Privacy Policy

Pulse ("we," "us," or "our") is the data controller responsible for your personal data and is the sole owner of the Pulse.com website ("Website"), Pulse mobile and desktop applications, Pulse services (each, a "Service") and all of the information collected on it. Pulse collects information from users in several ways (explained in detail in this privacy policy).

This privacy policy applies to personal data that we collect from you when you visit this Website, create an account, use our applications or services ("you" or "your" being interpreted accordingly). It provides information on what personal data we collect, why we collect personal data, how it is used, the lawful basis on which your personal data is processed, how it is stored, and how we share information.

This Privacy Policy describes how we might use your information if you:

  • Download and use our mobile application;

  • Engage with us in other related ways ― including any sales, marketing, or events.

Engage with us in other related ways ― including any sales, marketing, or events We respect your privacy and work hard to protect the confidentiality of information that you give us. We will only share your personal data with third parties in the event that it’s needed for the provision of services and data you have requested (explained in detail in this privacy policy).

  1. Personal data that we collect

User Accounts

If you decide to create an account, you will need to provide us with some personal data so we can provide you with access to our additional services that users benefit from. You may also elect to provide us with additional information about you, as described below.

During registration you will be required to provide us with either:

  • your username, wallet address, email address, username and password;

  • your account information with one of the following social Internet services:

Google, Twitter(X), Telegram, Apple;

  • your wallet information with one of the following digital wallet services:

MetaMask, WalletConnect, and

  • You may elect to log in to our services using Phemex account credentials.

In the event of registration with the third-party account, you authorize us to access and retrieve information that you have agreed to make available to us from the third-party platforms, such as your public profile, and wallet address, to facilitate your login and to enhance the services.

Contact data

We also process any personal data you choose to give when corresponding with us by phone, email, or otherwise visiting and interacting with this Website or any other services we operate.

By providing your phone number, email address, you agree to receive text messages from us. Message and data rates may apply. Message frequency varies. We will not share your phone number or email address with any other parties unless explicitly specified by this policy.

Partners data

We also process personal data you choose to give at registration and connection to the Partner Program.

Cookies and other technologies

We use browser cookies (small text files placed on your device) to administer our Site, gather and analyze statistical information, ensure security, to fight spam, and for advertising purposes. Cookies allow us to provide you with a better user experience when you browse our Website and also helps to improve its features.

Log files

Like most websites, we use web server log files. Records in our log files include internet protocol (IP) addresses, browser types, internet service providers, referring pages, exit pages, platform types, and date/time stamps. We use web server log files to administer the site, provide broad traffic information for site planning purposes, and to ensure that our terms of service agreement is being adhered to. Note that IP addresses are not tied to personal data in our web server log files.

Device information

We collect the following information about the devices you use to interact with our services: IP address of the device (from which we can also infer the country you are connecting from), device type, operating system, application and browser version. We collect this information to prevent spam and abuse of our services. IP addresses may be considered personal data in certain jurisdictions, and will be treated in accordance with this Privacy Policy.

Analytics

When you are using our Website, mobile and desktop applications, we may collect analytics information automatically. This information may include your general device information, device identifiers, network information, website, and application interaction events. We collect pseudonymous data only and this analytic information does not include any personal identifiable information from your profile. We use this information to analyze and improve the work of our services and applications, and to develop, test, and improve our service further. For this purpose we may use internal analytic as well as third party service providers. For further details about our use of third party service providers, please refer to the Analytics providers section below.

2. Data we receive from third parties

When you sign in to your account using your internet service credentials, such service sends us your username and the email address associated with the credentials you've used. We neither control nor take any responsibility for the way third parties provide information about you and/or process your personal data.

3. How Personal Information is Used

We use personal data in various ways that are necessary to provide the services you intend to use, certain legitimate interests, and as a necessity in order to comply with applicable law, as further described below.

We do not generally rely on your consent to allow us to process your personal data if there is another lawful ground available. If we do rely on your consent, we will make this clear to you at that time.

Profile

A profile is a set of information for each individual user that details his/her viewing preferences. User settings (chart settings, toolbars, buttons, etc.) are kept solely for the purpose of customizing the user’s experience when using the Website, applications or user accounts. We do not share private profile settings with any third parties.

Note that when you create an account, other users or visitors may access your public profile and see any information you have made publicly available about yourself.

User account and profile operations

We use your contact details, such as username, email address, or wallet address, in the following ways:

  • to authenticate your user account, ensure its security along with the security of our services, and to prevent spam, fraud, and abuse;

  • to acknowledge, confirm, and deal with your user account; and,

  • to send all new users a welcome activation email to verify their email address.

User account deleting

You may refuse to use our Website and/or application and may ask us to delete your account. Your account will be deleted after 30 days. During this time, you can stop the deletion process at any time.

Please note that if you have requested your account to be deleted, we will delete the subsequent personal data you have supplied us. Some data, such as published ideas/scripts/post and messages sent to other users, will be saved as they have already integrated into our system. This data must be stored to maintain the integrity of the platform.

For legitimate business processes and for compliance with legal obligations, including tax laws, audits, and security, we must retain certain data for an extended period. This data includes, but is not limited to, transaction logs, financial records, addresses, and employment details. The duration of retention for each type of data will comply with specific legal requirements, extending up to 10 years.

Note that search engines, as well as third parties, can keep copies of your publicly available information once your account has been deleted. It should also be noted that published ideas will remain on the site and messages sent to other users cannot be deleted.

Marketing

We may send you marketing emails about our products or services that are similar to the products or services you are subscribed to, including information about events and other promotions we feel may interest you. This is unless you have indicated to us that you do not wish to receive communications in this manner. We will send you other promotional information by email only with your consent, which was given at the time you provided us with your personal data. Users can opt out of receiving marketing communications at any time by clicking "unsubscribe" in one of the emails.

Social Notifications

We can notify you via email about new users who have followed you, liked an idea, new ideas of users that you follow, and so on. You can refuse to receive such notifications at any time by adjusting your accout setting.

Service-Related Announcements

On rare occasions, it may be necessary to send out service-related announcements. For instance, if our service is interrupted for a prolonged period or a major functionality upgrade is released, we might send all users an email message.

Customer Service

When you open a support ticket, we use your contact details as well as information about your device, server logs, a description of the problem, along with any other supporting materials (videos, screenshots, etc.) to help resolve the issue(s).

API

If you are using our API (Application Programming Interface) services, then we may process your personal data in order to be able to provide and support those services.

  1. Legitimate Interests

We will process your personal data as necessary for certain legitimate business interests, which include the following:

  • where we are asked to respond to any of your inquiries, comments, or grievances;

  • to administer our services in order to better understand how visitors interact with the Website and application, and ensure that they are presented in the most effective manner for you and your computer/device;

  • to develop and improve our mobile applications;

  • to share personal data among our affiliated businesses for administrative purposes, provide subscription services, and in relation to our sales and marketing activities, except where we require your consent, as described above;

  • to send you information about our products or services that are similar to the products or services you subscribed to (unless you have refused or opted out of receiving these emails at the time you provided us with your email address or you have indicated to us that you do not wish to receive communications in this manner). Our legitimate interest is to ensure our marketing is relevant to you, so we may process your data to send you information on our products or services that is specifically tailored to your interests;

  • we may anonymize, pseudonymize, aggregate and de-identify the data that we collect and use this data for our own internal business purposes, including sharing it with our business partners, our affiliated businesses, agents and other third parties for commercial, statistical and market research purposes. For example, to allow those parties to analyse patterns among groups of people and conducting research on demographics, interests, and behavior;

  • for internal business/technical operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes, and as part of our efforts to keep our Website, network, and information systems secure; and

  • to (a) comply with legal obligations, (b) respond to requests from competent authorities; (c) enforce our Terms of Use or House Rules; (d) protect our operations or those of any of our affiliated businesses; (e) protect our rights, safety or property, and/or that of our affiliated businesses, you or others; and (f) enforce or defend legal rights, or prevent damage. This means we can store and disclose your information to law enforcement authorities, state, or government agencies if we establish that such disclosure is necessary to comply with the law. This includes responses to court orders or subpoenas, as well as other judicial or regulatory processes.

As used in this privacy policy, “legitimate interests” means the interests of Pulse and our affiliated businesses in conducting and managing our business. When we process your personal data for our legitimate interests, we make sure to consider and balance any potential impact on you and your rights under data protection laws. Our legitimate interests do not automatically override your interests. We do not use personal data for activities where our interests override the impact they may have on our users, unless we have their explicit consent or those activities are otherwise required or permitted by law. You have the right to object to the processing of your personal data that is based on our legitimate interests at any time, on grounds relating to your particular situation.

  1. When would we share personal information

We share your personal data with third parties in the following situations:

  • Service providers: Pulse, like many businesses, occasionally engages with selected third parties who act on our behalf to support our operations, such as (i) card processing or payment services, (ii) IT suppliers and contractors (i.e. data hosting providers or delivery partners) as necessary to provide IT support and enable us to provide subscription services and other goods/services available on this Website or to users, (iii) web and mobile analytics providers, (iv) providers of digital advertising services, and (v) providers of marketing and sales software solutions. Pursuant to our instructions, these parties may access, process or store your personal data in the course of performing their duties to us and solely in order to perform the services we have hired them to provide.

  • Payment information: The payment information (name, postal address, payment card information or payment account information) is used for billing purposes only and is processed by our payment processors. When you are making a payment, we do not have access to your payment card information. Should we have any issues with processing an order, the email address you have provided will be used to contact you.

  • Pulse affiliated businesses: In order to provide the services you request from us, our affiliated businesses may access and process the information which we collect from you for the purposes described above, including offering products and services to you. Our affiliated businesses will only use your data for the purposes for which we originally collected said data.

  • Business transfers: If we sell our business or our company assets are acquired by a third party, personal data held by us about our general account users, subscription account users or customers may be one of the transferred assets.

  • Administrative and legal reasons: If we need to disclose your personal data (i) to comply with a legal obligation and/or judicial or regulatory proceedings, a court order or other legal process, (ii) to enforce our Terms of Use, House Rules or other applicable contract terms that you are subject to, or (iii) to protect us or our contractors against loss or damage. This may include, but is not limited to, exchanging information with the police, courts or law enforcement organisations.

  • Note that we do not share any personal information with our advertisers. They can only access general statistics that include the amount of impressions their ads have generated as well as clicks.

  1. Third Party Sites

Links to other sites

At our discretion we may add links (web links) to other websites from our Website. These websites can be run by third parties with separate and independent privacy policies. We, therefore, have no responsibility nor are we liable for any content, activities or privacy policies of these linked sites. We suggest you read the privacy policy of each and every site that you visit.

  1. Your Rights

Right to access

You have the right to access and be informed about your personal data processed by us. You may request a copy of your personal data. In addition, we give registered Users the possibility to view certain data through their user account with the Services.

Right to withdraw consent

In case the processing is based on a consent granted by you, you may withdraw the consent at any time. Withdrawing a consent may lead to fewer possibilities to use the Services. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

Right to rectify

You have the right to have incorrect or incomplete personal data we have stored about you corrected or completed by contacting us. Registered Users can correct or update some of their personal data through their user account with the Services.

Right to object

You may have the right to object to certain use of your personal data if such data are processed for other purposes than necessary for the purposes of this Privacy Policy or for compliance with a legal obligation. If you object to the further processing of your personal data, this may lead to fewer possibilities to use the Services.

Right to restriction of processing

You may request us to restrict processing of personal data for example when your data erasure, rectification or objection requests are pending and/or when we do not have legitimate grounds to process your data. This may however lead to fewer possibilities to use the Services.

Right to data portability

You have the right to receive the personal data you have provided to us yourself in a structured and commonly used format and to independently transmit those data to a third party.

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