Last Updated on: 15-January-2026
Effective in: 12-March-2026
1. INTRODUCTION
This Privacy Policy describes the policies and procedures of Thrico by PulsePlay Digital Private Limited, Sushma Cottage, Ram Nagar, Dharamshala 176215, Himachal Pradesh (“Company”, “we”, “us”, or “our”), a company incorporated and existing under the laws of India with its registered office at c/o Pulse Play Digital, Sushma Cottage, Ram Nagar, Dharamshala 176215, Himachal Pradesh. on the collection, use, disclosure, and protection of your information when you use our global Software-as-a-Service platform, associated websites, mobile applications, and related services (collectively, the “Services”).
This Privacy Policy is a legally binding document between you and the Company. The terms of this Privacy Policy will be effective upon your acceptance of the same (directly or indirectly in electronic form, by clicking on the “I accept” tab or by use of the Services) and will govern the relationship between you and the Company for your use of the Services.
By accessing or using the Services, you signify that you have read, understood, and agree to be bound by this Privacy Policy and our Terms of Service. If you do not agree with the terms of this Privacy Policy, you are advised not to use or access the Services.
2. SCOPE AND APPLICABILITY
This Privacy Policy applies to all users of the Services worldwide, including but not limited to users located in the United States of America.
For the purposes of this Policy, the Company shall act as the “data controller” or “Data Fiduciary” for the personal information we process, except where we act as a “data processor”
or “service provider” on behalf of our business customers, in which case our processing activities are governed by our contractual agreements with such customers.
3. GOVERNING LAWS AND LEGAL FRAMEWORK
Our privacy practices are designed to comply with a variety of legal frameworks. The processing of personal data under this Policy shall be governed by and construed in accordance with:
(a) The laws of the Republic of India, including the Digital Personal Data Protection Act, 2023, and any rules, regulations, and amendments promulgated thereunder.
(b) Applicable laws in the United States of America, including federal laws and state-specific privacy laws such as the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), the Virginia Consumer Data Protection Act (VCDPA), the Colorado Privacy Act (CPA), and other relevant state legislation, to the extent applicable to our operations.
(c) Other applicable international data protection laws relevant to the jurisdictions of our users.
Jurisdiction-specific disclosures and rights are detailed in the “Additional Disclosures for Specific Jurisdictions” section of this Policy.
This Privacy Policy applies to personal information relating to an identified or identifiable natural person (“Personal Data”) that is collected through our website mobile application, customer support channels, events and other interactions with our services where the user is located in the United States. Thrico does not intentionally collect or process de-identified information under this policy.
4. INFORMATION WE COLLECT
We collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“Personal Information”). We may collect the following categories of Personal Information:
(a) 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.
(b) 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.
(c) 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 transaction history.
(d) 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.
(e) 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.
(f) 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.
(g) 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.
(h) Cookies and Similar Technologies: Information collected through cookies, web beacons, pixels, SDKs, and other tracking technologies. Please refer to Section 11 for more details.
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.
5. HOW WE COLLECT YOUR INFORMATION
We collect Personal Information from various sources:
(a) Directly from You: When you register for an account, subscribe to our Services, populate your user profile, make a purchase, contact our customer support, or otherwise directly provide information to us.
(b) Automatically Through Your Use of the Services: We automatically collect certain information about your device and your interaction with our Services through server logs, cookies, and other tracking technologies.
(c) From Third-Party Sources: We may receive information about you from third parties, including our business customers (where we act as a processor), payment service providers, analytics providers, advertising networks, identity providers (e.g., when you use social login), and other partners.
6. PURPOSES FOR WHICH WE USE YOUR INFORMATION
We use your Personal Information for the following legitimate business and commercial purposes:
(a) To Provide, Operate, and Maintain the Services: To create and manage user accounts, process transactions, provide core features and functionality, and ensure the operational integrity of our platform.
(b) To Communicate with You: To respond to your inquiries, provide customer support, and send you important administrative and service-related communications, such as security alerts, technical notices, and updates to our terms and policies.
(c) For Billing and Account Management: To process payments, manage subscriptions, send invoices and reminders, and prevent fraudulent transactions.
(d) For Improvement, Analytics, and Personalization: To monitor and analyze usage, trends, and activities in connection with our Services, to improve user experience, to develop new products and features, and to personalize the content and features you see.
(e) For Research and Development: To use data, often in an aggregated or de-identified form, for internal research purposes to innovate and enhance our service offerings, technology, and security protocols.
(f) For Marketing and Promotional Communications: Subject to your consent where required by law, to send you newsletters, special offers, and other promotional materials about our Services. You may opt out of receiving marketing communications at any time by following the unsubscribe instructions in such emails.
(g) To Ensure Security and Prevent Fraud: To protect the security and integrity of our Services, to detect, prevent, and respond to fraud, abuse, security risks, and other harmful or illegal activities.
(h) For Legal Compliance and to Enforce Our Rights: To comply with our legal obligations under applicable law, to respond to lawful requests from public and government authorities, to enforce our Terms of Service and other agreements, and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others.
(i) Use of De-identified and Aggregated Information: We reserve the right to de-identify and/or aggregate Personal Information we collect. Such de-identified or aggregated data is not Personal Information, and we may use and disclose it for any lawful purpose, including but not limited to analytics, research, and reporting, without any restriction.
7. DISCLOSURE OF YOUR INFORMATION
We may share your Personal Information with the following categories of third parties:
(a) Affiliates and Subsidiaries: With our parent company, subsidiaries, and other affiliates within our corporate group for purposes consistent with this Privacy Policy.
(b) Service Providers and Vendors: With third-party vendors, consultants, and other service providers who perform services on our behalf. These may include cloud hosting providers, payment processors, analytics companies, customer support platform providers, and marketing partners. These service providers are bound by strict confidentiality and data processing agreements and are permitted to use your information only as necessary to provide services to us.
(c) Business Customers: Where we act as a data processor, we share information with the relevant business customer (your employer or the organization that has provided you with access).
(d) In Connection with a Corporate Transaction: In the event of a merger, acquisition, financing, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your Personal Information may be transferred as part of such a transaction, subject to standard confidentiality arrangements.
(e) For Legal Reasons and Law Enforcement: To comply with any court order, law, or legal process, including to respond to any government or regulatory request. We may also disclose information where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, or situations involving potential threats to the physical safety of any person.
8. INTERNATIONAL DATA TRANSFERS
As a company based in India, your Personal Information will be processed and stored in India and other jurisdictions where we or our third-party service providers operate. These jurisdictions may have data protection laws that are different from the laws of your country.
By using our Services, you acknowledge and consent to the transfer, storage, and processing of your information to and in India and other countries where our servers or service providers are located. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy, implementing appropriate safeguards such as standard contractual clauses or other lawful transfer mechanisms where required.
9. DATA RETENTION
We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.
The criteria used to determine our retention periods include the length of time we have an ongoing relationship with you, whether there is a legal obligation to which we are subject, and whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations).
Upon expiry of the retention period, your Personal Information will be securely deleted or anonymized.
10. DATA SECURITY
We have implemented and maintain reasonable and appropriate technical, administrative, and physical security measures designed to protect the security, confidentiality, and integrity of your Personal Information from unauthorized access, use, alteration, or disclosure. However, please be aware that no security measures are perfect or impenetrable, and we cannot guarantee the absolute security of your information.
11. COOKIES AND TRACKING TECHNOLOGIES
We use cookies, web beacons, and similar tracking technologies to operate and administer our Services, gather usage data, and improve your experience. A cookie is a small text file stored on your device. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our Services.
12. YOUR RIGHTS AND CHOICES
Depending on your jurisdiction, you may have certain rights regarding your Personal Information. These rights may include:
(a) Right to Access: The right to request access to the Personal Information we hold about you.
(b) Right to Rectification: The right to edit/update the correction of inaccurate or incomplete personal profile account information.
(c) Right to Erasure (Deletion): The right to request the deletion of your Personal Information, subject to certain exceptions.
(d) Right to Restrict Processing: The right to request that we restrict the processing of your Personal Information in certain circumstances.
(e) Right to Data Portability: The right to receive your Personal Information in a structured, commonly used, and machine-readable format.
(f) Right to Object/Opt-Out: The right to object to or opt-out of certain types of processing, such as direct marketing.
To exercise any of these rights, please contact us at thrico.dpo@Pulseplaydigital.com
Verification: To protect your privacy and security, we will take reasonable steps to verify your identity before processing your request. You may be required to provide sufficient information to allow us to reasonably verify you are the person about whom we collected Personal Information.
13. CHILDREN’S PRIVACY
The Services are not directed to individuals under the age of 13 (or a higher age as required by applicable law), and we do not knowingly collect Personal Information from children. If we become aware that we have inadvertently collected Personal Information from a child, we will take steps to delete such information from our records promptly.
14. THIRD-PARTY LINKS
Our Services may contain links to other websites or services that are not operated by us. This Privacy Policy does not apply to the privacy practices of those third parties. We encourage you to review the privacy policies of any third-party service you visit.
15. GOVERNING LAW AND DISPUTE RESOLUTION
This Privacy Policy and any dispute arising out of or in connection with it shall be governed by the laws of the Republic of India. The courts at New Delhi, India shall have exclusive jurisdiction to adjudicate any dispute arising out of or relating to this Privacy Policy.
16. CHANGES TO THIS PRIVACY POLICY
We reserve the right to amend this Privacy Policy at our discretion and at any time. When we make changes to this Privacy Policy, we will post the updated notice on the website and update the policy’s effective date. Your continued use of our Services following the posting of changes constitutes your acceptance of such changes.
17. CONTACT US
If you have any questions, comments, or concerns about this Privacy Policy or our privacy practices, or if you wish to exercise your rights, please contact our Data Protection Officer at:
Data Protection Officer: Email: thrico.dpo@Pulseplaydigital.com
18. ADDITIONAL DISCLOSURES FOR SPECIFIC JURISDICTIONS
18.1 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).
(a) 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”).
(b) 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.
(c) 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.
(d) Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights.
18.2 To exercise these rights, please submit a verifiable consumer request to us by contacting us at thrico.dpo@pulseplaydigital.com
Data Protection Officer – Thrico
E-mail – thrico.dpo@pulseplaydigital.com
Website: https://thrico.com
Address:
Thrico by PulsePlay Digital Private Limited