Last Updated on: 12-March-2026
Effective Date: 15-January-2026

INTRODUCTION

This Privacy Policy governs your use of the website https://thrico.com, domain names, sub domains, platforms, user portal, admin portal, web applications and mobile applications (collectively, the “Platform”) owned and operated by PulsePlay Digital Private Limited, with its registered office at Sushma Cottage, Ram Nagar, Dharamshala, Himachal Pradesh – 176215, India (hereinafter referred to as “Thrico”, “We”, “Us”, or “Our”). This policy explains how we collect, use, share, and protect your personal data when you interact with our website and services.

We may update this policy periodically. If we make material changes, we will notify you via the Website or other appropriate means and update the “Last Updated” date above. Continued use of the website after any such update shall constitute your deemed acceptance of the revised policy.

This Privacy Policy has been designed in accordance with leading global privacy standards to promote transparency, accountability, and consistency in how we handle data of different jurisdictions. Your consent remains our highest priority, and we will always seek your explicit approval before sharing any data beyond the scope of this policy, except as otherwise required by applicable law.

1. DEFINITION CLAUSE

1.1 “Customer” means any individual, Company, Partnership firm, body corporate, or other legal entity that subscribes to, licenses or otherwise avails the services offered by Thrico, whether on a paid or trial basis. (Earlier Version)

1.2 “Customer” shall mean and include the Community Owner and/or any individual, Company, Partnership Firm, body corporate, brand, organization, institution, association, or any other legal entity that subscribes to, licenses, creates, administers, manages, or otherwise avails the services or features offered by Thrico by PulsePlay Digital Private Limited, whether on a paid, trial or complimentary basis.

1.3 “User” means any individual who accesses, browses or uses the platform (Website or Mobile Application), including employees, representatives or authorized users of a Customer, or any person accessing the services through a Customer or otherwise.

1.4 “Activity” shall mean any action performed by a User on the Thrico by PulsePlay Digital Private Limited platform, including but not limited to posting, commenting, reacting, participating in discussions, completing tasks, engaging with content, or interacting within a Community.

1.5 “Coins” mean virtual, non-monetary, non-transferable engagement units that may be allocated based on User Activity within a Community. Coins have no cash value and do not constitute legal tender, property, financial instruments, or enforceable rights against Thrico.

1.6 “Digital Tokens” means platform-generated digital recognition markers, badges, credits or symbolic units awarded within a Community for engagement purposes only. Digital Tokens are not cryptocurrency, blockchain assets, securities or regulated financial products.

1.7 “Points” shall mean the non-monetary digital reward units allocated to a User for participation, engagement, referrals, or other activities on the Platform, the details of which may be recorded, processed, and maintained by the Platform as part of User account information in accordance with this Privacy Policy.

1.8 “Rewards” mean any incentive, benefit, privilege, or recognition offered by the Customer/Community Owner based on eligibility criteria independently determined by such Community Owner.

2. INFORMATION WE COLLECT

We collect personal data that you provide during account registration, profile creation, content submission, or use of our platform. This includes registration details, contact information, profile content (such as education, experience, skills, photo, and location), communications, and platform usage data. You may also choose to enable optional features like profile verifications or Calendar Sync, which allow us to access relevant information (e.g., calendar events) to enhance your networking experience and personalize platform recommendations.

Where we process sensitive personal data, we do so only with explicit consent and under enhanced safeguards, encryption, and restricted access.

2.1 Automated Decision-Making & Profiling

Where automated tools are used to provide recommendations, match opportunities, or personalize user experience, such processing is subject to human oversight. You may opt out of automated decision-making features where legally required.

2.2 Your Device and Location

When you visit or leave our Services (including some plugins and our cookies or similar technology on the sites of others), we receive the URL of both the site you came from and the one you go to, as well as the time of your visit. We also collect information about your network and device (e.g., IP address, proxy server, operating system, web browser and add-ons, device identifier and features, cookie IDs and/or ISP, or your mobile carrier). If you use our Services from a mobile device, that device will send us data about your location based on your phone settings. We will request opt-in consent before using GPS or other tools to identify your precise location.

2.3 Communications:

We process messages, comments, and document sharing on the Thrico platform in a secure manner. Automated systems may monitor or flag content to detect and prevent harmful, abusive, or prohibited material. Any manual review of communications is conducted strictly when necessary for platform safety, compliance with legal obligations, or as part of an authorized investigation.

2.4 Service Content:

When you interact with other Members, Creators, and any online communities on the Services, they may collect any content or information you disclose to them. Thrico may also collect any content or information you disclose with others through the Services.

2.5 Partners and Integrations

We may receive personal information such as your name, job title, or professional email address from our partners or clients — for example, and not limited to your use of Thrico through an employer, institution, or recruitment platform integrated with our Services. Such information is shared to enable account setup, workspace participation, or collaboration features or any other modules or features on the Thrico platform.

2.6 Affiliates and Related Services

We may also receive information from our affiliated companies or related services that enhance your experience on Thrico. For instance, integrated tools (such as productivity or communication platforms) may share data to help you connect with contacts, sync calendars, or access collaboration features seamlessly.

All such data exchanges occur in accordance with applicable data protection laws, and you retain control over any linked accounts or integrations through your account settings.

2.7 Service Use

We collect limited usage information when you access or interact with Thrico such as when you log in, view content, connect with others, or use platform tools. This includes data like IP addresses, device identifiers, browser type, and activity logs.

Such information helps us ensure platform security, improve performance, personalize your experience, and analyse overall usage trends. Cookies and similar technologies may be used

for these purposes in accordance with our [Cookie Policy]. A separate Cookie Policy governs the use of cookies and similar technologies for analytics, personalization, and advertising. Users can manage preferences through browser settings or cookie management tools.

2.8 Careers:

If you decide that you wish to apply for a job with us, you may submit your contact information and your resume online. We will collect the information you choose to provide on your resume, such as your education and employment experience. You may also apply through LinkedIn. If you do so, we will collect the information you make available to us on LinkedIn.

2.9 Payment Information

If you make a payment through the Services, we may request certain billing and financial information necessary to process the transaction, including your credit card or other payment method details. Your full payment information is transmitted directly to our third-party payment processor via secure channel, and we do not store full credit card numbers or security codes on our servers. However, we may retain transaction-related information, including the last four digits of your payment card, the payment method used, transaction amounts, timestamps, and related metadata, for purposes such as maintaining accurate account histories, providing invoicing and billing support, resolving disputes, and complying with our financial, legal, and audit obligations.

We also retain your billing address and other relevant identifiers to calculate applicable taxes, meet regulatory or compliance requirements, prevent or investigate suspected fraud or unauthorized transactions, and display on invoices or account records. In addition, we may collect and maintain commercial information associated with your use of the Services, including purchase histories, records of products or services obtained or considered, usage patterns, and related interactions, to support platform functionality, improve our offerings, enable customer support, enforce our Terms, and protect the interests and rights of the Thrico by PulsePlay Digital Private Limited.

To the maximum extent permitted by law, we may also use, retain, and analyse this information to enhance security, detect misuse, maintain platform integrity, and improve or develop new features, services, or business operations.

3. PERSONAL INFORMATION USAGE

We use your information to operate, improve, and secure Thrico’s services while ensuring transparency and user control. This includes enabling secure logins, supporting collaboration tools, and personalizing your experience by suggesting relevant connections, groups, and opportunities. Premium users gain access to enhanced tools, with visibility governed by their chosen settings, while enterprise clients may manage certain data policies in accordance with applicable laws. We may display non-intrusive, activity-based advertisements within the platform, but no personal data is shared with advertisers without your explicit consent. Anonymized data may be used to enhance platform functionality, conduct voluntary surveys,

and generate aggregated insights shared with community managers or researchers. Information received through support queries is used solely to resolve issues efficiently, and we also use your data to prevent fraud, ensure platform integrity, and comply with lawful and regulatory obligations.

4. YOUR INFORMATION IS SHARED AND DISPLAYED

4.1 Our Right to Share Data

Thrico may share personal data and non-personal data with its affiliates, service providers, payment processors, analytics partners, and government authorities where required by law, or in connection with business restructuring, merger, or assets transfers, in accordance with applicable data protection laws.

4.2 Profile Visibility

Your profile and related information may be visible to other registered Members and authorized users on Thrico, depending on your privacy settings. Subject to these settings, parts of your profile (such as name, role, and professional details) may also be discoverable by visitors through public search tools or third-party search engines. Visibility of certain

fields and content depends on factors such as your connection level, access rights, and the way others interact with the platform.

4.3 Posts, Comments, Likes, and Follows.

When you post, comment, like, or share content on Thrico, your actions may be visible to other Members or the public.

(a) Posts in private groups are visible only to members of that group, while public posts are viewable by all visitors.
(b) Content shared publicly can be re-shared or indexed elsewhere.
(c) When you follow a person, organization, or community, this relationship may be visible to others and to the entity you follow.
(d) We may notify others when you engage with their content or view their profile, if applicable.

4.4 Gamification and Community-Based Rewards

Thrico may offer Gamification features within the Platform that allows users to earn points, badges, rankings, digital tokens, recognition markers, or other engagements-based indicators which will lead to “Rewards” based on their participation, activity, interaction within specific Communities hosted on the Platform, which is determined by the Community Owner, all such gamification features are intended solely for engagement and recognition purposes and do not constitute gambling, betting, or any activity prohibited under the Public Gambling Act, 1867, or any applicable state gaming laws.

(a) Data we Process for Gamification

To enable gamification functionality, Thrico may process certain user activity data, including:

i. Profile information
ii. Community participation records
iii. Posts, comments, reactions and engagements metrics
iv. Event participation data
v. Leaderboard rankings and achievement history
vi. Interaction frequency and activity timestamps

This data is processed solely to;

i. Operate and display gamification features;
ii. Calculate engagement metrics
iii. Generate rankings or activity summaries; and
iv. Enable Community Owners to administer their rewards Programs.

(b) Role of Community Owners

Each Community hosted on Thrico may independently design and administer its own reward programs. The eligibility criteria, selection methodology, number of rewards, type of benefits, redemption process, and fulfilment of Rewards are determined exclusively by the respective community owner, administrator, brand, or organization (“Community Owner”)

Where necessary, Thrico may share relevant engagement or activity data with applicable Community Owner strictly for the purposes of administering their reward program, in compliance with applicable data protection laws.

(c) Thrico’s Limited Role

We act solely as a technology service provider facilitating community interaction and engagement tracking.

We as a Service provider;

i. Do not determine eligibility criteria for Rewards;
ii. Do not select or approve recipients;
iii. Do not control the quantity, or value of Rewards;
iv. Do not guarantee reward fulfilment; and We are not responsible for any disputes, claims, delays, non-delay, or dissatisfaction relating to Rewards offered by Community Owners. However, in circumstances where Thrico itself creates or administers a Community and offers Rewards in its capacity as a Community Owner, Thrico shall be subject to the same terms, eligibility criteria, representations, and obligations applicable to any other Community Owner under this Policy and the applicable Terms of Use. In such cases, Thrico’s responsibilities shall arise solely in its capacity as a Community Owner and not as a neutral platform intermediary

(d) Retention of Data

Gamification-related activity data is retained in accordance with our general data retention practices as outlined in this Privacy Policy. Aggregated and anonymized engagement data may be retained for analytics, platform improvement, and reporting purposes.

(e) Modification or Discontinuation

Thrico reserves the right to modify, suspend, restrict, or discontinue gamification features at any time for operational, legal, or business reasons. Such modification or discontinuation will not affect data already processed in accordance with this Privacy Policy.

5. Enterprise or Organization Accounts

If you access Thrico through your employer, institution, or client organization, administrators may manage your workspace participation and access controls. They will not have access to your private messages, but they may view data necessary for enterprise-level functions such as analytics, compliance, or internal collaboration. Certain professional or compliance users (such as regulated advisors) may be required to archive communications for legal reasons.

6. Third-Party Integrations

You may link your Thrico account with third-party services (for example, social media, calendar, or email tools) to share content or connect with contacts. In doing so, you may allow such services to access limited information from your profile or activity. Each linked service operates under its own privacy policy, and you can revoke such access at any time through your account settings.

All third-party processors and sub-processors undergo due diligence and are bound by written data protection agreements ensuring equivalent security and compliance standards, including transfer impact assessments where data is processed outside India, as required under applicable law.

7. Service Providers

We engage trusted third-party vendors subject to due-diligence, confidentiality obligations, and data-processing agreements (DPAs) to support operations such as hosting, analytics, payments, customer support, and marketing. These providers may access your personal information solely to perform their contractual duties on our behalf and are obligated not to use or disclose it for any other purpose.

8. Legal and Compliance Disclosures

We may disclose your information if required by law, regulation, subpoena, or court order, or when necessary to:

(a) Prevent or investigate suspected illegal activity or fraud;
(b) Enforce our Terms of Use or defend legal claims;
(c) Protect the safety, rights, or property of Thrico, its users, or the public; or
(d) Respond to lawful requests from authorities or regulators.

We will notify you were legally permissible before sharing such data.

We collect and retain only data necessary to fulfil the stated purposes. Data collected for one purpose shall not be used for another incompatible purpose without your consent.

9. Business Transfers

In the event of a merger, acquisition, restructuring, or sale of assets, your data may be transferred to the acquiring entity, subject to continued protection under this Privacy Policy.

In the event that Thrico by PulsePlay Digital, undergoes a merger, acquisition, consolidation, corporate restructuring, reorganization, change in control, sale of assets, strategic investment, or transfer of all or substantially all of its business or assets, your personal data may be transferred to, or accessed by, the successor, acquiring, or affiliated entity as part of such transaction.

Such transfer shall be subject to:

(a) Continued protection of your personal data under privacy terms that are substantially consistent with this Privacy Policy;
(b) Implementation of appropriate contractual and technical safeguards; and Compliance with applicable data protection laws, including the Digital Personal Data Protection Act, 2023.

Where required by applicable law, Thrico shall provide prior notice of such transfer and, where legally mandated, obtain necessary consent before transferring personal data to a successor entity.

If the successor entity intends to materially change the manner in which your personal data is processed, you will be notified and provided with an opportunity to review the updated privacy terms.

10. YOUR DATA RIGHTS AND PREFERENCES

10.1 Data Retention

We retain your personal data for as long as your account remains active or as required to provide our Services. Certain information may be preserved even after you become inactive, to maintain your profile, enable future reactivation, comply with legal obligations, or for legitimate business purposes such as analytics and security. Where possible, we may retain information in aggregated or de-identified form to prevent identification of any individual.

10.2 Your Rights and Controls

You have control over how your personal information is collected, used, and shared on Thrico. Depending on applicable laws, you may:

(a) Access or Download: Request a copy of your personal data.
(b) Rectify: Correct or update inaccurate or incomplete information.
(c) Deactivate: Deactivate your personal account.
(d) Delete: Request deletion of your personal data when it is no longer necessary for the purposes for which it was collected. This can be done after seven days of deactivating your account.
(e) Restrict or Object: Ask us to stop or limit the processing of your data under certain circumstances.
(f) Portability: Request that we provide your personal data in a structured, machine- readable format.

You can manage most of these preferences directly through your account settings, or you may contact us at thrico.dpo@pulseplaydigital.com. We will respond in accordance with applicable data protection laws.

10.3 Account Closure

You may close your Thrico account at any time. Once closed, your profile and related information will no longer be visible to other Members or visitors within a reasonable period (generally within 30 days), subject to applicable laws.

We may retain limited information as required to:

(a) Comply with legal or regulatory obligations;
(b) Resolve disputes or enforce our Terms;
(c) Prevent fraud, misuse, or security incidents; and
(d) Maintain records of your consent or communications preferences.

Content you have shared with others (e.g., group posts, comments, or collaborations) may remain visible to those users even after your account is deleted, and cached or archived versions of your content may persist temporarily in third-party systems.

10.4 Consent Management & Withdrawal

You may withdraw consent at any time through your account settings or by contacting us. Withdrawal will not affect prior lawful processing, but certain features may become unavailable. Thrico maintains auditable records of consent for all personal data processing activities, as required by applicable laws.

11. User Generated Content (UGC) and User Responsibility

11.1 Users are solely responsible for the content uploaded or shared through the platform and agree to indemnify and hold harmless Thrico against any claims, damages, or liabilities arising from such content.

11.2 Thrico may use data uploaded by Users, including user- generated content, for internal analysis, verification, compliance, fraud prevention and service improvement purposes.

11.3 Users agree to use the Platform lawfully, maintain confidentiality of account credentials, provide accurate information and refrain from misuse, unauthorized access or interference with the platform.

12. DATA PROTECTION OFFICER (DPO) & GRIEVANCE REDRESSAL

Thrico has appointed a Data Protection Officer (DPO) to oversee compliance and address privacy- related concerns.
You may contact the DPO at thrico.dpo@pulseplaydigital.com

A grievance redressal mechanism is in place to resolve user complaints within the timelines prescribed by the Digital Personal Data Protection Act, 2023 (DPDPA).

13. DISCLAIMER & LIMITATION OF LIABILITY

13.1 To the extent permitted by applicable law, Thrico shall not be responsible for any indirect, incidental, or consequential damages arising from the use of the Website, Mobile App or Services, including data loss, downtime, or security breaches, except where such limitation is restricted by applicable law.

13.2 The Platform may be temporarily unavailable due to scheduled maintenance, system upgrades, technical issues, cybersecurity incidents or other reasons beyond Thrico’s reasonable control. Thrico does not guarantee uninterrupted availability of the Platform and shall not be liable for any loss, damage or disruption arising from such downtime or unavailability.

13.3 Thrico implements reasonable administrative, technical and organizational safeguards to protect personal data against unauthorized access, disclosure, alteration or destruction. However, no method of transmission or storage is completely secure, and Thrico does not guarantee absolute security of information.

14. ADDITIONAL INFORMATION

14.1 Security Measures

We use encryption, secure hosting, firewalls, and other safeguards to protect your data. In the event of a data breach, we will notify affected users and authorities without undue delay, as required by applicable law.

In the event of a data breach likely to impact your rights, Thrico will notify the Data Protection Board of India and affected users without undue delay, detailing the nature of the breach, affected data categories, and mitigation steps taken

14.2 Cross-Border Transfers

Your data may be processed or stored outside India under adequate security measures and contractual safeguards consistent with applicable data protection laws.

Where personal data is transferred internationally, such transfers are protected through Standard Contractual Clauses (SCCs), adequacy decisions, or equivalent contractual safeguards, ensuring adequate protection as per applicable laws.

14.3 Legal Basis for Processing

We process your data under lawful grounds, including:

(a) Your consent;
(b) Contractual necessity;
(c) Legitimate business interests such as security and analytics.

14.4 Marketing and Do Not Track

We do not sell or share your information for third-party marketing. Thrico currently does not respond to “Do Not Track” (DNT) signals.

14.5 Children’s Data

We do not knowingly collect data from individuals under 18 years of age. The Platform is not intended for use by individuals under the age of 18 years. Any inadvertent collection will be promptly deleted upon notice.

14.6 Accountability and Governance Framework

Thrico maintains an internal data protection governance framework including privacy audits, employee training, and periodic compliance reviews to ensure ongoing adherence to legal and security standards.

14.7 Suspension of features

Thrico reserves the right, at its sole discretion, to modify, suspend, restrict or discontinue any module features, functionality or part of the platform, temporarily or permanently, at any time, including but not limited to where such action is required to comply with applicable laws, government directives, industry standards, security requirements or Thrico’s internal operational decisions. Thrico shall not be liable for any loss or inconvenience arising from such modification or discontinuation.

14.8 Business and Users Share Intellectual Property

All intellectual property rights in the platform, including software, design, text, graphics, designs, videos, media content and trademarks are owned by or licensed to Thrico by PulsePlay Digital.

Intellectual Property uploaded or shared by users or customers remains their property. By using the platform, Users grant Thrico a limited, non-exclusive, royalty-free license to use such content solely for the purpose of operating, maintaining securing, and improving the services.

14.9 Subscription Compliance

Continued access to the Platform is subject to timely payment of applicable subscription fees. Failure to make payments in accordance with agreed terms may result in suspension or restriction of access to the platform.

14.10 Pricing Revision

Thrico reserves the right to revise the subscription pricing at its discretion. Customers already paid for an annual subscription shall not be affected by such revisions during the existing subscription term. Customers on a monthly billing cycle may be subject to revised pricing upon renewal or subsequent billing periods.

14.11 Invoicing and Payment Terms

Subscription fees, billing cycles and payment terms shall be governed by the invoice issued by Thrico from time to time and any applicable subscription agreement.

14.12 Governing Law & Dispute Resolution

This Privacy Policy shall be governed by and construed in accordance with the laws of India. Any disputes arising out of or in connection with this Privacy Policy shall be resolved through

arbitration in New Delhi in accordance with the Arbitration and Conciliation Act, 1996, with proceedings conducted in English.

14.13 Limitation Period for Claims

Any claim or dispute arising out of or in connection with this Privacy Policy must be raised within three (3) years from the date on which the cause of action arises, in accordance with the Limitation Act, 1963.

15. Jurisdiction-Specific Privacy Rights

Additional rights may apply depending on your country or region of residence, please refer to the Jurisdiction-Specific Privacy Rights Section below.

In the event of any inconsistency between this General Privacy Policy and the Jurisdiction- Specific Sections below, the provisions appliable to your jurisdiction of residence shall prevail to the extent of such inconsistency.

15.1 Applicable Privacy Policy for Residents of European Union

This section applies to individuals located in the European Union and is intended to comply with the General Data Protection Regulation (“GDPR”), for detailed information please see the European Privacy Policy for European-specific privacy information

(a) Lawful Basis for Processing

Thrico processes personal data only where it has a lawful basis under Article 6 of the GDPR, including:

i. Consent: When you voluntarily provide information (e.g., creating an account, communicating with us, or subscribing to updates).
ii. Contractual Necessity: When processing is required to perform obligations under a user agreement or to deliver our platform services.
iii. Legal or Regulatory Obligation: When processing is necessary to comply with applicable laws, regulations, or lawful requests from authorities.
iv. Legitimate Business Interests: When processing supports Thrico’s operational, security, or service improvement functions, provided such interests do not override your privacy rights.

(b) Data Subject Rights

In compliance with the GDPR, you are entitled to exercise the following rights regarding your personal data:

i. Right of Access: You may request a copy of the personal data we hold about you.
ii. Right to Rectification: You may ask us to correct or update any inaccurate or incomplete information.
iii. Right to Erasure (“Right to be Forgotten”): You may request deletion of your personal data when it is no longer required for the purposes collected or where consent has been withdrawn.
iv. Right to Restrict Processing: You may request that we limit the processing of your personal data under certain circumstances.
v. Right to Data Portability: You may obtain your personal data in a structured, commonly used, and machine-readable format and transfer it to another service provider.
vi. Right to Object: You may object to the processing of your data based on legitimate interests or for direct marketing activities.
vii. Rights Regarding Automated Processing: You have the right not to be subject to decisions based solely on automated processing, including profiling, without human involvement. This Right is not to be subject to Automated Decision- Making under Article 22 GDPR.

(c) Cross-Border Data Transfers

When transferring your data outside the EU, Thrico by PulsePlay Digital Private Limited, ensures that adequate protection measures are in place, including:

i. Standard Contractual Clauses (SCCs) approved by the European Commission;
ii. Adequacy Decisions confirming comparable levels of data protection; or
iii. Sensitive or special category data is processed only with explicit consent and safeguarded through encryption and restricted access.
iv. All international transfers are conducted using robust technical and organizational safeguards to maintain data security and integrity.

(d) Right to Lodge Complaint

You have the right to lodge a complaint with your Competent Data Protection Supervisory Authority, we will respond in accordance with applicable data protection laws.

15.2 Additional Notice to residents of Canada

This section applies to residents of Canada and is intended to comply with the PersonalInformation Protection and Electronic Documents Act (“PIPEDA”)and applicable provincial privacy laws, for detailed information please see the  CANADA PRIVACY POLICY.

(a) Lawful basis for Processing data

Thrico processes personal information only where a lawful basis exists under applicable Canadian privacy laws. Depending on the nature of the data and purpose of use, processing is based on one or more of the following grounds:

i. Consent: When you voluntarily provide information (e.g., creating an account, communicating with us, or subscribing to updates).
ii. Contractual Necessity: When processing is required to perform obligations under a user agreement or to deliver our platform services.
iii. Legal or Regulatory Obligation: When processing is necessary to comply with applicable laws, regulations, or lawful requests from authorities.
iv. Legitimate Business Interests: When processing supports Thrico’s operational, security, or service improvement functions, provided such interests do not override your privacy rights.

(b) Cross-Border Data Transfers

Thrico may store or process personal data on servers located outside Canada, including in jurisdictions such as the United States or the European Economic Area (EEA).

When such transfers occur, Thrico ensures that appropriate safeguards are in place, such as:

i. Standard Contractual Clauses (SCCs) or other approved contractual instruments;
ii. Data processing agreements ensuring equivalent protection; and
iii. Vendor compliance audits to verify adherence to Thrico’s privacy commitments.
iv. You acknowledge that foreign government, courts, or law enforcement agencies may access your personal information under applicable law of those jurisdictions.

(c) Your Rights Under PIPEDA

Under PIPEDA, you have the right to:

i. Access the personal information Thrico holds about you;
ii. Request corrections to ensure data accuracy and completeness;
iii. Withdraw consent to data processing, subject to legal or contractual limitations; and
iv. File a complaint with the Office of the Privacy Commissioner of Canada (OPC) if you are unsatisfied with our handling of your personal data.

(d) Consent Withdrawal and Preference Management

You may withdraw your consent to data processing at any time, subject to legal or contractual restrictions. To do so please contact us at thrico.dpo@pulseplaydigital.com

(e) Complaints

If you are dissatisfied with our response, you may contact the Office of the Privacy Commissioner of Canada.

15.3 Applicable Privacy Policy for the Residents of the United States

This section applies to residents of the United States of America where comprehensive privacy laws apply, including California, and is intended to comply with California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), and other applicable state laws, you may refer to the detailed United States Privacy Policy provided herein for comprehensive information regarding your rights and our data handling practices applicable within the United States at USA Privacy Policy.

(a) Categories of Personal Information Collected

We collect information that identifies, relates to describes, is reasonably capable of being associates with, or could reasonably be linked, directly or indirectly, with particular consumer or household (“Personal Information”).

We may collect the following categories of Personal Information:

i. Identifiers and Contact Information: Full name, username, alias, postal address, billing address, unique personal identifier, online identifier, email address, phone number, or other similar identifiers.
ii. Account and Profile Information: Account credentials (including user ID and hashed passwords), profile photograph, professional title, company name, user preferences, language settings, and time zone.
iii. Commercial and Transactional Information: Records of products or services purchased, obtained, or considered, subscription history, payment information, (processed through our third-party payment gateways, such as the last four digits of a credit card and billing address), and transactional history.
iv. Internet or Other Electronic Network Activity Information: Internet Protocol (IP) address, device identifiers (e.g., MAC address), browser type and version, operating system, log data concerning your interaction with our Services, including but not limited to, pages viewed, features utilized, date and time stamps, clickstream data, and referring/exit URLs.
v. Geolocation Data: Non-precise location information, such as location derived from your IP address or information you provide, such as a city or postal code.
vi. User-Generated Content and Communications: Any data, files, text, images, or other content you upload, submit, post, or otherwise provide to the Services. This also includes records and copies of your correspondence with us, such as support tickets, email communications, chat logs, feedback, and survey responses.
vii. Inferences and Derived Information: Inferences drawn from any of the information identified above to create a profile about a user reflecting their preferences, characteristics, psychological trends, predispositions, behaviour, attitudes, intelligence, abilities, and aptitudes.
viii. Cookies and Similar Technologies: Information collected through cookies, web beacons, pixels, SDKs, and other tracking technologies.

We do not intentionally collect or process Sensitive Personal Information (such as government-issued identification numbers, precise geolocation, genetic data, or health information) unless it is strictly necessary for a specific feature of the Services and is provided with your explicit consent.

(b) Your Rights and Choices

Depending on your jurisdiction, you may have certain rights regarding your personal Information. These rights may include:

i. Right to Access: The right to request access to the Personal Information we hold about you.
ii. Right to Rectification: The right to edit/update the correction of inaccurate or incomplete personal profile account information.
iii. Right to Erasure (Deletion): The right to request the deletion of your Personal Information, subject to certain exceptions.
iv. Right to Restrict Processing: The right to request that we restrict the processing of your Personal Information in certain circumstances.
v. Right to Data Portability: The right to receive your Personal Information in a structured, commonly used, and machine-readable format.
vi. Right to Object/Opt-Out: The right to object to or opt-out of certain types of processing, such as direct marketing.

(c) For Residents of California (USA)

This section supplements the information contained in our Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California. We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) as amended by the California Privacy Rights Act of 2020 (CPRA).

i. Your Rights: You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months (the “Right to Know”). You also have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions (the “Right to Delete”). You have the right to request that we correct inaccurate Personal Information (the “Right to Correct”).
ii. Right to Opt-Out of Sale/Sharing: We do not “sell” Personal Information as the term is traditionally understood. However, under the CCPA, certain sharing of data for advertising purposes may be considered a “sale” or “sharing.” You have the right to direct us not to sell or share your Personal Information.
iii. Right to Limit Use of Sensitive Personal Information: You have the right to limit our use and disclosure of your Sensitive Personal Information to that use which is necessary to perform the services or provide the goods reasonably expected by an average consumer.
iv. Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights.
v. To exercise any of these rights, for questions, requests or complaints please contact us at thrico.dpo@pulseplaydigital.com.

Address: PulsePlay Digital Private Limited, Sushma Cottage, Ram Nagar, Dharamshala, Himachal Pradesh – 176215, India

15.4 Applicable Privacy Policy for residents of the United Arab Emirates (UAE)

This section applies to residents of the UAE and is intended to comply with the UAE Personal Data Protection Law, the detailed privacy policy of the UAE may be referred at UAE PRIVACY POLICY.

(a) How we collect your personal data

We collect your personal data through various lawful and transparent mean, depending on how you interact with our website, mobile application, and related digital services. The collection methods are designed to ensure compliance with the UAE Federal Decree-Law No. 45 of 2021 regarding the Protection of Personal Data (PDPL) and to uphold your privacy and data protection rights.

(i) Direct Interactions:

We collect personal data that you voluntarily provide to us when you:

(a) Register for an account, subscribe to our services, or create a profile on Thrico;
(b) Submit forms, surveys, or applications through our website or mobile platform;
(c) Communicate with us via email, telephone, live chat, or in person;
(d) Request information, participate in events, provide feedback, or seek customer support.

This includes information such as your name, contact details, and any other data you choose to share in the course of your interaction with Thrico.

(ii) Automated Technologies:

When you visit or use our online services, certain data may be collected automatically through cookies, analytics tools, web beacons, and server logs. These technologies help us:

(a) Recognize you as a returning user;
(b) Monitor website traffic and usage trends;
(c) Improve functionality, performance, and security; and
(d) Personalize your browsing experience.

The data collected through automated means may include your IP address, browser type, device information, and browsing patterns. You have the options to manage or restrict cookies through your browser or device settings; although some site features may not function properly without them.

(iii) Third-Party Sources:

We may receive personal data about you from third parties in accordance with applicable UAE laws and data protection standards. These sources may include:

(a) Business partners and affiliates who assist in delivering our services;
(b) Service providers, payment processors, or analytics platforms acting on our behalf;
(c) Publicly available sources such as social media platforms, business directories, or official government databases; and
(d) Other lawful third parties, where you have provided consent or where such disclosure is permitted under UAE law.
All third-party data sharing is conducted under strict confidentiality and data protection obligations, ensuring that any data received or shared is handled lawfully, securely, and solely for legitimate business or contractual purposes.

(iv) Your Rights

Under the UAE PDPL, you have the following rights concerning your personal data:

i. Right to Access – to obtain confirmation and a copy of your personal data being processed.
ii. Right to Correction – to request rectification of inaccurate or incomplete data.
iii. Right to Erasure – to request deletion of your personal data under certain lawful conditions.
iv. Right to Restrict Processing – to limit how your data is processed in specific circumstances.
v. Right to Data Portability – to receive your data in a structured, machine-readable format where applicable.
vi. Right to Object – to object to processing carried out for direct marketing or other legitimate interests.
vii. Right to Withdraw Consent – to withdraw previously given consent at any time, without affecting prior lawful processing.
viii. To exercise these rights, you may contact us at thrico.dpo@pulseplaydigital.com , we may require verification of your identity before responding to such requests.

(c) Complaints

You may file complaints with the UAE data officer or other competent regulatory authority.

16. Updates to this Privacy Policy

We reserve the right to update or modify this privacy policy at any time. Changes shall be effective upon posting on the platforms and continued use of the services constitutes acceptance of the updated policy.

17. CONTACT US

Thrico by PulsePlay Digital Private Limited is responsible for processing your information. If you have any questions, comments, or concerns about your Privacy Policy, you may email us at thrico.dpo@pulseplaydigital.com.

Additionally, if you have any questions, comments or concerns ab out our Privacy Policy, feel free to send correspondence to the following address:
PulsePlay Digital Private Limited
Sushma Cottage, Ram Nagar, Dharamshala, Himachal Pradesh – 176215, India.
This Privacy Policy complies with the Digital Personal Data Protection Act, 2023.
Your trust matters to us. We are committed to managing your data responsibly, securely, and transparently.