Privacy Policy

Last Updated: Sept 14, 2026

This Privacy Policy explains how Pulse Insights LLC ("Pulse Insights," "we," "us," or "our") handles personal information we collect through our website at pulseinsights.com (the "Site"), about users of the Pulse Insights service (the "Service"), in connection with our marketing activities, and in other settings where we post this policy.

Questions can be directed to privacy@pulseinsights.com.

1. What This Policy Does Not Cover

Our clients are businesses that use the Service to collect and manage information about their own users ("Customer Data"), including opinions, feedback, preferences, and information about how those users interact with the client's websites, applications, and services.

This Privacy Policy does not apply to Customer Data. With respect to Customer Data, Pulse Insights acts as a processor or service provider on the client's instructions, not as a controller. We do not use Customer Data for our own purposes. How Customer Data is handled is described in our Data Usage Policy and governed by our agreement with the client.

If you encountered a Pulse Insights survey or intervention on another company's website, that company decides what is collected and why. Their privacy policy governs, not this one.

2. Personal Information We Collect

a. Information you give us

• Contact information such as first and last name, professional title, organizational affiliation, postal address, email address, and telephone number.

• Profile information such as username, password, and preferences.

• Communications including information provided when responding to our surveys, participating in market research, taking part in calls that may be recorded with permission where permitted by law, reporting problems, or contacting support.

• Transaction information including billing information and transaction history. Payment card details are handled by our payment processor and are not stored by Pulse Insights.

• Marketing information such as communication preferences and engagement details.

b. Information from third-party sources

• Data providers that supply business contact and firmographic information.

• Business partners with whom we collaborate on joint marketing.

• Public sources such as professional social media platforms.

We may combine this information with information collected directly from you.

c. Information collected automatically

• Device data such as operating system, browser type, screen resolution, IP address, unique identifiers, and general location such as city or region.

• Usage data such as pages viewed, time on page, navigation paths, referring site, and access times.

d. Sensitive personal information

We ask that you not share sensitive personal information with us, including government identification numbers, racial or ethnic origin, political opinions, religious beliefs, health data, biometric data, criminal background, or union membership.

3. How We Use Personal Information

• Service delivery. Operating, maintaining, supporting, and improving the Service and the Site.

• Communication. Service notifications, support, and updates.

• Research and development. Analyzing use of the Site and Service to improve them and to develop new features. This does not extend to Customer Data, which is addressed in Section 1 and in the Data Usage Policy.

• Marketing. Sending promotional communications where permitted by law.

• Compliance and protection. Meeting legal obligations, preventing fraud and abuse, and protecting rights, privacy, safety, and property.

We may be required to disclose personal information processed under the EU-U.S. DPF, the UK Extension, and the Swiss-U.S. DPF in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

4. How We Share Personal Information

We do not sell personal information.

We do use advertising and analytics technologies on our Site, including tags operated by Google, Meta, LinkedIn, Microsoft, and AdRoll. Under some state privacy laws, the use of these technologies is treated as "sharing" personal information for cross-context behavioral advertising, even though we receive no payment for it. You can opt out using the Your Privacy Choices link in the footer of our Site, or by enabling a browser-based opt-out preference signal as described in Section 6.

We otherwise share personal information with:

• Service providers that host our infrastructure, deliver email, monitor errors, and support our operations. These are listed in our Subprocessors list.

• Advertising and analytics partners, as described above.

• Payment processors, for billing.

• Professional advisors, including legal and accounting advisors.

• Legal authorities, where required by law or to protect rights, safety, or property.

• Acquirers, in connection with a merger, acquisition, financing, or sale of assets.

Accountability for onward transfer. We remain responsible for the processing of personal data we receive under the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF and subsequently transfer to a third party acting as an agent on our behalf. We comply with the DPF Principles for all onward transfers, including the onward transfer liability provisions.

5. Artificial Intelligence

We use machine learning models in parts of the Service, and internally for ordinary business purposes such as drafting and analysis. Our providers are OpenAI and Anthropic, and neither retains nor trains on data transmitted through the Service. AI does not operate in the live end user session on client properties.

Our AI Policy describes this in full.

6. Your Choices and Rights

You may:

• Access, correct, or delete personal information we hold about you.

• Request a portable copy of your personal information.

• Opt out of marketing while continuing to receive service-related messages.

• Opt out of advertising and analytics sharing using the Your Privacy Choices link in our Site footer.

• Restrict or object to processing based on our legitimate interests.

Opt-out preference signals. We honor browser-based opt-out preference signals, including Global Privacy Control, as an opt-out of sharing for cross-context behavioral advertising for the browser that sends them.

Choice. If personal data covered by this policy is to be used for a materially different purpose than the one for which it was collected or subsequently authorized, or disclosed to a non-agent third party in a manner not specified here, we will give you an opportunity to choose whether to permit that use or disclosure. We will not use sensitive personal data for a new purpose without your affirmative opt-in consent.

To exercise any of these rights, email privacy@pulseinsights.com, call (888) 718-6860, or use the contact form on our Site. We may ask for information to verify your identity. If we decline a request, we will explain why, subject to legal restrictions.

7. Security and Retention

We maintain administrative, technical, and physical safeguards designed to protect personal information, including encryption in transit and at rest, role-based access controls, monitoring, and third-party penetration testing. We maintain a formal control program tracked against the SOC 2, GDPR, US Data Privacy, HIPAA, and EU AI Act frameworks, and are currently undergoing a SOC 2 Type II examination. Further detail is in our Data Usage Policy.

We retain personal information for as long as necessary for the purposes described in this policy and to meet legal, accounting, and reporting requirements. In determining retention periods we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure, the purposes of processing, whether those purposes can be achieved by other means, and applicable legal requirements.

8. Children

The Service is not directed to individuals under 18, and account holders must be 18 or older. We do not knowingly collect personal information from individuals under 18 through the Site or the Service. If we learn we have, we will delete it.

Where a Pulse Insights survey or intervention appears on a client's property, the client determines the audience and is responsible for compliance with laws relating to children's data on that property.

9. Third-Party Links

Our Site links to third-party sites we do not control. This policy does not apply to them.

10. Organization-Administered Accounts

Where an account is administered by an organization, that organization's administrators may be able to access, modify, or restrict data associated with accounts under their control.

11. Changes to This Policy

We will post changes here with an updated effective date. For material changes we will provide notice by email or on the Site before the change takes effect.

12. How to Contact Us

Email: privacy@pulseinsights.com
Phone: (888) 718-6860
Mail: Pulse Insights, LLC, 716 Beacon Street, #590578, Newton Center, MA 02459, Attn: Privacy

13. Information for U.S. State Residents

This section applies to residents of California and of other U.S. states with comprehensive privacy laws, including Virginia, Colorado, Connecticut, Utah, Texas, Oregon, and Montana.

Rights

Depending on your state, you may have the right to know and access the personal information we collect, to correct inaccuracies, to delete it, to receive a portable copy, to opt out of sale, sharing for targeted advertising, or profiling with legal or similarly significant effects, to limit use of sensitive personal information, and not to be discriminated against for exercising these rights. Where your state provides an appeal process for a denied request, we will inform you of it when we respond.

We do not sell personal information. We do share personal information for cross-context behavioral advertising as described in Section 4, and you can opt out through the Your Privacy Choices link or a browser opt-out preference signal.

Categories collected in the preceding 12 months

Statutory category What we collect Sources Purposes Disclosed to Identifiers Contact information, profile information You, third-party sources Service delivery, research and development, marketing, compliance and protection Service providers, advertising partners Commercial information Communications, marketing information You, third-party sources Service delivery, research and development, marketing, compliance and protection Service providers Financial information Billing and transaction information You, our clients Service delivery, compliance and protection Payment processors, service providers Online identifiers Device data You, automatic collection Service delivery, Site operation, research and development, marketing, compliance and protection Service providers, advertising partners Internet or network activity Usage data Automatic collection Service delivery, Site operation, research and development, marketing, compliance and protection Service providers, advertising partners Professional or employment information Contact information, profile information You, third-party sources Service delivery, research and development, marketing, compliance and protection Service providers Audio or visual information Recorded calls, where permitted and with permission You Compliance and protection, service delivery Service providers Inferences Preferences derived from the above Us Service delivery, Site operation, research and development, marketing, compliance and protection Service providers

We retain each category for the period described in Section 7. We may also disclose each category to our affiliates, professional advisors, and in connection with a business transfer.

14. Additional Information for European, UK, and Swiss Users

Controller and contact. Pulse Insights LLC is the controller of personal information covered by this policy. Our privacy contact can be reached at privacy@pulseinsights.com. For Customer Data, our client is the controller and Pulse Insights is the processor, as described in Section 1.

EU representative. Osano International Compliance Services Limited, ATTN: KQWI25, 28 North Wall Quay, Dublin 1, D01 H104, Ireland. Email: privacy@pulseinsights.com.

Legal bases.

Purpose Legal basis Service delivery and Site operation Performance of a contract, or our legitimate interest in providing the Site and Services you request Marketing Consent where required; otherwise our legitimate interest in promoting our business Research and development Our legitimate interest in improving our services and developing new ones Compliance and protection Compliance with legal obligations, or our legitimate interest in protecting rights, privacy, safety, and property Other purposes Your consent, which you may withdraw at any time

Your rights. You may ask us to opt you out of direct marketing, provide access to your personal information, correct inaccuracies, delete it, transfer a machine-readable copy, restrict processing, or object to processing based on legitimate interests. Email privacy@pulseinsights.com. We may request information to verify your identity, and applicable law may require or permit us to decline a request, in which case we will tell you why.

Cross-border transfers. Pulse Insights LLC complies with the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework as set forth by the U.S. Department of Commerce, and has certified adherence to the respective Principles. Pulse Insights LLC has no U.S. subsidiaries or related entities separately adhering to these frameworks. If there is any conflict between this policy and the DPF Principles, the Principles govern. To view our certification, visit https://www.dataprivacyframework.gov/.

FTC enforcement. Our compliance with these frameworks is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.

Independent recourse. Pulse Insights LLC has chosen VeraSafe as its Independent Recourse Mechanism for unresolved complaints under these frameworks, at no cost to individuals. Online complaint form: https://www.verasafe.com/privacy-services/dispute-resolution/submit-dispute/. Mail: VeraSafe, 100 M Street SE, Suite 600, Washington, D.C. 20003, United States.

Binding arbitration. Under certain conditions, individuals may invoke binding arbitration for residual claims, subject to the procedures and conditions in Annex I of the DPF Principles.