PRIVACY POLICY

PULSE Platform

Last updated: March 2, 2026

1. Introduction

This Privacy Policy describes how GoNetworking S.R.L., registered in the Republic of Moldova, processes personal data in connection with the PULSE Platform.

Company details:

GoNetworking S.R.L.
MD-2071, Strada Alba-Iulia 75/V, ap. 3
mun. Chișinău, Republic of Moldova
Email: byfriendsmd@gmail.com

By using the Platform, you agree to the practices described in this Policy.

2. Data Controller

For the purposes of applicable data protection laws, GoNetworking S.R.L. acts as the data controller.

3. Data We Collect

3.1 Data from Telegram Authentication

When users log in via Telegram, the Platform may receive:

Telegram User ID
Username
First and last name
Profile photo (if available)

The Platform does not access private messages, contact lists, or Telegram passwords.

3.2 Account Data

Internal user ID
Token balance
Subscription status
Event access records

3.3 Payment Data

Payments are processed by third-party providers (e.g., Paddle).

The Platform does not store:

full card numbers
CVV codes
bank details

We may receive limited transaction data such as:

transaction ID
payment status
country
billing email

3.4 Technical Data

IP address
device type
browser type
session logs

Collected for security and fraud prevention.

4. Purpose of Processing

We process data to:

provide Platform functionality
manage accounts and subscriptions
process payments
prevent fraud
improve Platform performance
comply with legal obligations

We do not sell personal data.

5. Legal Basis for Processing

Depending on the situation, processing is based on:

performance of a contract
legal obligations
legitimate interests (security, fraud prevention)
user consent (where required)

6. AI Functionality

The Platform may use AI-powered tools.

Users are responsible for the content they submit to AI features.

The Platform does not intentionally process sensitive personal data unless voluntarily submitted by the user.

7. Data Retention

Personal data is retained:

as long as the account remains active
as required for tax and legal obligations
for fraud prevention purposes

Users may request deletion of their account.

8. Data Sharing

We may share data with:

payment providers (e.g., Paddle)
hosting providers
analytics services
legal authorities if required by law

We do not share personal data for marketing resale purposes.

9. International Transfers

Data may be processed outside Moldova or the EU where service providers operate.

Appropriate safeguards are applied where required.

10. User Rights

Users may request:

access to their data
correction of inaccurate data
deletion of personal data
restriction of processing
data portability
withdrawal of consent (where applicable)

Requests can be sent to:

byfriendsmd@gmail.com

11. Security Measures

We implement technical and organizational measures to protect personal data, including:

secure server infrastructure
encrypted connections (HTTPS)
restricted internal access

However, no system is completely secure.

12. Children

The Platform is not intended for users under 18 years of age.

13. Changes to this Policy

We may update this Privacy Policy. Updated versions will be published on the Platform.