Pulse Privacy Policy

Last updated: May 6, 2026 Effective date: May 6, 2026

This privacy notice for Pulse, Inc. ("Company," "Pulse," "we," "us," or "our") describes how and why we might collect, store, use, and/or share ("process") your information when you use our services ("Services"), including the Pulse mobile application and any related services we provide. By using our Services, or by accessing our website at https://pulsepredictions.com or any website of ours that links to this privacy notice, you are accepting and consenting to this Privacy Policy.

This Privacy Policy is incorporated by reference into our Terms of Service. Capitalized terms not defined here have the meaning given in the Terms of Service.

1. WHAT INFORMATION DO WE COLLECT?

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• Phone number (collected through our authentication partner, Privy, for SMS one-time-passcode sign-in)
• Display name (optional; you may use a pseudonym — we do not require your real name)
• Email address (only if you choose to contact us)
• Profile information you create on Pulse, including display name and profile picture
• Feedback or support messages you send to us

Pulse does not currently allow users to post free-form content within the Services (no comments, reactions, posts, or messages between users). The personal information you provide is limited to what is described above.

Information Generated Automatically. We automatically collect certain information when you visit, use, or navigate the Services. This information may include:

• Wallet address. On first sign-in, Privy provisions an Ethereum-compatible (EVM) wallet using multi-party computation (MPC) so that the private key is generated and managed on your device. Pulse stores the resulting public wallet address linked to your account so the Services can show your balance and route your signed transactions to third-party protocols.
• Trading and prediction activity. When you take, modify, or close a position through the Services, the resulting activity (including the market, the side and size of the position, the price, the timestamp, and the resulting outcome) is recorded by the underlying public blockchain and may be displayed within the Services. As described in Section 3 below, your trading and prediction activity may be displayed automatically on a public Activity page within the Services, associated with your display name and wallet address.
• Device and technical information. Device model, operating-system version, application version, language and region settings, time zone, crash logs, and similar technical data.
• Usage data. Information about how you use the Services, such as screens viewed, features used, markets browsed, the timing and frequency of your interactions, and aggregate metrics.
• IP address and connection data. When you interact with our servers or our processors' servers, we receive your IP address and standard server-log information (timestamps, request paths, user-agent strings).
• Cookies and similar technologies. Like many businesses, we may use cookies, mobile-SDK identifiers, and similar tracking technologies for analytics and crash reporting.

Information from Third Parties.

• Privy. As our authentication and non-custodial wallet-infrastructure provider, Privy returns to us limited account information (e.g., user identifier, phone number, wallet address, and authentication state) so we can operate your account.
• Apple TestFlight (during beta) and the Apple App Store. While the application is distributed via TestFlight or the App Store, Apple provides us with limited tester information (e.g., tester email, build install information, crash diagnostics) under Apple's TestFlight and App Store terms.
• Analytics and crash-reporting providers. We may use a privacy-respecting analytics or crash-reporting provider that returns aggregated and event-level usage and crash information to us.
• Public blockchain data. Information about your wallet address, balances, and transactions is recorded on public blockchains (for example, Polygon) and is observable by anyone. We may read this information to display your balance or transaction history.

Information We Do NOT Collect. We do not collect:

• Social Security numbers or other government-identification numbers
• Driver's-license, passport, or national-ID numbers
• Payment-card numbers, bank-account numbers, or routing numbers
• Real legal names (beyond an optional display name you choose)
• Account passwords (the Services use passwordless SMS-OTP authentication via Privy)
• Biometric data
• Precise geolocation
• Children's data — see Section 8

We do not store your private keys or seed phrases on our servers. These are managed by Privy's MPC architecture and remain associated with your device. Do not send your private key, seed phrase, or recovery phrase to Pulse, our employees, or any support channel. Anyone asking you to do so is attempting to defraud you.

2. HOW DO WE PROCESS YOUR INFORMATION?

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
• To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service, including displaying market data and routing your signed transactions to third-party protocols.
• To display trading and prediction activity within the Services. We may process your wallet address, display name, profile picture, and on-chain activity to display public trading and prediction activity (including your own) on the Activity page and elsewhere within the Services. Pulse does not allow users to post free-form content; the activity displayed is limited to the on-chain trading and prediction events described above.
• To respond to user inquiries / offer support to users. We may process your information to respond to your inquiries and resolve any potential issues you might have with the Services.
• To send administrative information to you. We may process your information to send you details about our products and Services, changes to our terms and policies, and other similar information.
• To request feedback. We may process your information to request feedback and to contact you about your use of the Services.
• To protect the Services. We may process your information as part of our efforts to keep the Services safe and secure, including fraud monitoring and prevention.
• To identify usage trends. We may process information about how you use the Services to better understand how they are being used so we can improve them.
• To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.
• To comply with law and respond to legal requests. We may process your information to comply with subpoenas, court orders, or other legal process.
• To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.

We do not use personal information for cross-context behavioral advertising, profile-based targeting, or to make automated decisions that produce legal or similarly significant effects about you.

For users in the European Economic Area, the United Kingdom, or Switzerland, the lawful bases on which we rely are:

3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

We may share your data with third-party vendors, service providers, contractors, or agents ("third parties") who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it.

Sub-Processors. We currently rely on the following sub-processors:

• Privy — authentication (SMS OTP), embedded non-custodial wallet infrastructure (MPC key management), and account management.
• Apple, Inc. — application distribution and, during beta, TestFlight services.
• Cloud hosting and infrastructure providers — to host backend services and store operational data.
• Analytics and crash-reporting providers — to understand performance and stability.
• Customer-support tooling — if and when we use a ticketing or messaging tool to respond to you.
• Communications providers — to deliver SMS or email when needed.

Public Information Within the Services (Activity Page). Pulse displays trading and prediction activity on a public Activity page within the Services. By using the Services to take, modify, or close a position, you acknowledge and agree that the following information may be displayed publicly within the Services and visible to other users:

• Your display name and profile picture (if any)
• Your public wallet address (or a portion of it)
• The markets you have taken positions on, the side and size of those positions, the prices at which they were taken, and the timestamps of your activity
• The resolution and outcome of your positions, including profits and losses, and any aggregate statistics derived from that activity (for example, win rate, position count, or leaderboard standing)

Pulse does not allow users to post free-form text content (such as comments, reactions, or messages between users), so no user-generated commentary appears in the public Activity feed. The activity displayed is automatically generated from on-chain trading events and from your account profile.

Because the underlying activity is also recorded on a public blockchain (see "Public Blockchains" below), this information is independently visible to anyone, regardless of whether you use the Services. Choosing not to use the Services does not remove on-chain activity from public view.

Public Blockchains. The Services route transactions you initiate to public blockchain networks (such as Polygon) and to third-party prediction-market protocols (such as Polymarket). When you take a position, withdraw funds, or move tokens, the resulting transaction — including your public wallet address, the counterparties, the timestamp, and the amount — is recorded on the public blockchain. This information is publicly visible and cannot be deleted by Pulse, by Privy, or by any other party. Anyone can connect a wallet address to off-chain identifying information if they have it.

Third-Party Prediction-Market Protocols. When you place a position, your signed transaction is routed to a third-party prediction-market protocol (currently Polymarket's central limit order book on Polygon). That protocol receives the on-chain information necessary to process the order. Pulse does not transmit your phone number to the protocol.

Legal, Safety, and Protection. We may disclose personal information when we believe in good faith that disclosure is necessary to: comply with a subpoena, court order, or other legal process; comply with applicable law, regulation, or governmental request; enforce our Terms of Service or investigate suspected violations; detect, prevent, or address fraud, security, or technical issues; or protect the rights, property, or safety of Pulse, our users, or the public.

Corporate Transactions. If Pulse is involved in a merger, acquisition, financing, reorganization, sale of assets, bankruptcy, or similar transaction, personal information may be transferred as part of that transaction. We will require the recipient to honor the commitments in this Privacy Policy or notify you of any material changes.

With Your Direction. We will share personal information at your direction or with your consent.

What we do NOT do. We do not sell personal information for money. We do not share personal information for cross-context behavioral advertising. We do not "share" personal information within the meaning of the California Consumer Privacy Act, as amended by the CPRA.

4. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?

The Services may link to third-party websites, online services, or mobile applications and/or contain advertisements from third parties that are not affiliated with us and which may link to other websites, services, or applications. The Services may also include information obtained from third-party websites or sources, including prediction-market platforms such as Polymarket, Kalshi, and other decentralized protocols. Accordingly, we do not make any guarantee regarding any such third parties or their data, and we will not be liable for any loss or damage caused by the use of such third-party websites, services, or applications. The inclusion of a link towards (or presentation of data relating to) a third-party website, service, or application does not imply an endorsement by us. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this privacy notice. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services, or applications that may be linked to or from the Services. You should review the policies of such third parties and contact them directly to respond to your questions.

For convenience, the privacy policies of two key third parties are:

• Privy: https://privy.io/legal/privacy
• Polymarket: https://polymarket.com/privacy

5. PUBLIC-BLOCKCHAIN DISCLOSURE (IMPORTANT)

The wallet address provisioned to you by Privy is non-custodial — Pulse cannot freeze, move, or recover funds in it — but it is also pseudonymous, not anonymous. Every transaction you sign is broadcast to a public blockchain and stored permanently. Anyone, including data brokers, governments, counterparties, and adversaries, can:

• View your wallet's balance and full transaction history;
• Cluster your wallet with other addresses you control;
• Link your wallet to off-chain identity if they obtain identifying information from another source (for example, a centralized exchange you withdrew from, a public post, or a leaked database).

You should treat your wallet address as a public identifier. If you require a higher degree of privacy, do not use the Services.

6. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

We may use cookies and similar tracking technologies (like web beacons, pixels, and mobile-SDK identifiers) to access or store information for analytics, security, and to operate and improve the Services. The mobile application does not rely on browser cookies for its core functionality. You can disable advertising identifiers in your iOS settings.

We do not use third-party advertising trackers and we do not request permission to track your activity across other companies' apps and websites under Apple's App Tracking Transparency framework.

7. HOW DO WE HANDLE YOUR SOCIAL LOGINS AND WALLET PROVIDER?

The Services rely on a passwordless SMS one-time-passcode authentication flow operated by our authentication partner, Privy. When you sign in, we receive certain account information from Privy, including your phone number, user identifier, and the public wallet address of the non-custodial wallet provisioned to your device.

We will use the information we receive only for the purposes that are described in this privacy notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by Privy. We recommend that you review Privy's privacy notice (https://privy.io/legal/privacy) to understand how Privy collects, uses, and shares your personal information.

8. DO WE COLLECT INFORMATION FROM MINORS?

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18, or the legal age of majority in your jurisdiction (whichever is greater), or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at team@pulsepredictions.com.

We do not knowingly collect personal information from children under 13 in violation of the Children's Online Privacy Protection Act (COPPA).

9. HOW DO WE KEEP YOUR INFORMATION SAFE?

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process, including encryption in transit, access controls, vendor due diligence, and regular reviews of our security posture. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information-storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

Additional Security Considerations for Non-Custodial Wallets. If you use the Services to create or manage a non-custodial wallet, you are solely responsible for maintaining the security of your private keys, seed phrases, authentication factors, and the device on which the wallet was provisioned. We do not store your private keys or seed phrases on our servers. Loss of access to your device, your phone number, or your authentication factors may result in permanent loss of access to your wallet and to any digital assets held in it, and we cannot recover this information for you.

If we become aware of a security incident affecting your personal information, we will notify you and the relevant authorities as required by law. Report suspicious activity to security@pulsepredictions.com.

10. DATA RETENTION

We retain personal information for as long as we need it for the purposes described in this Privacy Policy and as required by applicable law.

• Account data (phone number, wallet address, account identifiers). Retained for the life of your account and for a reasonable period after account closure to address legal, security, and fraud-prevention needs.
• Usage and diagnostic data. Retained on a rolling basis (typically 12–24 months) and aggregated or deleted thereafter.
• Support communications. Retained for as long as needed to address the matter and a reasonable period thereafter.
• Records required by law. Retained for the period required by the applicable law (for example, tax, audit, or anti-fraud requirements).
• On-chain data. We cannot delete on-chain data. It persists on the public blockchain forever, regardless of the status of your Pulse account.

When we no longer need personal information, we delete it, anonymize it, or take reasonable steps to put it beyond use.

11. INTERNATIONAL DATA TRANSFERS

Pulse is based in the United States, and our processors may operate in the United States and other countries. If you access the Services from outside the United States, your personal information will be transferred to and processed in the United States and other jurisdictions whose data-protection laws may differ from those of your home jurisdiction.

For transfers from the European Economic Area, the United Kingdom, or Switzerland to a country that has not received an adequacy decision, we rely on appropriate safeguards, including the European Commission's Standard Contractual Clauses (SCCs) and the United Kingdom's International Data Transfer Addendum, where applicable. You may request a copy of the safeguards we use by contacting team@pulsepredictions.com.

12. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

13. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

If you are a resident of California, you are granted specific rights regarding access to your personal information under the California Consumer Privacy Act, as amended by the California Privacy Rights Act ("CCPA/CPRA").

Shine the Light Law. California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct-marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. Pulse does not currently disclose personal information to third parties for their direct-marketing purposes.

Minors. If you are under 18 years of age, reside in California, and have a registered account with the Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups).

Categories of Personal Information. Pulse collects the categories of personal information described in Section 1 above. We do not collect "sensitive personal information" for purposes of inferring characteristics about you within the meaning of the CCPA.

Sale or Sharing of Personal Information. Pulse does not sell or share personal information as those terms are defined under the CCPA. We have no obligation to honor a "Do Not Sell or Share" preference signal because we do not engage in those activities, but if we receive one we will treat it consistently with this policy.

Your CCPA/CPRA Rights.

• Right to know — request information about what personal information we collect and how we use and disclose it.
• Right to delete — request that we delete personal information we collected from you, subject to certain exceptions.
• Right to correct — request correction of inaccurate personal information.
• Right to limit use of sensitive personal information — Pulse does not process sensitive personal information for purposes that require this right.
• Right to non-discrimination for exercising your privacy rights.

Verification. Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us.

To exercise these rights, contact us at team@pulsepredictions.com.

14. DO RESIDENTS OF VIRGINIA, COLORADO, CONNECTICUT, UTAH, AND OTHER U.S. STATES HAVE SPECIFIC PRIVACY RIGHTS?

Yes. If you are a resident of a state with a comprehensive consumer-privacy law (including but not limited to Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Delaware, Iowa, Tennessee, Indiana, New Jersey, and other states as enacted), you may be granted specific rights regarding access to and use of your personal information.

Your rights.

• Right to be informed whether or not we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")

Pulse does not currently engage in targeted advertising, sale of personal data, or profiling.

Verification. We may request that you provide additional information reasonably necessary to verify you and your request. If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request.

Response time. Upon receiving your request, we will respond without undue delay, but in all cases, within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary. We will inform you of any such extension within the initial 45-day response period, together with the reason for the extension.

Right to appeal. If we decline to take action regarding your request, we will inform you of our decision and reasoning behind it. If you wish to appeal our decision, please email us at privacy@pulsepredictions.com. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may contact your state Attorney General to submit a complaint.

To exercise your rights, contact us at team@pulsepredictions.com.

15. DO RESIDENTS OF THE EUROPEAN ECONOMIC AREA, UNITED KINGDOM, OR SWITZERLAND HAVE SPECIFIC PRIVACY RIGHTS?

Yes. If you are located in the EEA, the UK, or Switzerland, you have rights under the General Data Protection Regulation ("GDPR") and applicable UK and Swiss data-protection law.

Your rights include:

• Right to access your personal information
• Right to rectification (correction)
• Right to erasure (deletion)
• Right to restrict processing
• Right to data portability
• Right to object to processing
• Right to withdraw consent (where we relied on it)
• Right to lodge a complaint with your local supervisory authority

We rely on the lawful bases identified in the GDPR table in Section 2.

To exercise your rights, contact us at team@pulsepredictions.com. We will respond within one month, extendable by two further months for complex requests, consistent with the GDPR.

16. HOW TO EXERCISE YOUR PRIVACY RIGHTS

Send your request to team@pulsepredictions.com from the email address or phone number associated with your account, and tell us which right you want to exercise. We will verify your identity using information already associated with your account.

You may use an authorized agent to submit a request on your behalf. We will require reasonable evidence of authorization. We may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

We will not retaliate or discriminate against you for exercising your privacy rights.

17. DO WE MAKE UPDATES TO THIS NOTICE?

We may update this privacy notice from time to time. The updated version will be indicated by an updated "Last updated" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes, by directly sending you a notification by SMS or email, or by another reasonable method. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

18. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may contact us at:

Email: team@pulsepredictions.com

By using Pulse, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy.

© 2026 Pulse, Inc. All rights reserved.