Privacy Statement
Last Updated: September 28, 2026
Leonard DeCarmine, doing business as Pulse Digital Labs and AI Prompt Creators ("Pulse Digital Labs," "us," "we," or "our"), thanks you for visiting the online and mobile resources we publish. We use the words "you" and "your" to mean you, the reader, and other visitors to our online and mobile resources who are, in all cases, 18 years of age or older. Our privacy statement ("this statement," "this privacy statement," and "our statement") informs you about from whom and the types of personal information we collect, how we use it, who we share it with and why, and what we do to try to protect it.
Online and mobile resources mean the websites we own, including pulsedigitallabs.com, hub.pulsedigitallabs.com, and any website operated under the AI Prompt Creators name, together with the internet features, memberships, communities, AI-powered tools, and apps we have created that allow you to interact with us or the content we provide.
California Notice of Collection of Personal Information: To learn more about your California privacy rights, please scroll down to “THE CALIFORNIA CONSUMER PRIVACY ACT.”
WHO WE ARE
Pulse Digital Labs is a sole proprietorship owned by Leonard DeCarmine and operated under the trade names Pulse Digital Labs and AI Prompt Creators. We provide artificial intelligence (AI) education, business education, coaching, consulting, digital marketing, GoHighLevel strategy and implementation, digital products, online communities, software-enabled services, assessments, automation services, training programs, subscriptions, and related products and services. For residents of the GDPR Jurisdictions, as defined below, and residents of U.S. states with applicable privacy laws, we are the data controller responsible for your personal data. For residents of California, to the extent the California Consumer Privacy Act applies to us, we are a "Business."
WHO WE COLLECT PERSONAL INFORMATION FROM
We may collect personal information from the following groups of data subjects: visitors to, and users of, our online and mobile resources; our customers, members, and clients; those who apply to work with us or for us; and third-party vendors and business partners.
Personal information generally means information that can be used to identify you or that can be easily linked to you (for example, your name, address, telephone number, email address, social security number, and date of birth). The privacy laws in some jurisdictions include unique elements in what they consider to be the personal information of the consumers or data subjects they protect. If those laws apply to us, as in the case of the California Consumer Privacy Act ("CCPA") or the European General Data Protection Regulation ("GDPR"), our use of the phrase "personal information" includes the unique elements required by such laws.
All the above categories exclude text messaging originator opt-in data and consent. This information will not be shared with any third parties.
The categories of information we collect from each of these groups, and the ways in which we use it, differ. The same person could fall into more than one group. Most of this statement addresses our processing and sharing of personal information collected from visitors to and users of our online and mobile resources and our customers.
WHAT WE COLLECT
There are two types of information that we obtain from you online and then store and use: (i) non-personal information that is collected automatically from each visitor, such as your device operating system; and (ii) personal information that you voluntarily provide to us or that is collected automatically.
By using our online and mobile resources or purchasing our products or services, you are signifying to us that you agree with this section of our privacy statement and that we may use and disclose your information as described.
Voluntarily Submitted Information
If you participate in certain activities through our online and mobile resources, you may be asked to provide us with information about yourself. The types of personal information we collect in those situations include identifiers (such as your name, email address, physical address, and phone number), professional information (such as the business you are in), commercial information (such as the products and services you purchase), and billing information (such as your billing address). Payment card details you enter at checkout are transmitted directly to our third-party payment processors as described under "Payments" below. We do not sell, rent, or trade voluntarily submitted personal information with third parties.
If you do not want us to collect this type of personal information, please do not provide it. This means you should not participate in the activities on our online and mobile resources that request or require it, and you may want to communicate with us by phone or regular mail instead.
Participation is strictly your choice. Not participating may limit your ability to take full advantage of the online and mobile resources, but it will not affect your ability to access information available to the general public on the online and mobile resources.
Some of the ways you voluntarily give us your personal information and how we use it:
Emails and Online Forms. When you send us an email or fill out an online form, such as to contact us, your email address and any other personal information (for example, home address or phone number) in the content of your message or attached to it are retained by us and used to respond directly to you and to process your request. Depending on the personal information provided, communications from us may be in the form of emails, telephone calls, and/or text messages (text messages are sent only with your consent, as described below). We may also send you information about our products or services we think may be of interest to you.
Registering for an Account or Membership. When you register for an account or membership, you submit personal information to us such as your name and email address, which we then retain. We use that information to create and manage your account, establish a password and profile, and communicate with you.
Registering for Events. When you register for services, webinars, workshops, events, conferences, or programs we host ourselves (rather than those outsourced to a third-party event manager with its own privacy policies), you will be submitting the types of identifiers described above. If the event requires a fee, you will also submit payment information to our payment processor. We use this information to register you for the event and send you communications regarding the event.
Becoming a Client, Member, or Subscriber. We use information provided by our customers to perform our contractual obligations, provide the products and services purchased, manage their accounts, and communicate with them. When we provide done-for-you services, such as building or managing systems in your GoHighLevel account, we access and process information in that account only as needed to perform the services you requested.
Social Media and Community Features. Some of our online and mobile resources offer community features that let users post messages and comments and upload images or other files and materials. If you choose to use these features, the information you post, including your screen name and any other personal information, will be visible to other members or the public and is not covered or protected by this statement.
AI-Powered Features and Content You Submit. Some of our online and mobile resources include AI-powered features, such as prompt tools, chat assistants, content generators, and automation tools. When you use these features, we collect the prompts, questions, text, files, and other content you submit ("Inputs") and the content generated in response ("Outputs"). See "AI-Powered Features" below for how we handle Inputs and Outputs.
Nova AI Co-Pilot Data Addendum: When members use Nova, our AI setup assistant, the following additional data is processed in real time: (a) microphone audio, captured per voice turn and processed for speech transcription, not stored after processing; (b) screen images, captured from the browser window the member chooses to share and sent with each turn so Nova can provide visual guidance, never recorded or stored. This data is transmitted to our AI sub-processors Google LLC (Gemini API, speech transcription and response generation) and ElevenLabs (text-to-speech voice synthesis) solely to fulfill the member's request. Session transcripts are held in temporary memory during the active session and cleared on session end or after 2 minutes of inactivity.
Voice, Image, and Likeness Materials. Some of our services create AI avatars, voice replicas, or other digital content based on your voice, photos, or video. We collect these materials only when you choose to upload them and give your express consent. We use them only to create the content you request, we do not use them to identify you, and we do not sell them. We delete these materials, and any voice or likeness models created from them, when you request deletion or close your account, unless the law requires us to keep them longer.
SMS Consent and Data Collection. We collect your mobile phone number for text messaging only when you voluntarily provide it through our web forms and check the box consenting to receive text messages. We use this information strictly to send you the account notifications, service alerts, or marketing messages you have opted into. Consent to receive text messages is not a condition of any purchase. Message frequency varies. Message and data rates may apply. Reply STOP to opt out or HELP for help at any time. We do not share or sell your SMS opt-in data or consent with any third parties or affiliates for marketing or promotional purposes. For more information, see our SMS Terms.
Automatically Collected Information
When you visit our online and mobile resources, basic information is passively collected through your web browser by tracking technologies such as cookies, pixels, tags, and web beacons. A "cookie" is a small text file downloaded onto your computer or mobile device when you access the online and mobile resources. It allows us to recognize your computer or mobile device and store information about your preferences or past actions.
We allow third-party vendors to use cookies or similar technologies to collect information about your browsing activities over time following your use of the site. For example:
* Google Analytics, a web analytics service provided by Google LLC ("Google"), uses cookies to help us analyze how you use the online and mobile resources. For more information on how Google uses this data, go to www.google.com/policies/privacy/partners/. You can opt out of Google Analytics at tools.google.com/dlpage/gaoptout.
* Meta Pixel, provided by Meta Platforms, Inc. ("Meta"), helps us measure the effectiveness of our advertising and show our ads to people who have visited our online and mobile resources. You can manage your Meta ad preferences in your Facebook or Instagram account settings.
* GoHighLevel (LeadConnector), the platform that hosts our websites, funnels, forms, calendars, chat widget, and memberships, uses cookies and tracking scripts to record page visits, form submissions, and conversions and to connect them to your contact record.
The internet activity information collected through cookies and similar means includes: the domain name and IP address from which you accessed our online and mobile resources; the type of browser and operating system you use; the date, time, and length of your visit; the specific pages visited, graphics viewed, and documents downloaded; the specific links to other sites you accessed from our online and mobile resources; and the specific links from other sites you used to access our online and mobile resources.
If you access our online and mobile resources from a phone or other mobile device, the mobile services provider may transmit to us uniquely identifiable mobile device information, which allows us to collect mobile phone numbers and associate them with the mobile device identification information. Some mobile phone vendors also operate systems that pinpoint the physical location of devices, and we may receive this information if location services are enabled on your device. If you do not want us to collect and use geolocation data, disable location services through your device settings.
We use automatically collected information and mobile device information to compile reports about popular pages on our online and mobile resources and to see how our customers and followers access them. We use that data to administer and improve the online and mobile resources, make your activities more convenient and efficient, and enhance functionality, such as by remembering certain information to save you time.
Data Retention
We use and retain your personal information in accordance with applicable law and as long as necessary to carry out the purposes described in this statement, in accordance with our internal data retention procedures. We retain usage data for internal analysis for a shorter period, except when this data is used to strengthen security or improve the functionality of our online and mobile resources, or when we are legally obligated to retain it longer.
User Beware: External Sites, Apps, Links, and Social Media
We maintain a presence on external social media platforms such as X (formerly Twitter), Facebook, Instagram, YouTube, TikTok, and LinkedIn. We may allow features of our online and mobile resources to connect with, or be viewable from, that external social media presence. Our online and mobile resources may also contain links to other websites or apps controlled by third parties.
We are not responsible for the content on, or the privacy practices of, social media platforms or any third-party sites or apps to which we link. Those apps, sites, and platforms are not controlled by us and have their own privacy policies and terms of use. If you have questions about how they collect and use personal information, read their privacy policies and contact them using the information they provide.
HOW WE USE YOUR INFORMATION
We use the information we collect from and about you for a variety of business purposes, in general to provide the services, improve customer experience and engagement, and develop the services. We are committed to protecting and maintaining the privacy of your information, and we will process your data only in accordance with applicable data protection law and this privacy statement.
We have a lawful basis for processing your data if:
* we need to process your information to provide you with the products or services you have requested or to enter into a contract;
* you have consented to such processing;
* we have a legitimate interest in processing your data, for example, for fraud prevention, direct marketing, network and information systems security, data analytics, enhancing, modifying, or improving our services, identifying usage trends, determining the effectiveness of promotional campaigns, and advertising; and/or
* we are legally obligated to process it.
We may use the information we collect from you for the following customer service and transaction purposes:
* To provide the requested services to you.
* To manage your account or membership.
* To personalize your experience and respond to your individual needs.
* To improve our websites based on the information and feedback we receive from you.
* To diagnose problems with our servers or our services.
* To respond to your customer service requests and support needs.
* To process transactions, such as purchases and subscriptions.
* To use and disclose your payment information only to process payments and prevent fraud.
* To provide AI-powered features and generate the Outputs you request.
* To administer a contest, challenge, promotion, survey, or other site feature.
* To develop new products or services and enhance current products and services.
* To send periodic emails about service updates, your orders, or your subscription.
* To protect the security or integrity of our services and our business, including protecting against and preventing fraud, unauthorized transactions, claims, and other liabilities.
We may use your information for the following commercial purposes:
* To send you marketing and promotional emails and, with your consent, text messages.
* To show you relevant advertising on third-party platforms, as described under "Online Tracking and Advertising" below.
* To target prospective customers with our services (such targeting is only performed with your permission where your consent is required by applicable law).
We may also use information you provide to us for other purposes as disclosed at the time you provide your personal information or otherwise with your consent.
Sales Tax Determination and Processing
We may collect and use certain personal information, such as billing address, IP address, and transaction information, to determine, calculate, and apply sales, use, value-added, or similar taxes where required by law. We may use third-party payment processors and tax calculation providers to assist with this. Tax amounts calculated through third-party services are provided for informational and convenience purposes. We do not warrant or guarantee the accuracy, completeness, or reliability of tax calculations generated by third-party systems, and we disclaim liability for errors, omissions, or discrepancies in those calculations.
WHEN/WITH WHOM DO WE SHARE PERSONAL INFORMATION
We use voluntarily provided personal information to respond to your inquiries and provide you with the services you have requested, among other uses described in this statement. We do not sell or rent your personal information to third-party data vendors or marketing companies. We disclose your information when required by law.
Our Brands
Pulse Digital Labs and AI Prompt Creators are trade names operated by the same owner. Information collected under one brand may be used under the other in the same manner described in this statement, including to send you information about products, services, or initiatives that may be of interest to you. This does not include SMS opt-in data or consent, which is never shared.
Service Providers
We share personal information with vendors that perform services for us, only as needed for them to provide those services.
These include:
* GoHighLevel (LeadConnector), for website hosting, customer relationship management, forms, calendars, email and text message delivery, chat, and memberships;
* Stripe and other payment processors, for payment processing and fraud prevention;
* Google, for analytics, email, and document storage;
* Meta, for advertising measurement and delivery;
* AI providers such as OpenAI, Anthropic, Google, and ElevenLabs, for AI-powered features;
* video, meeting, scheduling, and community platforms, for delivering trainings, calls, and member communities.
Legally Compelled Disclosures
We may disclose your information, including personal information, to government authorities, and to other third parties when compelled to do so by such government authorities, or at our discretion or otherwise as required or permitted by law, including but not limited to responding to court orders and subpoenas.
To Prevent Harm
We may disclose your information, including personal information, when we have reason to believe that someone is causing injury to or interference with our rights or property, other users of the online and mobile resources, or anyone else who could be harmed by such activities.
Business Transfer
If we, or substantially all of our assets, are acquired by one or more third parties as a result of an acquisition, merger, sale, reorganization, consolidation, or liquidation, personal information may be one of the transferred assets.
Vendor and Business Partner Standards
We have adopted standards for vendors and business partners who receive personal information from us. We attempt to bind them to those standards through written contracts or by selecting providers whose published terms meet them. We further attempt to restrict what our vendors and business partners do with the personal information we provide so that it is used only to the extent necessary to carry out the business purpose for which it was provided, is not disclosed to anyone else without our consent or instruction, and remains, as between us and the vendor or business partner, our property.
Please note that we cannot guarantee that all our vendors and business partners will agree to these requirements, nor can we ensure that, even when they do agree, they will always fully comply.
AI-Powered Features
We use AI to deliver our products and services and to run our business. When you use an AI-powered feature on our online and mobile resources, your Inputs are sent to third-party AI providers, such as OpenAI, Anthropic, Google, or ElevenLabs, to generate Outputs. These providers process Inputs under their own terms and privacy policies. Where the provider offers the option, we use settings under which your Inputs are not used to train the provider's AI models. We do not use your Inputs to train AI models.
We may store Inputs and Outputs to provide the feature, maintain your history, troubleshoot problems, prevent abuse, and improve our services.
Do not submit sensitive personal information, such as social security numbers, financial account numbers, passwords, or health information, into AI-powered features. AI-generated Outputs are provided for informational purposes, may be incomplete, outdated, or incorrect, and are not a substitute for professional legal, financial, tax, or medical advice.
Online Tracking and Advertising
We, service providers operating on our behalf, and third parties may collect information about your activity on our online and mobile resources and on third-party sites and apps using cookies, pixels, tags, software development kits, and web beacons. We may collect this information whether or not you are logged in and may associate it with your account or contact record.
We use this tracking data to:
* provide features that simplify your experience when you return;
* deliver relevant content and advertising based on your preferences and usage;
* measure, evaluate, and optimize our online and mobile resources and our advertising; and
* analyze traffic on our sites.
We may provide social media and advertising platforms with limited personal information, such as your hashed email address or other identifiers, which they match with their users' profiles. Based on this, the platform may show you our ads, find other users who may be interested in our ads, stop showing you our ads, and give us insights to improve our advertising.
Cookies. You can set your browser to warn you each time a cookie is placed or to block all cookies. Each browser is different, so check your browser's Help menu. If you turn cookies off, some features will not function properly.
Opting out. Some states give residents, or their authorized agents, the right to opt out of the "sale" or "sharing" of personal information or of "targeted advertising." To opt out, email [email protected] with the subject line "Do Not Sell or Share My Personal Information" and include your first name, last name, email address, and state. Browser-based opt-outs apply to the device and browser you are using, so if you clear your cookies or use another browser or device, you may need to opt out again. You may also opt out of targeted advertising directly with many ad networks and through the settings on your devices and social media accounts.
Global Privacy Control and Do Not Track. We treat a Global Privacy Control ("GPC") signal sent by your browser as a valid request to opt out of the sale or sharing of your personal information for that browser. We do not respond to other browser "do not track" signals.
THE CALIFORNIA CONSUMER PRIVACY ACT
When we collect personal information from California residents, we become subject to, and those residents have rights under, the California Consumer Privacy Act or “CCPA”. This section of our statement is used to allow us to fulfill our CCPA obligations and explain your CCPA rights. For purposes of this section, the words “you” and “your” mean only such California residents.
What did we collect from California Residents?
In the past 12 months, we collected the following categories of personal information: identifiers such as name, address, email address, phone number, IP address, and similar identifiers; personal information described in subdivision (e) of Section 1798.80 (California customer records statute) such as name, address, telephone number, and billing information; commercial information such as products or services purchased; internet or electronic activity such as browsing history and interactions with our websites and ads; geolocation data; audio, video, electronic, or similar information such as call recordings, and voice or image materials you upload; and professional information such as the business you are in.
We collect this information from you directly, from your devices, and from our service providers. We use it for the business and commercial purposes described in this statement, and we disclose it to the categories of service providers described above.
We do not sell personal information for money, and in the past 12 months we have not done so. Our use of advertising pixels and hashed-email matching with advertising platforms may be considered "sharing" for cross-context behavioral advertising under the CCPA. You have the right to opt out of this sharing as described under "Online Tracking and Advertising." We do not knowingly sell or share the personal information of anyone under 16. We do not use or disclose sensitive personal information for purposes other than those permitted by the CCPA.
Rights of California Residents
If you are a California resident, you have the right to request:
Access (Right to Know): the categories and specific pieces of personal information we have collected about you; the sources of that information; the business or commercial purpose for collecting, selling, or sharing it; and the categories of third parties to whom we disclosed it.
Deletion: that we delete personal information we collected from you. We may be unable to fully comply, such as if we need the information to complete a transaction, detect and protect against fraudulent or illegal activity, exercise our rights, or comply with a legal obligation.
Correction: that we correct inaccurate personal information about you.
Opt Out of Sale or Sharing: that we stop selling or sharing your personal information.
Limit Use of Sensitive Personal Information: that we limit our use of sensitive personal information to permitted purposes.
More information is available here. We will not discriminate against you for exercising these rights by treating you differently from other California residents who use our sites and resources or purchase our services but did not exercise their rights.
To exercise your rights under California law, contact us at [email protected]. We may ask you to fill out a request form. The CCPA only allows us to act on your request if we are able to verify your identity or your authority to make the request, so you will also need to follow our instructions for identity verification. If you make a verifiable request, we will confirm receipt and respond within the time frames prescribed by the CCPA.
RESIDENTS OF VIRGINIA AND OTHER U.S. STATES
If you are a resident of Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, or another U.S. state with a consumer privacy law that applies to us, you may have the right to: access your personal information; correct inaccuracies; delete your personal information; obtain a portable copy of your personal information; and opt out of the sale of your personal information, targeted advertising, and profiling that produces legal or similarly significant effects. Because our use of advertising pixels may be considered "targeted advertising" under these laws, you may opt out of it as described under "Online Tracking and Advertising."
If we deny your request, you have the right to appeal our decision. To exercise any of these rights or submit an appeal, contact us at [email protected]. We may ask you to fill out a request form, and we can act on your request only after we verify your identity or your authority to make the request. If you make a verifiable request, we will confirm receipt and respond within the time frames prescribed by your state's law. If we deny your appeal, you may contact your state Attorney General.
EMAIL COMMUNICATIONS, NEWSLETTERS, AND MARKETING
We may use your personal information to contact you with newsletters, marketing or promotional materials, and other information that may be of interest to you. You may opt out of receiving any or all of these communications by following the unsubscribe link or instructions in any email we send or by contacting us.
TEXT MESSAGES
If you opt in to receive text messages from us, you may opt out at any time by replying STOP to any message. Reply HELP for help. Message frequency varies, and message and data rates may apply. We do not share or sell your mobile phone number, SMS opt-in data, or consent with third parties or affiliates for their marketing or promotional purposes. See our SMS Terms for more information.
PAYMENTS
We offer paid products and services through our online and mobile resources and use third-party payment processors, such as Stripe, to process payments. We do not store your full payment card number. That information is provided directly to our payment processors, whose use of your personal information is governed by their privacy policies. We may receive and retain limited payment details, such as the card type, last four digits, and expiration date, to manage your account and subscriptions. These payment processors follow the standards set by PCI-DSS as managed by the PCI Security Standards Council, a joint effort of brands like Visa, Mastercard, American Express, and Discover. PCI-DSS requirements help ensure the secure handling of payment information.
Your Rights and Options
You may have to provide personal information to use most of the features of our online and mobile resources. You can opt out of certain activities like newsletters and announcements. Residents of California, other U.S. states with privacy laws, and data subjects whose personal information was obtained while they were in a GDPR Jurisdiction have additional rights described in this statement.
When you access your account, you have the option to change certain information about yourself, such as your billing address and telephone number.
Emails. If you consented to receive direct marketing from us, you may opt out of our marketing communications or change your preferences by following the link in the footer of any non-transactional email from us or by emailing us at [email protected]. Some communications from us are transactional or service communications (for example, account notifications and billing information). To ensure you have accurate information about your account and purchases, you do not have the option to unsubscribe from these messages.
GDPR Jurisdictions means the member countries of the European Union (Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, the Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, and Sweden) and the other countries of the European Economic Area (Iceland, Liechtenstein, and Norway).
Andorra, Argentina, Canada (commercial organizations only), the Faroe Islands, Guernsey, Israel, the Isle of Man, Japan, Jersey, New Zealand, Switzerland, and Uruguay have received "adequacy decisions" from the European Commission. Switzerland also has its own data protection law, the Federal Act on Data Protection.
The United Kingdom. Since the United Kingdom ("UK") left the European Union, it is governed by the United Kingdom General Data Protection Regulation ("UK GDPR"). We extend the rights described for GDPR Jurisdictions to data subjects in the UK.
If we use personal information you provided to send you materials, such as newsletters or product alerts by text or email, and you decide you do not want to receive them, you may opt out by following the opt-out instructions in the email or other communication (for example, by replying to a text with "STOP") or by contacting us using the information below. When we receive your request, we will take reasonable steps to remove your name from our distribution lists. It may take time to process your request, and you may still receive materials for a short period after you opt out. In addition to opting out, you have the ability to access, amend, and delete your personal information by contacting us.
CHILDREN'S PRIVACY
Federal law imposes special restrictions and obligations on commercial website operators who direct their operations toward, and collect and use information from, children under the age of 13. We take those requirements seriously, and consistent with them, our online and mobile resources are not intended for use by anyone under the age of 18. If we become aware that anyone under the age of 18 has submitted personal information to our online and mobile resources, we will delete that information and will not use it for any purpose. If you believe that someone under the age of 18 has submitted personal information to our online and mobile resources, please contact us at [email protected]. We encourage parents and legal guardians to talk with their children about the risks of providing personal information over the internet.
HOW WE PROTECT COLLECTED PERSONAL INFORMATION
We take reasonable security precautions to protect your personal information provided to our online and mobile resources. We have adopted a security program that includes technical, organizational, administrative, and other security measures designed to protect, in a manner consistent with accepted industry standards and applicable law, against anticipated or actual threats to the security of personal information (the "Security Program"). We cannot guarantee that your information, whether during transmission, while stored on our systems, or otherwise in our care, will be free from unauthorized access or that loss, misuse, destruction, or alteration will not occur. Except for our duty to maintain the Security Program under applicable law, we disclaim any other liability for any such theft or loss of, unauthorized access or damage to, or interception of any data or communications, including personal information. We believe our Security Program is reasonable and appropriate for our business and the nature of foreseeable risks to the personal information we collect, and we periodically review and update it, including as required by applicable law.
As part of our Security Program, we have incident response and management procedures that are activated whenever we become aware that your personal information was likely compromised. As part of our vendor and business partner oversight, we require that such parties notify us immediately if they have reason to believe that an incident has occurred affecting personal information we provided to them.
THE EU GENERAL DATA PROTECTION REGULATION
We collect or otherwise obtain personal information from data subjects located in the GDPR Jurisdictions. We fulfill our GDPR obligations with respect to our customers (and their own end clients) and our vendors and business partners through separate notices, contracts, or other terms provided to them at the time, and in the manner and form, that the GDPR and local law within each GDPR Jurisdiction require.
This section describes how we comply with the GDPR for personal information collected from visitors to and users of our online and mobile resources while they were in a GDPR Jurisdiction. For purposes of this section, the words "you" and "your" mean only such GDPR Jurisdiction-based visitors and users.
What Do We Collect From You in the GDPR Jurisdictions and How Do We Use It?
We collect from you the categories of personal information already described. The lawful bases on which we rely for such collection, use, and disclosure are: performance of a contract with you; your consent (for example, for marketing emails, text messages, and non-essential cookies, which you may withdraw at any time); our legitimate interests, as described in "How We Use Your Information"; and compliance with our legal obligations. We do not sell your personal information to third parties, and we do not use it for automated decision-making that produces legal or similarly significant effects on you.
Cross-Border Data Transfers and Third-Party Processors
We are based in the United States, and your information will be processed in the United States. If we transfer personal information from the GDPR Jurisdictions to a location that has not been deemed by the European Commission to have adequate privacy protections, we do so in the manner the GDPR permits, such as through standard contractual clauses included in our providers' terms.
Rights of Data Subjects in the GDPR Jurisdictions
While we attempt to allow all visitors and users of our online and mobile resources to exercise a degree of control over their personal information, under the GDPR we have a legal obligation to do so for you. With respect to personal information collected from you while you were in a GDPR Jurisdiction, you have these rights: transparency, access, correction, deletion, portability, restriction of processing, objection to processing, and withdrawal of consent (for more information, click here).
To exercise any of these rights, contact [email protected]. Your ability to exercise these rights is subject to conditions and exemptions described in Articles 12 through 23 of the GDPR. Among those conditions is our right to decline part or all of a request if we cannot resolve reasonable doubts about your identity, which helps minimize the risk that unauthorized persons use a GDPR right to access your personal information. We will respond to all requests without undue delay and within the time frames prescribed by the GDPR. If you are not satisfied with how we use your personal information or respond to your requests, you have the right to complain to your data protection regulator. Contact information for EU data protection regulators is available here.
Agent Authorization
You may authorize someone to make a privacy rights request on your behalf (an authorized agent). Authorized agents must demonstrate that you authorized them to act on your behalf or that they hold power of attorney under applicable law. We retain the right to request confirmation directly from you that the agent is authorized to make the request, or to request additional information to confirm the agent's identity. An authorized agent is prohibited from using a consumer's personal information, or any information collected from or about the consumer, for any purpose other than to fulfill the consumer's requests, for verification, or for fraud prevention.
Rights of Data Subjects in Other Jurisdictions
In other jurisdictions with similar data privacy regulations, we may collect from you the categories of personal information already described. We collect and manage (including disclose) such data in compliance with applicable local law. We do not sell your personal information to third parties, and we do not use it for automated decision-making that produces legal or similarly significant effects on you.
Changes to This Privacy Statement
This privacy statement is effective as of September 28, 2026, and replaces all prior versions. The English-language version of this privacy statement is the controlling version regardless of any translation.
We reserve the right to change or update this statement from time to time. When we do, we will update the "Last Updated" date at the top of this page. Please check our online and mobile resources periodically for changes, since all information collected is subject to the statement in place at that time.
Contacting Us
If you have questions about our privacy statement or privacy practices, please contact us at:
Attention: Privacy
Leonard DeCarmine, dba Pulse Digital Labs and AI Prompt Creators
29617 N Blackfoot Daisy Dr
San Tan Valley, AZ 85143
Email: [email protected]