06. Legal Framework

Last Updated: January 2026

1.1 Data Controller

PulseAnchorHub ("Controller"), registered at 707165, Str. Preot Pahomie nr. 209, Sat Deleni, Romania, Romania, is the data controller responsible for your personal data processing activities under the General Data Protection Regulation (EU) 2016/679 ("GDPR").

1.2 Categories of Personal Data

We process the following categories of personal data:

• Identification Data: Full name, email address, telephone number
• Technical Data: IP address, browser type and version, operating system, device identifiers
• Usage Data: Pages visited, time spent on pages, navigation patterns, referral sources
• Communication Data: Content of inquiries, feedback, and correspondence

1.3 Legal Basis for Processing

Personal data processing is conducted under the following legal bases:

• Consent (Article 6(1)(a)): For marketing communications and non-essential cookies
• Contract Performance (Article 6(1)(b)): For service delivery and project execution
• Legitimate Interest (Article 6(1)(f)): For website analytics, security monitoring, and service improvement

1.4 Data Retention Periods

Personal data is retained for the following durations:

• Contact form submissions: 24 months from last communication
• Service contract data: Duration of contract plus 6 years (statutory retention)
• Analytics data: 26 months (anonymized after 14 months)
• Marketing consent records: Until withdrawal of consent

1.5 Data Recipients

Your personal data may be shared with the following categories of recipients:

• Cloud infrastructure providers (hosting services within EU/EEA)
• Payment processing services (PCI DSS compliant)
• Analytics providers (data processing agreements in place)
• Legal and regulatory authorities (upon lawful request)

1.6 International Data Transfers

All personal data processing occurs within the European Economic Area (EEA). Should international transfers become necessary, we ensure adequate safeguards through Standard Contractual Clauses (SCCs) or adequacy decisions as per Article 46 GDPR.

1.7 Data Subject Rights

Under GDPR, you have the following rights:

• Right of Access (Article 15): Obtain confirmation of processing and copy of your data
• Right to Rectification (Article 16): Correct inaccurate personal data
• Right to Erasure (Article 17): Request deletion of your personal data
• Right to Restriction (Article 18): Limit processing in specific circumstances
• Right to Data Portability (Article 20): Receive data in structured, machine-readable format
• Right to Object (Article 21): Object to processing based on legitimate interests

1.8 Exercising Your Rights

To exercise any of these rights, contact our Data Protection Officer at [email protected]. We will respond to all requests within 30 days. You also have the right to lodge a complaint with the Romanian Data Protection Authority (ANSPDCP).

1.9 Data Security Measures

We implement appropriate technical and organizational measures including:

• Encryption of data in transit (TLS 1.3) and at rest (AES-256)
• Regular security assessments and penetration testing
• Access controls with principle of least privilege
• Employee training on data protection obligations
• Incident response procedures and breach notification protocols

Last Updated: January 2026

3.1 General Refund Conditions

PulseAnchorHub operates a milestone-based payment structure for all services. Refund eligibility is assessed based on project progress and deliverable completion status.

3.2 Pre-Project Cancellation

If cancellation occurs before project commencement:

• Full refund of any advance payments within 14 business days
• No cancellation fees for projects cancelled within 72 hours of signing

3.3 In-Progress Project Refunds

For projects in progress, refunds are calculated as follows:

• Milestone 1 (Discovery): 75% refund if cancelled before Phase 2 begins
• Milestone 2 (Architecture): 50% refund of remaining balance
• Milestone 3 (Execution): 25% refund of remaining balance
• Milestone 4 (Delivery): No refund; full payment due

3.4 Quality Disputes

If deliverables do not meet agreed specifications:

• Written notice must be provided within 14 days of delivery
• We will remediate issues within 30 days at no additional cost
• If remediation is unsuccessful, proportional refund will be issued

3.5 Refund Process

To request a refund:

• Submit written request to [email protected]
• Include contract reference and reason for refund
• Refund review completed within 5 business days
• Approved refunds processed within 14 business days

3.6 Non-Refundable Items

The following are non-refundable:

• Third-party licensing fees already incurred
• Domain registration and hosting fees
• Custom asset creation (photography, illustration, video)