Sale Pulse

Data Protection Declaration

Last updated: 13 July 2026

1. Controller

The controller responsible for processing personal data on this website within the meaning of the General Data Protection Regulation (“GDPR”) is:

Aratud UG (haftungsbeschränkt)

Kolonnenstr. 8

10827 Berlin

Germany

Email: info@aratud.de

“SalePulse”, “we”, “us” and “our” refer to Aratud UG (haftungsbeschränkt) as the operator of salepulse.de.

2. General information and legal bases

Personal data means any information relating to an identified or identifiable natural person.

We process personal data only where this is necessary to operate SalePulse, display and verify deal information, receive deal submissions, communicate with users, send the newsletter, protect the service against misuse, or comply with legal obligations.

Depending on the processing activity, we rely on the following legal bases:

  • Article 6(1)(a) GDPR: consent;
  • Article 6(1)(b) GDPR: steps taken at the request of a person before entering into a contract or performance of a contract;
  • Article 6(1)(c) GDPR: compliance with a legal obligation; and
  • Article 6(1)(f) GDPR: our legitimate interests or those of a third party, provided that the interests, fundamental rights and freedoms of the data subject do not override those interests.
  • Where storing information on, or accessing information from, a user’s device requires consent under Section 25 of the German Telecommunications Digital Services Data Protection Act (“TDDDG”), we obtain consent before activating the relevant technology unless the storage or access is strictly necessary to provide a digital service expressly requested by the user.

    3. Processing when visiting the website

    When you access salepulse.de, our systems and service providers may automatically process technical access information, including:

  • IP address;
  • date and time of access;
  • requested page, file or resource;
  • referring page or referrer URL;
  • browser type and version;
  • operating system and device information;
  • HTTP status code; and
  • amount of data transferred.
  • This information is processed to deliver the website, maintain technical stability, detect attacks and misuse, troubleshoot errors and protect the website and its users.

    The legal basis is Article 6(1)(f) GDPR. Our legitimate interests are the secure, reliable and efficient operation of SalePulse.

    Access logs stored on our own systems are normally deleted or anonymised after 14 days. Information required to investigate a technical or security incident may be retained until the incident has been resolved and any related legal claims have expired.

    The website uses TLS encryption. An encrypted connection can generally be recognised by “https” in the browser address bar.

    4. Hosting by Hetzner

    SalePulse is hosted using services provided by:

    Hetzner Online GmbH

    Industriestr. 25

    91710 Gunzenhausen

    Germany

    Hetzner may process website content, database information, uploaded files, technical metadata, backup data and server logs on our behalf where this is necessary to provide the hosting infrastructure.

    We use Hetzner Cloud infrastructure located within the European Union or European Economic Area.

    The legal basis for our use of hosting services is Article 6(1)(f) GDPR. Our legitimate interest is the secure and efficient provision of the website.

    We have concluded a data processing agreement with Hetzner in accordance with Article 28 GDPR.

    Backups are normally retained for up to 30 days. A backup may be retained longer where this is required to restore the service following a technical or security incident.

    5. Cloudflare network, DNS and security services

    We use network, DNS, content-delivery and security services provided by:

    Cloudflare, Inc.

    101 Townsend Street

    San Francisco, CA 94107

    United States

    Traffic to and from SalePulse may pass through Cloudflare’s network. Cloudflare may process:

  • IP addresses;
  • requested URLs and resources;
  • request and response headers;
  • browser and device information;
  • network and security signals;
  • date and time of requests;
  • cookies or security identifiers; and
  • information required to detect malicious or automated traffic.
  • This processing is used to deliver the website efficiently, protect it against distributed denial-of-service attacks and other malicious activity, prevent fraud and maintain availability.

    The legal basis is Article 6(1)(f) GDPR. Our legitimate interests are website security, fraud prevention and reliable service delivery.

    Cloudflare processes relevant personal data on our behalf under a data processing agreement. Cloudflare may also process certain information under its own responsibility where this is described in its applicable privacy documentation.

    Cloudflare operates a global network. Where personal data is transferred outside the European Economic Area, the transfer is based, where applicable, on an adequacy decision such as the EU–US Data Privacy Framework or on the European Commission’s Standard Contractual Clauses together with any necessary supplementary safeguards.

    Cloudflare’s retention periods depend on the service and configuration used. We configure the services to minimise data collection and retention where technically possible.

    6. Cookies and similar technologies

    SalePulse may use cookies, local storage or similar technologies that are technically necessary to:

  • operate and secure the website;
  • prevent automated abuse;
  • store privacy or consent choices;
  • maintain a form or session requested by the user; or
  • distribute traffic reliably.
  • Where such storage or access is strictly necessary, it is based on Section 25(2) TDDDG. Where personal data is also processed, the legal basis is Article 6(1)(f) GDPR or, where relevant, Article 6(1)(b) GDPR.

    SalePulse currently does not use third-party analytics cookies, advertising cookies or marketing trackers.

    If optional analytics, advertising, third-party embeds or other non-essential technologies are introduced, they will not be activated before the user has given any consent required under Section 25(1) TDDDG and Article 6(1)(a) GDPR. Consent can then be withdrawn at any time through the website’s privacy settings.

    Fonts used by SalePulse are hosted locally on our own website. When a font file is loaded, no connection is made to Google Fonts or another external font provider.

    7. Deal submissions

    Users may submit information about a store, event, pop-up or deal through the SalePulse submission form.

    Depending on the form version and information voluntarily provided, we may process:

  • store or business name;
  • address and location information;
  • website and public social-media links;
  • deal description, category, dates, conditions and availability;
  • photographs or links to photographs;
  • the submitter’s name or organisation;
  • the submitter’s email address or other contact details;
  • the date and time of submission;
  • IP address and technical security information; and
  • correspondence relating to review or verification of the submission.
  • We process this information to:

  • receive and review the submission;
  • verify, moderate, correct and publish deal information;
  • contact the submitter where clarification is required;
  • identify duplicate, misleading, unlawful or fraudulent submissions;
  • prevent abuse of the submission form; and
  • establish, exercise or defend legal claims.
  • The legal basis is Article 6(1)(f) GDPR. Our legitimate interests are operating a reliable local-deal platform, maintaining data quality, verifying submitted content and preventing abuse.

    Where a store owner, business operator or authorised representative contacts us concerning a promotional service or other contractual arrangement, Article 6(1)(b) GDPR may also apply.

    A contact email supplied for verification is not published unless the relevant person has expressly requested or consented to publication.

    Approved business details, deal information and photographs may be published on salepulse.de and distributed through SalePulse’s Instagram and Telegram channels.

    ### Photographs

    Please do not upload photographs showing identifiable customers, employees, passers-by, children, vehicle licence plates, private documents or other unnecessary personal information.

    Submitters must have the right to provide the submitted text and photographs. We may reject, crop or blur photographs containing unnecessary personal information or content that cannot lawfully be published.

    ### Retention of submissions

    Rejected submissions and associated contact information are normally deleted within 90 days after the review decision.

    Contact information relating to an approved submission is normally deleted within 12 months after the relevant deal has expired or after the last related communication, whichever occurs later.

    Published deal content is removed, marked as expired or archived when it is no longer current. Information may be retained longer where required by law or necessary to establish, exercise or defend legal claims.

    8. Cloudflare Turnstile

    The deal-submission form is protected using Cloudflare Turnstile, provided by Cloudflare, Inc.

    When the protected form is opened or used, the browser establishes a connection to Cloudflare. Turnstile may process signals including:

  • IP address;
  • TLS and browser characteristics;
  • user-agent information;
  • site key and website origin;
  • device, network and operating-system information;
  • date and time of the request;
  • challenge and interaction information;
  • Turnstile tokens; and
  • the result of the bot-detection check.
  • Turnstile uses these signals to distinguish legitimate users from automated or malicious requests and to protect the form against spam, bot submissions and other misuse.

    The legal basis for our use of Turnstile is Article 6(1)(f) GDPR. Our legitimate interests are protecting SalePulse, maintaining the quality of submitted information and preventing automated abuse.

    Any storage of or access to information on the user’s device that is strictly necessary for the security check is based on Section 25(2) TDDDG.

    Cloudflare acts as a processor when it uses Turnstile signals to protect our website on our behalf. According to Cloudflare’s Turnstile privacy information, Cloudflare also acts as an independent controller where it uses signals to improve Turnstile’s bot-detection capabilities.

    Turnstile is loaded only on pages or forms where the anti-abuse check is required. Cloudflare’s international-transfer safeguards are described in Section 5.

    We do not use Google reCAPTCHA.

    9. Newsletter subscription

    Users may subscribe to the SalePulse email newsletter. The newsletter may contain information about current deals, stores, pop-ups, local events, SalePulse features and related offers.

    The mandatory information for subscription is the email address. We may additionally process:

  • date and time of registration;
  • IP address used for registration;
  • date and time of confirmation;
  • the consent wording valid at the time;
  • delivery status;
  • bounce and complaint information; and
  • the date and method of unsubscribe requests.
  • We use a double-opt-in procedure. After registration, a confirmation email is sent to the supplied address. The subscription becomes active only after the confirmation link has been used.

    The legal basis for sending the newsletter is consent under Article 6(1)(a) GDPR.

    The registration and confirmation records are processed under Article 6(1)(f) GDPR. Our legitimate interests are demonstrating that valid consent was obtained and preventing misuse of email addresses.

    You may unsubscribe at any time using the unsubscribe link included in each newsletter or by contacting us. Withdrawal of consent does not affect processing carried out before withdrawal.

    After unsubscribing, the email address is removed from the active newsletter distribution list. We may retain limited evidence of the former consent and unsubscribe request for as long as necessary to demonstrate legal compliance or defend against claims.

    The email address may also be stored on a suppression list solely to ensure that no further newsletter is sent to that address.

    We do not use newsletter open or click tracking. If such tracking is introduced in the future, it will be activated only after obtaining any legally required consent and this declaration will be updated before activation.

    10. Newsletter delivery through Amazon SES

    We use Amazon Simple Email Service (“Amazon SES”) to deliver newsletter and transactional emails.

    The provider for customers in the European Economic Area is generally:

    Amazon Web Services EMEA SARL

    38 Avenue John F. Kennedy

    L-1855 Luxembourg

    Amazon SES is configured for the AWS Europe (Frankfurt) region, eu-central-1.

    For email delivery, AWS may process:

  • recipient email address;
  • sender address;
  • subject and message content;
  • delivery timestamps and technical identifiers;
  • IP and routing information;
  • delivery status;
  • bounce and complaint information; and
  • information required to prevent abuse and maintain email security.
  • The sending of the newsletter is based on consent under Article 6(1)(a) GDPR. Our use of Amazon SES as a technical delivery service is based on Article 6(1)(f) GDPR. Our legitimate interest is reliable, secure and scalable email delivery.

    AWS processes this information on our behalf under the AWS Data Processing Addendum, which includes the safeguards required under Article 28 GDPR.

    Although the SES service is configured in Frankfurt, AWS may process limited information in other locations where this is necessary to provide support, security or service operations. International transfers are protected by the safeguards contained in the AWS Data Processing Addendum, including the European Commission’s Standard Contractual Clauses where applicable.

    Delivery, bounce and complaint information is retained only for as long as required to operate the newsletter, maintain the suppression list and protect the email service against misuse.

    11. Contact by email or contact form

    When you contact us by email or through a contact form, we process the information you provide, such as:

  • name;
  • email address;
  • message;
  • attachments; and
  • date and time of communication.
  • The purpose is to respond to the inquiry and handle related follow-up communication.

    The legal basis is Article 6(1)(f) GDPR. Our legitimate interest is responding to inquiries and communicating with users and business operators.

    Where the inquiry concerns steps before entering into a contract or the performance of a contract, Article 6(1)(b) GDPR also applies.

    General inquiries are normally deleted within six months after the matter has been concluded. Information may be retained longer where required by law, needed for contractual documentation or necessary to establish, exercise or defend legal claims.

    12. Publicly available store and deal information

    SalePulse may research and collect information about stores, pop-ups, events and deals from publicly accessible sources, including:

  • official business websites;
  • publicly accessible social-media pages;
  • online directories;
  • public registers and open-data services;
  • OpenStreetMap and related geographic services;
  • publicly displayed storefront information; and
  • publicly visible advertisements or deal announcements.
  • The information may include:

  • business name;
  • business address;
  • website;
  • public social-media profiles;
  • public business contact details;
  • opening information;
  • deal description and dates;
  • public promotional material; and
  • photographs of public storefronts or promotional displays.
  • Most of this information relates to businesses rather than natural persons. Information relating to sole traders, named contacts or public business representatives may nevertheless constitute personal data.

    We process this information to identify, verify and publish relevant local deals, maintain the SalePulse store directory and improve the accuracy of the service.

    The legal basis is Article 6(1)(f) GDPR. Our legitimate interests are providing a local-deal information service, helping users discover Berlin businesses and maintaining accurate deal information.

    We limit collection to information relevant to these purposes. Publicly sourced information is reviewed and corrected where practical. It is removed or updated when it is no longer accurate or where a justified objection is received.

    A person whose personal data appears in a listing may contact us to request correction, removal or further information.

    Where Article 14 GDPR requires individual information concerning data obtained from another source, we provide that information unless a statutory exception applies, for example where individual notification would be impossible or involve disproportionate effort and the required safeguards are implemented.

    13. AI-assisted deal discovery

    SalePulse may use software tools, including artificial-intelligence-assisted tools, to identify, classify, deduplicate, summarise or verify publicly available deal information.

    These tools are used only for business-related public information such as:

  • store names;
  • public website addresses;
  • public deal descriptions;
  • categories;
  • deal dates; and
  • publicly advertised offer conditions.
  • We do not provide AI services with:

  • newsletter subscriber addresses;
  • deal submitters’ private contact details;
  • IP addresses;
  • private correspondence;
  • non-public user information; or
  • user-submitted photographs containing identifiable persons.
  • AI-generated or AI-assisted results are reviewed before publication where an error could materially affect the accuracy of a listing.

    We do not use AI services to make decisions producing legal or similarly significant effects concerning users within the meaning of Article 22 GDPR.

    If an AI provider is later used to process personal data beyond the limited public business information described above, we will identify the provider, categories of data, purpose, legal basis, retention arrangement and international-transfer safeguards in this declaration before that processing begins.

    14. Maps and OpenStreetMap

    SalePulse uses map data from OpenStreetMap to display stores and deals geographically.

    Where map tiles are loaded directly from infrastructure operated by the OpenStreetMap Foundation, the user’s browser establishes a connection to that infrastructure.

    The provider is:

    OpenStreetMap Foundation

    St John’s Innovation Centre

    Cowley Road

    Cambridge CB4 0WS

    United Kingdom

    The OpenStreetMap Foundation or its infrastructure providers may receive:

  • IP address;
  • browser and device information;
  • requested map tile coordinates;
  • referring page;
  • date and time of the request; and
  • technical request information.
  • The purpose is to provide the interactive map and display relevant locations.

    The legal basis is Article 6(1)(f) GDPR. Our legitimate interest is providing a useful map-based presentation of local stores and deals.

    Where personal data is transferred to the United Kingdom, the transfer is based on the applicable European Commission adequacy decision for the United Kingdom for as long as that decision remains valid. Other appropriate safeguards will be used if required.

    The map identifies the relevant data and tile provider in its attribution. If SalePulse changes the tile provider, this declaration will be updated accordingly.

    ### Browser location

    If you actively use a “locate me”, “near me” or similar function, your browser or device asks for permission to access your approximate or precise location.

    The location is used to centre the map or display nearby deals. Unless expressly stated otherwise when the function is used, the location is processed only for the current request and is not stored in a user profile.

    The legal basis is consent under Article 6(1)(a) GDPR. You can withdraw location permission through your browser or device settings.

    15. Instagram and Telegram

    SalePulse may publish approved deal content through its own Instagram and Telegram channels.

    The published content may include:

  • business names;
  • public business information;
  • deal descriptions;
  • links;
  • public promotional material; and
  • approved photographs.
  • Private submitter contact information and newsletter subscriber information are not published or transferred to Instagram or Telegram for this purpose.

    The legal basis for distributing approved business and deal content is Article 6(1)(f) GDPR. Our legitimate interests are informing users about current deals and increasing the reach of relevant Berlin businesses.

    Where content identifies a private individual, it is published only where an appropriate legal basis exists, such as consent.

    Instagram is operated for users in the European Economic Area by Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland.

    Telegram services are provided by Telegram Messenger Inc. Telegram acts as an independent controller when users access or interact with Telegram.

    Instagram and Telegram process information under their own responsibility when a user visits or interacts with a SalePulse account or channel on the relevant platform.

    SalePulse pages may contain ordinary links to Instagram or Telegram. An ordinary link does not itself cause the user’s browser to contact the platform. When the user clicks the link, the platform may receive the user’s IP address, browser and device information, referring page and interaction information. If the user is logged in, the visit may be associated with the platform account.

    We do not embed Instagram or Telegram tracking widgets on salepulse.de. If embedded platform content is introduced, it will be blocked until any legally required consent has been obtained and this declaration will be updated before activation.

    16. Recipients of personal data

    Personal data may be disclosed to the following categories of recipients where necessary:

  • hosting, infrastructure and backup providers;
  • DNS, content-delivery and website-security providers;
  • email-delivery providers;
  • map and geographic-data providers;
  • social-media platforms where approved content is published;
  • professional advisers, auditors and legal representatives;
  • public authorities where disclosure is legally required; and
  • processors engaged under Article 28 GDPR.
  • We do not sell personal data.

    17. International data transfers

    Some service providers may process personal data outside the European Economic Area.

    Where the European Commission has adopted an adequacy decision for the recipient country or transfer mechanism, the transfer may be based on that decision.

    Where no adequacy decision applies, we use an appropriate safeguard under Chapter V GDPR, such as the European Commission’s Standard Contractual Clauses, together with supplementary contractual, organisational or technical safeguards where required.

    18. Storage periods

    Unless a specific retention period is stated in this declaration, personal data is retained only for as long as necessary for the relevant processing purpose.

    The information is then deleted or anonymised unless continued retention is:

  • required by law;
  • necessary for contractual records;
  • required to demonstrate consent or compliance; or
  • necessary to establish, exercise or defend legal claims.
  • Statutory commercial and tax retention requirements may require certain business records and correspondence to be retained beyond the operational periods described above.

    19. Data security

    We use appropriate technical and organisational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access.

    These measures include, where appropriate:

  • encrypted data transmission;
  • access controls;
  • least-privilege permissions;
  • security monitoring;
  • backups;
  • software updates;
  • authentication controls; and
  • procedures for responding to security incidents.
  • No method of transmission or storage can guarantee absolute security. We therefore review the measures in light of the nature, scope and risks of the processing.

    20. Rights of data subjects

    Subject to the applicable legal requirements, you have the following rights:

  • right of access under Article 15 GDPR;
  • right to rectification under Article 16 GDPR;
  • right to erasure under Article 17 GDPR;
  • right to restriction of processing under Article 18 GDPR;
  • right to notification under Article 19 GDPR;
  • right to data portability under Article 20 GDPR;
  • right to object under Article 21 GDPR;
  • right to withdraw consent under Article 7(3) GDPR; and
  • right to lodge a complaint with a supervisory authority under Article 77 GDPR.
  • To exercise these rights, contact us at info@aratud.de.

    21. Right to object

    Where we process personal data on the basis of Article 6(1)(f) GDPR, you have the right to object to that processing at any time on grounds relating to your particular situation.

    If you object, we will stop processing the relevant information unless we demonstrate compelling legitimate grounds that override your interests, rights and freedoms, or the processing is necessary to establish, exercise or defend legal claims.

    Where personal data is processed for direct marketing, you may object at any time without giving reasons. After such an objection, the information will no longer be used for direct marketing.

    22. Withdrawal of consent

    Where processing is based on consent, you may withdraw that consent at any time with effect for the future.

    Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

    Newsletter consent can be withdrawn using the unsubscribe link in each newsletter. Location permission can be withdrawn through browser or device settings. Other consent can be withdrawn by contacting us.

    23. Right to lodge a complaint

    You have the right to lodge a complaint with a data-protection supervisory authority.

    The supervisory authority generally responsible for the controller is:

    Berliner Beauftragte für Datenschutz und Informationsfreiheit

    Alt-Moabit 59–61

    10555 Berlin

    Germany

    Email: mailbox@datenschutz-berlin.de

    You may also contact another supervisory authority where permitted under Article 77 GDPR.

    24. Obligation to provide information

    You are not generally required to provide personal data merely to browse SalePulse.

    Certain information is required to:

  • submit a deal;
  • receive the newsletter;
  • use location-based functions; or
  • receive a response to an inquiry.
  • Without that information, the relevant function may not be available.

    25. Children

    SalePulse is not specifically directed at children.

    Children should not submit personal data or subscribe to the newsletter without the involvement of a parent or legal guardian where such involvement is required by law.

    26. Changes to this declaration

    We may update this declaration where our services, providers, processing activities or legal requirements change.

    The current version is published on salepulse.de with its revision date.

    Material changes affecting consent-based processing will not apply retroactively without obtaining any consent required by law.