This Privacy Policy explains how Pulse Technology Solutions Inc (“Pulse,” “we,” or “us”) collects, uses, shares, and protects information through the Pulse dispatch platform at portal.dispatch.software, the Pulse driver application, the Pulse passenger application, and our website (together, the “Platform”). It applies to transportation providers and their staff, to drivers, to passengers, and to visitors.
Pulse provides software to transportation providers. When a provider uses the Platform to arrange trips, Pulse processes information on that provider’s behalf. Where that information is protected health information under HIPAA, Pulse acts as the provider’s business associate, and the Business Associate Agreement between Pulse and the provider governs. This Privacy Policy describes our practices generally and does not replace that agreement.
1. WHO THIS POLICY COVERS
• Providers and their staff: the transportation companies that hold accounts, and the dispatchers, administrators, and other personnel they authorize.
• Drivers: individuals who use the driver application to perform trips for a provider.
• Passengers: individuals who are transported on trips arranged through the Platform, whether booked by a broker, by a provider, or by the passenger through the passenger application.
• Visitors: anyone who visits our website or contacts us.
2. INFORMATION WE COLLECT
2.1 Provider Account Information. Business name, entity type, address, licence and authority numbers, the names and contact details of responsible persons and authorized users, login credentials, and billing information. Payment card details are collected and stored by our payment processor, Stripe, not by Pulse.
2.2 Driver Information. Name, contact details, date of birth, driver’s licence and any Taxi and Limousine Commission or other credential, vehicle registration, inspection, and insurance documents, photographs of documents you upload, the providers you are linked to, and records of the trips you perform. We may check credentials against public regulatory data sources, including New York City open data.
2.3 Driver Location. While you are logged in and on shift, the driver application collects your device’s location, including in the background, to dispatch trips, calculate arrival times, confirm arrival at and departure from pickup and drop-off points, and produce trip records. Location is not collected when you are logged out or off shift. You can stop collection at any time by going off shift or by disabling location permission, but the application will not function for trips without it.
2.4 Passenger Information. Name, contact details, pickup and drop-off addresses, appointment times, mobility and equipment needs, and, for trips arranged through Medicaid or a broker, member or authorization numbers and the name of the medical facility. Passengers using the passenger application also provide account details, payment information handled by Stripe, and trip history. Passenger information is provided to us by the provider, by the broker or trip source, or by the passenger.
2.5 Trip and Usage Information. Trip events and timestamps, routes, arrival-time estimates, fares, settlement and payroll records, problem reports, and messages and calls placed through the Platform. Calls between drivers and passengers are routed through a masked number; we log that a call occurred, its duration, and the parties, but do not record its content.
2.6 Device and Technical Information. Device type, operating system, application version, IP address, identifiers assigned by your device, log data, and, for the website, cookies and similar technologies used to keep you logged in, remember preferences, and understand how the site is used. Our Cookie Policy describes the categories of cookies we use and your choices about them.
3. HOW WE USE INFORMATION
We use information to operate the Platform: to create and manage accounts; to receive, assign, dispatch, route, and track trips; to verify driver and vehicle credentials; to calculate fares, earnings, and settlements; to bill providers; to support users; to produce the trip records providers need for billing, compliance, and audit; and to connect to brokers and trip sources. We also use information to secure the Platform, to detect and prevent fraud and misuse, to comply with law and with regulatory and contractual retention requirements, to improve the Platform, and to communicate with you about your account.
We do not sell personal information. We do not use passenger information for marketing. We do not use protected health information for any purpose other than those permitted by the Business Associate Agreement with the relevant provider.
4. HOW WE SHARE INFORMATION
4.1 With Providers. Driver information, driver location, and trip records are shared with the provider a driver performs trips for, because the provider is responsible for the trip and for the driver’s credentials. Passenger information is shared with the provider performing the trip.
4.2 With Brokers and Trip Sources. Where a trip originates from a broker, health plan, or government trip source, we exchange trip status, vehicle location, arrival-time estimates, and driver and vehicle identifiers with that source as required for the trip and for the provider’s contract with it.
4.3 With Passengers. A passenger may see the assigned driver’s first name, vehicle description, approximate location, and estimated arrival time for their trip.
4.4 With Service Providers. We use third parties to host the Platform, process payments (Stripe), provide mapping and geocoding, route telephony and messaging, send notifications, and verify credentials against public data. These providers process information only on our instructions and under contracts that require them to protect it. Where a service provider handles protected health information, it is bound by a business associate agreement.
4.5 With Our Founders. Pulse is owned by Noark Co. d/b/a Darter and Minds’ Eye Innovations, which license technology to Pulse and provide engineering and operational support. Their personnel who support the Platform are bound by the same confidentiality and protected health information obligations as Pulse’s own workforce.
4.6 For Legal Reasons. We disclose information where required by law, subpoena, or court order; to regulators including Medicaid programs and transportation licensing authorities in connection with audits and investigations; to protect the rights, safety, or property of Pulse, its users, or the public; and in connection with a merger, acquisition, or sale of assets, in which case the acquirer takes on the obligations in this Policy.
5. WORKFORCE LOCATION
Some of the people who support the Platform work outside the United States. Their access to information is limited to their role, is subject to the same contractual obligations as our United States workforce, and is restricted to the locations we have approved. Where a provider, broker, health plan, or government program prohibits access to protected health information from outside the United States, we comply with that restriction, and personnel outside the United States work only with de-identified data for that provider.
6. RETENTION
Our full retention schedule, covering every category of information we hold, is set out in our Data Retention Policy. In summary: we retain trip records and associated passenger information for six years from the date of the trip, and driver, vehicle, and credential records for six years after they cease to be active, because providers must keep these records to meet Medicaid, licensing, and broker contract requirements. We retain provider account information for two years after the account closes. We retain information longer where a legal hold, audit, or investigation requires it. When information is no longer needed, we delete it or de-identify it.
7. SECURITY
We protect information using administrative, technical, and physical safeguards appropriate to its sensitivity, including encryption in transit and at rest, access controls and multi-factor authentication, role-based access so that each user sees only what their role requires, audit logging, and a written security program reviewed at least annually. No system is completely secure, and we cannot guarantee that unauthorized access will never occur. If a breach affects your information, we will notify you and the provider concerned as required by law and by our Business Associate Agreements.
8. YOUR CHOICES AND RIGHTS
8.1 Access and Correction. Providers and drivers can view and update account information through the Platform. Passengers who wish to access or correct their information should contact the provider that performed the trip, which is the entity responsible for their records; we will assist that provider in responding. Where we hold protected health information as a business associate, requests for access, amendment, or an accounting of disclosures are handled through the provider under the Business Associate Agreement.
8.2 Deletion. You may ask us to delete information we hold about you. We will do so unless we are required to retain it under Section 6 or by law, in which case we will tell you the basis for retention.
8.3 Location. Drivers control location collection through their device settings and by going off shift, as described in Section 2.3.
8.4 Communications. You may opt out of non-essential email by using the unsubscribe link. Operational messages about trips and your account cannot be opted out of while your account is active.
8.5 State Rights. Residents of California, Colorado, Connecticut, Virginia, and other states with consumer privacy laws may have additional rights, including the right to know what personal information we collect, to request its deletion, and not to be discriminated against for exercising those rights. Information we process on behalf of providers is generally exempt from those laws as business-to-business or as health information regulated by HIPAA, but where a right applies, you may exercise it by contacting us as described in Section 11 and we will respond within the period the law requires. We do not sell personal information and have not done so in the preceding twelve months.
9. CHILDREN
The Platform is not directed to children, and drivers and provider staff must be adults. Passengers may include minors transported to medical appointments; their information is provided to us by the provider or broker responsible for the trip, is protected health information handled under the Business Associate Agreement, and is not used for any other purpose. The passenger application is not intended for use by anyone under eighteen without a parent or guardian.
10. CHANGES TO THIS POLICY
We may update this Policy. We will post the updated Policy on the Platform and, for material changes, notify account holders by email or in the application at least thirty (30) days before the change takes effect.
11. CONTACT
Questions, requests, and complaints about privacy may be sent to support@dispatch.software or to Pulse Technology Solutions Inc, 75 E 3rd St, Sheridan, WY 82801, U.S.A. Security incidents may be reported to security@dispatch.software.