the hold ends, and keep it only for that purpose.
10. Your rights
10.1 Depending on where you live, you may have the right to:
- ask whether we process your personal data, and get a copy;
- have wrong data corrected;
- have your data deleted;
- restrict some uses;
- object to some uses (see 10.2);
- receive the data you gave us in a portable format;
- withdraw consent you gave, at any time, without affecting earlier use;
- not be subject to purely automated decisions with significant effects;
- complain to a data protection authority.
10.2 Your right to object. Where we rely on legitimate interests (section 5), you can object at any time, for reasons relating to your situation. We will then stop, unless we have compelling legitimate grounds that override your interests, rights and freedoms, or we need the data to bring or defend legal claims. You can object to direct marketing at any time, and we will then stop using your data for it.
10.3 To use a right, email [email protected]. We may ask you to confirm who you are. We reply within one month, and tell you if we need more time. We do not charge unless a request is clearly unfounded or excessive.
10.4 If your data is in a customer's account, we will direct you to the customer, as explained in section 3.
10.5 Complaints. You may complain to your local data protection authority. In the EU you can find it at edpb.europa.eu. In the UK it is the Information Commissioner's Office, and in Switzerland the Federal Data Protection and Information Commissioner. In the UAE, the regulator is the UAE Data Office. We would like the chance to fix the problem first, so please write to us.
11. If you live in the United States
11.1 We do not sell your personal information, and we do not share it for cross-context behavioural advertising (advertising based on your activity across other businesses' sites and apps).
11.2 Depending on your state, you may have the right to know what personal information we collect, use and disclose about you; to have it deleted; and to have it corrected. Sections 4 to 6 describe what we collect, where it comes from, why we use it and who receives it, and section 9 says how long we keep it.
11.3 To use these rights, email [email protected]. We will check who you are before we act, and someone you authorise may make the request for you. We will not treat you differently for using your rights. If your data is in a customer's account, we act for that customer and will direct you to it (section 3).
12. Security
12.1 We protect personal data with measures that match the risk. Examples that exist in the software today: data separated between customers by database-level row security, hashed passwords and API keys, encrypted storage of integration credentials, optional two-step sign-in, role-based access, single sign-on and SCIM provisioning for customers who use them, and an audit log of key actions. Connections between your browser and Pulseri are encrypted with TLS 1.2 or higher. See the Security page for what we do and what we do not claim. No system is perfectly secure.
12.2 If a personal data breach affects you and is likely to result in a risk to your rights, we will tell you and the authorities as the law requires. For Customer Data we notify the customer as set out in the DPA.
13. Children
Pulseri is for businesses and is not aimed at children. You must be 18 or older to create an account. We do not knowingly collect personal data from children for our own purposes. Our Acceptable Use Policy does not allow customers to survey children under 16 (or a higher age of digital consent where the child lives) without our written agreement. A customer that has that agreement is responsible for the lawful basis and any parental consent. If you think a child has given us personal data, write to [email protected] and we will delete it.
14. Links to other sites
Links on our site or in the product to other sites are not covered by this policy.
15. Changes to this policy
We will post changes here with a new "Last updated" date. We will email account owners about changes that matter at least 30 days before they apply. A change required by law, or an urgent change for security, may apply sooner; we will tell you as soon as we can. Previous versions are kept in the change log.
16. Contact
[email protected] | STAFFINGG L.L.C-FZ, Meydan Grandstand, 6th floor, Meydan Road, Nad Al Sheba, Dubai, United Arab Emirates