PRIVACY POLICY

Last updated: 24 October 2026

1. Who is responsible

RM Digital LLC
99 Wall Street #244
New York, NY 10005
United States
Phone: +1 (917) 695-8983
Email: info@rm-digital-services.de

For all questions about Echo Pulse Community and data protection, please write to info@echopulsecommunity.de.

Authorized managers: Riccardo Campisi, Melina Witzigmann

Representative in the EU (Art. 27 GDPR)

We value your privacy and your rights as a data subject and have therefore appointed Prighter Group with its local partners as our privacy representative and your point of contact for the following regions:

  • European Union (EU)

Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal data). If you want to contact us via our representative, Prighter or make use of your data subject rights, please visit the following website: https://app.prighter.com/portal/14311689134.

2. What this policy covers

This policy explains how we process personal data when you use our website echopulsecommunity.de and its member area, the Echo Pulse app for iOS and Android („the app“), and our live sessions and community calls. Personal data is any information relating to an identified or identifiable person.

3. In short

  • We process data to run the community, the app and your membership.
  • We do not sell your data. The app shows no ads and uses no advertising IDs or tracking.
  • On our website we use the Meta Pixel to measure our advertising – only if you agree in the cookie banner.
  • What you post in the community chat is visible to all members.
  • You can delete your app account in the app at any time.

4. Website

Hosting. Our website is hosted by IONOS SE, Elgendorfer Str. 57, 56410 Montabaur, Germany. The servers are located in Germany. IONOS processes the data generated when you visit the website. Legal basis: our legitimate interest in providing the website securely and reliably (Art. 6(1)(f) GDPR).

Server log files. When you visit our website, your browser automatically transmits the page visited and the time of access, the amount of data transferred and whether the request succeeded, browser type and version, operating system, referrer URL and IP address. We use this data to deliver the website, for security and to analyse errors (Art. 6(1)(f) GDPR). Log files are deleted as soon as they are no longer needed for these purposes.

Fonts. We load the font „Inter“ from our own server. No connection to third-party servers is made.

Meta Pixel (only with your consent). On our website we use the Meta Pixel of Meta Platforms Ireland Ltd., Merrion Road, Dublin 4, D04 X2K5, Ireland („Meta“). It helps us measure how well our ads on Facebook and Instagram work and show our ads to people who may be interested. The pixel is only loaded after you click „Accept“ in the cookie banner. It then stores identifiers on your device and transmits to Meta your IP address, browser and device information, the pages you visit and events such as page views. If you are logged in to Facebook or Instagram, Meta can link this information to your account. Meta may also process the data in the USA (Meta Platforms, Inc.); Meta is certified under the EU–US Data Privacy Framework. For the collection and transmission of the data, Meta and we are joint controllers (Art. 26 GDPR) under Meta’s Controller Addendum (facebook.com/legal/controller_addendum); any further processing is Meta’s responsibility (facebook.com/privacy/policy). Legal basis: your consent (Art. 6(1)(a) GDPR, Section 25(1) TDDDG). You can withdraw it at any time with effect for the future via „Cookie settings“ at the bottom of every page.

Cookie banner. We store your choice in the cookie banner in your browser’s local storage for 12 months, so that we do not ask you again on every visit. This is strictly necessary (Section 25(2) no. 2 TDDDG; Art. 6(1)(c) and (f) GDPR).

Contact and cancellation form. If you contact us via a form or by email, we process the data you provide – in particular your name, email address and message – to handle your request. Legal basis: Art. 6(1)(b) GDPR for contract-related requests, otherwise Art. 6(1)(f) GDPR. For the cancellation form, we also process the type and date of the cancellation to carry it out and confirm receipt. We delete this data once it is no longer needed – for cancellations, after they have been processed – unless statutory retention obligations apply.

5. Membership and payment via Whop

Memberships bought on our website are sold by Whop Inc., 41 E 11th St, New York, NY 10003, United States. Whop handles order and payment under its own responsibility and is a separate controller for this. Whop’s privacy policy applies: https://whop.com/privacy

As the provider of Echo Pulse Community, we receive from Whop the data needed to manage your membership – in particular your name, email address and membership status. For each payment, Whop also sends us the date and amount, so that we can see when your membership was last paid and when the next payment is due. We process it to perform our contract with you (Art. 6(1)(b) GDPR). Whop is based in the USA; see Whop’s privacy policy for the safeguards under Art. 44 et seq. GDPR.

6. Live sessions and community calls (Zoom)

We hold live sessions and community calls via Zoom, provided by Zoom Video Communications, Inc., 55 Almaden Boulevard, San Jose, CA 95113, United States. Depending on your settings, Zoom processes your name or display name, email address, video and audio, chat messages and technical metadata such as IP address and connection data.

Recordings: Live sessions and calls are recorded and then made available to members. We announce the recording at the start of each call. Taking part with your own camera and microphone is voluntary – you can keep both switched off and still take part.

Legal basis for holding the calls: Art. 6(1)(b) GDPR. Legal basis for recording your video and audio: your consent (Art. 6(1)(a) GDPR), which you give by actively taking part with camera or microphone switched on. You can withdraw it at any time with effect for the future by writing to info@echopulsecommunity.de. More information: https://explore.zoom.us/en/privacy/

7. The Echo Pulse app

7.1 Servers and database. The app runs on Supabase (Supabase, Inc., USA). Your app data – account, profile, posts, media and settings – is stored on Supabase servers in Ireland (EU). Supabase processes the data on our behalf under a data processing agreement. Legal basis: Art. 6(1)(b) GDPR.

7.2 Login and registration. You sign in with your email address and a one-time six-digit code that we send to you by email. When you register in the app, we also process your first name, last name, the app language you chose and, if you enter one, an invitation code. Codes and emails are sent via our mail server at IONOS. After registration we send you a welcome email and add your name, email address and registration date to our internal member list; for this we use the automation service Make (Celonis) and Google Sheets (Google). Unfinished registrations are deleted after two days. The app keeps you signed in by storing your login securely on your device. Legal basis: Art. 6(1)(b) GDPR.

7.3 Profile and membership. Your profile consists of your first name, last name and profile picture. Other members see your first name, the first letter of your last name and your profile picture. We also process your membership status (free, Premium or admin), when you last used the app and your notification settings. Admins with the relevant permission can see the member list including status and last activity. Legal basis: Art. 6(1)(b) GDPR.

7.4 Community chat and news. When you post in the community chat, we process what you send – text, photos, videos, voice messages and video messages – together with the time and your profile name and picture. Reactions (hearts) are stored as well. Your posts are visible to all members of the app. Before uploading, the app removes location data from photos and videos. You can edit your text messages and delete your posts at any time.

To keep the community safe, you can report and block members. We store reports, blocks and moderation decisions. Admins with moderation rights are notified when a member blocks someone and can see who blocked whom, so that they can identify abusive behaviour. A filter blocks certain words and links, and the number of messages per minute is limited. If a member is suspended from the chat, we keep a note of their email address so that the suspension still applies if they delete and re-create their account.

Legal basis: Art. 6(1)(b) GDPR for providing the community; Art. 6(1)(f) and (c) GDPR for moderation and our obligations under the EU Digital Services Act. Our legitimate interest is a safe community free of illegal and abusive content.

7.5 Automatic translation. The app translates chat messages, news and notifications into each member’s app language. For this, the text is sent to DeepL SE, Maarweg 165, 50825 Cologne, Germany. DeepL processes the text on our behalf and does not use it to train its models. Legal basis: Art. 6(1)(b) GDPR.

7.6 Push notifications. We only send push notifications if you allow them on your device. We then process a push token for your device, your app language, your notification settings (news, trade ideas, chat) and a log of the notifications sent (recipient, title, delivery status). Notifications are delivered via Expo (650 Industries, Inc., USA) and the push services of Apple (Apple Push Notification service) and Google (Firebase Cloud Messaging). You can switch each type of notification on or off in your profile in the app, or all of them in your device settings. On iPhone, the app can also show live sessions and community calls as a Live Activity on the lock screen; for this we process an additional push token from Apple that is only used to update this display. Legal basis: your consent (Art. 6(1)(a) GDPR, Section 25(1) TDDDG). The notification log is deleted after 30 days; tokens of devices on which the app has been removed are deleted automatically.

7.7 Videos. Videos in the app and in the website member area are streamed from Bunny.net (BunnyWay d.o.o., Slovenia). When you play a video, your IP address, device information and playback data are processed. Legal basis: Art. 6(1)(b) GDPR.

7.8 Device permissions. The app only asks for a permission when you use the function that needs it: camera (photos, videos, video messages), microphone (voice and video messages), photos (sending pictures and videos, saving result images), calendar (adding a live session to your calendar) and notifications. Only the content you choose to send is uploaded. Calendar entries are created on your device; we do not receive any calendar data. You can withdraw these permissions at any time in your device settings.

7.9 Premium subscription (in-app purchase). You can buy Premium as a subscription in the app. The purchase is made via Apple’s App Store or Google Play. Apple or Google is the seller and processes your payment data under its own privacy policy; we never receive your payment card details.

To manage subscriptions we use RevenueCat (RevenueCat, Inc., USA). RevenueCat receives the internal user ID of your account (not your name or email address), the purchase receipt from Apple or Google and transaction data such as product, price, currency, country, purchase date and expiry date. From this we learn whether your subscription is active, via which store, until when, and whether it renews. We store this with your membership and log each subscription event. Legal basis: Art. 6(1)(b) GDPR. Subscription events are kept for three years.

Deleting the app or your account does not cancel your subscription. You cancel it in your Apple or Google account settings.

7.10 Invitation programme. Every member with a name in the app has a personal invitation code. If you enter a code when you register, we store who invited whom; the member who invited you sees your first name, the first letter of your last name and the status of the reward. If you request a payout of rewards, you give us the amount, your MT5 account ID and the email address of your account at Tauro Markets, and we may exchange messages with you in a support chat. We pass these details to Tauro Markets via WhatsApp (in a chat with Tauro Markets staff) so that the reward can be credited to your trading account. Legal basis: Art. 6(1)(b) GDPR. Payout records are kept for as long as statutory retention obligations require.

7.11 App updates and technical data. The app receives updates via Expo (EAS Update). For this, your IP address, device type, operating system and app version are transmitted. We also collect technical data (e.g. app start time and errors) via Expo to find and fix problems. This data is not used to build user profiles. Legal basis: Art. 6(1)(f) GDPR; our legitimate interest is a stable and secure app.

7.12 Data stored on your device. The app stores on your device only what it needs to work: your login (in secure storage), language, settings, which videos you have watched and temporary copies of content for faster loading. This is strictly necessary to provide the app you requested (Section 25(2) no. 2 TDDDG). The app does not use advertising identifiers or tracking cookies.

7.13 Sharing. If you share a result image via WhatsApp, Instagram or another app, the image is passed to that app at your request. That app’s privacy policy applies.

7.14 Support. If you write to info@echopulsecommunity.de, we process your email address and message to handle your request. Legal basis: Art. 6(1)(b) or (f) GDPR.

8. Deleting your account

You can delete your app account at any time – in the app under Profile → Delete app account, at echopulsecommunity.de/delete-account or by email to info@echopulsecommunity.de.

When you delete your account, we permanently delete your profile, profile picture, chat posts including photos, videos and voice messages, notification settings, push tokens and login. We keep only:

  • your membership record (email address and access status) while you have an active membership or subscription, or until you ask us to delete it as well;
  • a chat suspension, if there is one, linked to your email address, so that it cannot be bypassed (Art. 6(1)(f) GDPR);
  • reports about your content in the moderation log for 12 months (Art. 6(1)(c) and (f) GDPR);
  • data we must keep by law, such as payout records.

9. Recipients and transfers outside the EU

We only share your data where this is needed to provide our services, where you have consented or where we are legally required to. We use these service providers:

  • IONOS SE (Germany) – website hosting, sending emails
  • Supabase, Inc. (USA; data stored in Ireland) – app servers, database, file storage, login
  • 650 Industries, Inc. / Expo (USA) – push notifications, app updates, technical data
  • Apple (USA / Ireland) – App Store, in-app purchases, push notifications
  • Google (USA / Ireland) – Google Play, in-app purchases, push notifications, Google Sheets
  • RevenueCat, Inc. (USA) – subscription management
  • DeepL SE (Germany) – translation
  • BunnyWay d.o.o. / Bunny.net (Slovenia) – video streaming
  • Make (Celonis) – welcome email, member list
  • Zoom Video Communications, Inc. (USA) – live sessions and calls
  • Whop Inc. (USA) – sale of memberships on the website
  • Meta Platforms Ireland Ltd. (Ireland / USA) – Meta Pixel on the website, only with your consent
  • Tauro Markets – crediting referral rewards
  • WhatsApp Ireland Ltd. – passing on payout details to Tauro Markets

Apple and Google (for purchases), Whop, Tauro Markets and WhatsApp act as separate controllers. For the Meta Pixel, Meta and we are joint controllers (see section 4). All others process data on our behalf.

RM Digital LLC itself is based in the USA, and several of our providers are too. Where personal data is transferred to the USA, this is based on the EU–US Data Privacy Framework if the recipient is certified, and otherwise on the EU Standard Contractual Clauses (Art. 46(2)(c) GDPR).

10. How long we keep data

  • App account, profile, settings: until you delete your account
  • Chat and news posts: until you or a moderator delete them, or with your account
  • Uploaded media not attached to a post: 24 hours
  • Unfinished registrations: 2 days
  • Push notification log: 30 days
  • Moderation log: 12 months
  • Subscription events: 3 years
  • Payout records: until the statutory retention period ends
  • Website log files: as soon as they are no longer needed

All other data is kept only as long as needed for its purpose, unless statutory retention obligations apply.

11. Your rights

You have the right to:

  • access the data we process about you (Art. 15 GDPR)
  • have incorrect data corrected (Art. 16 GDPR)
  • have your data deleted (Art. 17 GDPR)
  • restrict processing (Art. 18 GDPR)
  • data portability (Art. 20 GDPR)
  • object to processing based on legitimate interests (Art. 21 GDPR)
  • withdraw consent at any time with effect for the future (Art. 7(3) GDPR)

To exercise these rights, write to info@echopulsecommunity.de. You also have the right to lodge a complaint with a data protection supervisory authority, in particular in the EU country where you live or work (Art. 77 GDPR).

You can also submit requests about your data protection rights, such as access or erasure, easily via our Trust Center at Prighter: https://app.prighter.com/portal/14311689134.

12. Age

Our offering is only for adults. You must be at least 18 years old to use the app.

13. Required data and automated decisions

You need to provide your email address, first name and last name to create an account; to post in the chat, you also need a profile picture. Everything else is voluntary. We do not make automated decisions with legal or similarly significant effects (Art. 22 GDPR).

14. Social media

Where we link to our social media profiles, we use simple links. Data is only transferred to the respective provider when you click the link. The provider is responsible for processing on its site.

15. Changes

We update this privacy policy when our processing or the legal requirements change. The version published here applies.