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Privacy Policy

Last Updated: October 2025

This Privacy Policy ("Policy") governs the collection, use, storage, and sharing of personal data by Pulse World ("Pulse", "We", "Us", "Our") in connection with your access to and use of our website, platform, and services, available at [https://app.pulseworld.com] (collectively, the "Platform"). This Policy applies to all users and visitors ("User", "you", "your") who use the Platform in their personal capacity.

By accessing and using Pulse World, you agree to the practices described in this Policy, including the collection, processing, and transfer of your personal information. Please read this Policy carefully alongside our Terms of Service. In the event of a conflict between the English version of this Policy and any translation, the English version shall prevail.


1. DEFINITIONS

  • "Personal Data" refers to any information that identifies or can be used to identify an individual, directly or indirectly.

  • Processing” means any operation which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

  • "Document(s)" refers to any medium containing recorded information, whether digital, physical, electronic, or audiovisual.


2. ACCEPTANCE

By using our Platform or Services, you confirm that you understand and agree to this Policy. If you do not agree, you should discontinue use immediately. You may withdraw your consent at any time by ceasing access to the Platform.


3. INFORMATION WE COLLECT

We may collect the following categories of Personal Data from you:

  • Identification Data: first name, maiden name, last name, username or similar identifier, marital status, date of birth and gender, nationality, identification numbers (driver’s licence number, passport number, or national ID card number), government-issued identity documents, images collected for identity verification, biometric data.

  • Contact Data: residential address, telephone numbers, email address.

  • Location Data: information about location of your device.

  • Marketing Data: your communication preferences, your preferences in receiving marketing from us and our partners.

  • Profile Data: username, feedback and survey responses.

  • Technical Data: internet protocol (IP) address, domain name, hardware, system activity, login data, browser type and version, time zone settings and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Platform.

  • Transaction Data: wallet address, blockchain transaction activity and other account activity.

  • Usage Data: information about how you use the Platform, products and services.

  • Voluntary Information: information which is collected from time to time (for example, through surveys) to enable us to improve our services or consider the wider needs of our users or potential users, or voluntary information that might be collected from you upon request and subject to your specific consent, for the purpose of provision of any of the services to you.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.

If you fail to provide Personal Data

Where we need to collect Personal Data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel a service or restrict the account you have with us but we will notify you if this is the case at the time.


4. HOW IS YOUR PERSONAL DATA COLLECTED

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity, Contact, Marketing,
Location, Usage, Correspondence Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes Personal Data you provide when you:

    • apply for our products or services;

    • create an account on the Platform;

    • provide information to verify your identity and meet our legal obligations;

    • subscribe to our service or publications;

    • request marketing to be sent to you;

    • enter a competition, promotion or survey; or

    • give us feedback or contact us.

  • Automated technologies or interactions. As you interact with our Platform, we will automatically collect Technical, Transactional and Usage Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy for further information.

  • Third parties or publicly available sources. We may receive Personal Data about you from various third parties and public sources as set out below:

    • Technical Data from analytics providers such as Google;

    • Contact, and Transaction Data from providers of technical and payment services;

    • Identity and Contact Data from compliance and verification service providers.


5. HOW WE USE YOUR INFORMATION

We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you to deliver our service. ‍

  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. ‍

  • Where we need to verify your identity, prevent fraud or unlawful activity, comply with a legal obligation.


6. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below a description of all the ways we plan to use your Personal Data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your Personal Data where more than one ground has been set out in the table below.

PURPOSE / ACTIVITY
TYPE OF DATA
LEGITIMATE INTEREST / LEGAL BASIS

To register you as a new customer

a. Identification b. Contact

a. Performance of a contract with you (Art 6(1)(b) in the GDPR)

To deliver our products and services, process orders, manage payments, fees and charges

a. Identification

b. Contact

c. Location

d. Marketing

e. Profile

f. Transaction

a. Performance of a contract with you (Art 6(1)(b) GDPR)

b. Necessary to comply with a legal obligation (Art 6(1)(c) GDPR)

To verify your identity: and/or to prevent and detect fraudulent and unlawful activities

a. Identification

b. Contact

c. Transaction

d. Technical

e. Usage

a. Performance of a contract with you (Art 6(1)(b) in the GDPR)

b. Necessary for our legitimate interests to safeguard services provided by Pulse ((Art 6(1)(f) GDPR)

c. Necessary to comply with a legal obligation (Art 6(1)(c) GDPR)

To manage our relationship with you which will include:

a. Notifying you about changes to our terms or Privacy Policy; and

b. Asking you to leave a review or take part in a survey

a. Identification

b. Contact

c. Profile

d. Marketing

a. Performance of a contract with you (Art 6(1)(b) in the GDPR)

b. Necessary for our legitimate interests to keep our records updated and to study how customers use our products/services ((Art 6(1)(f) GDPR)

c. Necessary to comply with a legal obligation (Art 6(1)(c) GDPR)

To administer and protect our Platform (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data, etc.)

a. Identification

b. Contact

c. Technical

d. Usage

a. Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud (Art 6(1)(f) GDPR)

b. Necessary to comply with a legal obligation (Art 6(1)(c) GDPR)

To deliver relevant website content and advertisement to you and measure or understand the effectiveness of the advertising served to you

a. Identification

b. Contact

c. Profile

d. Usage

e. Marketing

f. Technical

g. Voluntary information

a. Necessary for our legitimate interests to study how customers use our products / services, to develop them, to grow our business and to inform marketing strategy (Art 6(1)(f) GDPR)

To use data analytics to improve the Platform, products / services, marketing, customer relations and experiences

a. Identification

b. Contact

c. Technical

d. Usage

e. Profile

f. Marketing

g. Voluntary Information

a. Necessary for our legitimate interests to define types of customers for our products and services, to keep the Platform updated and relevant, to develop our business (Art 6(1)(c) GDPR)

Marketing

With your permission and/or where permitted by law, we may also use your Personal Data for marketing purposes, which may include contacting you by email with information, news, and offers on our products and services. You will not be sent any unlawful marketing or spam. We will always obtain your express opt-in consent before sharing your Personal Data with third parties for marketing purposes and you will be able to opt-out at any time. ‍

Opting Out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to Personal Data provided to us as a result of your use of the services. Opting out will not opt you out of receiving non-marketing information such as statements and account updates.

Change of Purpose

We will only use your Personal Data in accordance with the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.


7. DATA SHARING & TRANSFERS

We may share your Personal Data in the following scenarios:

  • Operational service providers: In order to deliver our services to you, we will need to share your Personal Data with third parties who provide us with tools and services including onboarding, professional advice, data storage, payment processing, accounting, invoicing, advertising and marketing, IT, security and fraud detection, customer support and communication channels.

  • Verification service providers: In order to prevent, detect fraud and comply with our legal obligations, we will need to share your Personal Data with third party identification verification service providers.

  • Law enforcement agencies and regulators: We may need to share your Personal Data with law enforcement agencies or government officials. We will only do this when we are required to do so by court order, formal request, specific regulation, or when we believe in good faith that sharing your Personal Data will prevent financial loss, physical harm, or we are obligated to report suspicious and illegal activities.

  • Third parties in business transactions: We may choose to sell, merge parts or transfer our business or our assets to third parties. We may acquire other businesses or merge with them. If such business change happens, the new owners may use your Personal Data in the same way as set out in this Privacy Policy.

  • Affiliates and partners: We may share your Personal Data with our affiliates and partners for legitimate business purposes, including operational efficiencies, service and product delivery, and to meet applicable legal and regulatory obligations.

By agreeing to this Privacy Policy, you consent to such sub-processors collecting and processing your Personal Data pursuant to the terms hereof.

We require all third parties to respect the security of your Personal Data and to treat it in accordance with applicable law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.


8. SECURITY MEASURES

Pulse implements physical, electronic, and administrative safeguards to protect Personal Data. These include firewalls, encryption, and strict access controls. However, no system is completely secure, and we cannot guarantee absolute protection against unauthorized access or breaches.


We use cookies and similar technologies in accordance with our Cookie Policy.

You may accept or reject non-essential cookies using our Cookie Consent Manager or browser settings. Disabling cookies may affect your experience.


10. DATA STORAGE AND INTERNATIONAL TRANSFER

Data collected may be stored and processed in jurisdictions outside of your own, where data protection laws may differ. By using the Platform, you consent to such international data transfers.

If you are located in the European Economic Area (“EEA”), the UK, or Switzerland, we rely on the Standard Contractual Clauses (“SCCs”) to provide an adequate level of data protection for the transfer of your Personal Data from the EEA, the UK, or Switzerland, where the country of import is not deemed adequate under applicable law.


11. DATA RETENTION

We will only retain your Personal Data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.


12. YOUR RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your Personal Data. If you wish to exercise any of the rights set out above, please contact us.

Request access to your Personal Data (commonly known as a "Data Subject Access Request"). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.

Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it, or when you have withdrawn your consent and there is no other legal ground for processing. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below). Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data, for example, if you want us to establish its accuracy or the reason for processing it.

Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

No Fee Usually Charged

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What We May Need From You

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time Limit to Respond

We try to respond to all legitimate requests within one month or in accordance with applicable law. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.


The Platform may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.


14. POLICY UPDATES AND YOUR DUTY TO INFORM US OF CHANGES

Pulse reserves the right to modify or update this Policy at any time. Material changes will be communicated by posting an updated Policy on the Platform. Continued use of the Platform after changes implies consent to the revised Policy.

It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us.


15. CONTACT

For inquiries, concerns, or requests related to this Policy, please contact us at: https://support.pulseworld.com/support/home

Company details:

Filtrolabs Software Ltd (reg. nr. 2186235) P.O. Box 3175, Road Town, Tortola, British Virgin Islands

If you are a European Union resident and you believe that we have not adequately resolved your data protection query, you have the right to contact your local data protection supervisory authority. We would, however, appreciate the chance to deal with your concerns so please contact us in the first instance.

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