Privacy Policy
Effective Date: 19 November 2024
Last Updated: 13 August 2026
PUNT LTD ("Punt", "Pulse", "we", "our", or "us") respects your privacy and is committed to protecting your personal data.
This Privacy Policy explains how we collect, use, store and share your personal data when you use our mobile applications and related services, including Pulse and Punt (the “Apps”).
PUNT LTD is the data controller responsible for your personal data.
1. Information We Collect
We collect different types of information depending on how you use our Apps.
1.1 Information You Provide
Account Information
For some of our Apps, this may include your name, email address, username and other information associated with your account.
Pulse uses anonymous accounts. You can use Pulse without providing an email address or password. Pulse creates a unique account identifier so that your activity can be associated with your account.
Profile Information
Information you choose to add to your profile, such as a username, profile image or other optional details.
User Content
Information and content you submit through our Apps.
This may include Takes, opinions, reactions and other interactions or content you choose to submit.
Communications
Information you provide when contacting us, including support requests, feedback and other communications.
1.2 Information Collected Automatically
Usage Data
Information about how you use our Apps, including features used, interactions, sessions, time spent and other app activity.
Device Information
Information such as device type, operating system, app version, IP address and other technical information.
Log and Diagnostic Data
Crash reports, diagnostics, performance information and other technical logs.
1.3 Information from Third Parties
We may receive information from third-party services that support our Apps, such as analytics, authentication, hosting and other technology providers.
2. How We Use Your Data
We use personal data to:
Provide, operate and maintain our Apps and services
Create and manage user accounts
Enable features and functionality within the Apps
Process and display user-generated content
Generate fan consensus within Pulse
Moderate user-generated content
Generate and process headlines and other content within Pulse
Understand how people use our Apps
Analyse usage and improve our products and services
Monitor and improve app performance and reliability
Provide customer support and respond to enquiries
Communicate with you about our services and important updates
Detect, prevent and investigate fraud, abuse and misuse
Comply with legal and regulatory obligations
Protect our rights, users and services
3. Pulse
Pulse allows users to follow sports stories, react to them and share opinions.
Reactions and opinions submitted by users may be combined and analysed to generate a fan consensus around sports stories.
We use artificial intelligence technology provided by OpenAI to assist with:
Generating fan consensus from user opinions
Moderating user-generated content
Generating or processing headlines and other content
Where user-generated content is displayed to other users, information such as your username, opinion or reaction may be displayed depending on the features available within Pulse.
4. Artificial Intelligence
We use artificial intelligence services provided by OpenAI in connection with Pulse.
Information may be processed by OpenAI to provide features including:
Fan consensus generation
Content moderation
Headline generation and processing
We use these services to operate and improve Pulse and its features.
We do not use AI to make decisions that have legal or similarly significant effects on you.
5. Analytics
We use analytics services to understand how users interact with our Apps and to improve their performance and functionality.
Pulse: We use PostHog for analytics and product usage analysis.
Punt: We use Firebase Analytics for analytics and product usage analysis.
These services may collect information such as:
App usage and interactions
Device and technical information
Session information
App version
Performance information
Other information necessary to understand how the Apps are being used
We use this information to understand usage patterns, identify problems, measure product performance and improve our Apps.
6. Legal Basis for Processing
We process personal data under applicable data protection laws, including the UK GDPR and, where applicable, the EU GDPR.
Depending on the circumstances, we rely on the following legal bases:
Contract
Where processing is necessary to provide our Apps and their features to you.
Legitimate Interests
Where processing is necessary for purposes such as improving our Apps, understanding usage, maintaining security, preventing misuse and operating our business, provided those interests are not overridden by your rights.
Consent
Where we rely on your consent, including where required for certain marketing communications or tracking technologies.
Legal Obligation
Where processing is necessary for us to comply with a legal or regulatory obligation.
7. Data Sharing
We do not sell your personal data.
We may share personal data with third parties where necessary to operate our services, including:
7.1 Service Providers
OpenAI — artificial intelligence services used within Pulse
PostHog — analytics and product usage analysis for Pulse
Firebase Analytics — analytics and product usage analysis for Punt
Cloud hosting and infrastructure providers
Authentication and account-management services
Customer support providers
Other technical service providers required to operate the Apps
These providers may process personal data on our behalf and are subject to appropriate contractual and security safeguards where required.
7.2 Legal and Regulatory Authorities
We may disclose personal data where required by law, regulation or legal process, or where necessary to protect our rights, users, property or security.
7.3 Business Transfers
If PUNT LTD is involved in a merger, acquisition, restructuring, investment, sale of assets or similar transaction, personal data may be transferred as part of that transaction, subject to applicable law.
8. International Data Transfers
Some of our service providers may process personal data outside the UK or European Economic Area.
Where personal data is transferred internationally, we take appropriate steps to ensure that the transfer is protected in accordance with applicable data protection law, which may include adequacy regulations or appropriate contractual safeguards such as Standard Contractual Clauses.
9. Data Retention
We retain personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy, including to:
Provide and maintain our Apps
Maintain user accounts and activity
Comply with legal and regulatory obligations
Resolve disputes
Prevent fraud and misuse
Enforce our agreements
When personal data is no longer required, we will delete or anonymise it where reasonably practicable.
You can request deletion of your account and associated personal data at any time, subject to applicable legal requirements.
For Pulse, because accounts are anonymous, account deletion may be associated with the unique account identifier rather than an email address.
10. Your Rights
Depending on your circumstances and applicable law, you may have rights including:
Access to your personal data
Correction of inaccurate personal data
Deletion of your personal data
Restriction of processing
Objection to processing
Data portability
Withdrawal of consent where processing is based on consent
You may exercise your rights by contacting:
For Pulse, because accounts are anonymous, we may need additional information to identify the relevant account before fulfilling certain requests.
You also have the right to lodge a complaint with the relevant data protection supervisory authority. In the UK, this is the Information Commissioner's Office (ICO).
11. Cookies and Tracking Technologies
Our websites may use cookies and similar technologies.
Our Apps may use similar technologies, including software development kits (SDKs), analytics tools and device identifiers, to operate the Apps, understand usage, monitor performance and improve our services.
We use PostHog for analytics and product usage analysis for Pulse and Firebase Analytics for analytics and product usage analysis for Punt.
Where consent is legally required for non-essential tracking technologies, we will request it.
12. Marketing Communications
We may send marketing communications where we have a lawful basis to do so.
Where consent is required, we will obtain your consent before sending marketing communications.
You can opt out at any time by using the unsubscribe option provided in an email or contacting hello@wearepunt.com.
Pulse does not require an email address to use the App.
13. Children's Privacy
Our Apps are not intended for users under 13 years of age, or a higher minimum age where required by applicable local law.
We do not knowingly collect personal data from children in violation of applicable law.
If we become aware that we have collected personal data from a child in circumstances where it should not have been collected, we will take reasonable steps to delete it.
14. Data Security
We implement appropriate technical and organisational measures designed to protect personal data against unauthorised access, loss, misuse, alteration or disclosure.
These measures may include:
Encryption
Access controls
Secure infrastructure
Authentication and authorisation controls
Monitoring and security measures
However, no method of transmitting or storing information is completely secure, and we cannot guarantee absolute security.
15. Third-Party Links and Content
Our Apps may contain links to third-party websites, services or content.
We are not responsible for the privacy practices of third parties. We recommend reviewing the privacy policies of third-party services before providing them with personal information.
16. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes to our Apps, services, technology, legal requirements or data practices.
Where changes are material, we may notify you through the Apps, by email or by other appropriate means.
The latest version will always be available at our privacy policy URL.
17. Contact
PUNT LTD
Data Protection Contact:
hello@wearepunt.com