Pulsify — Privacy Policy

1. Who we are and what this policy covers

1.1 This policy applies to Pulsify Pty Ltd (ACN 693 476 167) ("Pulsify", "we", "us", "our") and to the Pulsify accounts payable platform at pulsify.tech and app.pulsify.tech (the "Service"), our website, and the free calculators, generators, and other tools we publish on our website (the "Free Tools").

1.2 We are committed to handling personal information in accordance with the Privacy Act 1988 (Cth) ("Privacy Act") and the APPs. Where we handle personal information of individuals located outside Australia, additional laws may apply (see clause 14).

1.3 "Personal information" means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether true or not and whether recorded in a material form or not.

2. The two capacities in which we handle personal information

2.1 Information we handle as a controller (collected directly). When you create an Account, contact us, subscribe to updates, book a demo, or use our website and Free Tools, we decide how and why your personal information is handled. This policy governs that handling.

2.2 Information we handle on behalf of our customers (as a service provider). Our customers (and their advisers, such as bookkeepers and accountants) connect accounting systems and mailboxes to the Service and upload documents. Those connected sources and documents may contain personal information about third parties — for example, supplier contacts and the bank account details on invoices ("Customer Data"). We handle Customer Data on behalf of, and under the instructions of, the relevant customer, who is responsible for that information and for having the right to provide it to us. If you are a supplier or other third party whose information appears in Customer Data and you have a question about it, please contact the business that uses our Service; we will assist that business to respond.

3. The personal information we collect

3.1 Information you give us directly, including: your name, business name, email address, phone number, role, login credentials, billing and payment-method details (processed by our payment provider — see clause 6.3), and the contents of your communications with us.

3.2 Information in Customer Data you or your connected sources provide, which may include: supplier and contact names, email addresses, phone numbers, business identifiers (including ABNs), bank account and BSB numbers appearing on invoices and statements, invoice and transaction details, and the contents of emails in mailboxes you connect to the Service.

3.3 Information we collect automatically when you use the Service, website, or Free Tools, including: device and browser information, IP address, log and usage data, pages viewed and actions taken, and information collected through cookies, analytics, session-analytics, and advertising technologies (see clause 10).

3.4 Information you enter into a Free Tool. Our Free Tools ask you to enter details so the tool can produce a result or document, and those details may include personal information such as names, contact details, employee or supplier details, pay and invoice figures, and bank account details. As explained in clause 9, that information is processed in your browser and is not sent to or stored by Pulsify. If you separately give us your email address to receive updates, we collect and use that email address.

3.5 We do not seek to collect "sensitive information" (as defined in the Privacy Act, such as health information). Please do not route special categories of sensitive information through the Service. Where sensitive information is incidentally contained in Customer Data, we handle it on the customer's behalf under clause 2.2.

4. How we collect personal information

4.1 We collect personal information: directly from you; from your authorised users; from systems and mailboxes you connect to the Service (for example, Xero, MYOB, and email providers); from documents processed through the Service; from public sources such as the Australian Business Register when validating an ABN; and automatically through your use of the Service and website.

4.2 Where it is reasonable and practicable, we collect personal information directly from the individual concerned. Because of the nature of the Service, much of the personal information in Customer Data is provided to us by our customers rather than by the individuals it concerns; clause 2.2 explains how that information is handled.

5. Why we use personal information

5.1 We use personal information to:

(a) provide, operate, maintain, secure, and support the Service, including reading, extracting, coding, validating, matching, and routing invoices and related documents;

(b) provide fraud-risk features, including comparing bank account details against records, checking ABNs against the Australian Business Register, and flagging duplicates and anomalies for review;

(c) create and manage Accounts and authenticate users;

(d) process Fees and manage billing;

(e) communicate with you about the Service, including service, security, and administrative messages, and (where permitted) marketing you can opt out of;

(f) improve, develop, and train the features and accuracy of the Service, subject to clause 8;

(g) understand how our website and Free Tools are used, and measure, target, and improve our marketing and advertising, including working out which advertisements and pages lead people to sign up;

(h) comply with our legal obligations and enforce our agreements; and

(i) handle Customer Data as instructed by the relevant customer.

5.2 We will only use personal information for a purpose for which it was collected, a directly related secondary purpose you would reasonably expect, or another purpose you have consented to or that is permitted by law.

6. Automated processing and disclosure to third parties

6.1 Automated processing and machine learning. The Service uses automated processing, including machine learning, to read and extract data from documents, suggest general ledger codings, classify incoming emails, detect duplicates and anomalies, flag bank-detail changes, validate ABNs, and route items through approval workflows. These outputs are decision-support tools. They are presented to your authorised users for review, and approval and payment decisions are made by people in your business, not by Pulsify and not solely by automated means. We will provide further information about our automated processing on request and will update this policy to meet transparency requirements as they take effect under the Privacy Act.

6.2 Service providers and recipients. We disclose personal information to third parties who help us provide, run, and promote the Service, including: cloud hosting and infrastructure providers; providers of artificial intelligence and machine-learning processing; the accounting and email platforms you connect (for example, Xero, MYOB, and your email provider); product-analytics and session-analytics providers; advertising, tag-management, and marketing platforms (including search, social, and AI-assistant advertising networks); scheduling, form, and email-marketing tools we use to handle enquiries and sign-ups; our payment provider; and professional advisers. We require these providers to handle personal information consistently with this policy and the Privacy Act.

6.3 Payments. We use a third-party payment provider to process subscription Fees. Pulsify does not store full payment-card numbers. The provider handles that information under its own terms and security standards.

6.4 Other disclosures. We may disclose personal information where required or authorised by law, to enforce our terms, to protect our or others' rights and safety, or in connection with a sale or reorganisation of our business (in which case we will require the recipient to protect the information).

6.5 We do not sell personal information.

7. Sending information overseas

7.1 Some of our service providers (including cloud hosting and AI-processing providers) are located, or store data, outside Australia. This means personal information we handle may be disclosed to, or accessed from, recipients in countries including the United States.

7.2 Before disclosing personal information overseas, we take steps that are reasonable in the circumstances to ensure the overseas recipient handles it consistently with the APPs, including through contractual protections. Some countries may not have privacy laws equivalent to Australia's.

8. How we use data to improve the Service and AI features

8.1 We may use personal information and Customer Data to operate, secure, support, and improve the accuracy of the Service, including its automated features.

8.2 We may create and use de-identified and aggregated data derived from use of the Service for any business purpose, including improving our models and the Service, provided that data does not identify any individual, customer, or authorised user. We will not use identifiable Customer Data to train models that we make available to other customers without the relevant customer's consent.

9. Our free tools

9.1 We publish free calculators, generators, and other tools on our website. You do not need an Account to use them, and we do not ask you to sign in.

9.2 What you type into a Free Tool stays in your browser. Free Tools run entirely on your device. The details you enter, and any document or result the tool produces, are processed in your browser and are not transmitted to, collected by, or stored on Pulsify's systems. We cannot see them, and we do not keep a copy. Anything you download or print from a Free Tool is yours to store and share as you see fit.

9.3 What we do collect when you use a Free Tool. We collect the usage and device information described in clause 3.3, such as which tool you used and how you got to it, through the cookies, analytics, session-analytics, and advertising technologies described in clause 10. Some of these technologies record how visitors interact with a page. We take reasonable steps to configure them so that they do not capture what you type into a Free Tool, but they are not a substitute for your own judgement: please do not enter more personal information into a Free Tool than the task requires.

9.4 If you give us your email address. Some Free Tools invite you to give us your email address to receive updates from Pulsify. That is optional, you can use the tool without it, and you can unsubscribe at any time using the link in any email we send.

9.5 The results are general information only. Free Tools produce general information and templates. They are not financial, tax, accounting, or legal advice, and you are responsible for checking that any result or document is correct and appropriate for your circumstances.

10. Cookies, analytics, and advertising

10.1 Our website, Free Tools, and Service use cookies and similar technologies (including tags, pixels, and software development kits) to keep you signed in, remember preferences, measure usage, improve performance, and support our advertising. Some are essential to how the website and Service work; others are optional.

10.2 Analytics and session analytics. We use analytics tools to understand how visitors and users find and move through our website, Free Tools, and Service, including which pages and features are used, and to identify errors and points of friction. These tools may record a replay of how a visitor interacted with a page, such as clicks, scrolling, and navigation. We take reasonable steps to configure them to exclude the contents of forms and Free Tool inputs.

10.3 Advertising and conversion measurement. We advertise Pulsify on third-party platforms, including search, social, and AI-assistant advertising networks. We and those platforms use cookies and similar technologies on our website to measure whether an advertisement led to a visit, a sign-up, or another action, to attribute those actions to the campaign that produced them, and to show relevant advertisements for Pulsify to people who have visited our website. These technologies involve disclosing information such as your device and browser information, IP address, and the pages you visited to those platforms, who handle it under their own privacy policies and may combine it with other information they hold about you. We do not disclose the contents of Customer Data or of anything you enter into a Free Tool to advertising platforms, and we do not sell personal information (clause 6.5).

10.4 Your choices. You can control non-essential cookies through your browser settings, through any cookie controls we provide, and through the ad-settings or opt-out controls offered by the advertising platforms themselves. Many browsers also offer a "do not track" or tracking-protection setting. Disabling some cookies may affect how the website, Free Tools, or Service work.

11. Security and retention

11.1 Security. We implement and maintain reasonable technical and organisational measures designed to protect personal information from misuse, interference, and loss, and from unauthorised access, modification, or disclosure. These include access controls, encryption in transit, and monitoring. No system is completely secure, and we cannot guarantee absolute security.

11.2 Retention. We keep personal information only for as long as needed for the purposes in this policy, to provide the Service, and to meet legal, accounting, and record-keeping obligations. When no longer needed, we take reasonable steps to destroy or de-identify it. On termination of a customer's subscription, we handle Customer Data as set out in our Terms of Service, after which we may delete it (subject to legal retention requirements and to de-identified or aggregated data under clause 8.2).

12. Accessing and correcting your information

12.1 You may ask us to access or correct the personal information we hold about you. We will respond within a reasonable time and in accordance with the APPs. We may need to verify your identity, and in limited cases permitted by law we may decline a request, in which case we will explain why.

12.2 If the personal information is contained in Customer Data we handle on behalf of a customer (clause 2.2), we will refer your request to, or assist, the relevant customer, who is best placed to action it.

12.3 There is usually no charge to make a request. If a request requires substantial effort, we may charge a reasonable fee and tell you in advance.

12.4 We do not hold what you enter into a Free Tool (clause 9.2), so there is nothing for us to give you access to, correct, or delete in relation to that information.

13. Data breaches

13.1 We maintain processes to identify, contain, and assess data breaches. Where a breach is likely to result in serious harm to affected individuals, we will comply with the Notifiable Data Breaches scheme under the Privacy Act, including notifying the Office of the Australian Information Commissioner (OAIC) and affected individuals where required. Where a breach affects Customer Data, we will notify and work with the relevant customer.

14. Individuals and customers outside Australia

14.1 The Service is used by customers in jurisdictions including Australia and New Zealand. If you are located outside Australia, your personal information may be handled in Australia and in the other countries described in clause 7. Additional privacy laws may apply to your information, and where they do, we will comply with them to the extent applicable.

15. Children

15.1 The Service and the Free Tools are business tools and are not directed to, or intended for use by, individuals under 18. We do not knowingly collect personal information from children.

16. Changes to this policy

16.1 We may update this policy from time to time. We will post the updated version with a new "last updated" date and, where changes are material, take reasonable steps to notify you (for example, by email or in-product). The version in force when you use the Service applies.

17. Contact us and complaints

17.1 If you have a question, request, or complaint about how we handle personal information, contact our Privacy Officer:

Privacy Officer, Pulsify Pty Ltd
Email: privacy@pulsify.tech

17.2 We will acknowledge your complaint, investigate, and respond within a reasonable time. If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au, or to the relevant privacy regulator in your jurisdiction.