Privacy Policy

At Pu'ersa, inclusive of our affiliated entities ("Pu'ersa", "us", "we", or "ours"), we hold your privacy in high regard and diligently strive to ensure the security of any data we receive from or about you. Our Privacy Policy elucidates the protocols we follow regarding the Personal Information we gather from or about you as you access our website, applications, and services, which we collectively term as "Services". However, this Privacy Policy does not extend to information we process on behalf of our business clients, like our API. The handling of such data is dictated by our agreements with customers, which outlines the terms of access and usage of our offerings.

1. Collection of Personal Data​

We gather personal data related to you, termed as “Personal Information”, as described below:

Personal Information You Supply: We gather Personal Information when you establish an account for utilizing our Services or engage in communication with us as follows:

• Account Details: Upon setting up an account with us, we accumulate information linked to your account, comprising your name, contact data, account login credentials, payment card details, and transaction history, collectively referred to as “Account Information”.
• User Provided Content: During the usage of our Services, we gather Personal Information embedded in the inputs, file uploads, or feedback that you provide to our Services, which we term as “Content”.
• Interaction Information: In the event of communication with us, we accumulate your name, contact data, and the content of any messages you send, referred to as “Communication Information”.
• Social Interaction Data: We maintain pages on social media platforms like Instagram, Facebook, Medium, Twitter, YouTube, and LinkedIn. When you engage with our social media pages, we accumulate Personal Information that you choose to share with us, such as your contact details, collectively known as “Social Information”. Furthermore, the entities hosting our social media pages may supply us with aggregate data and analytics about our social media engagement.

Personal Information We Acquire Automatically from Your Interaction with the Services: As you visit, employ, or interact with the Services, we gain the following details about your visit, usage, or interactions, which we term as “Technical Information”:

• Log Details: Information that your browser autonomously forwards when you use our Services. Log details include your Internet Protocol address, browser type and configurations, the date and time of your request, and your interaction with our website.
• Usage Information: We may autonomously gather data about your interaction with the Services, such as the types of content that you view or engage with, the features you use and the actions you take, your time zone, country, dates and times of access, user agent and version, the type of computer or mobile device, and your computer connection.
• Device Details: This encompasses the name of the device, operating system, device identifiers, and the browser you employ. The information collected might depend on the type of device in use and its settings.
• Cookies: We utilize cookies to operate and manage our Services, and enhance your experience. A “cookie” is a chunk of information forwarded to your browser by a website you visit. You can configure your browser to accept or reject all cookies, or to alert you whenever a cookie is offered so you can decide each time whether to accept it. However, rejecting a cookie might in some instances prevent you from using, or negatively impact the display or functionality of, a website or certain areas or features of a website. For more details on cookies, please visit All About Cookies.
• Analytics: We may employ a range of online analytics tools that utilize cookies to aid us in understanding how users engage with our Services and to augment your experience when you utilize the Services.

2. The utilization of personal data​

We might utilize Personal Information for a range of purposes, including:

• To deliver, manage, uphold, and/or examine the Services;
• To enhance our Services and facilitate research;
• To correspond with you;
• To create new initiatives and services;
• To forestall fraud, criminal activities, or misappropriation of our Services, as well as safeguard the security of our IT infrastructure, systems, and networks;
• To execute business transitions; and
• To adhere to legal requirements and procedures, and to safeguard our rights, privacy, safety, or assets, as well as those of our affiliates, you, or other third parties.

Information in Aggregate or Anonymized Form. We might aggregate or anonymize Personal Information in a way that it cannot be used to identify you, and we use such data to evaluate the effectiveness of our Services, to enhance and introduce features to our Services, to facilitate research, and for other similar purposes. Additionally, we might occasionally assess the general behavior and traits of users of our Services and disclose aggregated data like general user statistics to third parties, publish such aggregated data, or make such aggregated data widely accessible. We may accumulate aggregated data through the Services, via cookies, and through other methods outlined in this Privacy Policy. We will retain and use anonymized information in an anonymous or de-identified format and we will not attempt to reidentify the information, unless mandated by law.

3. Sharing of personal data​

There might be instances where we would need to disclose your Personal Information to third parties without additional notification to you, unless otherwise mandated by law:

• Service Providers and Contractors: In our quest to fulfill business operational needs and deliver certain services, we may need to share Personal Information with vendors and service providers. This includes but is not limited to providers of hosting services, cloud services, IT services, email communication software, and web analytics services, among others. These entities will only access, process, or store Personal Information as per our directives and only in the capacity of rendering their services to us.
• Corporate Transactions: In the event of key transactions such as strategic dealings, reorganization, bankruptcy, receivership, or service transition to another provider (altogether referred to as a “Transaction”), your Personal Information and other related data might be disclosed during the diligence process with parties involved in the Transaction and might be transferred to a successor or affiliate as part of that Transaction, along with other assets.
• Legal Obligations: We may disclose your Personal Information, inclusive of details about your interaction with our Services, to governmental authorities, industry peers, or other third parties (i) if compelled by law or in the sincere belief that such action is required to meet a legal commitment, (ii) to safeguard and defend our rights or property, (iii) if we, in our sole discretion, determine a violation of our terms, policies, or the law; (iv) to detect or avert fraud or other unlawful activity; (v) to secure the safety, security, and integrity of our products, our employees, or our users, or the public, or (vi) to guard against legal liability.
• Affiliates: We may share Personal Information with our affiliates, which refers to an entity that has control over, is controlled by, or is under common control with Pu'ersa. Our affiliates may use the Personal Information we share in accordance with this Privacy Policy.

4. Your entitlements​

Based on geographical location, individuals within globally might have specific statutory rights concerning their Personal Information. For instance, you might be entitled to:

• Obtain access to your Personal Information as well as details about its processing.
• Erase your Personal Information from our database.
• Correct or update your Personal Information.
• Migrate your Personal Information to a different party (right to data portability).
• Limit our processing of your Personal Information.
• Revoke your consent - at any point in time, especially where our legal basis for processing depends on your consent.
• Express disagreement towards the way we process your Personal Information.
• Register a complaint with your local data protection regulator.

These rights can often be exercised through your Pu'ersa account. If you encounter difficulties in exercising these rights via your account, kindly forward your request to [email protected].

A brief on accuracy: Services like Cyber Bubble produce responses by interpreting a user's inquiry and, in reply, forecasting the most probable subsequent words. Sometimes, the most probable words might not necessarily be factually correct. Due to this, we advise against relying on the factual accuracy of our model outputs. If you discern that Cyber Bubble output includes factually incorrect data about you and you wish us to rectify the error, please forward a correction request to [email protected]. Given the technical intricacies of our model operations, we may not be able to rectify every inaccuracy.

5. Additional U.S. State Disclosures​

The following table provides additional information about the categories of Personal Information we collect and how we disclose that information. You can read more about the Personal Information we collect in “Personal information we collect” above, how we use Personal Information in “How we use personal information” above, and how we retain Personal Information in “Security and Retention” below.

As mandated by local legislation, and barring certain exceptions, individuals may exercise the following rights in relation to their Personal Information:

• The right to be informed about our handling of your Personal Information, including the specific elements of Personal Information that we have gathered from you;
• The right to request the erasure of your Personal Information;
• The right to rectify any inaccuracies in your Personal Information; and
• The right to not be subjected to discriminatory practices when exercising any of your privacy rights.

Please note that we do not "sell" or "share" Personal Information for the purpose of cross-contextual behavioral advertising, as those terms are understood under relevant local laws. Moreover, we do not process sensitive Personal Information with the intent to deduce certain attributes about a consumer.

Rights Exercise. Where local legislation allows, the privacy rights outlined in this section can be exercised by submitting a request to [email protected].

Authentication. To prevent illicit access, alteration, or removal of your Personal Information, we may necessitate that you verify your identity prior to submitting a request for knowledge, correction, or deletion of Personal Information. Should you not have an account with us, or if suspicious activity is detected, we might request additional Personal Information and residency proof for authentication. Should we fail to authenticate your identity, we will be unable to fulfill your request.

Approved Representatives. A request for rights can also be submitted through an approved representative. In such instances, the representative must provide signed written consent to act in your stead and you may be asked to verify your identity and provide residency proof independently. Requests from approved representatives can be submitted to [email protected].

Contesting Decisions. Your place of residence may grant you the right to contest a decision we make in response to requests to exercise your rights as per local legislation. To contest a decision, please forward your request to [email protected].

6. Protection of Minors​

Our Service is not intended for children below 13 years of age. Pu'ersa does not intentionally gather Personal Information from children under the age of 13. If you suspect a child under the age of 13 has provided Personal Information to Pu'ersa via the Service, please reach out to us at [email protected]. We will look into any reports and, if necessary, expunge the Personal Information from our systems. If you are aged between 13 and 18, parental or guardian consent is mandatory to use our Services.

7. External Website Links​

Our Service may feature links to websites not owned or managed by Pu'ersa, which includes social media platforms (“Third Party Sites”). Your interactions with these Third Party Sites are governed by their specific privacy policies and terms of service, not this Privacy Policy. The inclusion of these links does not imply our endorsement or validation of these sites. For information regarding their privacy procedures and policies, please directly contact these Third Party Sites.

8. Data Security and Retention​

We employ reasonable commercial standards of technical, administrative, and organizational measures to safeguard Personal Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction, both online and offline. Nevertheless, no online or email transmission is completely secure or error-free. Emails sent to or received from us may not be secure. As such, we advise careful consideration of what information you send to us via the Service or email. Furthermore, we cannot be held accountable for any circumvention of privacy settings or security measures on the Service, or third-party websites.

We retain your Personal Information only as long as necessary to provide our Service to you, or for other valid business reasons like resolving disputes, ensuring safety and security, or meeting our legal obligations. The retention duration of Personal Information depends on several factors, such as the quantity, type, and sensitivity of the data, potential risk from unauthorized use or disclosure, our reasons for processing the data, and legal requirements.

9. Users Across the Globe​

If you use our Service, you acknowledge and understand that your Personal Information will be processed and stored in our facilities and servers located in the United States, and may also be shared with our affiliates and service providers located in other jurisdictions.

Our Service is temporarily not intended for users in the EEA, UK, North Korea, Iran, Russia or Switzerland.

10. Revisions to the Privacy Policy​

This Privacy Policy may undergo changes occasionally. In such cases, the revised version will be published on this page, except when a different form of notification is necessitated by applicable law.

11. Getting in Touch with Us​

Should you have any inquiries or issues that have not been clarified in this Privacy Policy, please forward your request to [email protected].