Privacy Policy
Last updated: 18 February 2025
Privacy Policy
This Privacy Policy details certain policies implemented throughout Southern Pulse, Inc. (“Southern Pulse”) governing Southern Pulse’s collection and use of personal data about users of our Southern Pulse services that allows you to engage with our retrieval-augmented generation AI research tool, called “Nelson,” at the URL https://nelson.southernpulse.com (“Site”). Collectively, the Site and the services provided through the Site are referred to as the “Services”.
Southern Pulse complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Southern Pulse adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF. Southern Pulse also adheres to the UK Extension to the EU-U.S. DPF for personal data received from the United Kingdom, and to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles, the UK Extension, and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, please visit https://www.dataprivacyframework.gov/.
Southern Pulse is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
Information Collection
You may browse our Site without providing us with any personal data.
In order to register for an account on our Site and to use our Services, we require you to submit your personal data to us. When you register for an account on our Site and to use our Services, you may be required to provide us with personal data such as your first name, last name, password, email address, phone number, business address, username, and password.
If you use our Services, you may place online orders. In conjunction with your use of the Services, we will collect information about your online orders and related public documents and information that you order. When you make a purchase through the Services, you will be required to submit a credit card or ACH information for billing purposes. Our third party payment processor will process your payment. If you contact us, we will collect any personal data that you include in your communications to us.
Information Use
We use your personal data for the following purposes and rely on the following lawful bases to process your personal data:
Specifically, we use your personal data to:
Cookies and Online Tracking
We use small text files called cookies to improve overall experience on the Site. A cookie is a piece of data stored on the user's hard drive containing information about the user. Cookies generally do not permit us to personally identify you. We generally use session cookies to authorize each request to use the Site and such cookies expire when you exit the Site.
Southern Pulse does not track users over time or over multiple websites. Southern Pulse does respond to browser do not track signals.
Children's Privacy
Southern Pulse recognizes the privacy interests of children and we encourage parents and guardians to take an active role in their children's online activities and interests. The Site and Services are not directed to children under the age of 18. Southern Pulse does not target its Services to children under 18. Southern Pulse does not knowingly collect personal data from children under the age of 18. If we learn that a child under the age of 18 provided us with personal data, we will delete that information. If your child has provided personal data, please contact us so we can delete it. If you are under the age of 18, please do not provide us with any personal data.
Disclosure
We provide your personal data and the data generated by cookies and the aggregate information as follows.
We provide your personal data to the vendors and service agencies that we engage to assist us in providing our services to you. For example, we may use a third party payment processor, to process payments for our Services. Such third party entities are obligated to use your personal data solely to provide the services to us.
We will disclose your personal data if we reasonably believe we are required to do so by law, regulation or other government authority or to assist in any governmental or law enforcement investigation, to protect our or our users' rights or to enforce our terms of use.
We will not sell your personal data to any company or organization except we may transfer your personal data in conjunction with a transaction such as a financing or to a successor entity upon a merger, consolidation or other corporate reorganization in which Southern Pulse participates or to a purchaser of all or substantially all of Southern Pulse’ assets to which the Services relate or in the event of a bankruptcy or related or similar proceedings.
Southern Pulse's accountability for personal data that it receives under the Data Privacy Framework and subsequently transfers to a third party is described in the Data Privacy Framework Principles. In particular, Southern Pulse remains responsible and liable under the Data Privacy Framework Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless Southern Pulse proves that it is not responsible for the event giving rise to the damage.
Security
We employ procedural and technological measures that are reasonably designed to help protect your personal data from loss, unauthorized access, disclosure, alteration or destruction. Southern Pulse uses secure socket layer, firewalls, two-factor authentication, password protection and other security measures and policies to help prevent unauthorized access to your personal data.
Data Retention
We will only keep your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers, such as payment data, generally for seven years after they stop being customers for tax purposes. Please note that we may retain information that is otherwise deleted in anonymized and aggregated form, in archived or backup copies as required pursuant to records retention obligations, or otherwise as required by law.
In some circumstances you can ask us to delete your data; see Updating and Deleting Personal Data and Your Rights below for further information.
Privacy Policy Updates
Southern Pulse may need to update this Privacy Policy from time to time. If so, Southern Pulse will post its updated Privacy Policy on our Site and Services along with a change notice. Southern Pulse may also send registered users of our Services a notice that this Privacy Policy has been changed. Southern Pulse encourages you to review this Privacy Policy regularly for any changes. Your continued use of the Site and/or Services and/or continued provision of personal data to us after the posting of such notice will be subject to the terms of the then-current Privacy Policy.
Updating and Deleting Personal Data
Southern Pulse provides you with the ability to review, update and/or delete certain contact information that you provide to us by accessing your account. Your right to access your personal data may be restricted in exceptional circumstances, including, but not limited to, when the burden or expense of providing this access would be disproportionate to the risks to your privacy in the case in question, or when the rights of persons other than you would be violated by the provision of such access. If we determine that your access should be restricted in a particular instance, we will provide you with an explanation of our determination and respond to any inquiries you may have. If you are located in the European Union, you have other rights as set forth in the Your Rights Section below.
Notice to Users Outside of the United States
While Southern Pulse is an international business, we operate primarily in the United States, and as a result regardless of where you use our Services or otherwise provide information to us, the information we collect may be transferred to and maintained on servers located in the United States. The laws, regulations and standards of the country in which this information is stored may be different from your own country. The European Union's General Data Protection Regulation (“GDPR”) allows for transfer of personal data from the European Union to a third country in certain situations. By consenting and agreeing to the terms of use and this Privacy Policy, you agree to the transfer of all such information to the United States of America which may not offer an equivalent level of protection to that required in other countries, particularly the European Union, and to the processing of that information by Southern Pulse on servers located in the United States of America as described in this Privacy Policy. We also comply with the EU-US Data Privacy Framework, its UK Extension, and the Swiss-US Data Privacy Framework. In our discretion, we may adopt other means, such as entering into data processing agreements that include the EU Standard Contractual Clauses or enter into different certification programs under applicable law for ensuring adequate safeguards. If you wish to execute a data processing agreement with us, please contact us.
Your Rights
If the General Data Protection Regulation or the UK GDPR applies to you because you are in the European Union or the United Kingdom, you have rights under data protection laws in relation to your personal data:
Rights in relation to automated decision making and profiling – that’s a right you have for us to be transparent about any profiling we do, or any automated decision making. These rights are subject to certain rules around when you can exercise them. If you wish to exercise any of the rights set out above, please contact us at privacy@evidencity.com.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Access Statement
Pursuant to the Data Privacy Frameworks, EU, UK, and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under the Data Privacy Frameworks, should direct their query to privacy@evidencity.com. If requested to remove data, we will respond within a reasonable timeframe.
Choice Statement
We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to privacy@evidencity.com.
Complaints
In compliance with the Data Privacy Framework Principles, Southern Pulse commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to the Data Privacy Frameworks. European Union, United Kingdom, and Swiss individuals with DPF inquiries or complaints should first contact Southern Pulse by email at privacy@southernpulse.com. Southern Pulse has further committed to cooperate with the panel of European Data Protection Authorities (DPAs), the UK Information Commissioner's Office (ICO), and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved DPF complaints concerning data transferred from the EU, UK, and Switzerland respectively.
If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact the relevant authority for more information or to file a complaint:
The services of EU DPAs, UK ICO, and Swiss FDPIC are provided at no cost to you.
If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms.
See https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf
Questions
If you have any questions regarding this Privacy Policy including any requests to exercise your legal rights, please contact us via email at privacy@southernpulse.com.
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