Privacy Policy

I-PULSE

PRIVACY POLICY

EFFECTIVE DATE: 12/10/2026

LAST UPDATED: 12/10/2026, 2026

1. ABOUT THIS POLICY

This Privacy Policy explains how I-Pulse Inc. and its affiliated companies (collectively, “I-Pulse,” “we,” “us,” or “our”) collect, use, disclose, and retain personal information in connection with the website located at www.ipulse-group.com (the “Website”).

This Policy applies to personal information we collect through the Website. Sections 1 through 15 reflect the requirements of United States privacy laws. Annex A applies if you are in the European Economic Area or the United Kingdom, and Annex B applies if you are in Japan. An Annex supplements Sections 1 through 15 and prevails over them in the event of conflict.

This Policy is intended to satisfy the requirements of the comprehensive consumer privacy laws in effect across the United States. Because those laws use different terminology to describe substantially similar rights and obligations, this Policy describes them in general terms rather than naming individual states. Where a particular state grants you a right described below, that right is available to you.

2. PERSONAL INFORMATION WE COLLECT AND DISCLOSE

The table below describes the categories of personal information we have collected through the Website in the preceding twelve months, the sources of that information, the categories of third parties to which we disclose it for a business purpose, and whether we sell or share it.

3. SENSITIVE PERSONAL INFORMATION AND CATEGORIES WE DO NOT COLLECT

We do not collect sensitive personal information through the Website, and we do not use or disclose personal information for the purpose of inferring characteristics about you. In particular, we do not collect through the Website:

• Social Security numbers, driver’s license numbers, passport numbers, or other government-issued identification numbers;
• financial account numbers, payment card numbers, or account access credentials;
• biometric or genetic information;
• precise geolocation information;
• health, medical, or health insurance information;
• information concerning racial or ethnic origin, national origin, citizenship or immigration status, religious or philosophical beliefs, union membership, sex life, or sexual orientation;
• education records; or
• the contents of your mail, email, or text messages, other than communications you choose to send to us directly.

We do not knowingly collect personal information from individuals under 18 years of age. The Website is directed to businesses and professionals and is not intended for children.

4. HOW WE USE PERSONAL INFORMATION

We use the personal information described above for the following business and commercial purposes:

• to respond to your inquiries and communicate with you about our businesses, technologies, and potential commercial relationships;
• to operate, maintain, secure, and improve the Website and to diagnose technical problems;
• to measure and analyze traffic to the Website and understand how visitors use it;
• to detect, prevent, and respond to spam, fraud, security incidents, and other malicious or unlawful activity;
• to maintain records of your cookie and privacy preferences;
• to comply with legal obligations, respond to lawful requests from government authorities, and establish, exercise, or defend legal claims; and
• to evaluate, negotiate, or complete a corporate transaction such as a merger, acquisition, financing, or sale of assets.

We will not use your personal information for a materially different, unrelated, or incompatible purpose without first providing you notice.

We may create deidentified or aggregated information from personal information, such as statistics about how visitors use the Website. We maintain and use that information only in deidentified or aggregated form, we do not attempt to reidentify it, and we do not authorize our service providers to do so.

5. HOW WE DISCLOSE PERSONAL INFORMATION

We disclose personal information to the following categories of recipients for the business purposes described above:

• Service providers and processors, including website hosting and information technology providers, analytics providers, customer relationship management and marketing platform providers, and security and anti-spam providers. These recipients are contractually restricted from using personal information for any purpose other than performing services for us.
• Our affiliated companies, where relevant to responding to your inquiry or to the commercial relationship you are seeking.
• Professional advisors, including our attorneys, auditors, and insurers.
• Government authorities, courts, and other parties where we believe disclosure is necessary to comply with applicable law, to respond to lawful process, or to protect the rights, property, or safety of I-Pulse, our personnel, or others.
• Counterparties and their advisors in connection with a merger, acquisition, financing, reorganization, or sale of all or part of our business, subject to appropriate confidentiality protections.

6. WE DO NOT SELL OR SHARE PERSONAL INFORMATION

We do not sell personal information, and we do not share personal information for purposes of cross-context behavioral advertising or targeted advertising, as those terms are defined under applicable state privacy laws. We do not use personal information to engage in profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. We have not sold or shared personal information in the preceding twelve months.

7. COOKIES, ANALYTICS, AND OPT-OUT PREFERENCE SIGNALS

The Website uses cookies and similar technologies, including cookies that are strictly necessary for the Website to function and cookies that measure Website traffic and usage. A detailed description of each cookie, its purpose, and its duration is available through the cookie preference control on the Website.

You can manage your cookie preferences at any time through the cookie preference control available on the Website, and through your browser settings. Disabling certain cookies may affect the functionality of parts of the Website.

Where required by applicable law, we recognize and honor opt-out preference signals, including the Global Privacy Control (GPC), transmitted by your browser or a browser extension. When we detect such a signal, we treat it as a request to opt out of any sale or sharing of personal information associated with that browser.

Some browsers also offer a “Do Not Track” setting. There is no common industry or legal standard governing how websites must respond to Do Not Track signals. We treat a Do Not Track signal in the same manner as the opt-out preference signals described above.

Your agreement to these technologies. Outside the European Economic Area and the United Kingdom, by continuing to use the Website without opting out or withdrawing consent through the cookie preference control, you agree that we and our third-party providers may use cookies and similar technologies to collect and analyze information about your visit, including the pages you view, the links you select, and how you arrived at the Website, and that those providers may receive that information directly from your browser.

8. HOW LONG WE KEEP PERSONAL INFORMATION

We retain personal information only for as long as reasonably necessary for the purposes described in this Policy, or for a longer period where required by law or necessary to establish, exercise, or defend legal claims. Our general retention periods are:

Information deleted from the live Website database may persist in backups until those backups expire in the ordinary course.

9. YOUR PRIVACY RIGHTS

Depending on where you reside, you may have some or all of the following rights with respect to your personal information.

• Right to know and access. You may request confirmation of whether we are processing your personal information, and request access to that information, including the categories collected, the sources, the purposes for collection, and the categories of third parties to which it is disclosed.
• Right to correct. You may request that we correct inaccurate personal information we maintain about you, taking into account the nature of the information and the purposes of processing.
• Right to delete. You may request that we delete personal information we have collected from you, subject to exceptions permitted by law.
• Right to data portability. You may request a copy of your personal information in a portable and, to the extent technically feasible, readily usable format.
• Right to opt out of sale, sharing, and targeted advertising. As described above, we do not sell or share personal information or use it for targeted advertising. Should that change, we will update this Policy and provide a mechanism for you to opt out.
• Right to opt out of profiling. You may opt out of profiling in furtherance of decisions producing legal or similarly significant effects. We do not currently engage in such profiling.
• Right to limit the use of sensitive personal information. We do not collect sensitive personal information through the Website.
• Right to non-discrimination. We will not deny you goods or services, charge you a different price, or provide you a different level or quality of service because you exercised any of these rights.
• Right to appeal. If we decline to act on your request, you may appeal that decision as described below.

10. HOW TO EXERCISE YOUR RIGHTS

To submit a request, contact us using the details in Section 15 below. Please include enough information for us to identify you and the records you are asking about, and describe your request with sufficient particularity for us to evaluate and respond to it.

Before responding, we will take reasonable steps to verify your identity, which may include matching the information you provide against information already in our records or asking you to confirm your request from the email address associated with it. We will not use information you provide for verification for any other purpose.

We will respond to your request within the period required by applicable law, generally within 45 days of receipt. Where reasonably necessary, we may extend that period once by an additional 45 days and will notify you of the extension and the reason for it. There is no charge for a response, unless your request is manifestly unfounded, excessive, or repetitive, in which case we may charge a reasonable fee or decline to act and will tell you why.

An authorized agent may submit a request on your behalf. We may require the agent to provide proof of your written authorization, and we may require you to verify your own identity directly with us and confirm that you have authorized the agent to act.

11. APPEALS

If we decline to take action on your request, we will explain why. You may appeal that decision within a reasonable period by contacting us using the details in Section 15 and identifying your submission as an appeal. We will respond in writing within the period required by applicable law, generally within 45 or 60 days depending on your state of residence, and explain the reasons for our decision. If your appeal is denied, we will provide you with information about how to submit a complaint to your state attorney general or other applicable regulator.

12. DATA SECURITY AND STORAGE

We maintain reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, use, disclosure, alteration, and destruction. No method of transmission over the internet or method of electronic storage is completely secure, however, and we cannot guarantee absolute security.

I-Pulse is a global group with operations in multiple countries. Personal information collected through the Website is stored in the United States and may be accessed by our affiliated companies and service providers in other countries where we operate. Where we transfer personal information internationally, we take steps designed to ensure it continues to receive appropriate protection.

13. LINKS TO THIRD-PARTY WEBSITES

The Website contains links to websites and online services operated by third parties, including social media platforms. We provide these links for convenience, and their inclusion does not imply that we endorse or are affiliated with the linked site beyond any relationship we have disclosed.

We do not control third-party websites and are not responsible for their content, security, or privacy practices. When you follow a link to a third-party website, that website’s operator collects and uses information about you under its own privacy policy and terms. We encourage you to review the privacy policy of any website you visit through a link on the Website.

14. CHANGES TO THIS POLICY

We may update this Policy from time to time. When we do, we will revise the “Effective Date” and “Last Updated” dates above. If we make material changes, we will provide additional notice, such as by posting a prominent notice on the Website. We encourage you to review this Policy periodically.

15. CONTACT US

If you have questions about this Policy or wish to exercise any of the rights described above, please contact us:

I-PULSE INC.

Attn: Privacy

Suite 2, Level 2, 435 Hudson Street
New York, NY 10014

Email: [privacy@ipulse-group.com]

Telephone:

If you need this Policy in an alternative accessible format, please contact us using the details above and we will work with you to provide it.

ANNEX A — EUROPEAN ECONOMIC AREA AND UNITED KINGDOM

This Annex applies if you are in the European Economic Area or the United Kingdom. Terms used in it have the meanings given in the EU General Data Protection Regulation and the UK GDPR.

A.1 Controller. I-Pulse Inc. is the controller of personal data collected through the Website. Our contact details are in Section 15. [Our representative in the Union is [__________]. Our representative in the United Kingdom is [__________].]

A.2 Legal bases. We rely on the following legal bases:

• Responding to your inquiry and related correspondence — our legitimate interest in responding to enquiries about our business and, where you ask us to take steps before entering into a contract, performance of that contract.
• Operating, securing, and maintaining the Website, including spam and fraud prevention — our legitimate interest in keeping the Website available and secure.
• Analytics and contact-management cookies — your consent.
• Complying with legal obligations and establishing, exercising, or defending legal claims — compliance with a legal obligation and our legitimate interest in protecting our rights.
• Evaluating or completing a corporate transaction — our legitimate interest in managing our business.

A.3 Your rights. In addition to the rights in Section 9, you have the right to access your personal data; to have it rectified or erased; to restrict or object to its processing, including processing based on legitimate interests; and to data portability. Where we rely on consent, you may withdraw it at any time, which does not affect the lawfulness of processing before withdrawal. We will respond within one month, which we may extend by two further months where necessary, and will tell you if we do.

A.4 Complaints. You may lodge a complaint with the supervisory authority in your country of residence, your place of work, or the place of the alleged infringement. In France this is the Commission Nationale de l’Informatique et des Libertés; in the United Kingdom, the Information Commissioner’s Office.

A.5 Providing personal data. You are not required to provide personal data to us. If you choose not to complete a contact form, we will not be able to respond to your inquiry.

A.6 International transfers. Personal data collected through the Website is transferred to and stored in the United States. Where a recipient is certified under the EU-U.S. Data Privacy Framework or its UK Extension, we rely on that framework. Otherwise we rely on the European Commission’s standard contractual clauses and, for transfers from the United Kingdom, the International Data Transfer Addendum. You may request a copy of the relevant safeguards using the contact details in Section 15.

A.7 Automated decision-making. We do not make decisions producing legal or similarly significant effects concerning you based solely on automated processing, including profiling.

A.8 Cookies. If you are in the European Economic Area or the United Kingdom, we set only strictly necessary cookies unless you consent to others. You may give or withdraw consent at any time through the cookie preference control on the Website.

ANNEX B — JAPAN

This Annex applies if you are in Japan and is provided under the Act on the Protection of Personal Information (the “APPI”).

B.1 Business operator. The personal information handling business operator responsible for personal information collected through the Website is I-Pulse Inc., [address], represented by [name, title].

B.2 Utilization purposes. We utilize personal information for the purposes described in Section 4.

B.3 Security control measures. We have established a basic policy for the proper handling of personal data and internal rules governing its acquisition, use, storage, provision, and deletion. We take organizational, personnel, physical, and technical security control measures, and we exercise necessary and appropriate supervision over our employees and over the service providers to which we entrust personal data. Personal information collected through the Website is stored on servers located in the United States and may be handled by our affiliated companies and service providers in [France, Japan, the United Kingdom, and the United States]. We implement security control measures having regard to the personal information protection systems of those countries. For further information on our security control measures, please contact us using the details in Section 15 and we will respond without delay.

B.4 Provision to third parties. We entrust the handling of personal information to the service providers described in Section 5, within the scope necessary to achieve the utilization purposes, and we exercise necessary and appropriate supervision over them. We do not otherwise provide personal information to third parties without your consent, except where the APPI permits.

B.5 Transfers to third parties in foreign countries. Where we provide your personal information to a third party in a foreign country in reliance on your consent, we will first give you the name of that country, information on its personal information protection system, and information on the measures taken by the recipient.

B.6 Requests. You may request disclosure of your retained personal data and of records of its provision to third parties, and may request correction, addition, deletion, cessation of utilization, erasure, or cessation of provision to third parties. Send requests to the contact point in Section 15. We do not charge a fee for responding.

B.7 Complaints. Complaints about our handling of personal information may be sent to the contact point in Section 15.