Privacy Policy

1. Introduction

1.1 This Privacy Policy ("Policy") explains how Ackrolix Innovations Private Limited ("Puls-E", "we", "us", "our") collects, uses, stores, shares and protects your information when you use the Puls-E mobile application and any related website, mobile site or connected service (together, the "Platform") and the services offered through it (the "Services").

1.2 This Policy is to be read together with our Terms & Conditions and Cancellation & Refund Policy. Capitalised terms not defined here carry the meaning given in the Terms & Conditions.

1.3 By creating an Account or using the Services, you confirm you have read and understood this Policy. Where the law requires consent, we will ask for it separately and explicitly — your use of the Platform alone is not treated as consent to process sensitive data.

1.4 This Policy is an electronic record under the Information Technology Act, 2000 and does not require a physical or digital signature.

1.5 We comply with the Digital Personal Data Protection Act, 2023 (India), the Information Technology Act, 2000 and rules thereunder, the EU/UK General Data Protection Regulation where applicable, and other applicable data protection laws.

2. Who we are and how to reach us

3. Age requirement — 18+ only

3.1 The Platform is intended solely for users aged 18 or older. We do not permit anyone under 18 to create an Account or use the Services.

3.2 We verify age at sign-up. Because your date of birth is a mandatory input to your astrological reading, we use it to confirm eligibility. An Account showing a date of birth less than 18 years prior to the date of registration will not be activated.

3.3 We do not knowingly collect personal data from any person under 18. If we become aware that a user is under 18, or that an Account was created using inaccurate date-of-birth information, we will suspend the Account and delete the associated personal data — including birth details, reflections, chat history and derived pattern data — without further notice.

3.4 We further reserve the right to terminate any Account where, in our reasonable judgement, continued use is unsuitable for the user.

3.5 If you believe a person under 18 has provided us with personal data, contact privacy@puls-e.ai and we will delete it promptly.

3.6 Minors and Users below the age of 18: We reserve the right to terminate accounts of minors who are using our services if we believe the environment around our platform is not safe for a minor, at our discretion. Children under the age of 13 are not deliberately given their personal information by Pulse - Pattern Intelligence. Please do not submit any Personal Data through the Services if you are under the age of 13, as you will not be allowed to utilise the Services. Please get in touch with us if you think a child under the age of 13 may have provided Pulse - Pattern Intelligence with Personal Data through the Services, and we'll do our best to remove that data from our records.

3.7 Child Safety Standards — prohibition of CSAE. Pulse - Pattern Intelligence has zero tolerance for Child Sexual Abuse and Exploitation (CSAE). We strictly prohibit any content, conduct or use of the Platform that sexualises, exploits, endangers or harms children, including the creation, storage, sharing or solicitation of child sexual abuse material (CSAM). Any violation of these standards will result in immediate account termination and, where appropriate, reporting to the relevant law-enforcement and child-safety authorities. If you have a child-safety concern relating to Pulse - Pattern Intelligence, please contact our designated child-safety contact at privacy@puls-e.ai, and we will review and act on your report promptly.

4. Definitions

4.1 "Personal Data" — any data about an individual who is identifiable by or in relation to such data, including name, email, phone number, date of birth, time of birth, place of birth and address.

4.2 "Sensitive Personal Data" — data which, if disclosed, could cause harm, including: (i) account credentials; (ii) financial information; (iii) physical, physiological and mental health conditions; (iv) mental wellbeing indicators; (v) medical records; (vi) biometric data; (vii) sexual orientation; (viii) astrological birth data (date, time and place of birth) used to generate personalised profiles; and (ix) precise geolocation.

4.3 "Non-Personal Data" — data that does not identify you, including aggregated statistics, device type, OS version and anonymised logs.

4.4 "Processing" — any operation performed on data, including collection, storage, use, analysis, disclosure, transfer and erasure.

4.5 "Reading" — any output generated for you by the Platform, including your day score, the thirteen daily parameters, peak and risk windows, muhurat guidance, personality profile, compatibility reading, pattern report or Puls-e AI response.

5. Information we collect

5.1 Information you provide directly

5.2 Information collected automatically

(a) Precise device location. Where you grant operating-system permission, we collect your device's latitude, longitude and timezone. This is used solely to anchor time-sensitive astrological calculations — your Peak and Risk windows, Rahu Kaal, Yama Ganda, Abhijit Muhurta and muhurat guidance — to where you physically are, so the guidance remains accurate when you travel. You may revoke this permission at any time in device settings, after which we fall back to the place of birth or profile location saved on your Account. We do not use location for advertising, and we do not build a location history or movement profile.

(b) Device and technical data. Device type and model, unique device identifier, operating system and version, app version, carrier, browser type, language, timezone and IP address.

(c) Usage data. Features accessed, screens viewed, session start and end times, login timestamps, notification delivery and interaction, and searches conducted in the Platform.

(d) Cookies and similar technologies — see Clause 16.

5.3 Information from third parties

(a) Social sign-in. You may register using Google, Apple or Facebook. This uses OAuth: you authenticate directly with that provider, and we receive only the limited profile fields you approve — typically name, email address and profile image. We never ask for, receive, or store your password for any third-party service.

(b) Payment processor. We receive confirmation of payment status and a transaction reference from our payment providers. See Clause 5.4.

5.4 Payment information

Upon subscribing, we collect your subscription plan, billing cycle, renewal date and transaction reference.

We do not collect, receive or store your card number, CVV, UPI PIN, net-banking credentials or bank account details at any time. These are handled exclusively by:

• Razorpay Software Private Limited (PCI-DSS Level 1, RBI-authorised) for web and Android purchases; and
• Apple Inc. or Google LLC where you purchase through their in-app billing systems.

5.5 Information we do not collect

We do not collect biometric data, government identity numbers (Aadhaar, PAN, passport), contact lists, photo library contents, microphone or camera data, SMS or call logs, or health data from any device health platform.

6. Sensitive Personal Data — special protections

6.1 We recognise that the following categories, which are central to the Services, are sensitive: your date, time and place of birth; your mood, anxiety, overthinking and wellbeing indicators; and any health or personal circumstance you disclose in a reflection or in conversation with Puls-e AI.

6.2 We process Sensitive Personal Data only on your explicit, informed and separately obtained consent, and only to deliver the Services you request.

6.3 We never use Sensitive Personal Data for advertising, never sell it, and never disclose it to another user without your explicit consent.

6.4 You may withdraw consent to sensitive processing at any time under Clause 14. Doing so will limit or end your ability to receive Readings, as birth data is indispensable to them.

7. How and why we use your information

We do not sell your personal data. We do not serve behavioural or targeted advertising. We do not share your data with data brokers.

8. Artificial intelligence and automated processing

This clause is important; please read it in full.

8.1 Your Readings are computed, not judgements about you

Your day score, parameters, timing windows, patterns and profiles are generated by our proprietary astrological and analytical engine from your birth data and your own entries. They are provided for self-reflection and entertainment. They produce no legal or similarly significant effect. We do not use them, and do not permit them to be used, to make or inform decisions about your credit, employment, insurance, education, housing, healthcare or access to any service.

8.2 Third-party AI processing — what leaves our systems

To generate conversational replies in Puls-e AI, and to compose the written text of your daily readings, advisories, pattern summaries and compatibility insights, we transmit to a third-party large-language-model provider, OpenAI, acting as our processor under a written data-processing agreement:

• the message text you send to Puls-e AI;
• relevant context from your current Reading (scores, windows, chart-derived facts computed by our own engine);
• limited profile context (such as first name and prior turns in the conversation);
• for compatibility insights, the display names and chart-derived compatibility facts of the people being compared.

Your raw birth date, time and place, email address, phone number, contacts and payment details are not sent to the AI provider; readings are computed on our own servers and only the derived context above is shared.

This means anything you type into Puls-e AI — including any health, relationship, financial or emotional information you choose to share — is transmitted to that provider for the sole purpose of composing a reply.

The provider is contractually prohibited from using your data to train or improve its models, from retaining it beyond what is necessary to return a response, and from using it for any purpose of its own.

Please avoid entering information you would not wish to be processed in this way.

8.3 Behavioural profiling

Your Personal Model and weekly/monthly pattern reports involve analysis of your activity and reflections over time. This constitutes profiling under applicable law. It is carried out on the basis of the consent you give when you accept this Policy at registration, and deleting your Account erases all derived pattern data.

8.4 Your controls

AI processing is integral to the Services: every reading, pattern and assistant reply depends on it, so it cannot be switched off separately. You may: (i) clear your Puls-e AI conversation history at any time from within the chat; (ii) request human review of any output that concerns you by contacting privacy@puls-e.ai; and (iii) withdraw your consent entirely by deleting your Account in Settings, which permanently erases your personal data and all derived pattern data. If you do not wish your data to be processed as described in this clause, please do not use the Services.

9. Wellbeing, crisis situations, and what Puls-E is not

9.1 Puls-E is not a medical device, not a diagnostic or therapeutic tool, and not a substitute for professional medical or mental-health care. The Anxiety, Overthinking, Mood and Decision-making indicators are reflective signals derived from your chart and your own entries. They are not clinical assessments and must not be treated as such.

9.2 If our systems detect language suggesting self-harm, suicidal ideation or acute crisis, Puls-e AI will cease providing astrological guidance and will surface crisis helpline information instead.

9.3 We do not contact emergency services, family members, or any third party on your behalf, and we do not monitor your account for crisis outside of an active conversation. You must not rely on Puls-E in an emergency.

9.4 If you are in distress or danger, contact local emergency services, or in India: Tele-MANAS 14416 or KIRAN 1800-599-0019.

9.5 We retain a minimal, access-restricted record that a safety response was triggered, for the purpose of improving the safety system. This record is not used for profiling or shared with any third party.

10. Who we share your information with

We share Personal Data only as set out below.

10.2 Other users. In a Compatibility Reading, the other party sees only your display name and profile photo. Your date of birth, time of birth, place of birth, gender, reflections, chat history and pattern data are never disclosed to another user without your explicit, separate consent.

10.3 Legal disclosure. We may disclose data where required by law, court order, or a lawful request from a governmental or law-enforcement authority. Where permitted, we will notify you first.

10.4 Business transfer. In a merger, acquisition, reorganisation or sale of assets, your data may be transferred to the successor entity, subject to equivalent protections. We will notify you of any change in the identity of the data fiduciary.

10.5 Professional advisers. Auditors, lawyers and insurers, under confidentiality obligations, where necessary.

10.6 We do not sell, rent, or trade your Personal Data.

11. International transfers

11.1 The Platform is hosted on Amazon Web Services (AWS) across multiple locations. Certain processors listed in Clause 10 operate outside India, notably the AI provider.

11.2 Where we transfer data from the EEA or UK to a country without an adequacy decision, we rely on Standard Contractual Clauses together with supplementary technical and organisational measures. Copies are available on request at privacy@puls-e.ai.

11.3 Where you access the Platform from outside India, you acknowledge your data will be processed in India, which may have data protection standards that differ from your jurisdiction.

12. How long we keep your data

12.2 We may retain data beyond these periods only where required for legal claims, regulatory obligations or dispute resolution, and only for so long as necessary.

13. Security

13.1 We implement appropriate technical and organisational safeguards, including:

• TLS 1.2 or higher for all data in transit;
• AES-256 encryption for data at rest;
• passwords stored only as salted cryptographic hashes, never in plain text;
• role-based access control, restricting Personal Data to personnel who require it;
• mandatory confidentiality obligations and periodic training for such personnel;
• logging and monitoring of administrative access;
• periodic security review and vulnerability assessment.

13.2 Breach notification. In the event of a personal data breach we will notify the Data Protection Board of India and affected users as required under Section 8(6) of the DPDP Act, and, where GDPR applies, the relevant supervisory authority within 72 hours of becoming aware.

13.3 Your responsibilities. You must keep your credentials confidential and not share Account access. Notify us immediately at privacy@puls-e.ai of any suspected unauthorised access.

13.4 No method of transmission or storage is completely secure, and while we work hard to protect your information we cannot guarantee absolute security. Nothing in this Clause limits your statutory rights, or our liability, where applicable law does not permit such limitation.

14. Your rights

14.1 You have the following rights, exercisable free of charge:

• (a) Access — obtain confirmation of processing and a copy of your data.
• (b) Correction — have inaccurate or incomplete data corrected.
• (c) Erasure — have your data deleted (see Clause 15).
• (d) Restriction — restrict processing in defined circumstances.
• (e) Portability — receive your data in a structured, machine-readable format, or have it transmitted to another controller.
• (f) Objection — object to processing based on legitimate interests, and to profiling.
• (g) Withdraw consent — at any time, without affecting prior lawful processing.
• (h) Not be subject to solely automated decision-making producing legal or similarly significant effects, and to obtain human review (see Clause 8).
• (i) Nominate — nominate another individual to exercise your rights in the event of death or incapacity (DPDP Act, Section 14).
• (j) Grievance redressal — Clause 21.
• (k) Complain to the Data Protection Board of India or your local supervisory authority.

14.2 How to exercise. Use in-app Settings where available, or email privacy@puls-e.ai. We may request proportionate verification of identity before acting.

14.3 Timeline. We respond within 30 days. Complex requests may be extended by a further 30 days with notice.

14.4 No fee. We do not charge for responding to any rights request.

15. Account deletion

15.1 You can delete your Account and all associated personal data directly in the app: Settings → Account → Delete Account. No email, no request form, no fee.

15.2 Account deletion is available only within the app. If you cannot access the app, contact privacy@puls-e.ai and we will assist you with deletion.

15.3 On deletion we erase your birth details, profile, reflections, Puls-e AI history, Personal Model and pattern data, and notification tokens. Deletion completes within 30 days, during which the Account is deactivated and recoverable on request.

15.4 We retain only what law requires — principally payment and invoice records under Clause 12 — and anonymised aggregate statistics that cannot be linked to you.

15.5 Deleting your Account does not automatically cancel or refund an active subscription. See the Cancellation & Refund Policy.

16. Cookies and tracking

16.1 Our website uses strictly necessary cookies (session, security, load balancing) and, with your consent, analytics cookies. You may manage preferences through our cookie banner or your browser.

16.2 Our mobile application does not use cookies. It uses a device identifier for authentication and crash reporting.

16.3 We do not use advertising identifiers (IDFA / GAID), advertising SDKs, cross-app tracking, or cookies for behavioural advertising on any surface.

16.4 We honour "Do Not Track" and Global Privacy Control signals where technically supported.

17. Communications and marketing

17.1 Transactional messages — payment confirmations, security alerts, policy changes and service notices — are necessary to the Services and cannot be opted out of while your Account is active.

17.2 Promotional messages and daily insight notifications are sent only with consent, via the channels you approve (email, SMS, WhatsApp, push, in-app). You may opt out at any time through in-app Settings, device notification settings, or the unsubscribe link, without deleting your Account.

18. Third-party links and services

The Platform may link to third-party websites or applications not operated by us. This Policy does not apply to them, and we are not responsible for their privacy practices. Please review their policies before providing information.

19. Feedback and unsolicited information

19.1 If you voluntarily send us ideas, suggestions, feature requests, reviews or other feedback about the Platform ("Feedback"), by any channel, you agree we may use, reproduce, modify and implement that Feedback without restriction, compensation, credit or confidentiality obligation.

19.2 This applies only to ideas about the product. It does not apply to any Personal Data, Sensitive Personal Data, health or wellbeing information, or birth details you may include. Such information remains fully protected under this Policy however you send it to us, and we will not publish, disclose or commercially exploit it. Personal information sent to support is handled on the same terms as data collected in-app.

20. Changes to this Policy

20.1 We may update this Policy. The version in force is always published on the Platform with its effective date.

20.2 Material changes will be notified to your registered email address and in-app at least 7 days before taking effect. Where a change requires consent under applicable law, we will obtain fresh consent rather than rely on continued use.

20.3 Please keep your email address current. We are not responsible for failure to receive notice where the registered address is inactive or incorrect.

21. Grievance Officer and Data Protection Officer

In accordance with the Information Technology Act, 2000, the Information Technology (Reasonable Security Practices) Rules, 2011, the Consumer Protection (E-Commerce) Rules, 2020, and the DPDP Act, 2023:

Name: Janendra Gulati
Designation: Grievance Officer & Data Protection Officer
Address: 136-P, 3rd Floor, Rider House Building, Sector 44, Gurugram-122003, Haryana, India
Email: privacy@puls-e.ai
Phone: +91 124 449 5878
Hours: Monday–Friday, 10:00–18:00 IST
We acknowledge grievances within 24 hours and resolve them within 30 days.

22. Jurisdiction-specific rights

22.1 EEA / UK. Legal bases are set out in Clause 7. You may lodge a complaint with your national supervisory authority. We have not appointed an EU/UK representative; for any data protection query, contact us at privacy@puls-e.ai.

22.2 California. You may request disclosure of categories of personal information collected, used and disclosed; request deletion; and opt out of "sale" or "sharing". We do not sell or share personal information as defined by the CCPA/CPRA. We will not discriminate against you for exercising these rights.

22.3 India. You have the rights set out in Chapter III of the DPDP Act, 2023, including the right to nominate. Complaints may be escalated to the Data Protection Board of India after exhausting our grievance process.