Privacy Policy

Last updated May 23, 2023

Pulsar Money Platform and its subsidiaries and affiliates (collectively, “Platform” or “we”) respect the privacy of Personal Data and are committed to protecting it. This Privacy Policy (the “Policy”) describes the policies and procedures Platform has implemented to protect Personal Data processed by Platform in accordance with applicable Data Protection Laws. This Policy also describes how Platform collects, uses, and discloses Personal Data from your interactions with us, including when you visit Platform websites and other online platforms, as well as your privacy rights. This Policy does not apply to the Personal Data of Platform's employees, contractors, or job applicants, which are subject to separate data protection policies.

Platform has voluntarily opted to apply the protections and obligations outlined in this Policy to all Data Subjects. However, such protections and obligations may be beyond the legal requirements of the jurisdiction of certain Data Subjects. Data Protection Laws vary widely across jurisdictions, and while Platform will strive to meet this Policy for all Data Subjects, the Data Protection Laws for the Data Subject ultimately govern the protections conferred in the specific jurisdiction applicable to that Data Subject.

Definitions

“Controller”means a natural or legal person, public authority, agency, or other body that, independently or jointly with others, determines the purpose and means of Processing Personal Data, as defined in Data Protection Laws. For purposes of applicable Data Protection Laws, the Controller of the Personal Data Processing described below is Pulsar Money, owner of Pulsar Money Platform, Inc. and its subsidiaries and affiliates. All references in this policy to “Astra Labs”, “Pulsar Money Platform”, “our”, “us” or “we” refer to Pulsar Money, or our group companies and suppliers which provide services to us, as appropriate.

“Data Protection Laws”means privacy laws and regulations that apply to Pulsar Money Platform's Processing of your Personal Data. This primarily includes the Regulation (EU) 2016/679 (GDPR), the Singapore Personal Data Protection Act 2012 (PDPA), the Chinese Cyber Security Law (the CS Law), the Chinese Personal Information Protection Law (PIPL), and applicable state and federal privacy laws in the United States.

“Data Subject” refers to you, as a natural person who can be identified, directly or indirectly, by reference to your Personal Data.

“Personal Data” means any information attributable to an identified or identifiable natural person (a Data Subject), as defined in Data Protection Laws. Personal Data does not include data where the identity has been removed (anonymous data).

“Process” or “Processing” or “Processed” or “Processes” means any operation or set of operations performed upon Personal Data, whether or not by automatic means, such as collecting, recording, using, organizing, structuring, storing, adapting or altering, retrieving, disclosing by transmission, disseminating or otherwise making available, aligning or combining, restricting, erasing, or purging.

“Processor” means a natural or legal person, public authority, agency, or other body that Processes Personal Data on behalf of a Controller. Processors may include third-party service providers, applications, or agencies utilized by Pulsar Money Platform in the course of business.

“Special Category Data”(also known as “Sensitive Personal Data”) means Personal Data revealing racial or ethnic origin, criminal history, political opinions, religious or philosophical beliefs, sexual orientation, trade union membership, precise geolocation, or health, genetic, or biometric data, or data pertaining to a child or minor.

Collection of Personal Data

a. Website Data

Pulsar Money Platform may collect your Personal Data on our websites. The technologies we use to track your movements around our websites may include cookies, tracking scripts and pixels, or tagging technologies. We, or third parties on our behalf, collect and use personal information which may include:

Your first and last name
Your email address
Your telephone number
Your inquiry and/or general information about your interest in our Services
Information you provide when you correspond with us
Your job title
Your bank/payment details
Details about how you use our Services
Your social media usernames/handles
Information about your marketing preferences

b. Tracking Tools

We use tracking tools, such as Google Analytics, which generate information about your use of our websites. Such information may include:

A navigation path that you follow on our websites
How long you spend on our websites and subpages
The subpage from which you leave our websites
The country, region, or city from where you access our websites
Returning or new visitor status
Host name of the accessing computer (IP address)

How We Use Your Personal Data

Pulsar Money Platform processes personal data to operate, improve, understand, and personalize our services. We collect and use personal data for the following purposes:

To fulfill the reason you provided the information to us.
To communicate with you about our services, including service announcements, updates, or offers.
To provide support and assistance for our services.
To create and manage your account or other user profiles.
To personalize website content and communications based on your preferences.
To deliver newsletters, emails, and facilitate events.
To respond to user inquiries and fulfill user requests.
To improve and develop our services, including testing, research, analysis, and product development.
To protect against or deter fraudulent, illegal, or harmful actions.
To comply with our legal or contractual obligations, resolve disputes, and enforce our Terms of Use.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

How We Share Your Personal Data

1. Service Providers

We disclose contact information, usage analytics, and demographic data to our service providers. These third-party service providers help us provide our services and operate our business.

2. Successors to Our Business

Your personal data may be transferred to a third party if we undergo a merger, acquisition, bankruptcy, or other transaction in which that third party assumes control of our business.

Security Measures

Pulsar Money Platform has implemented appropriate elements of privacy by design in conjunction with technical and physical safeguards designed to protect the security of Personal Data from unauthorized or unlawful Processing. However, nobody can guarantee that data transmitted through or stored on the Internet will be 100% secure all the time.

Retention of Personal Data

Pulsar Money Platform will only retain your Personal Data for as long as is reasonably necessary for the purpose for which it was collected, or as legally required. The criteria used include:

Regulatory requirements we are subject to;
Whether a legal claim might be brought against us;
The necessity of the information to provide our services;
The types and sensitivity of personal information being Processed.

International Data Transfers

Pulsar Money Platform may transfer your Personal Data to countries other than the country in which you initially provided the information. When we do so, we will protect that information as described in this Privacy Policy and in compliance with applicable legal requirements.

Your Rights and Choices

Depending on your jurisdiction, you may have certain rights regarding your Personal Data, including:

The right to access, correct, update or request deletion of your Personal Data;
The right to restrict processing under certain circumstances;
The right to request portability of your Personal Data;

To exercise any of these rights, please email [email protected].

Changes to This Privacy Policy

We reserve the right to update or modify this Privacy Policy at any time. If we make material changes, we will notify you by posting an updated version on our website or by other means.

Contact Information

If you have any questions or concerns, please contact our Data Protection Officer at [email protected] or at:

Pulsar Money SRL
Sibiu, Romania

By using our services and providing your Personal Data to us, you acknowledge that you have read and understood the terms of this Privacy Policy.