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Pulsor Suite

Data Processing Agreement

Terms under which Pulsor processes personal data on behalf of customers.

Draft document, awaiting legal review. It describes how Pulsor Suite actually works but has no contractual value until the reviewed version is published. Items in square brackets are still to be completed.

1. Roles of the parties

The Customer is the controller of the personal data contained in its documents, messages and User accounts. Pulsor (ELECTRAPPS [legal form, registration number and registered office to be completed]) processes it as processor, only to provide Pulsor Suite. This agreement is part of the Terms of Service.

2. Processing described

  • Subject: hosting, indexing, search and AI analysis of the Customer's documents and messages; management of User accounts.
  • Data subjects: the Customer's employees and the persons named in its documents (clients, suppliers, candidates…).
  • Data: identification and contact data, professional data, and any data the documents contain. The Customer avoids putting in special-category data unless needed and lawful.
  • Duration: the contract, then the deletion period below.

3. Instructions

Pulsor processes data only on the Customer's documented instructions: the contract, the settings chosen in the platform (sources connected, rights, AI provider) and written requests. Pulsor informs the Customer if an instruction seems unlawful.

4. Security measures

  • each request is filtered by the User's rights before any content reaches an AI model;
  • logical isolation between Customers in Pulsor Cloud;
  • encryption in transit (TLS); AI keys and connector credentials stored encrypted; encryption at rest depending on the hosting [to be confirmed for Pulsor Cloud];
  • passwords and PINs stored as hashes; second factor by PIN at the Customer's choice;
  • audit log of sign-ins, documents opened, exports and administrative actions;
  • limited, personal and logged access for Pulsor staff, with authenticator-app MFA on the platform console.

5. Subprocessors

The Customer authorizes the subprocessors listed on the subprocessors page. Pulsor announces any new subprocessor [30] days in advance; the Customer may object on reasonable grounds. Pulsor imposes the same obligations on them and remains responsible for them.

6. Data subject requests

Administrators can find, export, correct and delete documents and accounts themselves. Pulsor helps the Customer answer requests it cannot handle alone.

7. Breach notification

Pulsor notifies the Customer of any personal-data breach affecting it without undue delay and at the latest [48] hours after becoming aware of it, with the information available, then follow-ups.

8. Audits

Pulsor provides the information needed to demonstrate compliance with this agreement. On-site audits: [conditions to be completed].

9. Deletion and return

At the end of the contract, the Customer exports what it wishes; Pulsor then deletes Customer Data, including indexes, within [30] days, and backups at the end of their rotation cycle [duration to be confirmed].