PulseChat — Privacy Policy
1. Who we are
PulseChat is operated by [COMPANY LEGAL NAME], registered at [REGISTERED ADDRESS]. We are the data controller for the personal data described in this policy. For any question about it, contact [SUPPORT EMAIL].
The service is distributed to Telecel Ghana subscribers in partnership with Upstream. Telecel Ghana handles subscription billing and holds your account relationship, so questions about charges should go to Telecel Ghana customer care.
2. What we collect
Information that identifies you
- Your mobile number (MSISDN), when you sign in by entering it
- A subscriber identifier provided by Upstream, which links your session to your subscription
- A randomly generated device identifier stored in a cookie on your phone
When you arrive through a link sent to you by SMS, we receive the subscriber identifier but not your mobile number.
Information you give us
- The text you type into the chat and the other tools
- Images you upload to be transformed or animated
- The details you provide when building a CV, such as your name, contact details, work history and education
Information generated by your use
- Content produced for you: images, videos, CVs and presentations
- Your chat history
- Daily usage counts, so fair-use limits can be applied
- Your subscription and eligibility status
3. Why we use it
- To authenticate you and confirm your subscription is active
- To produce the content you request
- To apply daily usage limits fairly across subscribers
- To make your content and chat history available to you
- To reconcile usage with the operator for billing purposes
- To investigate misuse and to comply with legal obligations
- To understand how the service is used, in aggregate, so we can improve it
We do not use your content to train artificial intelligence models, and we do not sell your personal data.
4. Legal basis
We process your data to perform the contract between us when you subscribe, to meet our legal obligations, and for our legitimate interests in operating the service securely and preventing abuse. Where the law requires consent, we ask for it.
5. Where your data is processed
The service runs on servers located in [SERVER LOCATION]. The artificial intelligence providers listed above process data outside Ghana, including in the United States and the European Union. Where data leaves Ghana we rely on the providers' contractual safeguards for international transfers.
6. How long we keep it
- Generated images, videos, CVs and presentations: 4 days, then deleted automatically
- Images you upload for video generation: 4 days, then deleted automatically
- Chat history: your 50 most recent conversations
- Account and usage records: retained while your subscription is active, and afterwards as required for billing reconciliation and legal compliance
Deletion of generated files is permanent and the files cannot be recovered. Every file has a download button while it is available.
7. Your rights
Under the Data Protection Act, 2012 (Act 843) you have the right to:
- ask what personal data we hold about you
- ask us to correct data that is inaccurate
- ask us to delete your data, subject to our legal and billing obligations
- object to certain processing, or ask us to restrict it
- complain to the Data Protection Commission of Ghana
To exercise any of these, write to [SUPPORT EMAIL] from, or quoting, the mobile number you use for the service so we can identify your account. We respond within [RESPONSE PERIOD] days.
You can stop all processing associated with your subscription at any time by cancelling it: send STOP to 2126 from your Telecel Ghana line.
8. Security
Access to the service requires authentication against the operator's systems. Traffic between your phone and the service is encrypted. Access to stored data is restricted to the people who need it to run the service. No system is completely secure, and we cannot guarantee absolute security.
9. Children
The service is not intended for anyone under 18 and we do not knowingly collect data from children. If you believe a child has used the service, contact us and we will delete the data.
10. Cookies
We store one cookie containing a randomly generated device identifier. It does not identify you personally and is required by the authentication system to recognise your device between sessions. Google Analytics sets its own cookies to measure usage.
11. Changes to this policy
We may update this policy. Material changes will be published before they take effect, and continuing to use the service means you accept the updated policy.
12. Contact
[COMPANY LEGAL NAME] — [REGISTERED ADDRESS] — [SUPPORT EMAIL]
Data Protection Commission of Ghana: for complaints about how your personal data has been handled.