Privacy Policy

Last Updated: May 1, 2025

Fwollo LLC ("Company," "we," "us," or "our") respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you access or use the Pulse Up mobile application, website, and related services (collectively, the "Service").

By using the Service, you consent to the practices described in this Privacy Policy.

1. Information We Collect

1.1 Personal Information

We may collect the following personal information when you create an account or interact with the Service:

  • Phone Number (required for pulsing and topic creation)
  • Email Address (optional)
  • Apple ID or Google ID (if used for sign-in)
  • Username (publicly displayed on topics you create)
  • Display Name (publicly displayed on topics you create)
  • Additional Profile Information (optional, subject to your visibility settings)

Your phone number and email address will always remain confidential and are never publicly displayed.

1.2 Usage Data

We collect usage data to improve the Service, including:

  • Topics you create, search for, or view
  • Pulsing activity (support expressions)
  • Interaction patterns within the Service, including clicks and feature usage
  • Engagement statistics (e.g., screen time)

1.3 Device and Location Information

We automatically collect certain information about your device, including:

  • Device type, operating system, and application version
  • IP address (used for security and fraud prevention)

Location Data:
Your approximate location (city, state, or country level) may be used for generating heatmaps and trending data. Pulse Up never shares your precise location or any identifiable activity history with other users. While aggregate engagement data may be used to improve the platform, individual pulse actions are never publicly linked to user identities.

2. How We Use Your Information

We use your information for the following purposes:

  • To provide, maintain, and enhance the Service
  • To verify identities and prevent spam or abuse
  • To enforce topic uniqueness and resolve disputes
  • To generate aggregated analytics such as heatmaps and trending topics
  • To personalize your experience and recommend relevant content
  • To notify you about activity on topics you support
  • To comply with legal obligations and maintain security

3. Data Sharing and Disclosure

We do not sell personal information. However, we may share your information as follows:

3.1 Third-Party Service Providers

We may share data with trusted third-party service providers who assist in operating the Service, such as hosting providers, analytics companies, or security firms. These providers are bound by strict confidentiality obligations.

3.2 Legal Compliance and Security

We may disclose your information if required by law, legal processes, government requests, or to protect our rights, security, and property or that of others.

3.3 Business Transfers

In the event of a merger, acquisition, or sale of Pulse Up or its assets, your data may be transferred. Users will be informed of any significant changes in data ownership or practices.

4. Pulsing, Topic Visibility, and Anonymity

4.1 Pulsing Privacy

Pulses (support actions) are not publicly linked to your identity. Other users cannot identify how you pulsed.

We internally track pulses to:

  • Provide accurate counts
  • Prevent duplicate pulsing
  • Manage platform functionality

Individual pulsing activity is not displayed publicly or disclosed outside our internal administrative processes.

4.2 Topic Creation Visibility

  • Your username and display name are publicly displayed as the creator of topics.
  • Topics remain publicly visible even if you delete your account, but are labeled as "Created by a Former User."
  • Your phone number and email address remain private and are never displayed publicly.

5. Disputes, Topic Transfers, and Username Claims

We may transfer topic ownership or usernames in response to verified claims of trademark infringement, official organizational representation, or impersonation. Users involved in disputes may have their data reviewed internally for claim verification purposes, but no personal information will be publicly disclosed.

6. Data Security

We implement appropriate security measures to protect your data from unauthorized access, alteration, disclosure, or destruction. However, no security system is entirely foolproof, and absolute security cannot be guaranteed.

7. Your Privacy Rights

7.1 Access and Correction

You may access, review, and update your account information at any time within the Service.

7.2 Data Deletion

You can request deletion of your account and personal information by contacting us at contact@pulseup.com .
Topics you created will remain visible but labeled as "Created by a Former User."
Your pulses remain stored for aggregate analytics and cannot be individually deleted.

7.3 Opt-Out

  • You can opt out of receiving push notifications through your device settings.
  • Marketing emails can be unsubscribed via the instructions provided in each email.

8. Data Retention

We retain your personal information as long as necessary to fulfill the purposes outlined in this policy or as required by law. Pulsing data may be retained indefinitely for analytical purposes.

9. International Data Transfers

The Service operates in the United States. If you access the Service from outside the U.S., you consent to your data being transferred to, processed, and stored in the United States, which may have different data protection laws than your jurisdiction.

10. Children's Privacy

The Service is not intended for individuals under 13. We do not knowingly collect data from children under 13. If we discover a child under 13 has provided personal information, we will delete it in compliance with applicable law.

11. Clarification on Legal and Regulatory Neutrality

Pulse Up is not a voting or polling platform in any legal, governmental, or electoral sense.

  • It does not conduct elections, referenda, or scientific surveys.
  • All expressions of support ("pulses") are intended for public awareness, sentiment exploration, and advocacy.
  • No part of the Service constitutes or substitutes for official voting or polling mechanisms.
  • Insights and trends provided on the platform are not representative of official public opinion metrics.

12. Changes to the Privacy Policy

We may update this Privacy Policy periodically. We will notify you of significant changes through the Service or via email. Continued use of the Service after policy updates indicates acceptance of the new terms.

13. Contact Us

For questions or concerns regarding this Privacy Policy, contact us at:
📩 Pulse Up:  contact@pulseup.com

14. Additional Disclosures for California Residents (CCPA)

If you're a California resident, you have the following rights under the California Consumer Privacy Act (CCPA) and CPRA:

14.1 Your Rights:

  • Right to know what personal information we collect
  • Right to access that data
  • Right to request deletion
  • Right to correct inaccurate data
  • Right to opt-out of sale/sharing (we don’t sell your data)
  • Right to non-discrimination for exercising these rights

To submit a request, email us at contact@pulseup.com with the subject: “California Privacy Request”

14.2 Categories of Data Collected:

  • Identifiers (e.g., phone, IP)
  • Internet or usage data
  • Geolocation (approximate only)
  • Inferences drawn from usage

We do not sell personal information.

15. Additional Disclosures for European Users (GDPR)

If you're located in the European Economic Area (EEA) or United Kingdom, you are protected under the General Data Protection Regulation (GDPR).

15.1 Legal Basis for Processing:

  • Your consent
  • Legitimate interests (e.g., preventing spam)
  • Performance of a contract
  • Compliance with legal obligations

15.2 Your GDPR Rights:

  • Access your personal data
  • Correct or erase it
  • Restrict or object to processing
  • Request data portability
  • Withdraw consent at any time

To make a request, email contact@pulseup.com with the subject: “GDPR Data Request”

15.3 Data Transfers

Your data may be stored in the U.S. We apply appropriate safeguards to protect your information in line with GDPR standards.

15.4 Data Protection Contact

You can contact our Data Protection Officer at contact@pulseup.com or file a complaint with your local data protection authority.