Privacy policy

1. Controller and processor

In Puls there are two roles in data protection, and they are kept separate.

For the financial data you enter into Puls and for the personal data contained in it, for example names in item descriptions and the names of business partners, you are the controller, that is, the company that uses Puls. Dodana vrijednost d.o.o. is the processor of that data and processes it only on your instructions, as set out in the Data processing agreement.

For user account data and users' contact details, and for billing and issued invoice data, the controller is Dodana vrijednost d.o.o., Ribnjak 56, 10000 Zagreb, Croatia, OIB 28795267248, entered in the court register of the Commercial Court in Zagreb. We process that data for our own purposes of managing the contractual relationship and meeting legal obligations.

To run the service, provide support and keep it secure, authorised persons at Dodana vrijednost see on an internal page, for all workspaces, user account data (for example name, e-mail address, time of the last sign-in and whether two-factor sign-in is on), company memberships and roles, and the company data Puls already holds (for example name, OIB tax number, subscription and its status, connection to the accounting software, event code and number of users). Only named accounts with two-factor sign-in turned on can open that page, and we log every access and export, every company opened, invitation sent, user removed from a company and account or company deleted, keep the log for 12 months and then delete it.

Dodana vrijednost d.o.o. is also the controller for sign-ups from the trade fair page, for enquiries sent through the form on puls-value.com and for consents to receive news. More on these in points 6 and 7.

For any question about data protection, write to info@puls-value.com.

2. What data we collect

• Account data: name, e-mail, company name, OIB and business activity.
• Financial data you upload (income, expenses, plan and actuals by period) to show the analysis and indicators.
• When you connect your books or upload a list of open items: the names of your customers and suppliers with their open invoices and turnover, for debt ageing, reminders to customers, indicators and the bank package. They may include sole traders and other natural persons. In that list we keep only the name, without the partner code and without the OIB, and only the latest reading. We also keep the file you upload.
• Data for billing and invoicing: address, OIB or VAT identification number and data on issued invoices. We do not store payment card data; it is handled by the payment service provider.
• When you write to us through the “Write to us” form on puls-value.com: name, company, e-mail address, topic and message. More in point 6.
• When you sign up on the trade fair page: name, company and e-mail address, and, with a request for a quote for accounting services, also what you need and your telephone number, if you entered it. More in point 6.
• When you give or withdraw consent to receive news: when you did so and with which wording. More in point 7.
• Technical data necessary for the service to work (e.g. sign-in records).
• Data for two-factor sign-in, if you turn it on, and security records about it.

3. Purpose and legal basis of processing

We process data to provide the financial controlling service (performance of a contract, Article 6(1)(b) of the General Data Protection Regulation, GDPR) and to meet legal obligations. We do not use your financial data for profiling and do not sell it to third parties.

We process sign-ups from the trade fair page and enquiries from the form because you sent them yourself and ask us for an invitation, a quote or a reply. The legal basis is your request (steps prior to entering into a contract, Article 6(1)(b) GDPR). We send news only with your consent (Article 6(1)(a) GDPR).

4. Where data is stored

Data is stored and processed on servers within the European Union. The providers we use for this are listed in point 8.

Data is transferred outside the European Economic Area only to the sub-processors listed in point 8 and only under the standard contractual clauses of the European Commission. You can request a copy of the clauses at info@puls-value.com.

5. Artificial intelligence in Puls

For commentary on results, answers to questions, suggestions and drafting a business plan, including reading a document you upload, we use an artificial intelligence service of an external provider. We send it calculated figures and indicators, category names, account numbers and names, company data and what you yourself type or upload, and only when you or another user of your company starts that action. The processing takes place in the United States of America, with the standard contractual clauses of the European Commission as the transfer safeguard. Text written by artificial intelligence is informative and does not constitute tax or legal advice.

We keep the conversation with the artificial intelligence (AI) consultant with your user account and the company you are asking about, so that it remains available to you, and only the person who asked can see it. We keep each message for 12 months from its creation and then delete it. You can delete the conversation yourself with the “Delete conversation” button, and when your access to a company ends, we delete your conversations about that company immediately.

A question you speak to the consultant instead of typing it is converted into text by your browser's speech service, and only when you click the microphone. The audio is not sent to Puls or to any third party other than that browser service, and Puls receives only the text of the question, as if you had typed it.

6. Sign-ups and enquiries from puls-value.com

On the trade fair page puls-value.com/accept2026 you can leave your name, company and e-mail address. We store them in order to send you an invitation to register for Puls (owners and directors), to contact you with a quote for accounting services (companies looking for an accounting office) or to contact you with terms of cooperation (bookkeeping services). We send a confirmation of the sign-up to the address you entered.

With a request for a quote for accounting services we also store what you selected under “What do you need” (“Bookkeeping and payroll”, “Advice and finance” or “Not sure yet”) and your telephone number, if you entered it, so that we can call you. The telephone number is optional.

An enquiry sent through the “Write to us” form on puls-value.com (name, company, e-mail address, topic and message) arrives by e-mail in the info@puls-value.com mailbox and we use it only to reply. It is not entered into the Puls database.

The quote for accounting services, on a request from the trade fair page or on an enquiry with the topic “Accounting with a direct link to Puls”, is given by Dodana vrijednost d.o.o., Ribnjak 56, 10000 Zagreb, OIB 28795267248, as an accounting office. This is the same company that provides Puls, so your request is not passed on to another company.

Sign-ups and enquiries are seen only by authorised persons at Dodana vrijednost. To know whether a sign-up led to a registration, we compare the sign-up by e-mail address with user accounts in Puls. We do not enter the telephone number or the “What do you need” choice into the list of news recipients.

To practices and companies we contact first, with an offer of Puls, we write to the general business e-mail address they have published on their own website. With it we keep the name, the town and data from the public company register (for the United Kingdom, Companies House). The legal basis is our legitimate interest (Article 6(1)(f) GDPR). Every message says where we got the address and carries an unsubscribe link. Whoever unsubscribes or objects receives no further messages from us, and we delete an address without a reply 12 months after the last message.

7. News with consent

We send news only to persons who have expressly asked for it: with the tick box on the trade fair page, with the tick box at registration in Puls or with the “News about Puls” switch in the app's Settings. The tick box is never pre-ticked and is not a condition for signing up or registering. The tick box on the trade fair page covers news from Dodana vrijednost and Puls, and the tick box and the switch in the app cover news about Puls. We send news at most once a month. The legal basis is your consent (Article 6(1)(a) GDPR). We record when you gave or withdrew consent and with which wording.

We send news through an e-mail sending provider, which acts as our processor. It keeps the data in the European Union, and also engages companies outside the European Economic Area, under the standard contractual clauses of the European Commission. The same provider also delivers the other e-mail Puls sends and keeps a record of its sending.

We enter into the list of news recipients only persons who have given consent, and only the following data:

• for a sign-up from the trade fair page: e-mail address, name, company, type of sign-up (owner, accounting office or bookkeeping service), source (the trade fair tag) and date of consent,
• for a user of the app: e-mail address, source (the Puls app) and date of consent.

We enter nothing else into that list, including the telephone number, the “What do you need” choice or data from Puls. An address without consent does not enter the list.

You can withdraw consent at any time: with the unsubscribe link in every news message, with the “News about Puls” switch in the app's Settings or by writing to info@puls-value.com. After that we no longer send you news. Withdrawal does not affect the lawfulness of sending before the withdrawal. Messages necessary for using Puls and the reply to your sign-up (confirmations, account notices) still arrive, because they are not news. Reminders and other Puls messages that are not necessary are not news either. You unsubscribe from them separately, with the unsubscribe link in the message itself.

8. Sub-processors

To provide the service we engage sub-processors, exclusively to the extent necessary for the service to work. They are listed by name in Annex 1 of the Data processing agreement, which also sets out the notice of changes to the list and your right to object.

• Database, user sign-in and file storage provider. European Union.
• Provider of the server on which the application runs. European Union.
• Artificial intelligence service provider. The functions described in point 5. United States of America, with the standard contractual clauses of the European Commission as the transfer safeguard.
• E-mail sending provider. Sending e-mail and keeping the list of news recipients. European Union, with the standard contractual clauses of the European Commission for transfers outside the European Economic Area.
• Billing provider. Billing and subscription management. For payment data it acts as an independent controller, and for subscription data as a sub-processor. European Union, with safeguards for transfers outside the European Economic Area.
• Invoicing provider. Issuing and fiscalising invoices for the subscription and, for users who connect their books, reading their accounting data. European Union.
• Domain name and visit measurement provider for the public pages, without cookies. European Union and a global delivery network, with the standard contractual clauses of the European Commission for transfers outside the European Economic Area.

9. Your rights

You have the right of access, rectification, erasure and portability of your data, as well as the right to object and to restriction of processing. You can send a request to our contact address, and you can also lodge a complaint with the Croatian Personal Data Protection Agency (AZOP). If the request concerns data for which a Puls client is the controller, we forward the request to that client without delay and do not act on it ourselves. You can withdraw consent to receive news as described in point 7.

10. Retention and deletion

We keep data for as long as the contractual relationship lasts. While the user account exists, the data remains stored even when access is locked because the trial period has expired or the subscription has not been paid.

Conversations with the AI consultant do not wait for the service to end. We delete each message of a conversation 12 months after its creation, and you can delete it earlier with the “Delete conversation” button. Deleting a user account also deletes all conversations of that user, and the end of access to a company deletes that user's conversations about that company.

We keep sign-ups from the trade fair page until you tell us to delete them, and at most two years from the trade fair. We keep an address on the list of news recipients until you withdraw consent. When you withdraw it in the app or by message, we remove the address from the list, and the contact remains recorded with the e-mail sending provider, outside the list, until you tell us to delete it. The record of consent of an app user is deleted together with the user account.

After the service ends, at your choice, we return the data to you in a machine-readable format or delete it. You tell us your choice within 30 days of the end of the service, and we delete the data no later than 90 days after the end of the service. Data in backups is deleted in the regular rotation cycle of those backups.

The exception to deletion is data we are required to keep by law, above all issued invoices and fiscal data. We keep it until the statutory period expires, in accordance with tax and accounting regulations, and do not process it for any other purpose.