Privacy Policy

1. Who we are

PVUG Technologies LTD ("Pulsedew," "we," "us," or "our") operates the Pulsedew platform at pulsedew.com and app.pulsedew.com.

For the purposes of the General Data Protection Regulation (GDPR), PVUG Technologies LTD is the data controller for merchant (business user) account data. For end-customer data collected through wallet passes, the merchant is typically the data controller and Pulsedew acts as a data processor on the merchant's instructions.

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2. Scope

This Privacy Policy applies to:

• Merchants — business owners and staff who create accounts and use the Pulsedew dashboard, scanner app, and related services.
• Website visitors — people who browse pulsedew.com.
• End-customers — people who add a loyalty or gift card pass to Apple Wallet or Google Wallet at a merchant's invitation. End-customers should also review the merchant's privacy notice and our Customer Terms.

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3. Data we collect — merchants and website visitors

Account and profile data

• Name, email address, business name, and business type
• Login credentials (passwords stored hashed)
• Billing address and payment method details (processed by our payment provider)

Usage data

• Dashboard activity, scan logs, broadcast history
• Device type, browser, IP address, and access timestamps
• Support correspondence

Website data

• Cookies and similar technologies (see Cookie Policy)
• Analytics data if you consent to analytics cookies

We do not knowingly collect sensitive personal data from merchants beyond what is necessary to provide the service.

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4. Merchant customer data — processor role

When you use Pulsedew to manage loyalty or gift card programs, you may upload or generate data about your customers, including:

• First name (and optionally other identifiers you choose to collect)
• Stamp/point progress, visit history, reward status
• Gift card balances and redemption history
• Wallet pass identifiers required to deliver notifications

You are responsible for ensuring you have a lawful basis to collect and process this data and for providing appropriate privacy notices to your customers. Pulsedew processes this data solely to provide the service you configure, in accordance with our agreement with you and our Terms of Service.

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5. Legal bases for processing (GDPR Article 6)

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6. Retention periods

Merchants may export their customer data at any time from the dashboard. Upon account termination, data is deleted or anonymised within [X] days unless retention is required by law.

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7. Sub-processors

We use trusted sub-processors to operate the service. Current categories include:

A current list of sub-processors is available on request at team@pvug.tech. We require sub-processors to provide appropriate data protection safeguards.

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8. International transfers

We aim to process and store data within the European Economic Area (EEA). If data is transferred outside the EEA, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses approved by the European Commission.

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9. Your rights — merchants

Under GDPR, you have the right to:

• Access — request a copy of your personal data
• Rectification — correct inaccurate data
• Erasure — request deletion where applicable
• Portability — receive your data in a structured, machine-readable format
• Objection — object to processing based on legitimate interests
• Restriction — request limited processing in certain circumstances
• Withdraw consent — where processing is based on consent

To exercise these rights, contact team@pvug.tech. We respond within one month.

You also have the right to lodge a complaint with your local supervisory authority. In Uganda, this is the Personal Data Protection Office (PDPO), National Information Technology Authority — Uganda (NITA-U). EU residents may also contact their local supervisory authority.

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10. End-customer rights

If you are a customer who added a wallet pass from a merchant using Pulsedew:

• Contact the merchant first for access, correction, or deletion of your data — they are the data controller.
• To stop notifications, remove the pass from Apple Wallet or Google Wallet.
• For platform-related questions, contact team@pvug.tech and we will assist or forward your request to the merchant as appropriate.

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11. Security measures

We implement appropriate technical and organisational measures, including:

• Encryption in transit (TLS) and at rest where applicable
• Access controls and authentication for staff systems
• Regular security reviews and monitoring
• Incident response procedures

No method of transmission over the internet is 100% secure. We cannot guarantee absolute security but work continuously to protect your data.

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12. Cookies

We use cookies and similar technologies on pulsedew.com. See our Cookie Policy for details and how to manage preferences.

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13. Children

Pulsedew is a business-to-business service. We do not knowingly collect personal data from children under 16. If you believe we have collected such data, contact team@pvug.tech.

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14. Changes to this policy

We may update this Privacy Policy from time to time. We will post the revised version on this page with an updated "Last updated" date. Material changes will be communicated to registered merchants by email where appropriate.

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15. Contact