Privacy Policy

PULSECORE TECH LTD

Effective Date: 1 April 2026 | Version 1.0

Data Controller: PULSECORE TECH LTD

Company Number: 17068502

Registered Address: 20 Wenlock Road, London, N1 7GU, England

ICO Registration: [ICO Registration Number — insert upon ICO registration]

Contact: [email protected]

Applicable Law: UK GDPR | Data Protection Act 2018

1. Introduction

This Privacy Policy (“Policy”) describes how PULSECORE TECH LTD (“Company”, “we”, “us”, or “our”), company number 17068502, registered at 20 Wenlock Road, London, N1 7GU, England, collects, uses, processes, stores, and protects personal data in connection with the website at https://orbiano.com (“Website”) and the sale of digital products through it.

The Company acts as data controller for all personal data processed under this Policy. We operate in accordance with the UK General Data Protection Regulation (“UK GDPR”) and the Data Protection Act 2018 (“DPA 2018”). Our ICO registration number is: [ICO Registration Number — insert upon ICO registration].

Questions about this Policy or requests to exercise your rights should be directed to [email protected].

2. Data We Collect

2.1 Data You Provide Directly

When registering an account, making a purchase, requesting support, or submitting a refund request, we may collect:

• full name;
• email address;
• billing address and country;
• payment method type (e.g. card brand and last four digits — full card data is never stored by the Company; it is processed solely by our payment service provider);
• identity verification documents, where required for AML compliance;
• correspondence you send to us, including support tickets and refund communications.

2.2 Data Collected Automatically

When you visit the Website, we may collect:

• IP address and approximate geographic location (derived from IP);
• browser type, version, and language;
• device type and operating system;
• pages visited, session duration, and navigation behaviour;
• date and time of access;
• data collected via cookies (see Cookies Policy at https://orbiano.com/cookies-policy).

2.3 Transaction Data

We retain records of all completed transactions, including order reference, product purchased, amount paid, payment method type, date of purchase, and delivery status. This data is retained for financial, legal, and compliance purposes.

2.4 What We Do Not Collect

We do not collect or process special category data as defined in Article 9 UK GDPR (such as health, biometric, or racial data). We do not knowingly collect data from persons under 18 years of age.

3. Lawful Basis for Processing

3.1 Performance of Contract (Art. 6(1)(b) UK GDPR)

We process your name, email address, billing address, and transaction data to form and perform the purchase contract — including delivering Digital Products, managing your account, and handling refund or support requests. This is the primary lawful basis for processing in connection with purchases.

3.2 Legal Obligation (Art. 6(1)(c) UK GDPR)

We process data where required to comply with legal obligations, including anti-money laundering legislation (MLR 2017, POCA 2002), tax record-keeping requirements (HMRC), and responses to lawful requests from competent authorities (NCA, OFSI, ICO, law enforcement).

3.3 Legitimate Interests (Art. 6(1)(f) UK GDPR)

We process data for the purposes of fraud prevention and detection, transaction monitoring, security of the Website and our systems, and analytics to improve our services. We have assessed that our legitimate interests in these activities are not overridden by your rights and freedoms.

3.4 Consent (Art. 6(1)(a) UK GDPR)

Where we rely on consent — for example, for non-essential cookies or direct marketing — we obtain it separately and it is never a condition of making a purchase. You may withdraw consent at any time. Withdrawal does not affect the lawfulness of any processing carried out prior to withdrawal.

4. Purposes of Processing

We process personal data for the following purposes:

• creating and managing user accounts;
• processing orders and delivering Digital Products;
• processing payments and maintaining financial records;
• conducting identity verification where required by AML obligations;
• providing customer support and handling complaints and refund requests;
• detecting, preventing, and investigating fraud and financial crime;
• complying with legal and regulatory obligations;
• maintaining Website security and functionality;
• sending transactional communications (order confirmations, delivery notifications, support responses);
• with your consent: sending marketing communications about our products.

5. Sharing of Personal Data

We do not sell personal data to third parties. We share data only where necessary and only in the following circumstances:

5.1 Payment Service Providers

We share order and billing information with our payment service provider(s) for the purpose of processing transactions. These providers handle card data as independent controllers under their own PCI-DSS and data protection obligations.

5.2 Identity Verification Providers

Where AML or fraud-related identity verification is required, we share the minimum necessary personal data with authorised verification providers. These providers act as data processors under written data processing agreements compliant with UK GDPR.

5.3 IT and Hosting Providers

Our hosting and infrastructure providers may have technical access to data stored on our systems. They act as data processors under contractual data processing agreements and may access personal data only to the extent necessary to provide their services.

5.4 Legal and Regulatory Disclosure

We may disclose personal data to the NCA, HMRC, OFSI, ICO, law enforcement agencies, or other competent authorities where required or permitted by applicable law — including under POCA 2002, the Terrorism Act 2000, and MLR 2017.

5.5 Business Transfers

If the Company is involved in a merger, acquisition, or sale of assets, personal data may be transferred to the acquirer. We will notify affected users before any such transfer takes effect, where we are legally able to do so, and will ensure the receiving party is bound by data protection obligations at least equivalent to those set out in this Policy.

6. International Data Transfers

We endeavour to process and store all personal data within the United Kingdom. Where a transfer outside the UK is necessary (for example, where a service provider is based outside the UK), we implement appropriate safeguards including UK International Data Transfer Agreements (IDTAs) or, where applicable, the UK Addendum to EU Standard Contractual Clauses. Details of the safeguards in place for any specific transfer are available upon request.

7. Data Retention

We retain personal data only as long as necessary for the purpose for which it was collected and to comply with applicable legal obligations:

• Transaction and financial records: minimum 6 years from the date of the transaction (Limitation Act 1980; HMRC record-keeping requirements);
• AML and identity verification records: minimum 5 years from the end of the business relationship, or 5 years from the date of the relevant transaction, whichever is later (Regulation 40, MLR 2017);
• Account data: retained for the duration of the active account plus 2 years following closure, to address any subsequent disputes or enquiries;
• Support and refund correspondence: 3 years from the date of the final communication in the relevant thread;
• Cookie and analytics data: as specified in the Cookies Policy.

On expiry of the applicable period, data will be securely deleted or irreversibly anonymised.

8. Your Rights Under UK GDPR

You have the following rights in respect of personal data we hold about you:

• Right of access (Art. 15): to request a copy of the personal data we hold about you;
• Right to rectification (Art. 16): to request correction of inaccurate or incomplete data;
• Right to erasure (Art. 17): to request deletion of your data where retention is no longer justified, subject to our legal obligations (for example, we cannot delete transaction records during their mandatory retention period);
• Right to restriction of processing (Art. 18): to request that we limit our use of your data in certain circumstances;
• Right to data portability (Art. 20): to receive data you have provided to us in a structured, machine-readable format, where the processing is based on contract or consent;
• Right to object (Art. 21): to object to processing based on legitimate interests, including direct marketing;
• Rights regarding automated decisions (Art. 22): the Company does not currently make legally or similarly significant decisions about individuals by solely automated means. If this changes, you will be informed and given the right to request human review.

To exercise any of the above, send a written request to [email protected]. We will respond within one calendar month. We may ask you to verify your identity before processing the request. There is no charge for a reasonable request.

If you are dissatisfied with our response, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO): https://ico.org.uk | 0303 123 1113 | Wycliffe House, Water Lane, Wilmslow, SK9 5AF.

9. Security

We maintain appropriate technical and organisational measures to protect personal data against unauthorised access, loss, or disclosure, including encryption in transit (TLS), access controls, and regular security reviews. No internet transmission is entirely secure; you use the Website at your own risk in respect of transmission security.

10. Children

The Website is not directed at persons under 18. We do not knowingly collect data from minors. If you believe a minor has provided personal data to us, contact [email protected] and we will take steps to delete it promptly.

11. Cookies

We use cookies and similar technologies. For full details of the cookies used, their purposes, retention periods, and how to manage your preferences, see our Cookies Policy at https://orbiano.com/cookies-policy.

12. Changes to This Policy

We may update this Policy from time to time. Material changes will be communicated to registered users by email and posted on the Website with an updated effective date before taking effect. We encourage you to review this Policy periodically.

13. Contact and Complaints

For privacy enquiries or to exercise your rights:

PULSECORE TECH LTD (Company No. 17068502)

20 Wenlock Road, London, N1 7GU, England

Email: [email protected]

Website: https://orbiano.com

For complaints: Information Commissioner’s Office | https://ico.org.uk | 0303 123 1113