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Pulp’in privacy policy

https://www.pulpin.io, [email protected]

At Pulp’in · we transform marketing communications through instant, interactive personalized video. Protecting data is central to our mission and our technology architecture. This policy explains how we collect, use, protect, and share information in connection with our services. By using our website https://www.pulpin.io/ and our services, you accept the practices described in this policy.

1. Identity of the data controller

The controller of your personal data on this site is: Pulp’in Email: [email protected]

2. Data we collect and why

The data we process depends on your relationship with us (website visitor, PULP’IN Lite user, or PULP’IN Core customer).

A. Website visitors (pulpin.io): • Browsing data: we may collect technical data such as your IP address, browser type, pages viewed, and visit duration, via cookies, to analyse traffic to our site and improve how it works. • Contact data: when you contact us through a form or by email (for example to request a demo), we collect your name, email address (we recommend using a professional email in this context), your company, and any other information you choose to provide.

B. Users of our services: • PULP’IN Lite: as described on our site, if you do not wish your data to remain stored on your own servers, you may export your customer data (CSV, Excel, or simplified connectors) to our cloud platform (OVH, France, Gravelines site) to generate videos. That data is stored securely in our cloud and encrypted. When data remains on your servers (which we recommend to avoid unnecessary processing), you remain the sole data controller. When we store your data on our servers at your express request, we act as a processor (for the service we provide to you) and, for data necessary to operate the service, also as a controller in part.

• PULP’IN Core: as detailed on our site, our solution can be deployed on your premises (on-site hosting). In that case, no transfer of sensitive data to Pulp’in is required. Your data stays in your secure ecosystem and our engine turns it into video directly in your environment. Pulp’in then acts mainly as a processor and does not determine the purposes of processing.

In accordance with Article 28 of the General Data Protection Regulation (GDPR), Pulp’in complies with its obligations as defined in a specific contract governing that relationship.

3. How we protect your data

The security of your data is our top priority, as reflected in our value “Secure: data stays where it belongs”, which has driven years of R&D so our technical development keeps your data “with you”.

• Encryption: we use end-to-end encryption (SSL/TLS) for data in transit. Data at rest is also encrypted. • Secure architecture: our technology is designed to minimise data exposure. PULP’IN Core with on-site hosting ensures highly sensitive data never leaves your infrastructure. • Restricted access: access to personal data is strictly limited to team members who need it to provide the service (e.g. technical support), bound by contractual confidentiality obligations. • Secure development practices: we follow industry best practices to secure our code and infrastructure.

4. Sharing data with third parties

We do not sell your personal data. We do not make it available to third parties for rent. We do not reuse it for “training” or “analytics” other than statistical or usage data you may ask us to provide.

We may share it with subprocessors who help us deliver our services and whom we identify clearly either in this privacy policy (for example our cloud host, OVH) or in pre-contractual, contractual, or service follow-up exchanges.

We use third-party providers or subprocessors only to the strict extent necessary to run our service and maintain quality. They are under contract and we require protection obligations equivalent to our own.

A list of these subprocessors is available on request.

5. How long we keep your data

Pulp’in follows CNIL recommendations on retention and archiving. We have a retention and archiving policy that we can provide to customers on request.

In summary: • Prospect/visitor data is kept for 3 years from the last contact. • Customer (account) data is kept for the duration of the contractual relationship, then archived in line with our legal obligations (including accounting: 10 years for invoices). • Customer data imported into PULP’IN Lite is kept only for as long as needed to generate videos, unless you choose to store it on our platform (in which case erasure and archiving follow CNIL recommendations and any specific contractual terms we agree). You may delete it at any time via your interface.

6. Your rights (GDPR & French Data Protection Act)

Under European and French law, individuals whose data Pulp’in processes have the following rights regarding their personal data: • Right of access, rectification, and erasure. • Right to restriction of processing and data portability. • Right to object to processing, including for marketing. • Right to give instructions on what happens to your data after your death.

As controller (e.g. data entered on our site), we commit to honouring and facilitating the exercise of your rights. As processor (e.g. data processed when generating personalized videos), we commit to facilitating the exercise of your rights with the controller (the Pulp’in customer who distributes the personalized video).

To exercise these rights or ask about this policy, contact us at [email protected]. We will respond within one month. You also have the right to lodge a complaint with the CNIL (French Data Protection Authority), including via: https://www.cnil.fr/fr/plaintes

7. Cookies

Our site uses cookies for proper operation and audience analysis. On your first visit, a banner informs you and lets you consent or refuse non-essential cookies (including analytics). You can change your preferences at any time.

8. Changes to this policy

We may update this privacy policy to reflect changes to our services or legal requirements. The current version is always the one dated and available on this page.

Contact us: Pulp’in · Data Protection [email protected] This policy supplements Pulp’in's general terms and conditions.