Privacy notice
Controller: Link Pulse Ltd, Agiou Artemiou 6, 7102 Aradippou, Cyprus. Privacy contact: contact@pharmspan.com. Effective date: [REQUIRED]. This notice describes data processing by the operator of a directory and paid communication-access platform.
Data we collect
Account email address, account ID, role, language, sign-in request and security events; supplier corporate identity/registry details and submitted verification references; approved catalog selections; payment status, amount, transaction identifiers, chargebacks and receipts where applicable (not full payment card details); chat entitlement start/end times, participating account identities, room identifiers, device/server metadata and encrypted message events hosted through Matrix; numerical communication-only feedback, event provenance, rule reports and support messages; necessary session/local-storage information and connection/security logs. A participant may voluntarily submit decrypted selected chat excerpts in a report; these are no longer confidential to support.
Why we process it and legal basis
Contract performance (GDPR Art 6(1)(b)): email-code login, account functions, paid access, messaging entitlement, supplier directory, receipts and user-requested communication. Legal obligations (Art 6(1)(c)): applicable tax/accounting records, consumer obligations and valid regulatory requests. Legitimate interests (Art 6(1)(f)) subject to balancing: preventing impersonation, abuse and ranking fraud; maintaining platform security; investigating reports and enforcing disclosed rules. Consent (Art 6(1)(a)) only for processing actually relying on consent, such as optional analytics/marketing if ever enabled; consent may be withdrawn. Do not treat agreement to the Terms as GDPR consent for all processing.
Encrypted chat and metadata
Where correctly deployed and active, Matrix E2EE encrypts message contents on participating devices. The homeserver can still process encrypted events, sender/recipient or room identity, timestamps and operational metadata. The operator can infer that two accounts communicated, but should not be able to recover the message plaintext without a participant's keys or a voluntary report. A receiving participant can copy/share messages. The current development client has no key backup or recovery; moving devices or clearing browser storage may make old messages unreadable.
Recipients, processors and international transfers
Technical recipients may include [REQUIRED: ACTUAL HOSTING PROVIDER AND COUNTRY], [REQUIRED: SMTP/EMAIL PROCESSOR AND COUNTRY], [REQUIRED: APPROVED PAYMENT PROCESSOR AND COUNTRY], and [REQUIRED: BACKUP/SUPPORT PROCESSORS]. Account identification and selected contact details become accessible to counterparties necessary for the communication. Some suppliers may be based outside the EEA, including China or Hong Kong. Assess and disclose applicable international personal-data transfers, safeguards (such as SCCs and transfer assessment where required), or an applicable alternative basis; E2EE does not eliminate all metadata transfer obligations. Keep an actual processor register and subprocessor contracts.
Retention
Account and profile data: [REQUIRED: PERIOD / CRITERIA]. OTP records: [REQUIRED]. Payment/tax records: [REQUIRED: PERIOD SUBJECT TO CYPRUS TAX LAW]. Verification documents: [REQUIRED: MINIMIZED RETENTION]. Encrypted message events and backup: [REQUIRED: RETENTION/DELETION POLICY]. Security/report logs: [REQUIRED]. After account deletion, retain only data required by law or necessary to defend legal claims, with a published explanation. Technical copies/backups expire according to [REQUIRED: ACTUAL SCHEDULE].
Rights and contact
Where applicable, users may request access, rectification, erasure, restriction, portability, object to legitimate-interest processing, and withdraw consent. Request via contact@pharmspan.com. There may be identity-verification requirements and lawful exemptions. Complaints may be lodged with Cyprus Commissioner for Personal Data Protection or a competent supervisory authority. Information on any automated decision-making with legal or similarly significant effect: [REQUIRED: CONFIRM REAL PROCESSING; RANKING OF ORGANIZATIONS IS NOT AUTOMATICALLY PERSONAL PROFILING].
Security and updates
We use organizational and technical safeguards described at Security, but cannot promise absolute confidentiality of endpoints or metadata. We may update this notice after notifying users as legally required. For the actual processing inventory use the controller's approved records, not assumptions in this draft.