Privacy Policy

TruePulse (“we,” “us,” or “our”) is committed to protecting the privacy of our customers and the employees whose data is processed through our platform. This Privacy Policy explains what data we collect, how we use it, and your rights in relation to it.

This policy applies to the TruePulse platform at true-pulse.online and all related services. By using our Service, you agree to the practices described here.

1. Data We Collect

Account and Administrator Data

When you create a TruePulse account we collect:

• Name and email address
• Organisation name
• Password (stored as a one-way cryptographic hash — we cannot recover your password)
• Billing information (processed and stored by our payment provider, Stripe — we do not store card details)
• Account activity logs for security purposes

Employee Directory Data

To send surveys, administrators upload an employee directory containing employee names, email addresses, and optional attributes (department, location, employment type, etc.). This data is stored securely and used solely to send survey invitations and segment aggregate results.

Survey Response Data

When employees complete surveys, we collect their responses. Survey responses are stored anonymously — we do not link individual responses to employee identities. Responses are attributed only to the aggregate group or segment, never to a named individual. This is enforced at the architectural level, not just as a policy.

Usage and Technical Data

We automatically collect certain technical data when you use the Service, including:

• IP address, browser type, and device information
• Pages visited and features used (via analytics)
• Error logs and performance data
• Cookies and session tokens (see Section 7)

2. How We Use Your Data

We use the data we collect to:

• Provide, operate, and improve the TruePulse Service
• Send survey invitations to employees on behalf of administrators
• Generate aggregate analytics and reports
• Process payments and manage subscriptions
• Respond to support requests
• Send product updates and service notifications (you may opt out of marketing emails)
• Detect fraud, abuse, and security threats
• Comply with legal obligations

We do not sell your data. We do not use Customer Data (including employee data or survey responses) for our own advertising or commercial purposes beyond operating the Service.

3. Legal Basis for Processing (GDPR)

For users in the European Economic Area and the United Kingdom, our legal bases for processing personal data are:

• Contract: Processing necessary to provide the Service to you under our Terms of Service.
• Legitimate interests: Improving our Service, preventing fraud, and maintaining security — where these interests are not overridden by your rights.
• Legal obligation: Where we are required to process data to comply with applicable law.
• Consent: For marketing emails, where we request your consent separately.

4. Data Sharing and Third Parties

We share data only with the following categories of third parties, and only as necessary:

• Stripe— for payment processing. Stripe’s privacy policy governs the data they receive.
• Cloud infrastructure providers — we use Google Cloud Platform / Firebase to host our database and services. Data is stored in the EU by default.
• Email delivery providers — to send survey invitations and notifications on your behalf.
• Analytics providers — to understand how the Service is used (aggregate, not individual-level data).

We do not share personal data with advertisers, data brokers, or any third party for their own commercial purposes.

We may disclose data if required by law, court order, or to protect the rights, property, or safety of TruePulse, our customers, or the public.

5. Data Retention

We retain your account data for as long as your account is active. Anonymised survey response data is retained to provide historical trend analytics. If you close your account, we will delete your data within 30 days upon request.

Some data may be retained longer where required by law (e.g., financial records for tax compliance).

6. International Data Transfers

TruePulse operates globally. If you are located in the EEA or UK, your data may be transferred to and processed in countries outside those regions (including the United States) by our service providers. Where such transfers occur, we ensure appropriate safeguards are in place, including Standard Contractual Clauses approved by the European Commission.

7. Cookies

We use cookies and similar technologies for:

• Essential cookies: Authentication, session management, and security. These are necessary for the Service to function and cannot be disabled.
• Analytics cookies: To understand how the Service is used (e.g., Google Analytics). You can opt out via your browser settings or cookie preferences.

We do not use advertising or tracking cookies. Survey respondents who complete surveys via a unique link are not tracked with persistent cookies.

8. Your Rights

Depending on where you are located, you may have the following rights regarding your personal data:

• Access: Request a copy of the personal data we hold about you.
• Correction: Request correction of inaccurate data.
• Deletion: Request deletion of your data (subject to legal retention requirements).
• Portability: Request your data in a structured, machine-readable format.
• Objection: Object to processing based on legitimate interests.
• Restriction: Request restriction of processing in certain circumstances.
• Withdrawal of consent: Withdraw consent for marketing emails at any time.

To exercise any of these rights, email us at privacy@true-pulse.online. We will respond within 30 days.

If you are in the EEA or UK and believe we have not handled your data lawfully, you have the right to lodge a complaint with your local supervisory authority (e.g., the ICO in the UK).

9. Employee Survey Respondents

If you have completed a TruePulse survey as an employee, your employer (the organisation that sent you the survey) is the data controller for your participation. TruePulse acts as a data processor on their behalf.

As described above, your individual responses are not linked to your identity. Only aggregate, anonymised results are visible to your employer. If you have questions about how your employer is using survey data, please contact their HR team directly.

10. Security

We implement industry-standard security measures including encryption in transit (TLS), encryption at rest, access controls, and regular security reviews. However, no system is completely secure. If you discover a security vulnerability, please report it responsibly to security@true-pulse.online.

11. Children

The Service is not directed at individuals under 16. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, contact us and we will delete it.

12. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes via email or in-app notice at least 14 days before they take effect. The current version will always be available at true-pulse.online/privacy.

13. Contact

For privacy questions or to exercise your rights, contact us at privacy@true-pulse.online.