Privacy Policy

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PulseUp is a dynamic AI solutions provider specializing in crafting personalized machine learning implementations, connecting businesses with global AI thought leaders, and offering comprehensive, self-paced digital learning for ambitious executives. This Privacy Policy describes how we process and handle data provided to PulseUP in connection with your use of our products, services, apps, and websites that link to this policy (we refer to these collectively as our “services”).

Information security and privacy are at the heart of what PulseUP values and promotes as a company. As such, we think it’s important to be transparent about how we handle your information. That level of transparency also makes for a lengthy document, but we’ve tried to make it more readable by organizing it into a logical structure and using plain language.

PulseUP offers a variety of services, and this policy describes our comprehensive approach to ensuring privacy considerations across all our services.  We have some unique approaches to managing data for certain of our products and services. Please refer to “Product Specific Privacy Notices” below for more details.

This policy uses the term “personal data” to refer to information that is related to an identified or identifiable natural person.

In this policy, “PulseUP”, “we”, “us” and “our” refer to the below companies or brands in this section, or the brands listed in the Product Privacy Notices, that are responsible for your data: 

Ineffable Ventures Corp, (a U.S. company)

See the Contact Us section below for our contact details or you can email us at privacypolicy@pulseup.ai

How PulseUP handles your information depends on our relationship with you.

This section describes the various types of information we collect from and about you. The information we may collect may differ depending on which product you use.

For example, our Identity Protection products may collect a significant amount of information about you to help provide our services, but our VPN products only collect a limited amount of information. To understand the context in which collection occurs, see Section 2 (How do we use your information?) and our Product Privacy Notices. More information about some of the mechanisms we use to collect this information, such as cookies, is available in Section 4 (Tracking Technologies & Cookies) and our Cookie Policy.

We and our service providers need to collect certain information about you to provide our services, respond to your requests, and manage your account with us. Where service components go beyond the base service, we provide you with clear choices to decide if you want these additional functions.

• Account information. Some services require or allow you to create an account before you can access them. As part of registering for an account, we may collect information such as your name, username, email address, password and certain other information from you, including if applicable, your Circle account and login information. For our identity protection products, we will also request your Social Security Number and other information.
• Billing and payment information. In order to purchase a service, you may need to provide us with certain details such as billing name, billing contact details (street addresses, email addresses), and payment instrument details.
• Identity verification information. Some services require you to verify your identity as part of creating an account. We may collect information such as email addresses or phone numbers for this purpose.
• Communications and submissions. You may choose to provide us with  information you volunteer when you communicate with us (e.g. via email, phone, or chat for support or to inquire about our services), including when you fill out an online form, respond to surveys, provide feedback, post comments to our website, participate in promotions, participate in forums, websites and related information services to share your experiences or discuss technical issues ,or submit information through our services.
• Camera, Photos.  You may choose to provide us with images and other information from your device’s camera and photos to further enable us to provide the services. For example, you may provide us with a photo of your driver’s license to monitor your license id number. 
• Documents.  You may choose to upload documents and other files to our services that are stored on your device.

In order to continuously improve the levels of service we provide, we automatically collect information about your use of our services to monitor for problems and look for opportunities to make improvements. Some of this information is collected using cookies and similar technologies (see below for more information and how to opt-out of our use of cookies).

• Usage information. We collect information about how you interact with our services, such as how often you use our services, how much bandwidth you use, and when and for how long you use our services.
• Device information. We collect information from and about the device you use to access our services, including about the browsers, PulseUP apps and if applicable, Circle apps you use to access our services. For example, we may collect device identifiers, browser types, device types and settings, operating system versions, mobile, wireless, and other network information (such as internet service provider name, carrier name and signal strength), and application version numbers.
• Diagnostic information. We may collect information about the nature of the requests that you make to our servers (such as what is being requested, information about the device and app used to make the request, timestamps, and referring URLs). However, our VPN product does not log any information that associates your identity with your VPN browsing activity. We do not maintain any records that show what you were browsing or accessing through a VPN connection. See the VPN Product Privacy Notice for more information.
• Location information. Unless otherwise expressly stated, we do not collect your location information based on your device’s GPS or other device sensor data. However, we may collect your approximate location by calculating an imprecise latitude and longitude based on your IP address to provide you with better service (e.g. to connect you to the nearest and fastest VPN server).

As part of our services, we can receive information about you from third parties. We take the same level of precautions and transparency of use that we provide for information you provide us directly.

• Referrals. If you are invited to use an PulseUP service, the person who invited you may submit information about you, such as your email address or other contact information.
• Third Party Accounts. Some services may allow you to register an account using a third-party account (such as a Google or Microsoft account), and in some cases, you may register third party accounts such as your bank accounts or social media accounts with us. If you do so, that third party may send us some information about you that they have. You may be able to control what information they send us via your privacy settings for that third party account.
• Threat Information. We receive information from reputable members of the security industry who provide information to help us to provide, develop, test, and improve our services (for example, lists of malicious URLs, spam blacklists, phone number blacklists, and sample malware). Some of this information may contain personal data on an incidental basis.
• Business Customers. Organizations that use our business and enterprise products may submit personal data to facilitate account management and invite individuals to use those products. We process such information at the direction of such business customers.

Monitoring Services. For some of our products and services, we will collect publicly available information about you from third parties to provide the extent of disclosures to you. For example, court records, home title, auto title, and dark web scanning.

PulseUP uses your information for the purposes described below. PulseUP employs internal risk management functions to ensure we continue to only use your information for the purposes we disclose to you and are taking appropriate steps to protect that data from exposure.

• To provide, maintain, troubleshoot, and support our services. We use your personal data for this purpose on the basis that it is required to fulfill our contractual obligations to you. Examples: using information about how much bandwidth you use and how long you use our services in order to provide the services in accordance with a plan to which you have subscribed; using threat and device information to determine whether certain items pose a potential security threat; and using usage information to troubleshoot a problem you report with our services and to ensure the proper functioning of our services.
• For billing and payment purposes. We use your information in order to perform billing administration activities and process payments, which are required to fulfill our contractual obligations.
• To communicate with users and prospective users. We use your information to communicate with you via email, SMS, push notifications or other messaging about the Services or relevant updates, including by responding to your requests, and sending you information and updates about our services. We may do this in order to fulfill our contract with you, because you consented to the communication, or because we have a legitimate interest in providing you with information about our services.
• To promote, operate or improve our services and advance our or a third party’s legitimate interests. We want to offer you the best services and user experiences we can, so we have a legitimate interest in continually improving and optimizing our services. To do so, we use your information to help ensure the effective delivery of our Services, and communications to you as well as to our other customers and partners. Examples of when we may use your information for this purpose: to notify you about changes to our terms or this Privacy Policy; to promote and administer co-branded offers with trusted partners; enable participation in interactive features of our Services; communicate commercial promotions or inform you about additional Services or features that we think you may be interested in; confirm sales conversions and conduct lead generation activities; analyze certain usage, device, and diagnostic information to understand aggregated usage trends and user engagement with our services (and, for example, invest in technical infrastructure to better serve regions with increasing user demand); use device and threat information or data to conduct spam, scam, threat, fraud and other scientific research to improve our detection capabilities; improve our machine-learning algorithms to enhance our services; we review customer feedback to understand what we could be doing better; use information such as who or what referred you to our services to understand how effective our advertising is; use information to administer promotional activities such as sweepstakes, contests, offers, promotions and referral programs. 
• For measurement, research and analytics, including to develop new services. We have a legitimate interest in using your information for measurement, research and analytics, including to plan for and develop new services. For example, we may analyze certain usage information to understand how users interact with our services and make improvements; we may use customer feedback to understand what new services users may want.
• For advertising and marketing our Services, including through the use of cookies. Our app is not ad supported, and we do not share personal information from our app with third party advertising services.
• Aggregated or anonymized data, for any purpose where the information is aggregated or anonymized so that no individual data is directly, or indirectly, identifiable. 
• To prevent harm or liability. We may use information for security purposes (such as to investigate security issues or to monitor and prevent fraud) and to prevent abuse. We may do this to comply with our legal obligations, to protect an individual’s vital interests, or because we have a legitimate interest in preventing harm or liability to PulseUP and our users. For example, we may use account, usage, and device information to determine if an entity is engaging in abusive or unauthorized activity in connection with our services.
• For legal compliance. We internally use your information as required by applicable law, legal process, or regulation. To learn about our practices regarding sharing your information with third parties for legal compliance purposes, see Section 3.1 below. We also use your information to enforce our legal rights and resolve disputes and complaints.

In some situations, PulseUP may share your information with third parties who may collect, store, use, process and transfer the data for PulseUP. PulseUP employs oversight processes and controls to the secure sharing of data with only trusted parties.

Neither PulseUP, nor any of the companies that comprise PulseUP, sell your personal data (except if you utilize our free products).

We may disclose your information in the following circumstances:

• In accordance with your instructions or consent. For example, some services may allow you to register an account using a third-party account (such as a Google or Microsoft account). If you choose to do so, we will share information with the third-party account provider.
• To your business organization (for our business services). If a business customer is providing you with access to our services through a business account, others in that organization may be able to see and manage your account and the information associated with it (such as an administrator).
• For collaborating with others. Some services may provide ways for different users to interact or collaborate with each other. Your information will be shared in connection with those activities if you choose to engage in them.
• Affiliates. We may share your name, email address, and other contact information with our subsidiaries and affiliates including to better market our collective products and services to you. We and our affiliated entities may also share information with third-party data controllers where such sharing is legally required, such as with the use of certain cookies and related tracking technologies for compliance with specific geographic laws.
• With our partners. We may provide your personal data to partners to confirm your eligibility for joint or co-branded offers or to communicate and administer such offers (e.g. verify eligibility, assess effectiveness of joint offer, etc.). Our partners are not allowed to use any data including personal data that they receive from us for any purpose except for communicating, evaluating, improving, and administering the offer in question. This will not affect the partner’s ability to use personal data that it may already have obtained from you or other sources. If you do not wish to receive promotional emails from our partners, you can unsubscribe directly using the unsubscribe link or tool provided in the partner’s email or other communication to you.
• Third-party service providers. We may disclose the information we collect to service providers to help us provide some aspects of our services, we work with trusted third parties and partners. In cases where we may share your personal data, we enter into appropriate confidentiality and data processing agreements with these third parties, review their security practices, and limit information sharing to the scope of what they are helping us with. Examples of activities that third parties help us with include:
  • processing customer payments
  • providing analytics about our services to help us understand how the services are being used
  • providing sales and customer support
  • maintaining the infrastructure required to provide our services
  • delivering our marketing and advertising content
• For security research purposes. A sanitized subset of our threat intelligence data may be shared with selected reputable members of the cybersecurity industry for the purpose of security threat research and facilitating community efforts to improve online security.
• In connection with a business transaction. If a substantial corporate transaction occurs, for example changes to ownership or control of all or part of our services, assets, or business, sale of a website, initial public offering, or an investment entity is conducting due diligence in connection with an acquisition or investment, then we may share the personal data we collect in connection with that substantial corporate transaction.
• Aggregated or de-identified data. We may aggregate and de-identify any data we collect and use and share such data so that it no longer reveals the identity of an individual user for regulatory compliance, research and analysis, our own marketing and advertising activities and other legitimate business purposes.
• To comply with legal process and the law.  If you use our VPN product, we protect your privacy by ensuring that we do not log or record online activities that you conduct over a VPN connection in any way that can be tied back to you, meaning that we do not have any data to share with law enforcement and government agencies who make requests for information about what you were doing through a VPN connection. Subject to the foregoing, we may share your information if we are required to do so by applicable law; to comply with our legal obligations; to comply with legal process; and to respond to valid law enforcement requests relating to a criminal investigation, or alleged or suspected illegal activity that may expose PulseUP, you, or any of our other users to legal liability. If we share your information for these purposes, we limit the information shared to what is legally necessary, and challenge information requests that we believe are unlawful, overbroad, or otherwise invalid.
• To enforce our rights and prevent fraud and abuse. We may share limited amounts of your information to enforce and administer our agreements with customers and users, and to respond to claims asserted against PulseUP. We may also share your information in order to protect against fraud and abuse against PulseUP, our affiliates, users and others.

About Tracking Technologies

PulseUP collects certain information by automated means when you interact with our Services. Like many companies, PulseUP uses various technologies including “cookies” and related technologies such as pixel tags on our Services to help us collect information, primarily on our websites and in our marketing emails. Our Service Providers (such as analytics providers) may also place cookies and similar technologies on the Services. For convenience, we refer to these as “tracking technologies,” although they are not always used to track individuals.

Tracking technologies include:

• Cookies: Cookies are small portions of text that are stored on the device you use to access our services. Cookies enable us (or third parties that we allow to set cookies on your device) to recognize repeat users. Cookies may expire after a period of time, depending on what they are used for. Please see our Cookie Policy for more details.
• Pixel Tags / Page Tags / Web Beacons / Tracking Links: These are small, hidden images and blocks of code placed in web pages, ads, and our emails that allow us to determine if you perform a specific action. When you access a page, ad, or email, or click a link, these items let us know that you have accessed that page, opened an email, or clicked a link.
• SDKs: SDKs or software development kits are software code provided by our business partners that let our software interact with the services those partners provide. For example, in our free mobile apps, we may use an SDK to enable our app to serve ads from an advertising network. Sometimes these interactions will involve that business partner collecting some information from the device on which the software is run.
• Google Analytics: We use Google Analytics to help us understand how users use our services. Google makes available a Google Analytics Opt Out Browser Add-On if you do not want to participate in Google Analytics.

When you visit Our Site, PulseUP may view and/or store the IP address of the device you are using. PulseUP uses this information to determine the general physical location of the device and understand from what regions of the world Our Site’s visitors come from. PulseUP also may use this information to enhance the Site.

Opt-out of receiving marketing communications from PulseUP- you may elect for us not to contact you for marketing purposes, by emailing us at privacypolicy@PulseUP.ai or following the instructions in the section below labeled Your Rights with your Personal Data. Some browsers offer a “Do Not Track” (“DNT”) signal whereby you may indicate your preference regarding tracking and cross-site tracking. PulseUP does not currently recognize or respond to DNT signals.

Depending on your country of residence, you may have certain legal rights in relation to your personal data that we maintain. Subject to exceptions and limitations provided by applicable law, these may include the right to:

• Access and receive a copy of your personal data we have collected from You or shared in the past 12 months;
• Update or correct your personal data if it changes or if you believe that any information that we have collected about you is inaccurate or out-of-date;
• To object to or restrict our use or processing of your personal data;
• Email marketing - unsubscribe to our email list by clicking the link at the bottom of marketing emails.
• SMS marketing - you can reply with the word ‘Stop’ to any SMS in order to unsubscribe  
• Tailored advertising using third party cookies - refer to our list of advertising services using cookies here for company-specific choices, or visit http://optout.aboutads.info to exercise an industry-wide opt-out. In addition, you may reject or delete cookies through your browser settings. 
• Request that we delete or erase your personal data;
• Data portability;
• If we are relying on your consent to process your personal data, you have the right to withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing We conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent.
• Lodge a complaint with a data protection authority;
• Request that we provide you with the categories of personal data we collect, disclose or sell about you; the categories of sources of such information; the business or commercial purpose for collecting or selling your personal data; and the categories of third parties with whom we share personal data. This information may also be provided in this Privacy Policy.

Please note your rights and choices vary depending upon your location, and some information may be exempt from certain requests under applicable law.

You may be able to exercise some of these rights by using the settings and tools provided in our services. For example, you may be able to update your user account details via the relevant account settings screen of our apps. You may also be able to opt out from receiving marketing communications from us by clicking an “opt out” or “unsubscribe” link in such communications. Specifically, the GDPR gives users residing in the EU the rights to access, correct, delete, or object to the processing of your personal information. 

For all users, if you wish to exercise any of these rights, you may also contact us using the details in the “Contact Us” section below. As permitted by law, we may ask you to verify your identity before taking further action on your request. 

We may revise this policy from time to time. Review it occasionally so that you keep up-to-date on our most current practices. We will put the ‘Last Updated’ date at the top of each policy. If you disagree with such an update to this policy, you may cancel your services account. If you do not cancel your account before the date the update becomes effective, your continued use of our services will be subject to the updated Privacy Policy.

We expect this Privacy Policy to evolve over time and welcome feedback from our users about our privacy practices. If you have any questions or complaints about our privacy practices, you can contact us at  privacypolicy@PulseUP.com or at the following addresses, based on the product that you use:

Ineffable Ventures Corp  dba PulseUP

2980 NE 207th St STE 307, Aventura, FL 33180, Estados Unidos

privacypolicy@pulseup.ai