Privacy Policy

Last Updated: April 13, 2025

1. Introduction

Welcome to AronPulse. This Privacy Policy explains how Moșilă Andrei Alexandru – Persoana Fizică Autorizată (“AronPulse”, “we”, “us”, “our”), located in Romania, collects, uses, discloses, and protects your personal data when you visit our website aronpulse.com (“Website”), purchase our digital products (“Products”), or inquire about or engage our custom services (“Services”).

We are committed to protecting your privacy and complying with applicable data protection laws, including the General Data Protection Regulation (GDPR).  

2. Data Controller

The data controller responsible for your personal data is: Moșilă Andrei Alexandru – Persoana Fizică Autorizată, located in Oradea, Romania, reachable at hello@aronpulse.com, or by phone at 0040724790790.

3. What Personal Data We Collect

We may collect and process the following types of personal data:

  • Data You Provide Directly:
    • Contact Information: Name, email address when you contact us, subscribe to our newsletter, or potentially during product purchase (via our payment processor).
    • Communication Data: Information you provide when you communicate with us regarding inquiries, support, or services.
    • [If applicable later for custom services: Business details, project requirements, etc.]
  • Data Collected Automatically:
    • Technical Data: IP address, browser type and version, operating system, device information.
    • Usage Data: Information about how you use our Website, such as pages visited, time spent on pages, referring website addresses, clicks. (See also our Cookie Policy).
  • Data from Third Parties:
    • Payment Processors (e.g., Gumroad): When you purchase a Product, our payment processor (Gumroad) handles the transaction. They act as Merchant of Record and have their own privacy policy. They may share limited information with us necessary to confirm the purchase (e.g., purchaser name/email, product bought), but we do not typically process or store your full payment card details.

4. How We Use Your Personal Data and Legal Basis

We use your personal data for the following purposes, based on these legal grounds under GDPR:

  • To operate and maintain our Website: (Legal Basis: Legitimate Interest – ensuring website functionality and security).
  • To process and fulfill Product orders: (Legal Basis: Contractual Necessity – processing handled primarily by Gumroad; we use shared confirmation data for records).
  • To provide future custom Services (AI Agents, Workflows): (Legal Basis: Contractual Necessity – based on separate service agreements).
  • To communicate with you: Respond to inquiries, provide support, send service-related updates. (Legal Basis: Legitimate Interest; Contractual Necessity if related to purchase/service).
  • To send marketing communications (e.g., newsletter): Only if you have provided your explicit Consent. You can withdraw consent at any time.
  • To improve our Website, Products, and Services: Analyze usage data to understand user needs and enhance offerings. (Legal Basis: Legitimate Interest – provided data is aggregated or anonymized where possible).
  • To comply with legal obligations: Maintain financial records, respond to legal requests. (Legal Basis: Legal Obligation).
  • To ensure security: Protect against fraud and unauthorized access. (Legal Basis: Legitimate Interest).

5. Data Sharing and Disclosure

We do not sell your personal data. We may share your data with the following categories of third parties only when necessary:

  • Payment Processors: Gumroad (or similar) to process Product payments.
  • Service Providers: Hosting providers, email marketing platforms, analytics providers, IT support.
  • Professional Advisors: Lawyers, accountants, consultants, when necessary for legal or business purposes.
  • Legal Authorities: If required by law or to protect our legal rights.

International Data Transfers: Some of these third-party service providers may be based outside, or transfer personal data to locations outside, the European Union (EU) or European Economic Area (EEA). When this occurs, we endeavor to select providers who commit to adequate levels of data protection. This often involves relying on mechanisms approved by the European Commission, such as Adequacy Decisions for certain countries, or implementing safeguards like Standard Contractual Clauses (SCCs) where necessary.

For detailed information on how a specific service provider handles international data transfers and the specific safeguards they have in place, please refer directly to their respective Privacy Policies and Data Processing Agreements (DPAs). We recommend reviewing the policies of key providers such as:

Please note: Ensuring the adequacy of these safeguards for international transfers is a complex legal matter. While we aim to use reputable providers, you should review their policies to understand their practices fully.

6. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. Retention periods vary depending on the type of data and purpose:  

  • Data related to purchases may be kept for the period required by Romanian tax law.
  • Contact form inquiries may be kept for 12 months after resolution.
  • Newsletter subscription data is kept until you unsubscribe.
  • Analytics data may be kept in an aggregated/anonymized form for 24 months.

7. Your Data Protection Rights (GDPR)

Under GDPR, you have the following rights regarding your personal data:

  • Right to Access: Request copies of your personal data we hold.
  • Right to Rectification: Request correction of inaccurate or incomplete data.
  • Right to Erasure (‘Right to be Forgotten’): Request deletion of your personal data under certain conditions.
  • Right to Restrict Processing: Request limitation of how we process your data under certain conditions.  
  • Right to Data Portability: Request transfer of your data to another organization, or directly to you, under certain conditions.  
  • Right to Object: Object to processing based on legitimate interests.
  • Right to Withdraw Consent: Withdraw your consent at any time where processing is based on consent (e.g., for newsletters).

To exercise any of these rights, please contact us at hello@aronpulse.com. We will respond to your request in accordance with GDPR requirements.

8. Right to Lodge a Complaint

You have the right to lodge a complaint with the Romanian National Supervisory Authority for Personal Data Processing (ANSPDCP) if you believe our processing of your personal data infringes GDPR. Contact details can be found on their website https://www.dataprotection.ro/.

9. Data Security

We implement appropriate technical and organizational measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. These include measures like HTTPS encryption for the Website, secure hosting environments, and access controls. However, no internet transmission is completely secure.  

10. Children’s Privacy

Our Website, Products, and Services are not intended for children under the age of 16 (or applicable age in jurisdiction). We do not knowingly collect personal data from children.

11. Cookies

We use cookies on our Website. Please see our separate Cookie Policy for detailed information on the cookies we use, their purpose, and how you can manage them.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any significant changes by posting the new policy on the Website and updating the “Last Updated” date. We encourage you to review this policy periodically.  

13. Contact Us

If you have any questions about this Privacy Policy or our data protection practices, please contact us at: hello@aronpulse.com