This policy describes how MyPuls, Inc., a Delaware corporation (United States) with its registered office at 2810 North Church Street, Wilmington, Delaware 19802, United States ("MyPuls", "we", "us"), collects, uses, shares and protects personal data in connection with the website mypuls.app and its subdomains, the MyPuls software (the "Service"), our commercial communications and our relationships with customers, prospects and partners.
It supplements the terms of service and the data processing agreement annexed to them. In the event of any discrepancy between the French version and a translation, the French version prevails.
For any question or request about your data, write to contact@mypuls.app or by post to the address above.
1. The two roles of MyPuls
MyPuls acts as a data controller when it processes the data needed to run its website, customer accounts, billing, support, security and commercial prospecting. This policy covers that processing.
MyPuls acts as a data processor when it processes, on behalf of its customers and on their instructions, the data of the creators, fans and users that its customers manage through the Service. That processing is governed by the data processing agreement annexed to the terms of service. If you are a creator or a fan whose data is processed in the Service by an agency, that agency is the controller and your rights are exercised with it in the first instance; we assist it in responding.
2. Data we collect
Account data. When you create an account or are added as a user by a customer, we collect your name, email address, phone number where applicable, the name of your company or agency, your role, your language and your login credentials, with the password stored in encrypted form.
Billing data. Payments are processed by our provider Stripe. We receive from Stripe the cardholder's identity, the last four digits and expiry date of the card, the payment history and the billing address. We never store your full card number.
Usage and technical data. When you use the website or the Service, we record your IP address, device and browser type, pages viewed, actions performed in the Service, login dates and times, technical logs and session identifiers. This data is used to operate and secure the Service and to understand how it is used.
Support and correspondence data. When you write to us by email, chat, Telegram or any other channel, we keep the content of those exchanges and the information you provide.
Prospecting data. If you run an agency or work as a content creator, we may hold your professional contact details (name, email address, phone number, Telegram handle, agency name, country, platforms used), obtained directly from you, at events, from partners, from publicly available sources or from professional contact databases. We use them to introduce the Service to you. You may object at any time, and every commercial message contains a link or an address to do so.
Platform data. When a customer connects a MYM, OnlyFans, Fansly or other platform account to the Service, the data of that account is processed in the Service on behalf of that customer, with MyPuls acting as a processor under the data processing agreement.
We do not knowingly collect data from anyone under eighteen. The Service is reserved for adult professionals.
3. Why we use this data
To provide the Service and perform the contract: create and manage your account, give you access to features, bill you, provide support and inform you of changes to the Service.
To keep the Service secure and working: prevent unauthorised access, fraud and abuse, monitor performance, diagnose incidents and keep technical logs.
To improve the Service: analyse how features are used, on an aggregated basis wherever possible, in order to develop them.
To communicate with you: answer your requests, send you information about your account and about new features, and, where you are a customer or a professional prospect, present offers related to your activity.
To comply with our legal obligations: accounting, tax, responses to requests from authorities, handling of disputes.
For individuals located in the European Union or the United Kingdom, this processing relies on the performance of the contract, on our legitimate interest in operating, securing, improving and promoting the Service to professionals, on your consent where required, in particular for certain cookies, and on our legal obligations.
4. Automated assistance features
Certain features of the Service, including the digital employee Aurel, use language models supplied by third party providers to suggest, write or send messages, analyse conversations and produce statistics. The data needed for these features is transmitted to those providers only to the extent required, under contract, and they are not permitted to use it to train their models. These features are activated and configured by the customer, who keeps control of and responsibility for them.
If you are a fan of a creator whose account is managed through the Service, some of the messages you receive may be written or sent by these features. The agency or creator using them is responsible for informing you and for processing your data in that context; you may exercise your rights with them, or write to us and we will forward your request.
5. Who we share data with
Our service providers, which process data on our behalf and under contract: hosting and infrastructure, transactional and commercial email delivery, payment, language model providers, support, audience measurement and productivity tools. The list of our sub-processors is available on request.
The platforms to which the Service connects, to the extent needed for the integrations to work and in accordance with the agreements made with them.
Our advisers, insurers, auditors and, where applicable, the authorities, where the law requires it or to defend our rights.
An acquirer or successor, in the event of a merger, acquisition, sale of assets or reorganisation, with notice to the individuals concerned.
We do not sell personal data and we do not share it for third party targeted advertising.
6. International transfers
MyPuls is established in the United States and its providers are located in the United States and the European Union. Data may therefore be processed in both. Where data of individuals located in the European Union or the United Kingdom is transferred outside those territories, we put appropriate safeguards in place, in particular the standard contractual clauses adopted by the European Commission, together with supplementary measures where necessary.
7. Retention periods
Account data is kept for the duration of the contractual relationship and then for as long as needed to meet our accounting, tax and legal obligations and to handle any disputes.
Billing data is kept for the period required by applicable accounting regulations.
Technical logs and connection data are kept for no more than twelve months, unless a security incident requires longer retention.
Prospecting data is kept for three years from your last contact with us, or until you object if that comes first.
Data processed on behalf of customers is kept according to their instructions and deleted at the end of the subscription under the conditions set out in the terms of service.
8. Security
We implement technical and organisational measures appropriate to the nature of the data: encryption of data in transit and at rest, strong authentication for administrative access, segregation of environments, logging, regular backups, restriction of access to the people who need it and confidentiality obligations for those people. No system is infallible; in the event of a data breach likely to create a risk to your rights, we inform you as required by law.
9. Cookies and trackers
The website and the Service use cookies that are strictly necessary for their operation (session, authentication, security, preferences), which do not require consent. They may also use audience measurement tools to understand website traffic and use of the Service. Where the law requires it, these tools are activated only with your consent, which you can withdraw at any time through the banner provided or your browser settings. We do not use third party advertising cookies.
10. Your rights
Depending on where you live, you have the following rights over your data: access, rectification, erasure, restriction of processing, portability, objection, in particular to commercial prospecting, and withdrawal of your consent where processing relies on it.
If you live in the European Union or the United Kingdom, you may lodge a complaint with the supervisory authority of your country, in France the CNIL.
If you live in California or another US state with a personal data protection law, you have in particular the right to know what data we hold about you, to request its correction or deletion, and to opt out of its sale or sharing for targeted advertising. We do not sell or share personal data within the meaning of those laws. We do not treat you differently for exercising your rights.
To exercise your rights, write to contact@mypuls.app from the address linked to your account, or by post to the registered office. We may ask you to verify your identity. We respond within the time limits set by applicable law, in principle within one month.
If your data is processed in the Service by an agency on whose behalf we act, we forward your request to that agency and assist it in responding.
11. Commercial communications
When we send you commercial messages, each message states the identity and postal address of the sender and contains a simple way to stop receiving them. We process opt-out requests without delay and within ten days at the latest. We do not send you commercial text messages without your prior agreement.
12. Changes
We may amend this policy to reflect changes in the Service, our providers or the law. The current version is published on mypuls.app with its date. In the event of a material change, we inform you by email or in the Service before it takes effect.
13. Contact
MyPuls, Inc.2810 North Church Street
Wilmington, Delaware 19802
United States
contact@mypuls.app