Privacy notice

Who we are

Pulse Context is operated by Dharach Pte. Ltd., a company incorporated in Singapore, with its registered office at 10 Anson Road, #25-06, International Plaza, Singapore 079903. Our team and our operations are based in Barbados. Dharach Pte. Ltd. is the data controller for the personal data described in this notice.

We use "Pulse Context", "we", "us" and "our" to mean Dharach Pte. Ltd. and the team that runs it.

Our privacy contact is matt@dharach.com. Write to that address for any privacy question, or to exercise a right set out below.

What this notice covers

This notice explains how we handle personal data when you visit this website and when you contact us. It also covers the platform, because that is where personal data most often reaches us.

The platform itself is a separate service, provided under contract to the organisations that use it. Where a customer contract and this notice differ, the contract governs the data processed in delivering that service.

Information we collect from this website

• What you send us. If you email us, your message reaches our mail server, along with your email address, your name if you give it, and anything else you include. We use it to reply and to keep a record of the conversation.
• Server logs. Our host, GitHub, records standard request information such as IP address, browser type, and the pages requested, so the site can be operated and protected.

We do not use analytics, advertising or tracking pixels, and we set no cookies of our own. Fonts, images and the audio on this site are served from this domain rather than from a third party, so visiting a page does not tell an advertising network who you are.

We do not ask for, and would ask you not to send, sensitive personal information by email. If it arrives, we will delete it.

How we use it, and on what basis

• To reply to you and to keep a record of it. This is our legitimate interest in running our business, and it is the taking of steps at your request before any contract between us.
• To operate and protect the website. This is our legitimate interest and our legal obligation to keep a public service available and safe.
• To keep the platform secure and to meet our legal obligations.

We do not add you to a mailing list because you emailed us, and we do not use your details for advertising.

Who we share it with

• GitHub, Inc., which hosts this website. Pages are served from GitHub's infrastructure in the United States, so server logs for your visit are processed there.
• Our professional advisers, if we need them, for example to comply with a legal obligation.

We do not sell personal data, and we do not share it for advertising. If we ever added a processor that handles data from this website, we would name it here.

How long we keep it

• Enquiries. We keep emails and the conversation for 24 months from your last message, then delete them.
• Server logs. Kept for as long as our host keeps them, which is a short operational window of a few weeks.

The platform: signals, provenance and personal data

This is the part of our work that most often involves personal data, so it is worth being precise about it.

• What we ingest. Broadcast radio, local news, and public social posts.
• What we keep. The transcript or text of each signal, with the time it aired or was posted, who published it, and a link back to the original. We keep the source, because an answer you can check is the whole point of the product.
• What that means for individuals. A broadcast voice or a social post can be personal data about a person who appears in it. We do not add names to a transcript beyond what the source itself says, and we do not build profiles of individuals.
• Who it can affect. Presenters, organisers, officials, and anyone else whose words end up in a signal we ingest. Our customers receive answers that quote or point to these sources, so a signal can reach an organisation that is not the publisher.
• Partner surfaces. Some third-party products and services are built on Pulse data. Where we provide data to a partner, we provide only what the source already published, and that partner's own terms and privacy notice govern what they do with it. We ask partners to honour source attribution.

If you appear in a signal, or you published one, you can ask us to review it, to correct it, or to remove a link to it from the answers we serve. Email matt@dharach.com. We treat a request from the publisher of a source as authoritative for that source.

How long the platform keeps a signal, and who can query it, is governed by the contract with the customer that operates it, rather than by this notice.

Your rights

Under the Data Protection Act, 2019-29 of Barbados, and the Personal Data Protection Act 2012 of Singapore where it applies to us, you have the right to:

• be told whether we process your personal data, and to be given a copy of it
• have inaccurate data rectified, and incomplete data completed
• have data erased, or its processing restricted, in the circumstances the law allows
• have data you gave us provided in a portable, machine-readable format
• object to processing we carry out on the basis of legitimate interests
• withdraw consent, where we rely on consent
• lodge a complaint with the Data Protection Commissioner in Barbados, or with the Personal Data Protection Commission in Singapore

We respond within one month. We do not charge for a request unless it is manifestly unfounded or excessive.

We do not use your data for automated decision-making that produces legal or similarly significant effects about you.

International transfers

Some processing happens outside Barbados. This website is hosted in the United States, and our Singapore incorporation means some administrative records are held in Singapore. Where personal data leaves Barbados we rely on contractual safeguards and on the standard contractual clauses where they are required. We will tell you if we rely on a specific safeguard and how to obtain a copy of it.

Security

We serve every page over TLS, keep access to personal data limited to the people who need it, and log administrative access to our systems. No system is perfectly secure, so please do not email us anything sensitive.

Children

This site is not directed at children under 16, and we do not knowingly collect their personal data. If you believe a child has sent us personal data, email us and we will delete it.

Changes to this notice

We will post the new effective date at the top of this page when we make a material change. If a change affects how we use data you have already given us, we will tell you directly.