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ZeroPulze Privacy Policy

This Privacy Policy has been prepared in English. Translations into other languages may be provided for convenience only. In the event of any inconsistency or conflict between a translated version and the English version, the English version shall prevail.

Last updated: 2025-10-02

This Privacy Policy explains how Three Beautiful Trees AB (“we,” “us,” or “our”) collects, uses, and protects personal data when you use our website, applications, and services (the “Service”). We are committed to complying with the General Data Protection Regulation (GDPR) and other applicable privacy laws.

By using the Service, you agree to this Privacy Policy.

1. Data Controller

The Service is provided by:
Three Beautiful Trees AB
Email: info@ZeroPulze.com
Address: Strovarvagen 4. 14634 Tullinge. Sweden

We act as the data controller for the processing of your personal data.

2. Data We Collect

We may collect the following categories of personal data:

  • Account data: name, email address, password (encrypted).
  • Subscription & payment data: billing details, payment provider info (processed via third parties such as Stripe, Apple, or Google). We do not store full credit card numbers.
  • Usage data: interactions with the Service, toggling between visual/audio, button presses, session length.
  • Performance data: reaction time (time between stimulus and “Next”), session history, training progress.
  • Device data: IP address, browser, device type, operating system.
  • Support requests: any personal data you include when contacting us.
  • Cookies & tracking: necessary cookies for login and functionality; analytics cookies only with your consent.

2a. Cookies and Similar Technologies

We use cookies and similar technologies to operate and improve the Service. Cookies
are small text files placed on your device when you visit our website or use our app.

We use the following categories of cookies:

  • Essential cookies – Required for the Service to function (e.g. login, subscription management, security). These cannot be turned off.
  • Performance & analytics cookies – Help us understand how users interact with the Service and improve features (used only with your consent).
  • Preference cookies – Remember your choices, such as language or audio/visual toggle.
  • Marketing cookies – May be used to deliver relevant offers (only with your explicit consent).

Your choices

When you first access the Service, you will be asked to provide your preferences
through a cookie banner. You may:

  • Accept all cookies
  • Reject non-essential cookies
  • Customize your choices

You can also change or withdraw your consent at any time in the cookie settings of
the Service or through your browser settings.

3. Purposes and Legal Bases of Processing

We process your data for the following purposes:
  • Provide the Service (account, subscriptions, session features) → legal basis: contract performance (Art. 6(1)(b) GDPR).
  • Payments (via third-party providers) → contract performance & legal obligation.
  • Performance tracking (reaction times, session stats) → legitimate interest (Art. 6(1)(f)), to give insights and improve the Service.
  • Support & communication → contract performance & legitimate interest.
  • Marketing emails (optional) → consent (Art. 6(1)(a)).
  • Analytics & improvements → legitimate interest or consent depending on cookie settings.
  • Legal compliance (tax, accounting, fraud prevention) → legal obligation (Art. 6(1)(c)).

4. Data Retention

  • Account data: kept as long as you maintain an account.
  • Subscription & payment data: stored for the required legal/accounting period (up to 7 years under Swedish law).
  • Performance data: stored until you delete your account or request deletion.
  • Cookies: stored according to consent settings and browser controls.
  • Support communications: up to 2 years for follow-up and quality purposes.

5. Sharing of Data

We may share your data with:

  • Payment providers: e.g., Stripe, Apple App Store, Google Play.
  • Analytics providers: only with your consent (e.g., Google Analytics).
  • Hosting & infrastructure providers: cloud services for secure storage.
  • Legal authorities: if required by law.

We do not sell or rent your data.

6. International Transfers

If data is transferred outside the EU/EEA (e.g., cloud hosting in the US), we ensure adequate protection through Standard Contractual Clauses (SCCs) or other safeguards required by GDPR.

7. Your Rights under GDPR

You have the right to:
  • Access your data.
  • Rectify inaccurate or incomplete data.
  • Erase your data (“right to be forgotten”).
  • Restrict or object to processing.
  • Data portability (receive your data in machine-readable format).
  • Withdraw consent (for marketing or cookies) at any time.
To exercise your rights, contact us at: info@ZeroPulze.com

You also have the right to lodge a complaint with your local Data Protection Authority (in Sweden: Integritetsskyddsmyndigheten).

8. Security

We use appropriate technical and organizational measures to protect your data, including encryption, access controls, and secure storage. However, no system is 100% secure.

9. Children

The Service is not directed to children under 16. We do not knowingly collect personal data from children under this age.

10. Changes to this Policy

We may update this Privacy Policy from time to time. Material changes will be notified by email or within the Service.

11. Contact

If you have questions or requests regarding this Privacy Policy or GDPR, contact us at:
Email: info@ZeroPulze.com
Address: Strövarvägen 4, 146 34 Tullinge, Sweden