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Privacy Policy - Pulso

Last updated on May 1, 2026

1. Introduction

woku SpA (hereinafter, "woku", "We") operates Pulso ("Pulso" or "the Platform"), a service that talks with your end customers via call, web or WhatsApp to detect risk signals and trigger alerts to your team. woku SpA is the legal entity responsible for the processing of personal data associated with Pulso and is committed to protecting the privacy of users and to ensuring compliance with applicable data protection laws, including Law No. 19,628 of Chile (and its future reform), the General Data Protection Regulation of the European Union (GDPR, Regulation (EU) 2016/679), and other regulations in force according to the user's jurisdiction.

This Privacy Policy describes what data we collect through Pulso, how we use it, with whom we share it, how long we retain it, and what your rights are. For Clients who engage Pulso and where woku acts as a Data Processor, the specific conditions for the processing of their end-user data are additionally governed by the Pulso Data Processing Agreement (DPA).

2. Who we are and how to contact us

Data Controller: woku SpA (operator of Pulso)

Address: Calle 120 39 Dp 14 B, Hualpén, Chile 4600150

Privacy contact email: team@woku.app or pau@woku.app

Product website: woku.app/pulso

For any inquiry related to the processing of your personal data, you may write to us at the email indicated, identifying yourself with your full name and a description of your request.

3. Data We Collect

We collect the following types of personal data:

a) Data you provide to us directly:

  • Full name.
  • Email address.
  • Phone number, when WhatsApp or voice integrations are enabled.
  • Payment information (processed securely through our payment provider; Pulso does not store card numbers).
  • Company or business information (name, tax ID, industry).

b) Data we collect automatically:

  • Pulso usage data (admin panel pages visited, features used, access frequency).
  • IP address and device data (browser type, operating system).
  • Cookies and similar technologies (see Section 7).

c) Data of our clients' customers (end users):

  • Names, email addresses, phone numbers, transcripts and recordings of conversations with the Pulso Agent, conversation ratings, detected sentiment, identified risk signals, and generated alerts.
  • This data is processed on behalf of the Client in accordance with the Pulso DPA. Transcripts are anonymized before being used for product-improvement purposes or aggregate reports when applicable.

4. Legal Bases for Processing

We process your data only when a valid legal basis exists. Depending on the case, these are:

  • Performance of a contract: when processing is necessary to provide you with the service, for example, to manage your account and contracted Plan.
  • Consent: when you have given us express authorization, for example, for marketing communications or for call recording for quality purposes.
  • Legitimate interest: to improve the platform, prevent fraud, and ensure security, provided your fundamental rights do not prevail.
  • Compliance with legal obligations: when the law requires us to retain or disclose data.

5. Purposes of Processing

We use your data to:

  • Create and manage your Pulso account.
  • Process payments and manage your contracted Plan (Starter, Growth, or Scale).
  • Provide and maintain the Pulso service (AI agent conversations, signal detection, alerts, and integrations).
  • Send you service notifications, updates, and security alerts.
  • Analyze platform usage to improve features.
  • Handle support and customer service requests.
  • Comply with legal and regulatory obligations.
  • Send you marketing communications, only with your prior consent, revocable at any time.

6. Data Sharing with Third Parties

We do not sell or transfer your personal data to third parties for commercial purposes. To operate Pulso, we work with the following types of service providers (sub-processors), who act under our instructions and with adequate contractual safeguards:

  • Cloud infrastructure and hosting (for example, Amazon Web Services, Google Cloud).
  • Payment processing (Paddle, as Merchant of Record, where applicable).
  • Language models and voice / AI services (LLM providers and speech-to-text/text-to-speech providers, under clauses prohibiting the use of data to train public models).
  • Messaging and telephony (WhatsApp Business API provider and telephony providers used for the agent's calls).
  • Usage analytics tools (for example, Google Analytics or equivalent).
  • Transactional email services (Amazon SES).
  • Customer support tools (for example, Intercom, HubSpot).

The updated list of sub-processors is available upon request by emailing team@woku.app or pau@woku.app. We will notify any addition or replacement of sub-processors at least 30 days in advance.

We may disclose data when required by law, court order, or competent authority.

7. Use of Cookies

We use first-party and third-party cookies to:

  • Keep your session active on Pulso.
  • Remember your user preferences.
  • Analyze platform traffic and usage (analytics cookies).

Types of cookies:

  • Essential cookies: necessary for basic operation; cannot be disabled.
  • Analytics cookies: help us understand how the platform is used; can be disabled.
  • Marketing cookies: used only with your prior consent.

You can manage or withdraw your cookie consent at any time through your browser settings or our cookie preferences panel. No sensitive data is stored in cookies.

8. Data Retention

We retain your personal data for as long as necessary to fulfill the purposes described in this policy or while you maintain an active contractual relationship with Pulso. Specific retention criteria are:

  • Account data: during the validity of the contract and up to 3 years after termination, unless legally required for a longer period.
  • Billing data: up to 7 years, as required by Chilean tax regulations.
  • Activity logs: up to 12 months.
  • Conversation transcripts and recordings: during the validity of the contracted Plan and up to 12 additional months, unless otherwise instructed by the Client. They may be anonymized and retained indefinitely for statistical purposes when they no longer constitute personal data.

After these periods, data will be securely deleted or anonymized.

9. User Rights

In accordance with applicable legislation, you have the following rights over your personal data:

  • Access: request a copy of the data we hold about you.
  • Rectification: correct inaccurate or incomplete data.
  • Deletion ("right to be forgotten"): request the deletion of your data when it is no longer necessary.
  • Restriction of processing: limit the use of your data in certain circumstances.
  • Portability: receive your data in a structured, commonly used, and machine-readable format.
  • Objection: object to processing based on legitimate interest or for marketing purposes.
  • Withdrawal of consent: withdraw any consent granted at any time, without retroactive effect.

To exercise any of these rights, write to us at team@woku.app or pau@woku.app with your full name and a description of the request. We will respond within a maximum period of 30 business days. If you do not receive a satisfactory response, you may file a claim with the competent data protection authority in your country.

If you are an end user whose data is processed by Pulso on behalf of a Client (for example, when you have a conversation with the Pulso Agent through the service contracted by a business), your requests will be redirected to that Client, who acts as Data Controller.

10. Information Security

We apply appropriate technical and organizational measures to protect your data against unauthorized access, loss, or destruction, including:

  • Encryption in transit (TLS/HTTPS).
  • Encryption at rest for sensitive data.
  • Role-based access control (RBAC).
  • Continuous security monitoring.
  • Incident response procedures.

In the event of a security breach that affects your rights, we will notify you as soon as possible and, where applicable, notify the competent authorities within the legal timeframes.

11. International Data Transfers

Some of our providers may be located outside Chile or the European Union. In these cases, we ensure that transfers are carried out with appropriate safeguards, such as standard contractual clauses approved by the competent authorities, or to countries recognized as having an equivalent level of protection.

12. Changes to this Policy

We may update this Privacy Policy when necessary. When changes are significant, we will notify you by email or through a prominent notice on the platform at least 15 days in advance. The last update date will always be displayed at the beginning of the document.

13. Contact

For any privacy inquiry:

woku SpA (operator of Pulso)

Calle 120 39 Dp 14 B, Hualpén, Chile 4600150

Email: team@woku.app or pau@woku.app

Product website: woku.app/pulso