Privacy Policy

This Privacy Policy explains how SBI, operating as ZOE Pulse ("we," "us," or "our"), collects, uses, shares, and protects personal data when you use our websites at zoepulse.pro and zoeai.pro and our AI-powered market research platform (collectively, the "Service"). By using the Service, you acknowledge that you have read and understood this Privacy Policy.

1. Identity and Contact Details

The data controller responsible for your personal data is:

SBI, operating as ZOE Pulse
Websites: zoepulse.pro / zoeai.pro
Email: legal@zoepulse.pro

As the data controller, we determine the purposes and means of processing your personal data and are responsible for ensuring that processing is carried out in compliance with applicable data protection laws, including the EU General Data Protection Regulation (GDPR), the UK GDPR, and the California Consumer Privacy Act (CCPA/CPRA).

2. Contact for Privacy Inquiries

For any questions, concerns, or requests related to this Privacy Policy or the processing of your personal data, please contact us at:

Privacy Team
Email: legal@zoepulse.pro

We aim to respond to all privacy inquiries within 30 days. For requests made under GDPR, we will respond within one calendar month of receipt, unless the request is complex, in which case we may extend the response period by up to two additional months with prior notice to you.

3. Purposes of Processing and Legal Basis

We process your personal data for the following purposes, each paired with its lawful basis under Article 6(1) of the GDPR:

PurposeData UsedLegal Basis
Account creation and authenticationName, email address, hashed passwordPerformance of a contract (Art. 6(1)(b))
Providing the AI market research serviceBusiness name, industry, location, research inputsPerformance of a contract (Art. 6(1)(b))
Generating AI-powered research reportsBusiness profile data, research parameters, Google Places public dataPerformance of a contract (Art. 6(1)(b))
Processing payments and managing subscriptionsEmail, subscription tier, payment metadata (card details handled solely by Stripe)Performance of a contract (Art. 6(1)(b))
Sending transactional emails (confirmations, reports, password resets)Name, email addressPerformance of a contract (Art. 6(1)(b))
Sending marketing communications (with consent)Name, email addressConsent (Art. 6(1)(a))
Improving service quality and performanceUsage data, anonymized interaction patterns, error logsLegitimate interest (Art. 6(1)(f)) — improving our platform
Ensuring platform security and preventing fraudIP address, user agent, access logs, authentication eventsLegitimate interest (Art. 6(1)(f)) — security
Complying with legal obligationsAccount data, transaction recordsLegal obligation (Art. 6(1)(c))

Where we rely on legitimate interest as a legal basis, we have conducted a balancing test to ensure that our interests do not override your fundamental rights and freedoms. You may request details of this assessment by contacting us at legal@zoepulse.pro.

4. Categories of Personal Data

4.1 Account Data

When you create an account, we collect your full name, email address, and a password. Your password is cryptographically hashed using industry-standard algorithms before storage; we never store passwords in plaintext.

4.2 Business Profile Data

To deliver market research, we collect your business name, industry classification, geographic location, and any additional business details you choose to provide during onboarding or research configuration. We may also retrieve publicly available data about your business from the Google Places API, including public reviews, ratings, business hours, and address information.

4.3 Usage Data

We automatically collect technical and usage data when you interact with our Service, including:

4.4 Payment Data

We use Stripe as our payment processor. When you subscribe to a paid plan, Stripe collects and processes your payment card details directly. We do not receive, access, or store your full credit card number. We receive only a Stripe customer ID, the last four digits of your card, the card brand, subscription status, and billing-related metadata necessary to manage your account.

4.5 Data We Do Not Collect

We do not knowingly collect special categories of personal data (racial or ethnic origin, political opinions, religious beliefs, genetic or biometric data, health data, sexual orientation) unless you voluntarily include such information in free-text research inputs. We strongly advise against providing sensitive personal data in research parameters.

5. Third-Party Processors

We share personal data with the following third-party service providers who process data on our behalf under appropriate data processing agreements:

ProviderPurposeData SharedPrivacy Policy
Supabase (US)Database hosting and storageAll account and business data stored in our PostgreSQL databasesupabase.com/privacy
Vercel (US)Application hosting and edge deliveryIP address, request headers, access logsvercel.com/legal/privacy-policy
Google (US)Places API — public business data retrieval; Gemini LLM — AI report generationBusiness name, location, industry (for Places API lookups); anonymized research parameters (for LLM processing)policies.google.com/privacy
OpenAI (US)LLM processing for AI-generated research contentAnonymized research parameters and business context (no direct personal identifiers sent)openai.com/policies/privacy-policy
DeepSeek (China)LLM processing for AI-generated research contentAnonymized research parameters and business context (no direct personal identifiers sent)deepseek.com/privacy
Brevo (EU/France)Transactional and marketing email deliveryName, email addressbrevo.com/legal/privacypolicy
Stripe (US)Payment processing and subscription managementEmail, payment card details (handled directly by Stripe), billing metadatastripe.com/privacy

We do not sell, rent, or trade your personal data to any third party. Data shared with the processors listed above is strictly limited to what is necessary for them to perform their designated service on our behalf.

6. International Transfers

Your personal data is stored in the United States on Supabase's PostgreSQL infrastructure. Our application is hosted on Vercel's global edge network, with primary compute resources in the United States.

If you are located in the European Economic Area (EEA), the United Kingdom, or Switzerland, your data is transferred to the United States and potentially to other countries where our third-party processors operate. We ensure that such transfers are protected by appropriate safeguards, including:

Please note that DeepSeek operates from China. When DeepSeek is used for LLM processing, only anonymized research parameters are transmitted; no direct personal identifiers (such as your name or email address) are sent to DeepSeek. This transfer is safeguarded by Standard Contractual Clauses and supplementary technical measures including data minimization and pseudonymization.

You may request a copy of the relevant transfer mechanisms by contacting us at legal@zoepulse.pro.

7. Retention Periods

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected. The specific retention periods are as follows:

Data CategoryRetention PeriodRationale
Account data (name, email, password hash)Duration of account + 30 days after deletion requestContract performance; grace period for account recovery
Business profile dataDuration of account + 30 daysRequired to deliver the Service
Research projects and generated reportsDuration of account + 90 daysExtended grace period so users can export reports before permanent deletion
Payment and billing records7 years after transactionLegal obligation — tax and accounting regulations
Usage and access logs12 monthsSecurity monitoring and service improvement
Marketing consent recordsDuration of consent + 3 years after withdrawalLegal obligation — demonstrating valid consent
Support correspondence3 years after last interactionLegitimate interest — service continuity and dispute resolution

When retention periods expire, data is permanently deleted or irreversibly anonymized. Anonymized data that can no longer identify you may be retained indefinitely for statistical and analytical purposes.

8. Data Subject Rights (GDPR)

If you are located in the EEA, the United Kingdom, or Switzerland, you have the following rights under the GDPR with respect to your personal data:

You also have the right to lodge a complaint with a supervisory authority in the EU/EEA member state of your habitual residence, place of work, or place of the alleged infringement. A list of supervisory authorities is available at edpb.europa.eu.

9. How to Exercise Your Rights

To exercise any of the rights described above, you may:

When you submit a request, we may need to verify your identity before processing it. We will ask you to confirm information associated with your account (such as your email address) or to respond to a verification email. We will not require you to create an account solely to make a privacy request.

We will process your request free of charge unless the request is manifestly unfounded or excessive (for example, due to its repetitive character), in which case we may charge a reasonable fee or refuse to act on the request, providing you with reasons for our decision.

We will respond to your request within one calendar month. If your request is complex or we receive a large number of requests, we may extend this period by up to two additional months. We will inform you of any extension within the first month along with the reasons for the delay.

10. Statutory or Contractual Requirement

The provision of your name, email address, and password is a contractual requirement necessary to create your account and access the Service. Without this data, we cannot provide the Service to you.

The provision of business profile data (business name, industry, location) is a contractual requirement necessary to generate AI-powered market research reports. Without this data, the core functionality of the Service cannot operate.

The provision of payment data (processed by Stripe) is a contractual requirement for paid subscription tiers. You are not obligated to subscribe to a paid plan, but certain features are available only to paying subscribers.

You are not under a statutory obligation to provide any personal data to us. However, failure to provide the data described above will prevent us from fulfilling our contractual obligations to you.

11. Automated Decision-Making and Profiling

ZOE Pulse uses artificial intelligence (AI) and large language models (LLMs) to generate market research reports, competitive analyses, and strategic recommendations. This processing is a core feature of the Service and operates as follows:

Important: AI-generated reports are informational tools, not decisions that produce legal effects or similarly significantly affect you. The reports do not determine your eligibility for services, credit, employment, or any other outcome. They are research aids intended to support your own business decision-making.

We do not engage in automated individual decision-making or profiling that produces legal effects concerning you or similarly significantly affects you within the meaning of Article 22 of the GDPR.

If you have concerns about how AI is used in the Service, you may contact us at legal@zoepulse.pro to request human review of any AI-generated output.

12. Cookie Policy

Our Service uses cookies and similar technologies for the following purposes:

12.1 Strictly Necessary Cookies

These cookies are essential for the Service to function and cannot be disabled. They include session authentication cookies that maintain your logged-in state and CSRF tokens that protect against cross-site request forgery. Legal basis: legitimate interest (security and functionality).

12.2 Functional Cookies

These cookies remember your preferences (such as theme settings or dashboard configurations) to enhance your experience. Legal basis: legitimate interest (user experience).

12.3 Analytics Cookies

We may use analytics tools to understand how visitors interact with our Service. Where analytics cookies are used, they are deployed only with your consent, and you may withdraw consent at any time via your browser settings or our cookie management controls.

12.4 Managing Cookies

You can control and delete cookies through your browser settings. Note that disabling strictly necessary cookies may impair the functionality of the Service. For more information on managing cookies, visit allaboutcookies.org.

13. AI-Specific Disclosures

13.1 AI-Generated Content

Research reports, market analyses, competitive assessments, and strategic recommendations produced by ZOE Pulse are generated using artificial intelligence. While we strive for accuracy and quality through multi-pass auditing and validation processes, AI-generated content may contain inaccuracies, outdated information, or incomplete analyses. AI-generated reports should be used as one input among many in your business decision-making process, not as the sole basis for significant decisions.

13.2 No AI Training on Customer Data

We do not use your personal data, business data, research inputs, or generated reports to train, fine-tune, or improve any artificial intelligence or machine learning models. Your data is used solely to deliver the Service to you. The LLM providers we use (Google Gemini, OpenAI, and DeepSeek) are engaged under API terms of service that prohibit them from using API inputs and outputs to train their models.

13.3 Data Minimization in AI Processing

When sending data to LLM providers for report generation, we apply data minimization principles. Personal identifiers (your name, email address, and account credentials) are stripped before transmission. Only the business context and research parameters necessary for report generation are transmitted. LLM providers receive anonymized prompts and do not have access to your account information.

13.4 Human Oversight

Our AI system includes automated quality checks (dual audit at both the section and cross-section level). You may also request human review of any AI-generated output by contacting us. We continuously monitor and improve the quality of our AI outputs.

14. Your California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA). This section supplements the rest of this Privacy Policy with information specific to California residents.

14.1 Categories of Personal Information Collected

In the preceding 12 months, we have collected the following categories of personal information as defined by the CCPA:

14.2 Sale and Sharing of Personal Information

We do not sell your personal information. We have not sold personal information in the preceding 12 months, and we have no plans to sell personal information in the future.

We do not share your personal information for cross-context behavioral advertising. We do not participate in cross-context behavioral advertising as defined by the CPRA.

14.3 Your CCPA/CPRA Rights

As a California resident, you have the right to:

14.4 Exercising Your California Rights

To exercise your rights under the CCPA/CPRA, you may:

We will verify your identity before processing your request by confirming your email address and account information. You may designate an authorized agent to make a request on your behalf. If you use an authorized agent, we may require proof that you provided the agent with written permission and may require the agent to verify their own identity.

We will respond to verifiable consumer requests within 45 calendar days. If we need additional time, we will inform you of the reason and the extension period (up to an additional 45 days).

14.5 Financial Incentive Programs

We do not offer financial incentive programs tied to the collection, retention, or sale of personal information.

15. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we make changes, we will:

Your continued use of the Service after the updated Privacy Policy takes effect constitutes your acknowledgment of the changes. If you do not agree with the revised policy, you should discontinue use of the Service and delete your account.

16. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

SBI, operating as ZOE Pulse
Email: legal@zoepulse.pro
Website: zoepulse.pro

For EU/EEA residents, you may also contact your local data protection supervisory authority if you are unsatisfied with our response. A list of supervisory authorities is available at edpb.europa.eu.