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Data processing addendum — draft

DRAFT FOR COUNSEL — not an executed contract. Do not treat this page as a signed DPA or MSA.

Pulsar Cards does not hold a Type II audit report, a GDPR certificate, or a DPDP certificate. It is not an RBI-authorised payment system, prepaid instrument issuer, or payment aggregator. It is not a TRAI-registered Principal Entity or telemarketer unless operations records a Principal Entity ID. This site describes technical controls in the product today. Signed MSA, DPA, and audit reports are issued by counsel and a licensed CPA firm — not generated by this page.

Parties

This draft is between the customer (controller) and Navidad Infotech Pvt. Ltd. (processor) for Pulsar Cards hosted on the customer’s agreed environment. It is not executed by visiting this page.

Subject matter

Processing of account data, public card fields the customer publishes, contacts and notes the customer stores, and aggregate analytics. Visitor identity dossiers are out of scope because the product does not build them.

Instructions

The processor processes personal data only on documented instructions: to operate the card, exchange, follow-up, and invoice surfaces the customer enables. Export and deletion are available to the account holder in Settings.

Transfers

Hosting is the DigitalOcean Droplet described in the deployment notes. EU-US Data Privacy Framework participation is not claimed here. Counsel must name the transfer mechanism that applies to a given customer.

Request a signed copy

This page is not execution. Open a ticket if you need counsel to issue a signed addendum for your organization.

Request a signed DPA

Contact

contact@pulsar.cards. For India DPDP queries use the same address until a grievance officer is appointed in a signed notice — this page does not invent one.