Privacy Policy

1. Who We Are

Pulsera Ltd is the controller responsible for the personal information described in this Privacy Policy.

Company: Pulsera Ltd
Registered office: 315b Norwood Road, London, England, SE24 9AQ
Company number: 17185033
Contact email: support@pulsera.uk

For questions or requests concerning your personal information, contact us using the details above.

2. Who Can Use Pulsera

Pulsera is intended only for people aged 18 or over.

We may ask for your date of birth or use other reasonable age-assurance measures to confirm that you are eligible to use the service. We do not knowingly permit people under 18 to create an account or participate in matchmaking.

Where we reasonably believe that an account belongs to someone under 18, we may suspend or delete the account and take steps to remove the associated information.

3. Information We Collect

The information we collect depends on how you interact with Pulsera and which features you choose to use.

3.1 Account and contact information

This may include:

• Your full name and the name displayed to other users
• Email address
• Telephone number
• Date of birth and age
• Current city, country or general location
• Account status and communication preferences
• Login, verification and account-security information; and
• Social media handles or professional profile links that you choose to provide.

Although we may collect your full name for administration, safety or verification purposes, we may display only your first name or another limited identifier to potential matches.

3.2 Profile and matchmaking information

This may include:

• Gender and the genders you are interested in meeting
• Dating intentions and relationship goals
• Your description of yourself, occupation, education, upbringing, hobbies, interests, personality and lifestyle
• Height and other physical characteristics you choose to provide
• Location and willingness to travel or relocate
• Smoking, vaping, alcohol, exercise, travel and social habits
• Views concerning relationships and family, including whether you have children and whether you would like children
• Information you choose to provide about your education and financial stability
• Your religion, ethnicity, cultural background or countries of origin, where you choose to provide this information
• Dating preferences, desired qualities and deal-breakers
• Availability for dates or video calls
• Answers to personality, compatibility, attachment, communication or relationship-style questions; and
• Feedback about matches, dates or your experience using Pulsera.

Information you include in open-text answers may reveal more about you than the question specifically requests. You should avoid providing information that you do not want Pulsera to process.

Religion and ethnicity questions, where offered, are optional. You may choose not to answer them without preventing you from completing your profile.

We may offer optional preference-calibration exercises using example profiles, images or descriptions. We record your selections and may use them to infer private preference patterns and improve matching. Your selections are not made public.

Examples will normally use fictional, synthetic or appropriately licensed content. If an exercise uses real member content outside an ordinary match suggestion, or intentionally involves special category information, we will ensure that we have an appropriate lawful basis and obtain explicit consent where required.

3.3 Photos, video and visual information

We may collect:

• Profile photographs and other images you upload
• Images used for account verification or safety checks
• Profile videos or video introductions you choose to provide; and
• Technical or descriptive information derived from your photos or videos where we introduce visual analysis features.

Verification images or videos may include a live selfie or an image showing an action, pose or instruction requested by Pulsera. We may use this information to check that a profile appears genuine, current and operated by a real person. A verification check may be reviewed by an authorised member of the Pulsera team or, where clearly explained to you, by a verification provider.

Where enabled, Pulsera may use computer-vision or multimodal AI systems to analyse photos or videos. This may include image quality, objects, activities, setting, presentation, style and other visible, non-sensitive appearance information. We may use the resulting descriptions or compatibility features to improve recommendations, moderation, safety or profile quality.

We will not treat a vision model's output as an objective measure of attractiveness, character or compatibility. We will not intentionally use photos or videos to infer health or disability, racial or ethnic origin, religion, sexual orientation, political opinions or another special category characteristic unless we first explain the specific feature, establish an appropriate lawful basis and special category condition, and obtain explicit consent where required.

We do not use visual or audio analysis to claim that we can determine a person's honesty, emotions, personality or safety solely from their face, body, voice or behaviour.

Manual review of an ordinary photograph or video does not necessarily involve biometric recognition. If we introduce automated facial matching, liveness analysis or another system that creates or uses biometric information to uniquely identify or authenticate you, we will explain the proposed use before collection, update our data-protection assessment and identify an appropriate lawful basis and special category condition. Where consent is required, we will ask for it separately. Where reasonably possible, we will provide a suitable alternative verification route.

3.4 Messages and interactions

We collect messages and instructions you send to Pulsera through SMS, iMessage, WhatsApp, email, our website or other supported channels.

This may include:

• Conversations with our AI assistant
• Responses to onboarding questions
• Match acceptances and rejections
• Availability and scheduling messages
• Date feedback
• Customer-support messages
• Safety reports; and
• Other information you voluntarily communicate to us.

Depending on the feature and context, messages may be reviewed or processed by automated systems and authorised members of the Pulsera team.

3.5 Optional voice and audio features

Pulsera does not collect voice or audio information unless you send it to us or choose to use a voice feature that we make available. Before introducing a materially different voice feature, we will provide additional information where appropriate.

Where a voice feature is available and you choose to use it, we may collect:

• Voice notes or audio recordings
• Transcriptions of those recordings
• Information extracted from the words spoken; and
• Limited technical information about the recording.

We may use automated speech-to-text and language-analysis services to transcribe and understand your recording.

We will not use your voice to uniquely identify you, infer highly sensitive characteristics from the sound of your voice, or create a reusable voiceprint unless we first provide a specific explanation and obtain any consent required by law.

3.6 Special category and sensitive information

Some information Pulsera asks you to provide, or that you choose to include in your answers, may be treated as special category information under UK data-protection law. For example, information about the genders you are interested in may reveal information about your sexual orientation. Religion and ethnicity information, where requested, is optional.

Special category information may include information revealing or concerning:

• Racial or ethnic origin
• Religious or philosophical beliefs
• Political opinions
• Health or disability information
• Sexual orientation
• Sex life or intimacy preferences; or
• Biometric information used for identification.

We will only ask for or intentionally use this type of information where it is relevant to a clearly explained feature and we have both an appropriate lawful basis and a valid special category condition for doing so.

Where we rely on your explicit consent, the relevant question or feature will be optional unless the information is genuinely necessary to provide a service you specifically request. You can withdraw your consent, although this will not affect processing already carried out lawfully before withdrawal.

Please do not provide highly sensitive information about another person without their permission.

3.7 Optional calendar, contacts and connected services

Pulsera does not access a calendar, email account, device contacts or another connected account unless you choose to connect or authorise the relevant service. If we introduce an integration, we will explain the information requested and its purpose before you connect it.

Where an integration is available and you choose to connect it, we may collect information from services such as:

• Google Calendar or another calendar provider
• Your device contacts
• Social media or professional networking services
• Payment providers; and
• Other services you authorise Pulsera to access.

For calendar integrations, we may access availability, time zones, event times or limited event information to identify suitable meeting times. We will aim to collect only the information needed for the relevant scheduling feature.

For an optional email integration, we may request limited access to information such as selected messages, sender or recipient details, subject lines, timestamps or other content needed for the feature you choose. Before connection, we will explain the requested permissions, the categories of email information used and whether the feature reads, stores or analyses message content.

For other connected services, we will explain what information we intend to access and how we will use it before you authorise the connection.

We will not access connected services without your authorisation. You can normally disconnect an integration through the relevant settings or by contacting us.

3.8 Dates, bookings and video calls

When Pulsera organises a date or call, we may collect:

• Your availability and selected time slots
• Time zone and approximate location
• Booking status
• Whether participants joined or completed a call
• Venue preferences
• Reservation information
• Video-call technical information
• Date attendance, cancellation and no-show information; and
• Feedback or ratings provided after the date.

Unless we clearly tell you otherwise, Pulsera does not routinely record the audio or video content of dates or video calls.

Video-call or venue providers may separately process personal information under their own privacy terms.

3.9 Payment and transaction information

Where paid services are introduced and you choose to purchase one, we may collect:

• Subscription or purchase information
• Payment status
• Billing address
• Refund, chargeback and fraud-prevention information; and
• Limited payment-card information supplied by our payment provider.

Full card details will generally be processed directly by a payment provider rather than stored by Pulsera.

3.10 Technical, device and usage information

We may automatically collect:

• IP address
• Device type, operating system and browser
• Device identifiers
• Language and time-zone settings
• Referral source
• Pages, screens and features viewed
• Buttons clicked and actions completed
• Message delivery and engagement information
• Login, crash, diagnostic and performance information
• Approximate location derived from your IP address; and
• Cookie and similar-technology identifiers.

Where session-replay or product-analytics tools are used, we will configure them to exclude sensitive form fields, passwords, payment-card details and private message contents. We will provide any cookie or similar-technology choices required by law before activating non-essential tools.

3.11 Information from other people and sources

We may receive information about you:

• From another user who reports a safety concern
• From service providers assisting with verification, fraud prevention or moderation
• From connected services you authorise
• From publicly available sources where appropriate and lawful; or
• Through referrals, invitations or venue partners.

If another user provides information about you, we will use it only where reasonably necessary for safety, support, matchmaking or the operation of the service.

4. How We Use Personal Information

We may use personal information to:

4.1 Provide the service

This includes:

• Creating and managing your account
• Conducting onboarding
• Understanding your preferences
• Recommending potential matches
• Sending and managing introductions
• Recording match responses
• Arranging dates or video calls
• Providing messaging and customer support
• Processing payments; and
• Delivering features you request.

4.2 Personalise and improve matching

We may use your profile information, preferences, questionnaire answers, behaviour and feedback to:

• Assess potential compatibility
• Rank or prioritise possible introductions
• Avoid recommendations that conflict with stated deal-breakers
• Learn which types of introductions are more likely to be welcomed
• Tailor the frequency and format of introductions; and
• Improve matching systems and recommendation models.

Compatibility predictions are estimates and cannot guarantee attraction, safety, relationship success or any particular outcome.

4.3 Operate AI and automated systems

We may use artificial intelligence, machine learning, rules-based systems, embeddings and other automated methods to:

• Interpret written answers and messages
• Structure information from free-text responses
• Identify compatibility themes
• Generate explanations for a suggested match
• Recommend and rank potential matches
• Transcribe voice notes
• Detect spam, abuse, fraud or safety risks
• Support customer service
• Improve the relevance and performance of the service; and
• Develop and test new features.

Our systems may create inferred information, such as likely interests, compatibility indicators or preference patterns, from the information and feedback available to us.

AI-generated outputs may be inaccurate or incomplete. Where appropriate, matches, reports and safety decisions may also be reviewed by an authorised member of our team.

4.4 Human review and assisted matchmaking

Authorised team members or matchmakers may review profile information, photos, preferences, messages, potential matches and feedback where reasonably necessary to:

• Help select or quality-check introductions
• Investigate technical or safety issues
• Provide support
• Improve AI outputs
• Handle reports or complaints; or
• Prevent misuse of the service.

Access is limited according to role and operational need.

4.5 Safety, integrity and legal compliance

We may use information to:

• Confirm age or identity
• Detect fake, duplicate or fraudulent accounts
• Investigate reports, harassment, abuse or other prohibited conduct
• Enforce our Terms of Service
• Protect users, Pulsera and third parties
• Establish, exercise or defend legal claims
• Comply with legal and regulatory obligations; and
• Respond to lawful requests from authorities.

4.6 Analytics, research and product development

We may analyse information to:

• Understand how people use Pulsera
• Measure onboarding, engagement, matching and date outcomes
• Diagnose technical issues
• Test different product experiences
• Improve our algorithms, prompts and service design
• Conduct statistical or market research; and
• Develop new products and features.

Where reasonably possible, we use aggregated, de-identified or anonymised information for analytics and research.

We do not treat information as anonymous where it can reasonably be linked back to an identifiable person.

4.7 Communications and marketing

We may contact you with:

• Account and security messages
• Match suggestions
• Scheduling and date reminders
• Service announcements
• Requests for feedback
• Customer-support responses; and
• Marketing about Pulsera features, events, partner offers, sponsored experiences or promotions where permitted by law.

You can opt out of non-essential marketing messages at any time. You may still receive operational communications needed to provide the service.

Match suggestions, security alerts, active-match communications, booking confirmations and date reminders are operational communications. Partner promotions, sponsored offers and general re-engagement campaigns are marketing communications. We will not treat marketing as an operational message merely because it is delivered through the same messaging channel.

We do not use information about your sexual orientation, religion, ethnicity, health, sex life or other special category information to target advertising or sponsored offers unless we first provide a specific explanation and obtain the separate explicit consent required by law.

5. Our Legal Bases for Processing

Under UK data-protection law, we rely on one or more of the following legal bases:

Performance of a contract
We process information where it is necessary to create your account, provide matchmaking, arrange dates, process transactions or otherwise deliver the service you request.

Legitimate interests
We may process information where it is necessary for our legitimate interests or those of another person, provided those interests are not overridden by your rights.

These interests may include:

• Operating and improving Pulsera
• Personalising recommendations
• Understanding service performance
• Securing the service
• Preventing fraud and misuse
• Providing customer support; and
• Establishing or defending legal rights.

Where required, we assess the necessity and privacy impact of this processing.

Consent
We rely on consent for certain optional features, marketing communications, non-essential cookies and similar technologies, and certain uses of sensitive information.

Where consent is our basis, you can withdraw it at any time.

Legal obligation
We process information where necessary to comply with applicable laws, regulatory requirements, court orders or lawful requests.

Vital interests
In rare and urgent circumstances, we may process or disclose information where necessary to protect someone’s life or physical safety.

Special category information
Where Pulsera intentionally uses information concerning your sexual orientation, racial or ethnic origin, religious or philosophical beliefs, health, sex life or biometric information for personalised matchmaking or an optional feature, we generally rely on your consent under Article 6(1)(a) and your explicit consent under Article 9(2)(a) of the UK GDPR.

We may rely on another condition only where the law specifically permits it, for example where processing is necessary to establish, exercise or defend legal claims or, in a rare and urgent situation, to protect someone's vital interests. We will document the condition that applies.

6. AI Profiling and Match Recommendations

Pulsera uses or may use profiling to understand users and recommend potential matches.

Profiling may involve analysing or comparing information such as:

• Age and location
• Dating intentions
• Preferences and deal-breakers
• Lifestyle and relationship goals
• Personality and compatibility answers
• Your interactions with previous recommendations
• Feedback from matches and dates; and
• Similarity or compatibility indicators produced by our systems.

This processing may affect which potential matches are shown to you, the order in which they are considered, and how frequently you receive introductions.

A lower ranking does not necessarily mean that two people are incompatible. It means that, based on the limited information available, our system identified other introductions as potentially more suitable or operationally feasible.

Unless we tell you otherwise, Pulsera’s ordinary matching recommendations are not intended to produce legal or similarly significant effects without meaningful human involvement.

Where we introduce a solely automated decision that may have a legal or similarly significant effect, we will provide additional information and any rights or safeguards required by law. These may include the ability to request human review, express your view and challenge the result.

You may contact us if you want more information about the main factors used in a recommendation or believe that an automated output is materially incorrect.

7. How We Share Personal Information

We do not sell your personal information.

We may share it as described below.

7.1 Potential matches and other users

To provide matchmaking, we may show selected information to another user, including:

• First name
• Age
• General location
• Photos
• Occupation
• Profile description
• Dating intentions
• Relevant interests or preferences; and
• A summary explaining why we believe the introduction may be suitable.

We do not necessarily share every answer you provide. Some information may be used internally for matching without being displayed directly.

Where both people accept an introduction, we may share additional information needed to arrange the date, such as contact details, availability or booking information.

7.2 Service providers

We may use providers that support:

• Cloud hosting and databases
• Messaging, email, SMS, WhatsApp or iMessage delivery
• AI, language-model and machine-learning services
• Speech transcription
• Image processing and content moderation
• Video calls
• Calendar and scheduling
• Payments and fraud prevention
• Product analytics and experimentation
• Customer support
• Identity or age verification
• Cybersecurity
• Legal, accounting and professional advice; and
• Venue bookings.

These providers may process personal information only for agreed purposes and subject to appropriate contractual and security requirements.

We do not permit an AI service provider to use identifiable Pulsera profile information, private messages or matchmaking answers to train a general-purpose model for its own purposes unless we first provide a specific explanation and identify an appropriate lawful basis and special category condition. We seek to use business or API configurations that limit provider retention and model training where these options are available.

7.3 Venues and booking partners

Where Pulsera arranges an in-person date, we may share limited information with a venue or booking provider, such as a first name, reservation time, party size, booking reference or contact detail.

We will not ordinarily share your complete dating profile or private matchmaking answers with a venue.

7.4 Advertising, sponsorship and promotional partners

Pulsera may work with venues, brands or other partners to provide sponsored experiences, benefits or offers.

Unless we clearly tell you otherwise and obtain any permission required by law, Pulsera does not provide these partners with your private profile answers, dating preferences or contact details for their own marketing. We may provide aggregated or de-identified campaign information, such as the number of offers viewed, clicked or redeemed.

Where you choose to claim an offer, make a booking or share information with a partner, we will explain what information is shared. If a partner will use your contact details for its own direct marketing, we will ask you to make a separate, informed choice where required by law.

7.5 Corporate transactions

If Pulsera is involved in a merger, investment, financing, acquisition, reorganisation, sale of assets or insolvency process, information may be disclosed to professional advisers, investors or prospective purchasers subject to appropriate confidentiality protections.

7.6 Legal, regulatory and safety disclosures

We may disclose information where reasonably necessary to:

• Comply with law, regulation, legal process or a lawful government request
• Protect the rights, property or safety of Pulsera, our users or another person
• Investigate fraud, abuse or safety incidents; or
• Establish, exercise or defend legal claims.

7.7 With your direction or consent

We may share information where you ask us to do so, connect another service, or otherwise provide valid consent.

7.8 Law enforcement and government requests

Pulsera may receive requests for personal information from police, courts, regulators, government bodies or other competent authorities. We do not provide unrestricted or routine access to user information.

Before disclosing personal information in response to a request, we will take reasonable steps appropriate to the circumstances to verify the identity and authority of the requester, understand the legal basis and purpose of the request, and assess whether the requested disclosure is necessary, proportionate and appropriately limited. Where appropriate, we may ask the authority to narrow, clarify or provide additional legal process for a request.

We aim to disclose only the information reasonably necessary for the stated lawful purpose and to transmit it using appropriate security measures. We may preserve relevant records where we receive a valid preservation request or where preservation is reasonably necessary in connection with an investigation, safety incident or legal obligation.

In an emergency involving a credible and imminent risk of death or serious physical harm, we may disclose information where we reasonably believe disclosure is lawful, necessary and proportionate to address that risk.

We maintain records of material law-enforcement and government requests and our response where reasonably practicable and legally permitted. We may seek legal advice before responding. We may notify the affected user where appropriate and lawful, but we may delay or withhold notice where prohibited by law or where notice could reasonably prejudice an investigation, create a safety risk or undermine the purpose of the request.

Nothing in this section requires Pulsera to disclose information where there is no valid legal basis to do so.

8. International Transfers

Pulsera is based in the United Kingdom, but some service providers or recipients may be located in other countries, including countries outside the United Kingdom.

Where personal information is transferred internationally, we use an appropriate legal mechanism where required. Depending on the destination, this may include:

• A UK adequacy regulation
• The UK International Data Transfer Agreement
• The UK Addendum to approved standard contractual clauses; or
• Another safeguard or exception permitted by applicable law.

You may contact us for more information about the safeguards relevant to your information.

9. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes described in this policy, including providing the service, meeting legal obligations, resolving disputes and enforcing agreements.

Retention periods depend on the type of information and why we hold it. In determining a period, we consider:

• Whether your account remains active
• Whether the information is needed for an ongoing match, booking or support matter
• The sensitivity and volume of the information
• Safety, fraud and abuse-prevention needs
• Applicable limitation periods; and
• Legal, regulatory, tax and accounting requirements.

When you delete your account, we will delete or anonymise information that is no longer required. Some information may remain for a limited period in backups or where retention is reasonably necessary for safety, fraud prevention, legal compliance or the establishment, exercise or defence of legal claims.

Our current retention approach includes the following general periods, subject to an active safety investigation, dispute, legal obligation or documented legal hold:

• Active account information is normally retained while your account remains active
• Where an account has been inactive for an extended period, we may contact you and delete or anonymise the profile, ordinarily after 12 months of inactivity
• When you delete your account, we aim to remove profile information and photos from active systems within 30 days
• Verification images and videos are normally deleted within 30 days after the verification check is completed, unless they are needed to investigate suspected fraud, abuse or a legal claim
• Raw AI prompts and outputs containing identifiable profile information are retained only for the shortest period reasonably necessary for service operation, quality assurance, security or investigation and, where reasonably practicable, for no longer than 30 days
• Operational message content is normally retained for up to 90 days after the relevant interaction, active match or date, unless a longer period is required for support, safety or legal reasons
• User-level analytics information is normally retained for no longer than 13 months, after which it is deleted or aggregated where reasonably possible
• Security and administrative audit records may be retained for up to 24 months; and
• Encrypted backups may retain deleted information for a limited rolling period, ordinarily no longer than 90 days. Deleted information held only in a backup is not returned to ordinary use and will be removed as backups expire.

We may retain limited consent records, legal claims records, fraud-prevention records and communication-suppression information for longer where necessary to demonstrate compliance, protect users, prevent repeated abuse or establish, exercise or defend legal claims. We restrict the use of information retained for these purposes.

Information that has been genuinely anonymised and can no longer identify you may be retained for research, analytics and service improvement.

10. Data Security

We use reasonable technical and organisational safeguards designed to protect personal information against accidental or unlawful destruction, loss, alteration, disclosure or access.

These measures may include:

• Access controls and role-based permissions
• Encryption in transit and, where appropriate, at rest
• Logging and monitoring
• Secure cloud infrastructure
• Vendor assessments
• Staff confidentiality obligations
• Incident-response procedures; and
• Data minimisation and retention controls.

No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

You are responsible for protecting access to your device, telephone number, email and any connected accounts used with Pulsera.

11. Cookies, Analytics and Similar Technologies

We may use cookies, pixels, software development kits, local storage and similar technologies to:

• Keep the service functioning
• Remember preferences
• Protect accounts and prevent fraud
• Understand service usage
• Measure Pulsera and partner marketing performance
• Diagnose errors
• Conduct experiments; and
• Improve user experience.

Some technologies are strictly necessary to operate the service. Where required by law, we will request consent before using non-essential analytics, advertising or tracking technologies.

You can manage available choices through our cookie banner or settings and through your browser or device controls.

Blocking certain technologies may affect how parts of the service work.

Further details may be provided in a separate Cookie Policy.

12. Your Data-Protection Rights

Depending on the circumstances, you may have the right to:

• Request access to your personal information
• Request correction of inaccurate or incomplete information
• Request deletion of your information
• Request restriction of processing
• Object to processing based on legitimate interests
• Object to direct marketing
• Receive certain information in a portable format
• Withdraw consent at any time where processing is based on consent
• Request safeguards in relation to certain automated decisions; and
• Complain to a data-protection regulator.

These rights are not absolute and may be subject to legal exceptions.

We may need to verify your identity before completing a request. We will not ask for more verification information than is reasonably necessary.

To exercise a right, contact us at support@pulsera.uk.

You also have the right to complain to the UK Information Commissioner’s Office. We would appreciate the opportunity to address your concern first, but you are not required to contact us before approaching the regulator.

13. Account Deletion, Pausing and Communication Choices

You may be able to pause matching, stop particular communications or delete your account through the service or by contacting us.

Pausing your account may prevent new introductions while allowing us to retain the account so that you can return later.

Deleting your account is different from pausing it. When an account is deleted, we begin the deletion or anonymisation process described in the Data Retention section.

You may opt out of marketing messages by using the unsubscribe mechanism provided or contacting us. For messaging services that support recognised commands, you may also be able to use commands such as “STOP”.

Operational messages concerning security, transactions, scheduled dates or active matches may continue where necessary.

14. Third-Party Services and Links

Pulsera may link to or integrate with third-party websites, messaging services, calendars, social networks, venues, payment providers and video-call platforms.

Those organisations may process information as independent controllers under their own privacy policies. Pulsera is not responsible for the privacy practices of independent third parties.

You should review their policies before providing information or enabling an integration.

15. Changes to This Privacy Policy

We may update this Privacy Policy as Pulsera and applicable laws develop.

Where a change is material, we will take reasonable steps to notify you, such as through the service, by email or by message. We may request fresh consent where a change introduces processing that legally requires it.

The date at the top shows when this Privacy Policy was last updated.

16. Contact Us

For privacy questions, requests or complaints, contact:

Pulsera Ltd
17185033
315b Norwood Road, London, England, SE24 9AQ
support@pulsera.uk