Privacy Policy
This Policy explains how Pulscam collects, uses, stores, shares and protects personal data for accounts, adult eligibility, creator and studio verification, payments, safety, moderation, support and platform operation.
1. Data controller and contacts
Pre-launch controller status: the final Pulscam legal operator will be identified here after Romanian business registration and before public commercial launch. Until the legal name, legal form, registration number and registered office are inserted, this page remains a pre-launch privacy notice rather than a complete final controller-identity disclosure.
2. Scope
This Policy applies to visitors, registered viewers, creator applicants, approved creators, studios, studio-managed performers, Live Participants/co-models, persons appearing in content, affiliates and referred users, persons submitting reports or legal notices, payment and payout participants, and persons communicating with Pulscam support or compliance teams.
It covers processing controlled by Pulscam. Third parties may provide their own notices where they act as independent controllers.
3. Categories of personal data
Account and profile data
Username, email address, password hash, authentication records, role, language, country settings, account status, stage name, profile information, public media, notification settings and accepted policy versions.
Age, identity and eligibility data
Date of birth, country or residence, adult declarations, legal name, identity-document images and metadata, selfie or liveness captures, verification results, consent records, review notes, rejection reasons, recheck history and Live Participant/co-model verification associations.
Studio and business data
Studio identity, registration, ownership or control information, representatives, authority records, performer associations, studio earnings and tier information, payout details, tax data and compliance evidence.
Payment, wallet and paid-feature data
Token purchases, wallet ledger entries, tips, private-show and spy-show activity, ticket grants, private messages, wall posts, Fan Club memberships and upgrades, VIP membership, paid social-link access, paid media, refunds, reversals, chargebacks, creator or studio earnings, payout requests, payout-method references, settlement records, accounting exports, tax identifiers and fraud-review results.
Affiliate and referral data
Affiliate account and link identifiers, referral code and source, attribution state, referred-account identifiers, campaign or promo-asset references, reward type and amount, reward hold and reversal status, purchase-reward basis, anti-abuse signals, postback/integration records and related audit data.
Technical, device and security data
IP address, user-agent, browser and device information, operating system, session identifiers, login history, security events, cookie and storage choices, device or network risk indicators and account-recovery records.
Content, communications and investigations
Broadcasts, uploaded media, profile and wall content, public chat, private messages, private-room activity, support communications, reports, takedown requests, moderation decisions, reporter feedback, appeals, copyright notices, legal requests and evidence-preservation records.
4. Sources of personal data
Pulscam may obtain data directly from the individual; from an authorized studio, creator or co-performer; from identity or liveness systems; from payment and payout providers; from devices, browsers and server logs; from persons submitting reports; from public content; from authorities; and from service providers assisting Pulscam.
Where a studio provides data concerning a performer, Pulscam may also deliver the relevant privacy and verification information directly to that performer.
5. Purposes and legal bases
| Purpose | Typical legal basis |
|---|---|
| Account creation, login and service delivery | Contract performance or steps requested before entering into a contract. |
| Creator, performer and Live Participant verification | Contract, steps before contract, legitimate interests or legal obligation where applicable; any Article 9 condition for special-category or biometric processing must match the actual processing and final legal analysis. |
| Token purchases, paid features, earnings, payouts and accounting | Contract performance, legal obligation and legitimate interests in fraud prevention, reconciliation and legal claims. |
| Affiliate attribution, rewards, holds and reversals | Performance of the applicable platform/referral arrangement and legitimate interests in reward administration, fraud prevention and reconciliation. The first-party affiliate referral cookie itself is optional Marketing storage and is written only after the user enables Marketing in Cookie settings. |
| Safety, moderation and policy enforcement | Legitimate interests, contractual necessity and legal obligations. |
| Security and fraud prevention | Legitimate interests and applicable security or legal obligations. |
| Legal claims, valid requests and evidence preservation | Legal obligation and legitimate interests in establishing, exercising or defending legal claims. |
| Optional analytics and marketing | Consent where required by law. |
Final commercial publication must identify the exact legal basis for each production processing activity and any Article 9 condition where special-category data is processed. Runtime capability alone does not establish the legal basis.
6. Special-category data
Adult-platform content and communications may reveal information concerning sex life, sexual orientation, health or other sensitive matters. Identity verification may also involve biometric data used to confirm a person’s identity.
For biometric data processed for the purpose of uniquely identifying a creator or performer during identity and age verification, Pulscam relies on explicit consent under Article 9(2)(a) GDPR. Biometric processing does not begin without that explicit consent; if consent is not provided, the individual cannot complete biometric verification and is not eligible to broadcast. Other special-category processing remains subject to a separate applicable Article 9 condition where required. Pulscam does not use such data for unrelated advertising or ordinary commercial profiling.
7. Public and private content
Public broadcasts, public profiles, public chat, public wall posts and public media are visible to other persons and must not be treated as private.
Private messages and private interactions are not public, but Pulscam may access, preserve or review them where necessary for service delivery, support, safety, fraud prevention, policy enforcement, legal obligations or legal claims.
8. Creator verification workflow
Pulscam operates an internally controlled workflow that ensures required verification steps are completed in the correct sequence before a creator or studio-managed performer is presented for final review.
The workflow may confirm that required documents, declarations and captures are present; evaluate document-readability and consistency indicators; compare account information with submitted identity information; compare the selfie or liveness capture with the identity document; evaluate liveness and anti-spoofing indicators; identify missing or inconsistent information; and route the application to the correct next step.
Where a step is incomplete, unsuccessful or inconsistent, the application does not proceed to final approval. The applicant is returned to the relevant step and may be asked to replace a document, correct data, repeat selfie or liveness, provide an omitted declaration or explain an inconsistency.
Only a complete and internally coherent package proceeds to ADMIN REVIEW PENDING.
9. Automated tools and mandatory human review
Automated workflow and verification-support tools do not independently approve a creator or studio-managed performer.
Every complete verification package is reviewed manually by authorized Pulscam personnel. The reviewer may consider the identity document, authenticity and consistency indicators, selfie-to-document comparison, liveness result, account data, consent records, recheck history and relevant risk indicators.
The administrator records one of the following outcomes: APPROVED, RECHECK REQUIRED, REJECTED, or SUSPENDED PENDING ADDITIONAL REVIEW.
A positive automated result does not create a right to creator access. A failed or uncertain automated result is not by itself conclusive evidence of fraud.
Only a final APPROVED decision permits live broadcasting, monetization, tips, private paid interactions, paid creator media, earnings accumulation and payout access.
Applicants may provide corrections or additional evidence, repeat a verification step and request permitted human reconsideration. The final outcome is recorded with the reviewer, timestamp, status and appropriate reason category.
10. Recipients and sharing
Data may be shared where necessary with hosting, infrastructure, streaming, security, communications, payment, payout, accounting, tax, legal, support and verification service providers, as well as competent authorities where legally required.
Processors must act under documented instructions, confidentiality obligations and appropriate security and data-protection terms. The current Legal Center does not yet constitute a complete production subprocessor register; provider identities, roles, processing locations and transfer safeguards must be finalized before the relevant commercial processing is represented as complete.
11. International transfers
Where personal data is transferred outside the European Economic Area, Pulscam will use an applicable transfer mechanism, which may include an adequacy decision, Standard Contractual Clauses and supplementary safeguards.
The final transfer register and mechanisms must be confirmed before public commercial launch.
12. Retention
Pulscam retains data only for as long as necessary for the relevant purpose and applicable legal, accounting, safety, dispute or evidence requirements.
The current codebase does not establish one universal verified retention period for identity documents, raw liveness material, biometric-derived data, consent evidence, moderation evidence, payments, chargebacks and legal requests. Those categories therefore remain subject to a production retention schedule and deletion/hold implementation before a fixed public period is stated.
Where a documented legal hold applies, deletion may be paused only for the relevant data and justified period. When retention is no longer justified, data is deleted, anonymized or placed beyond ordinary use.
Specific technical retention disclosed elsewhere, such as first-party analytics retention or affiliate integration cleanup windows, does not automatically apply to identity, content, financial or legal evidence.
13. Security
Pulscam applies technical and organizational measures appropriate to the risk, including access controls, role-based permissions, least-privilege access, restricted storage, transport security, audit logging, backup and recovery controls, incident response, provider review, confidentiality obligations and secure-deletion procedures.
The final public version will describe only security controls verified as implemented in production.
14. Data-subject rights
Subject to applicable conditions and exceptions, individuals may request access, correction, completion, deletion, restriction, objection, portability, consent withdrawal, human intervention and review of certain automated decisions.
Requests may be submitted through legal@pulscam.com. Pulscam may verify the requester’s identity before disclosing or changing data.
15. Consent withdrawal
Where processing is based on consent, consent may be withdrawn at any time. Withdrawal does not affect processing lawfully completed before withdrawal.
Withdrawal does not automatically require deletion of data retained under a separate valid basis, such as a legal obligation, accounting requirement, legal claim, documented safety investigation or justified fraud-prevention record. Pulscam will identify the specific basis and retention period for continued processing.
16. Account closure
The current deletion flow for viewers and eligible independent models requires confirmation, suspends ordinary access and provides a seven-day cancellation window. During that period, a restricted cancellation-only authentication scope may be used to restore the account where eligible.
Account closure does not necessarily result in immediate deletion of all data. Limited records may remain for unresolved transactions, payouts, refunds, chargebacks, accounting, tax, safety, fraud prevention, consent evidence, adult eligibility and legal claims.
Public content will be removed, disabled or handled according to the Terms, creator agreements, purchased-access rules and documented legal holds.
17. Adults-only service
Pulscam is intended only for adults. Pulscam does not knowingly permit minors to create accounts, purchase adult services, broadcast or appear in adult content. Suspected underage access or content may result in immediate restriction, investigation, preservation and legally required reporting.
18. Personal-data breaches
Pulscam maintains procedures to identify, assess, contain and document personal-data breaches. Where required by law, Pulscam will notify the competent supervisory authority and affected individuals.
19. Supervisory authority
Individuals may lodge a complaint with the Romanian supervisory authority, Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal (ANSPDCP), or another competent authority where applicable.
20. Changes and contact
Material changes may be communicated through a platform notice, account notification, email or renewed acceptance where required. The current version and effective date will be displayed on this page.