Privacy Policy

1. Data Controller

The data controller is Maroš Chmeľ, registered at Juh 1064/49, 093 01 Vranov nad Topľou, Slovak Republic. Contact: pulsarmind.support@gmail.com

2. What data we collect

During registration and use of the application, we collect:

• Name and email address (from Google or email registration via Clerk)
• Subscription and payment data (processed via Stripe)
• Content created in the app – training inputs and scenarios, training results, Spider chart progress, earned badges
• Account settings – preferences, training history
• Technical data – registration date, last activity time
• Anonymized behavioral data (e.g. which features you use) – collected via PostHog analytics

3. How we use your data

We use your data to:

• Provide and personalize the Pulsar service
• Manage subscriptions and billing
• Track communication skills training progress and display statistics (Spider chart, badges)
• Send important account notifications (no marketing without consent)
• Improve the application based on anonymized analytics data
• Ensure service security and prevent application abuse

4. Third Parties

We use the following third parties to operate the application:

• Clerk – authentication and account management – processes personal data under a Data Processing Addendum in compliance with GDPR; certified under the EU-U.S. Data Privacy Framework
• Stripe – payment processing (we do not store card numbers)
• Google Gemini AI – content generation – data is processed under Paid Services, ensuring it is not used to train AI models; processing complies with the Google Data Processing Addendum
• Neon Db – data storage (PostgreSQL, EU region) – processes personal data under a Data Processing Addendum; implements security measures including at-rest and in-transit encryption
• PostHog – anonymized behavioral analytics (e.g. which features users use) – PostHog Cloud, EU region; does not process personal identifiers
• Vercel – application hosting – processes technical data (IP addresses, request logs) necessary for service operation; complies with GDPR; data centers in EU region available

Each of these parties has its own privacy policy and processes data in accordance with GDPR.

5. Legal basis for processing

We process your data based on:

• Contract fulfillment – providing the service you signed up for
• Legitimate interest – service improvement, security and prevention of application abuse
• Legal obligation – tax and accounting records

6. Data retention

We retain your data for the duration of the account and 12 months after its cancellation. Accounting records related to payments are kept for 10 years in accordance with Slovak legislation. Users may request immediate deletion of all personal data at any time, except data we are required to retain by law (invoices and accounting records).

7. Your Rights (GDPR)

As a user, you have the right to:

• Access your personal data
• Correction of incorrect data
• Deletion of account and data ("right to be forgotten")
• Data portability
• Object to processing based on legitimate interest

To exercise these rights, contact us at pulsarmind.support@gmail.com. We will respond to requests within 30 days.

8. Cookies

The application uses technical cookies necessary for authentication (Clerk) and sessions. PostHog uses anonymized cookies for behavioral analytics – they do not contain personal data. We do not use marketing cookies. To manage cookies, use your browser settings.

9. Security

All communication is encrypted using HTTPS/TLS. We do not store passwords – authentication takes place exclusively via Clerk. Data in the database (Neon) is encrypted at-rest and in-transit. We regularly monitor the security of our systems.

10. Changes

We will inform you of substantial changes to this policy by email or notification in the application at least 14 days in advance.

11. Contact and Complaints

For questions regarding personal data protection, contact us: pulsarmind.support@gmail.com.

You also have the right to lodge a complaint with the Office for Personal Data Protection of the Slovak Republic: dataprotection.gov.sk