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Privacy Policy

Version 2.0 · Last updated: September 2026

Ineffable Ventures Corp. d/b/a PulseUP
3158 Northeast 212th Terrace, Aventura, Florida 33180, United States
Privacy contact: privacypolicy@pulseup.ai

This Privacy Policy explains how PulseUP collects, uses, discloses, stores, and otherwise processes personal data in connection with our websites, applications, artificial intelligence solutions, consulting services, learning programs, and related services that link to this Policy (collectively, the “Services”).

Because PulseUP serves both individual users and business customers, our role may differ depending on the context. In some situations, PulseUP determines why and how personal data is processed and acts as a controller or business. In other situations, PulseUP processes personal data on behalf of a business customer and acts as a processor, service provider, contractor, or similar role under applicable law.

1. Who is PulseUP?

In this Privacy Policy, “PulseUP,” “we,” “us,” and “our” refer to Ineffable Ventures Corp., a Florida corporation doing business as PulseUP.

PulseUP is an applied artificial intelligence company that provides enterprise AI consulting, custom AI solutions, autonomous agents, data and personalization solutions, workshops, learning programs, and related professional services.

2. Scope and roles

This Privacy Policy applies to personal data processed through Services that link to this Policy, including our corporate website, contact forms, sales and marketing activities, learning programs, customer support, and PulseUP-operated applications or interfaces.

This Policy does not replace a customer-specific data processing agreement, statement of work, enterprise agreement, or other contract. Where PulseUP processes personal data solely on behalf of a business customer, the customer’s privacy notice and the applicable contract or data processing agreement generally govern that processing.

If another PulseUP product or service provides a separate privacy notice, that notice may apply in addition to, or instead of, this Policy for the relevant processing.

3. Personal data we collect

3.1 Information you provide directly

3.2 Information collected automatically

3.3 Information received from third parties

3.4 Sensitive personal data

PulseUP does not intentionally request sensitive personal data unless it is necessary for a specific Service, legally permitted, and appropriately protected. Business customers should avoid providing sensitive personal data to PulseUP unless it is necessary for the agreed purpose and authorized under applicable law and contract.

4. How we use personal data

Where applicable law requires a legal basis for processing, PulseUP may rely on performance of a contract, steps taken at your request before entering into a contract, legitimate interests, consent, compliance with legal obligations, protection of vital interests, or another lawful basis available under applicable law.

5. Artificial intelligence and automated processing

PulseUP develops and operates AI-enabled solutions and may use artificial intelligence systems, including large language models, speech technologies, machine learning models, retrieval systems, automation tools, and autonomous or semi-autonomous agents, to provide the Services.

5.1 Data processed by AI-enabled Services

Depending on the Service, AI systems may process prompts, instructions, documents, images, audio, voice recordings, transcriptions, messages, customer records, metadata, and other content provided by a user or business customer.

5.2 Third-party AI and infrastructure providers

PulseUP may use third-party model, cloud, communications, analytics, speech, or infrastructure providers to deliver AI-enabled Services. When we do so, we seek to use contractual, technical, and organizational safeguards appropriate to the nature of the processing. Specific providers may vary by product, customer configuration, geography, and technical requirements.

5.3 Model training and service improvement

PulseUP does not treat customer-provided confidential content as freely available training data. Whether particular content may be used to improve a PulseUP service depends on the relevant product configuration, customer agreement, consent, de-identification, and applicable law. Where PulseUP processes personal data solely on behalf of a business customer, we use that data for the customer’s documented purposes and our contractual obligations, unless otherwise authorized by the customer or permitted by law.

Third-party AI providers may have their own data-use terms. Where commercially and technically available, PulseUP may select enterprise, API, privacy, or no-training configurations appropriate to the relevant use case. Customers should review any product-specific terms or data processing addendum for additional details.

5.4 Automated decision-making

Some Services may use automated processing to classify, prioritize, recommend, summarize, score, route, detect patterns, or assist human decision-making. PulseUP does not intend to make solely automated decisions that produce legal or similarly significant effects about an individual unless the use is specifically designed for that purpose, permitted by applicable law, and subject to any required notice, safeguards, or human review.

5.5 Accuracy and human review

AI-generated outputs may be incomplete or inaccurate and should be reviewed appropriately before being used for high-impact decisions. Business customers are responsible for determining whether a particular AI-enabled workflow is appropriate for their use case and for implementing any human oversight required by law, contract, or internal policy.

6. Business customer data

Many PulseUP Services are provided to companies and organizations. When a business customer provides or makes personal data available to PulseUP and determines the purposes and essential means of processing, that business customer generally acts as the controller or business, and PulseUP acts as its processor, service provider, contractor, or similar role.

In those cases, PulseUP processes the data according to the customer’s documented instructions, applicable contract, data processing addendum, and law. Individuals seeking to exercise rights regarding data controlled by a PulseUP customer should generally contact that customer directly. Where appropriate, PulseUP will assist the customer in responding to valid requests.

Business customers are responsible for ensuring they have the rights, notices, consents, and other legal bases necessary to provide personal data to PulseUP and to authorize the intended processing.

7. How we disclose personal data

PulseUP does not sell personal data for money.

We may disclose personal data in the following circumstances:

8. Cookies, analytics, advertising, and tracking technologies

PulseUP and our service providers may use cookies, pixels, tags, SDKs, local storage, analytics tools, and similar technologies to operate the Services, remember preferences, measure performance, understand usage, improve user experience, support security, and, where permitted, measure or personalize marketing.

Depending on the website configuration, third-party tools may collect identifiers, IP address, browser or device information, page activity, referring URLs, and conversion events. We may use analytics services such as Google Analytics and may use advertising or social media technologies only as configured on the relevant website.

Where applicable law requires consent before non-essential tracking technologies are used, PulseUP will seek to implement an appropriate consent mechanism. Where applicable law requires recognition of legally valid opt-out preference signals, PulseUP will seek to honor such signals for the processing to which they apply.

You can also manage cookies through your browser settings. Disabling certain cookies may affect the functionality of the Services.

9. International data transfers

PulseUP is based in the United States and serves customers internationally. Personal data may therefore be processed in the United States and in other countries where PulseUP, our customers, affiliates, or service providers operate.

Where required by applicable law, PulseUP uses legally recognized transfer mechanisms and contractual or organizational safeguards designed to protect personal data transferred across borders. Depending on the jurisdiction, these may include standard contractual clauses, contractual commitments, transfer assessments, or other lawful mechanisms.

10. Data retention

PulseUP retains personal data only for as long as reasonably necessary for the purposes described in this Policy, to provide the Services, comply with contractual and legal obligations, maintain security and business records, resolve disputes, and enforce agreements.

Retention periods vary based on factors such as:

When personal data is no longer required, we seek to delete, anonymize, or otherwise dispose of it in accordance with applicable law, contractual requirements, and our operational processes. Residual copies may remain temporarily in backups or archives until overwritten or deleted in the ordinary course.

11. Data security

PulseUP uses administrative, technical, and organizational safeguards designed to protect personal data against unauthorized access, acquisition, disclosure, alteration, loss, or destruction. Safeguards may include access controls, authentication, encryption where appropriate, logging, monitoring, vendor controls, confidentiality obligations, incident response procedures, and security reviews.

No method of transmission or storage is completely secure. Accordingly, PulseUP cannot guarantee absolute security.

12. Your privacy rights

Depending on where you live and the context in which PulseUP processes your personal data, you may have rights such as:

To exercise a privacy right, contact privacypolicy@pulseup.ai. We may need to verify your identity and authority before completing a request. We may deny or limit a request where permitted by law, and we will explain the reason where legally required.

13. Additional information for California residents

If California privacy law applies to PulseUP’s processing of your personal information, California residents may have additional rights, subject to statutory exceptions and applicability thresholds.

Categories of personal information that PulseUP may collect include identifiers; customer records; commercial information; internet or other electronic network activity; approximate geolocation; professional or employment-related information; audio, electronic, visual, or similar information; inferences; and other information you choose to provide.

PulseUP does not sell personal information for money. Some online advertising or analytics activities may constitute “sharing” or targeted/cross-context behavioral advertising under certain laws depending on how a website is configured. Where applicable, PulseUP will provide legally required opt-out mechanisms and respond to qualifying opt-out preference signals.

PulseUP does not use or disclose sensitive personal information for purposes that require a separate right to limit unless a specific Service states otherwise.

Where California law grants rights regarding certain automated decision-making technologies, profiling, risk assessments, or related processing, PulseUP will provide the notices, choices, and safeguards required for processing to which those rules apply.

14. Additional information for Colombia residents

Where Colombian data protection law applies, PulseUP will process personal data in accordance with applicable principles of legality, purpose, freedom, truthfulness or quality, transparency, restricted access, security, and confidentiality.

Subject to applicable law, data subjects in Colombia may have rights to know, update, rectify, and request proof of authorization regarding their personal data; be informed about the use made of their data; submit complaints before the competent authority; revoke authorization or request deletion where legally available; and access their personal data free of charge in the cases provided by law.

Requests, consultations, or complaints may be submitted to privacypolicy@pulseup.ai. Please include sufficient information for PulseUP to identify the relevant data and respond to the request.

Where PulseUP processes personal data on behalf of a business customer, the customer may be the responsible party for the database or processing activity, and PulseUP may act as a processor. In such cases, individuals should ordinarily direct requests to the relevant business customer.

If personal data is transferred or transmitted outside Colombia, PulseUP will seek to apply the requirements and exceptions provided by applicable Colombian law.

15. Additional information for the EEA, United Kingdom, and Switzerland

Where European data protection laws apply, PulseUP processes personal data on one or more lawful bases, which may include performance of a contract, legitimate interests, consent, compliance with legal obligations, or another lawful basis.

Individuals may have rights of access, rectification, erasure, restriction, objection, data portability, withdrawal of consent, and complaint to a competent supervisory authority, subject to legal conditions and exceptions.

Where PulseUP transfers personal data from the EEA, United Kingdom, or Switzerland to a country that does not provide an equivalent level of protection, we seek to use an appropriate transfer mechanism where required.

16. Children’s privacy

PulseUP’s general business Services are not directed to children under 13, and we do not knowingly collect personal data from children under 13 through our general corporate website. Where a specific educational, customer, or other Service is intended for minors, PulseUP and the relevant business customer will seek to apply the notices, consents, age requirements, and safeguards required by applicable law.

If you believe a child has provided personal data to PulseUP inappropriately, contact privacypolicy@pulseup.ai.

17. Security incidents

PulseUP maintains incident response procedures intended to identify, investigate, mitigate, and respond to suspected security incidents. Where a personal data breach triggers legal or contractual notification obligations, PulseUP will provide notifications as required by applicable law or contract.

The Services may contain links to or integrations with third-party websites, platforms, or services. PulseUP is not responsible for the privacy practices of third parties acting independently from PulseUP. You should review their privacy notices before providing personal data to them.

19. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. We will post the revised version and update the “Last updated” date. Where required by law, we will provide additional notice or obtain consent before a material change becomes effective.

20. Contact us

For questions, privacy requests, or complaints, contact:

Ineffable Ventures Corp. d/b/a PulseUP
||BR|| Attn: Privacy
||BR|| 3158 Northeast 212th Terrace
||BR|| Aventura, Florida 33180
||BR|| United States
||BR|| Email: privacypolicy@pulseup.ai