Privacy Policy

BRAINWARE DWC-LLC ("Pulses," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy describes how we collect, use, disclose, and safeguard information when you visit our website (pulses.ai), use our platform, or interact with our Pulses Vision Devices (PVDs) and AI-powered services. Pulses is a Physical Intelligence platform. Our technology generates structured metadata from physical spaces — not surveillance footage. This distinction is fundamental to our architecture and this policy.

Pulses is designed with Privacy by Architecture — meaning privacy protections are enforced at the hardware and software level, not through policy alone. • Zero Video Storage: No video frames are written to disk or transmitted from any Pulses Vision Device. Raw visual data is processed on-device and immediately converted to anonymized structured metadata. • Edge Processing: All AI processing occurs on-device using NVIDIA Ampere architecture. No visual data leaves the device. Only structured, anonymized metadata is transmitted to the Pulses platform. • No Facial Recognition for Identification: Pulses does not use facial recognition technology to identify individuals. VIP and repeat visitor detection uses anonymized behavioral signatures (movement patterns, visit frequency, dwell characteristics) — not biometric data. • Silicon-Level Security: Each Pulses Vision Device contains a cryptographically unique firmware key burned into NVIDIA GPU silicon. Devices cannot be cloned, and storage cannot be swapped between units.

When you visit pulses.ai or interact with our online services, we may collect: • Contact Information: Name, email address, phone number, company name, and job title — provided when you request a demo, download content, or contact us. • Usage Data: Pages visited, time spent, referral source, browser type, device type, and IP address — collected automatically via cookies and analytics tools. • Form Submissions: Information you voluntarily provide through forms, including demo requests, Intelligence Audit requests, and consultation bookings. We do not sell your personal information to third parties.

When customers deploy Pulses Vision Devices and use the Pulses platform: • Metadata Only: The platform receives structured metadata — zone occupancy counts, dwell durations, movement patterns, queue depths, and similar operational data. This metadata is anonymized and cannot be used to identify individuals. • Account Data: Customer account information including administrator names, email addresses, organization details, and billing information. • Configuration Data: Skill configurations, AI Agent settings, connector integrations, and deployment parameters. • No Visual Data: The platform never receives, stores, or processes visual imagery from Pulses Vision Devices. This is architecturally enforced, not a configurable setting.

• Website Data: To respond to inquiries, schedule demos and audits, improve our website, send relevant communications (with consent), and analyze usage patterns. • Platform Metadata: To deliver real-time intelligence to customers, power AI Agent actions, generate analytics and reports, and improve platform performance. • Account Data: To manage customer accounts, provide support, process billing, and communicate service updates. We process data on lawful bases including: performance of contract, legitimate business interests, and explicit consent where required.

We may share information with: • Service Providers: Cloud hosting (Microsoft Azure), payment processing, and analytics providers who are contractually bound to protect your data. • Technology Partners: Microsoft and NVIDIA — only as required for platform operation and support. No customer data is shared for marketing purposes. • Legal Requirements: When required by law, regulation, legal process, or governmental request. • Business Transfers: In connection with a merger, acquisition, or sale of assets, with continued privacy protections. We never sell personal information. We never share platform metadata with third parties for advertising purposes.

Depending on your jurisdiction, you may have the right to: • Access: Request a copy of the personal information we hold about you. • Rectification: Request correction of inaccurate personal information. • Erasure: Request deletion of your personal information ("right to be forgotten"). • Restriction: Request restriction of processing of your personal information. • Portability: Request transfer of your personal information in a structured, machine-readable format. • Objection: Object to processing based on legitimate interests. • Withdrawal of Consent: Withdraw consent at any time where processing is based on consent. To exercise any of these rights, contact us at privacy@pulses.ai.

Pulses operates globally with headquarters in Dubai, UAE. Data may be transferred to and processed in jurisdictions outside your country of residence. We ensure appropriate safeguards are in place, including: • Standard Contractual Clauses (SCCs) for EU data transfers • Adequacy decisions where applicable • Binding Corporate Rules for intra-group transfers • Azure data residency controls for platform deployments

• Website Data: Contact form submissions and inquiry data retained for 24 months or until you request deletion. • Platform Metadata: Retained according to customer-configured retention policies (default: 12 months). Customers can configure shorter retention periods. • Account Data: Retained for the duration of the customer relationship plus 12 months for legal and audit purposes. • Vision Device Data: Not applicable — no visual data is stored at any point.

Pulses does not knowingly collect personal information from children under 16. Our platform is designed for enterprise and commercial use. If we become aware that we have collected personal information from a child under 16, we will take steps to delete that information promptly.

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy on our website with a revised "Last Updated" date. For significant changes, we will provide additional notice via email to registered customers.

For questions about this Privacy Policy or to exercise your privacy rights: • Email: privacy@pulses.ai • Address: BRAINWARE DWC-LLC, Dubai World Central, Dubai, United Arab Emirates • Data Protection Officer: dpo@pulses.ai For EU residents, you also have the right to lodge a complaint with your local data protection supervisory authority.