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Privacy Policy

Last Updated: 1 December 2025

Public Pulse Pty Ltd (ACN 668 509 019, ABN 90 668 509 019) (“we”, “us”, “our”, “Company”) is committed to protecting your privacy. This Privacy Policy describes how we collect, use, disclose, store, and safeguard your personal information when you visit our website or use our platform (collectively, the “Platform”).

1. Our Commitment to Privacy

We are bound by the Privacy Act 1988 (Cth) (the “Privacy Act”) and the Australian Privacy Principles (“APPs”) contained therein. We are committed to handling your personal information in accordance with the Privacy Act and the APPs.

2. Collection of Personal Information

2.1 Types of Information Collected

We collect personal information that is reasonably necessary for our functions, including:

  • Identity Data: Full name, job title, role, username, or similar identifiers.
  • Contact Data: Email address, telephone number, and postal address.
  • Account Credentials: Username, password (encrypted), and authentication data.
  • Constituent Data: Information uploaded by you regarding your constituents (e.g., names, addresses, correspondence history). This may include Sensitive Information within the meaning of the Privacy Act (such as political opinions or affiliations).
  • Technical Data: IP address, browser type, time zone, and device information.
  • Usage Data: Information about how you use and interact with our Platform.
  • Communications Data: Records of your communications with us.
  • Payment Information: Billing address and payment method details (processed by our third-party payment processor).

2.2 Methods of Collection

We collect personal information:

  • Directly from you: When you register, subscribe, complete forms, or contact support.
  • Automatically: Through cookies, server logs, and similar technologies as you navigate the Platform.
  • From third parties: Including payment processors, authentication providers (Google, Microsoft), and analytics providers.

3. Purposes for Collection, Use, and Disclosure

3.1 Primary Purposes

  • Service Provision: To provide, operate, maintain, secure, and improve the Platform.
  • Account Management: To create and manage your account and subscriptions.
  • Customer Support: To respond to enquiries and provide technical support.
  • Billing and Payment: To process payments and manage billing.
  • Security: To detect, prevent, and respond to fraud and security incidents.
  • Legal Compliance: To comply with applicable laws and regulations.

3.2 AI and Machine Learning

We use anonymised and aggregated usage data (including interactions with AI features) to train, test, and improve our AI and machine learning models. We do not use identifiable Customer Data to train general-purpose public AI models without your prior express written consent.

4. Disclosure of Personal Information

We may disclose your personal information to:

  • Service Providers: Including Supabase (hosting, Australia/AWS Sydney region), Cloudflare (CDN), OpenAI and Google Cloud Vertex AI (AI processing), and analytics providers.
  • Professional Advisers: Lawyers, accountants, auditors, and insurers.
  • Business Transfers: In the event of a merger, acquisition, or sale of assets.
  • Legal Authorities: When required by law or to protect rights and safety.

5. Cross-Border Data Transfers

5.1 Primary Data Storage

We primarily host and store your data in Australia, using Supabase with underlying infrastructure provided by Amazon Web Services (AWS) in the Sydney region.

5.2 Overseas Disclosures

Some of our Service Providers are located overseas, including in the United States (OpenAI, Google, Cloudflare). When we transfer personal information overseas, we take reasonable steps to ensure that the overseas recipient protects the information in a way that is substantially similar to the APPs.

6. Data Security

We implement and maintain appropriate technical and organisational security measures, including:

  • Encryption of data in transit (TLS 1.2+) and at rest (AES-256)
  • Role-based access controls (RBAC)
  • Multi-factor authentication (MFA) for administrative accounts
  • Regular security assessments and penetration testing
  • Comprehensive audit logging and monitoring
  • Incident response plan for security breaches

7. Notifiable Data Breaches

In the event of a data breach that is likely to result in serious harm, we will comply with the Notifiable Data Breaches (NDB) scheme under Part IIIC of the Privacy Act, including notifying affected individuals and the Office of the Australian Information Commissioner (OAIC).

8. Your Rights: Access, Correction, and Erasure

Under the Privacy Act, you have the right to:

  • Request access to the personal information we hold about you.
  • Request correction of inaccurate, out of date, incomplete, or misleading information.
  • Request deletion of your personal information in certain circumstances.

To exercise these rights, contact us using the details in Section 15. We will respond within 30 days.

9. Data Retention

  • Account Data: Retained for the duration of your account plus up to 7 years for compliance purposes.
  • Customer Data: Retained for 30 days after termination to allow data export, then securely deleted.
  • Usage Data: Retained for up to 2 years for analytics, or longer if aggregated and de-identified.
  • Payment Data: Retained for 7 years for taxation and financial record-keeping.

10. Cookies and Tracking Technologies

We use cookies, web beacons, and similar tracking technologies to collect information about your use of the Platform. For detailed information, please see our Cookie Policy.

11. Third-Party Links

The Platform may contain links to third-party websites. We are not responsible for the privacy practices of third-party websites.

12. Children’s Privacy

The Service is not directed to individuals under 18. We do not knowingly collect personal information from children.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new policy on this page and, where appropriate, by email notification.

14. Making a Complaint

If you have a complaint about our handling of your personal information, please contact our Privacy Officer. We will acknowledge your complaint within 7 days and provide a written response within 30 days.

If you are not satisfied with our response, you have the right to lodge a complaint with the Office of the Australian Information Commissioner (OAIC):

  • Website: www.oaic.gov.au
  • Phone: 1300 363 992
  • Email: enquiries@oaic.gov.au

15. Contact Us

If you have any questions or requests regarding this Privacy Policy, please contact our Privacy Officer:

Public Pulse Pty Ltd
Privacy Officer Email: privacy@publicpulse.com
General Email: legal@publicpulse.com
Address: 81-83 Campbell Street, Surry Hills, NSW 2010, Australia
ABN: 90 668 509 019
ACN: 668 509 019