/ Privacy Policy

Privacy Policy

1. We respect your privacy rights and recognize the importance of secure transactions and information privacy. This Privacy Policy describes how Pulse91 Limited and its affiliates (collectively “Pulse91, we, our, us”) collect, use, share or otherwise process your personal information through Pulse91 website www.pulse91.com, its mobile application, and m-site (hereinafter referred to as the “Platform”).

2. This Privacy Policy is an electronic agreement formed under the Information Technology Act, 2000 and the rules and regulations made there under (as amended till date) including the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 & the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021. It does not require any physical or digital signatures to make the terms of this policy binding. This privacy policy is a legally binding document. The terms of this privacy policy will be effective upon your use of our Platform /service. Please read this policy carefully, together with our Terms of Services (https://www.pulse91.com/Terms-of-Use).

3. By visiting our Platform, providing your information or availing our product/service, you expressly agree to be bound by the terms of this Privacy Policy and the applicable Terms of service. While accessing or using our platform/services, you have given explicit consent to collect, use, share or otherwise process your information in accordance with this Privacy Policy. If you do not agree, please do not access or use our Platform or service.

Application of Policy:

1. This policy governs each website, mobile site, application, and/or other service, regardless of how distributed, transmitted, published, or broadcast (“Service”) provided by Pulse91 Limited and/or its affiliates (“we,” “us,” or “our” or “Pulse91”) that links to this policy, which is binding on all those who access, visit and/or use Pulse91’s Services, i.e., Listing Service, Search Plus Services, JD Mart, JD Pay, JD Omni, JD Xpert, JD Shopping etc.,. This policy shall apply equally to all of our vendors, service providers, subcontractors, partners, agents, representatives, employees, and any other third parties. Pulse91 undertakes to only collect and use personal data voluntarily provided by you. You are able to browse our platform without disclosing any personal information about them. However you have to provide limited personal data to us, as may be required, in order to register or to avail certain services from us.

2.This policy applies to all contractors, suppliers, customers, users, vendors, sellers, partners, and other third party working on behalf of Pulse91 or accessing or using our platforms/service. It also applies to the head office, branches office and other offices of Pulse91 and all employees/officials of Pulse91. It applies to all data that Pulse91 holds relating to identifiable individuals, even if that information technically falls outside of the Privacy & Data Protection law. The said information includes, Names, address, mobile/telephone numbers, email Id of users and any other information collected or received by users while accessing or using our platforms/service.

3.This Privacy Policy is part of Pulse91’s Terms of Service and covers the treatment of user information, including personally identifying information, obtained by Pulse91, including information obtained when you access the Pulse91 platform, use the Pulse91 Service or any other software provided by Pulse91. Unless otherwise stated explicitly, this Policy applies to Personal Information as disclosed on any of our Platform. This policy does not apply to the practices of organizations that we do not own or to people that we do not employ or manage.

Objectives of policy:

1. Pulse91 is required to collect & use certain information about individuals, i.e., customers, suppliers/vendors, business contacts, employees, and the third parties with whom Pulse91 has a business relationship or may need to contact. This policy describes, how Pulse91 collects, receives, possesses, stores, deals or handle personal information including sensitive personal information about you and ensure that the same are available for review by you. The personal information must be collected, handled and stored to meet the data protection standards as well as legislative requirements. This policy ensures to comply with data protection law and follows the good practice and protects the rights of employees, customers, suppliers/vendors, business contacts, employees, and the third parties and how to stores and processes data and protects from the risks of data breach.

Collection of Information:

1. In the course of carrying out its various functions and activities, Pulse91 collects information from individuals & third parties and generates a wide range of information which is stored at our platform. These information can take many different forms, such as, corporate records, financial records, legal records, contracts, letters received from third parties, personnel/employees records, invoices, completed application forms, contact lists, email communications and attachments, photos etc.,. Pulse91 collects information in order to provide and continually improve its products & services. The information may be collected online or offline. Regardless of the collection method, the same privacy protection shall apply to all data/information including personal information.

2.We collect Personal Information from you in a variety of ways when you interact with us through our services, such as, installing, accessing, or using our Services; Create an account on our services; Request customer service or contact us; Conduct a transaction where we collect personal information, including when required by law and regulations; Submit a testimonial, rating or review, or other user-generated content that may be posted; Otherwise submit personal information to us along with any related content of the communication.

Transparency & Accountability Measures:

Privacy by Design: (a). Pulse91 shall implement policies and measures to ensure that managerial, organisational, business practices and technical systems are designed in a manner to anticipate, identify and avoid harm to you;
(b). Pulse91 shall implement policies and measures to ensure that the technology used in the processing of personal data is in accordance with commercially accepted or certified standards;
(c). Pulse91 shall implement policies and measures to ensure that the legitimate interest of businesses including any innovation is achieved without compromising privacy interests;
(d). Pulse91 shall implement policies and measures to ensure that privacy is protected throughout processing from the point of collection to deletion of personal data and processing of personal data is carried out in a transparent manner and the interest of the data provider is accounted for at every stage of processing of personal Data.

Transparency: Pulse91 shall take reasonable steps to maintain transparency regarding its general practices related to processing personal data and shall make the following information available in an easily accessible form as may be specified - the categories of personal data generally collected and the manner of such collection;
(a). the purposes for which personal data is generally processed;
(b). any categories of personal data processed in exceptional situations or any exceptional purposes of processing that create a risk of significant harm;
(c). the existence of and procedure for the exercise of data principal rights;
(d). the existence of a right to file complaints to the Authority;

Security Safeguards:Having regard to the nature, scope and purpose of processing personal data undertaken, the risks associated with such processing, and the likelihood and severity of the harm that may result from such processing, Pulse91 shall implement appropriate security safeguards including (a) use of methods such as de-identification and encryption; (b) steps necessary to protect the integrity of personal data; and (c) steps necessary to prevent misuse, unauthorised access to, modification, disclosure or destruction of personal data. Pulse91 shall undertake a review of its security safeguards periodically as may be specified and may take appropriate measures accordingly.

Personal Data Breach: Pulse91 shall notify the Authority of any personal data breach relating to any personal data processed by Pulse91 where such breach is likely to cause harm to any data principal. The said notification includes, (a) nature of personal data which is the subject matter of the breach; (b) number of data principals affected by the breach; (c) possible consequences of the breach; and (d) measures being taken by the data fiduciary to remedy the breach.

Record-Keeping: Pulse91 shall maintain accurate and up-to-date records of the following: (a) important operations in the data life-cycle including collection, transfers, and erasure of personal data to demonstrate compliance; (b) periodic review of security safeguards; (c) data protection impact assessments;

Data Audits: Pulse91 shall have its policies and the conduct of its processing of personal data audited annually by an independent data auditor. The data auditor will evaluate the compliance of Pulse91 with the provisions of law including (a) clarity and effectiveness of notices, transparency, security safeguards, instances of personal data breach and response thereto.

Monitoring and Enforcement:

Dispute Resolution & Recourse:Pulse91 shall define and document a cyber-incident management program which addresses the data protection & privacy related incidents. The incident management program includes a clear escalation path up to the executive management, legal counsel, and the board based on type and/or severity of the data breach. It shall define a process to register all the incidents/complaints and queries related to data breach. Pulse91 shall perform a periodic review of all the complaints related to data breach to ensure that all the complaints are resolved in a timely manner and resolutions are documented and communicated to the data principals. An escalation process for unresolved complaints and disputes which shall be designed and documented and the Communication of privacy incident / breach reporting channels and the escalation matrix shall be provided to all data providers.

Dispute Resolution & Escalation Process for Employees: Employees with enquiries or complaints about the processing of their personal information shall first discuss the matter with their immediate reporting manager. If the employee does not wish to raise an inquiry or complaint with their immediate reporting manager, or if the manager and employee are unable to reach a satisfactory resolution of the issues raised, the employee shall bring the issue to the attention of the Grievance Officer.

Dispute Resolution & Escalation Process for Customer / Third Party: Customers / Third Party with inquiries or complaints about the processing of their personal information shall bring the matter to the attention of the Grievance Officer in writing. Any disputes concerning the processing of the personal information of non-employees shall be resolved through arbitration.

Terms of Use, Policy & Revisions:

(a). If you choose to use Pulse91 Services, your use and any dispute over privacy is to this policy and our Terms of Use, including limitations on damages, resolution of disputes, and application of the prevailing law in India. If you have any concern about privacy at Pulse91, please contact us with a thorough description, and we will try to resolve it. Our business changes constantly and our Privacy policy will change also. You should check our websites frequently to see recent changes.
(b). Unless stated otherwise, our current Privacy Policy applies to all information that we have about you and your account. We assure that will never materially change our policies and practices to make them less protective of your information collected in the past without your consent.

Grievance Officer:

1. In accordance with Information Technology Act 2000 and rules & regulations made thereunder, the name and contact details of the Grievance Officer are provided below:

Name : Mr. Prateek Arora
Address: Pulse91, 365/6 New Sadak, Shastri nagar(Meerut)
Contact No: 9897007932
Email: grievanceofficer@pulse91.com

2. If you have a query, issue, concern, or complaint in relation to collection or usage of your personal information under this Privacy Policy, please contact us at the contact information provided above or write to us at privacy@pulse91.com /grievanceofficer@pulse91.com.