Privacy Policy

Updated 1/18/2024

Please read the following privacy policy carefully before using this software and/or web site. Your use, distribution or installation of this software and/or web site indicates your acceptance of this privacy policy. If you do not agree to any of the terms of this privacy policy, then do not install, access, distribute or use the software or web site.

Your privacy is important to Skytech Digital Solutions, LLC (“Skytech”), the developer and owner of Pulpit. This policy describes how Skytech processes the personal information we may collect about you when you use our software products, services, and web site or when you participate in, upload, stream, and view Pulpit events hosted by or in connection with Skytech (collectively, “Services”). In some cases, other subsidiaries and/or affiliates of Skytech may be considered data controllers, either together with Skytech or by themselves.

1. Information We Collect

The information we collect depends on what Services you use and how you use them. Please see below for more details.

A. Information You Give Us Directly

We may collect information that you provide us, including but not limited to:

Your Pulpit account information, including your email address, username, first and
last name, mailing address, phone number, and password;
Your security questions and answers;
Information you provide in response to surveys about our Services;
Information you provide when seeking help from us, such as emails and records of the issues you experience;
Information you may voluntarily provide through surveys or otherwise, including but not limited to age, gender, race, religion, political affiliation, and household income;
Information related to your donations and subscriptions;
Your mailing address for purchasing any merchandise online;
Billing information, such as your name, payment card number, payment amount, and payment account details;
Video and audio recordings and live streams.

B. Information You Provide When Online

When you participate in social features such as chat and live streaming any electronic information that you disclose may be read, copied, viewed, listed to, recorded, collected, or used by other participants, and may become publicly available.

When you participate online, your profile information may be visible. In addition, we collect information about the streams and content you view and participate in. We may record your activity and use it for diagnostic, subscription tracking, donation tracking and other purposes.

C. Other Information We Collect When You Use Our Services

We may collect other information automatically when you use our Services, including but not limited to:

IP address;
Information about your device, hardware, and software, such as your hardware identifiers, platform type, settings and components, Pulpit software and updates you have installed, and the presence of required plugins;
Approximate geolocation data (derived from IP or device settings);
Details about your use of Pulpit including your viewing of content on Pulpit;
Device event information, including crash reports, request and referral URLs and system activity details (e.g., whether you encountered an error or lost Internet access).

We also may collect and store information locally on your device.

D. Information Provided to Us by Third Parties

We may receive information about you contained in third-party user accounts when you use Pulpit Services on or through third-party platforms. This information is provided to Skytech as part of establishing or linking a Pulpit account. Your use of Pulpit Services through these third-parties indicates your agreement for the transfer of this information. Please contact these third-party providers directly for more information about the use of information on their platforms. These include, but are not limited to:

Digital payment processors (including, but not limited to, Stripe)
Apple
Google Play Store

E. Categories of Personal Information Processed

Depending on your use of our Services, the following categories of personal information may have been collected, shared, or disclosed in the preceding 12 months (as these processing activities are defined under applicable privacy laws, such as the California Consumer Privacy Act “CCPA”):

Identifiers; such as a real name, user name, account name, mailing address, email, online identifiers, device identifiers, IP address, or mobile device identifiers;
Purchase information; such as payment card number, payment account details, billing address, and other payment information;
Characteristics of Protected Classifications under state or federal law; such as age, religion, political affiliation, race, household income or gender;
Commercial Information; such as products or services interaction and purchase history;
Internet or Electronic Network Activity information; such as browsing history, search history, and information regarding interactions with our recorded content, streams, websites, applications, and/or advertisements;
Approximate (coarse) geolocation data; such as location data derived from IP address or device settings;
Audio or Electronic information; such as when you view our content, use chat features, or participate in live events;
Inferences; such as consumer preferences drawn from the above.

2. How We Collect Information

We and third parties may use technologies described below to collect information to deliver our Services.

A. Cookies and Similar Technologies

We do not use cookies.

We may use tracking pixels or clear GIFs to collect information about your use of our Services and your response to our marketing emails. We may use Internet log files (which contain technical data such as your IP address) to monitor traffic on our Services, troubleshoot technical problems, detect and prevent fraud, and enforce our End User License Agreement.

We also may use Analytics, Advertising, Anti-Cheat, and Anti-Fraud technologies in our Services. These technologies may utilize mechanisms as further described below.

B. Analytics Technologies

We may use internal and third-party analytics technologies to collect information about how you use our Services, your computer or device and the health of our Services. By use of our Services, you consent to our use of internal and third-party analytics technologies.

For instance, we may collect and store data from your computer or device when you use our Services. This information includes technical and related information about your computer or device and operating and/or network systems (such as IP Address and device ID), information about your engagement with certain features, usage statistics, system interactions and hardware. This data may include your username and related data as it relates to your use of Pulpit. If you participate in online Services, we may also collect, use, store, transmit and publicly display your personal and other data or identify content that is created and shared by you.

Third-party analytics technologies integrated into our Services may include, but are not limited to, various SDK [Software Development Kit] and API [Application Program Interfaces] integrations. These combine the information they collect in connection with your use of Pulpit Services with the information they have independently collected over time and/or across different platforms.

C. Ad Serving Technologies

Some of our Services may employ ad serving technologies that use clear GIFs, web beacons, tracking pixels, SDK, API, Google Ads, and other similar technologies to deliver offers and advertising to you within Pulpit as well as on third-party platforms and sites, and to measure the performance of our advertising campaigns. Some of these technologies can sync or connect behaviour across different websites and devices to tailor offers and advertising to your interests. For instance, you may be presented with an offer we think you might enjoy. Or, if you express interest, you may receive an advertisement later for that item or similar Services in Pulpit or third-party sites. Other advertising technologies enable offers to be temporarily uploaded to your web browser or mobile device and later replaced while you are online.

These technologies may collect and use information so we can serve appropriate offers and advertising to you, to measure effectiveness and distribution of these offers and advertising, and to understand how users interact with our Services. In addition to identifiers and certain information listed above, this information may include:

Advertisements served and the location of the ad;
Length of time an advertisement was visible;
Domain type, IP address, size of the advertisement;
Your interaction, if any, with the ad;
Advertisement response.

Third-party advertising companies may combine the information collected in the context of delivering an offer to you via our Services with other information they have independently collected over time and/or across different websites. Many of these companies collect and use information pursuant to their own privacy policies.

D. Anti-Cheat and Fraud Prevention Technologies

When you use our Services, we or third parties may use technologies and collect data about your machine or device, to create a machine “fingerprint” or “hash” of your machine components, for fraud prevention, security and authentication purposes. We may also monitor publicly available information, third-party sites, and/or use anti-cheat technology within our Services, including automated anti-fraud and abuse algorithms.

E. Streaming and Data Storage

We use Agora to collect the streaming video feed and metadata. We use Microsoft Azure for data storage of recorded video content and chat.

3. How We Use Your Information

We may use your personal information, both individually and combined together, in the following ways.

To operate our business and to enhance and personalize your experience, including to:

Operate, improve, and develop our Services;
Undertake research and analysis to develop and demonstrate our technology, and to better understand our participants;
Provide recommendations to you and others;
Help you find your friends or tell your friends about Pulpit;
Facilitate sharing on social networks;
Manage and serve targeted and contextual advertising;
Measure the effectiveness and distribution of advertising, including understanding who engages with our Services and how they interact with our Services;
Measure the health of our Services;
Detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, and prosecute those responsible for that activity;
Set up and maintain accounts for which you register;
Set up and facilitate loyalty programs;
Facilitate your use of Pulpit on multiple devices and/or platforms, as applicable;
Identify, fix, and troubleshoot bugs or functionality errors;
Provide software updates;
Measure streaming habits and engagement;
Perform audits, transactions, and other compliance activities;
Adhere to your preferences and to deliver content;
Help keep our Services safe and fair, resolve disputes, investigate and help curb fraud and illegal behaviour, comply with the law, and to enforce our agreements and policies;
Other purposes you consent to, are notified of, or are otherwise disclosed to you when you provide personal information.

To provide you support, including to:

Help identify and troubleshoot problems with your account or Services;
Facilitate surveys or questionnaires;
Communicate with you and respond to your specific requests, concerns, or questions;
Manage and send you confirmations and important information about your account, Services, purchases, subscriptions, and warranties.

To personalize our communications with you, including to:

Present offers and/or information relating to Pulpit and/or Services you might like;
Make recommendations to you;
Provide you with Service updates.

We retain the information we collect for as long as necessary to provide our Services, and we may retain that information beyond that period if necessary for legal, operational, or other legitimate reasons.

We may also de-identify, anonymize, or aggregate the information we collect, or collect it in a way that does not directly identify you. We may use and share such information as necessary for our business purposes and as permitted by applicable law.

4. Information We Share With Third Parties

Except as described below, we do not share, sell, or otherwise disclose personal information to third parties (as these processing activities are defined under applicable privacy laws, such as the California Consumer Privacy Act).

Service providers. We may employ third parties located in and outside of your country of residence to collect or process personal information on our behalf, including but not limited to conducting market surveys, providing IT and related services, facilitating credit card processing, facilitating live events, sending emails, or delivering and optimizing our Services. We require that any third party use the data only on our behalf and for purposes consistent with this policy.

Business partners. We may provide personal information to business partners with whom we jointly offer Services.

Affiliates. We may share personal information with our affiliated companies as is necessary for the purposes outlined in this notice.

Advertising partners. Through our Services, we may allow third-party advertising partners to utilize technologies and other tracking tools to collect information regarding your use of Pulpit and your device (e.g., your IP address, mobile identifiers, page(s) visited, location, browser information, time of day). We may also combine and share such information and other information (such as your de-identified account information, demographic information, hardware specifications, and past purchase history) with third-party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit third-party websites within their networks. This practice is commonly referred to as “interest- based advertising” or “online behavioural advertising.” We may allow access to other data collected by the Services to share information that may be useful, relevant, valuable, or otherwise of interest to you.

Disclosures to protect us or others. We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

Disclosure in the event of merger, sale, or other asset transfer. In the event of a reorganization, divestiture, merger, sale, or bankruptcy, we may transfer all information we collect to the relevant third party and will obtain your consent to do so if required by law or contract.

Third-party plugins. When third-party technologies or social tools are integrated into our Services, those third parties may collect information about your use of our Services.

Cross-Platform Sharing. Pulpit may allow you to connect with friends and members of a community regardless of what platform they use to access Pulpit. That other platform may receive your platform’s information to facilitate interaction. We will share your information with platforms to the extent necessary to enable Pulpit’s features. Your information received by these platforms may be subject to their respective privacy notices.

With Your Consent. We may share information with other third parties with your express consent, unless otherwise described above. For example, you may agree to us sharing your information with a certain company or organization to hear about their products, services, or promotions, or if you tell us that you want to link your Pulpit account with another company’s services. Use of the information you agree to share will be subject to those third parties’ respective privacy notices.

5. Where We Hold Your Information

Personal information we collect may be stored and processed for the purposes set out in this Privacy Policy in the United States or any other country in which Skytech or its affiliates and third- party agents operate. By consenting to the transfer of your personal data outside of your country of residence, you acknowledge that your personal information may be transferred to recipients in the United States and other countries that may not offer the same level of privacy protection as the laws in your country of residence or citizenship.

6. How We Protect Your Information

Security of your information is a priority. Even so, please be aware that no security measure is 100% perfect. Thus we cannot guarantee the security of your information at all times. You should always be diligent when it comes to the protection of your personal information.

7. Children

Skytech recognizes the importance of protecting children’s privacy online. As applicable, we strive to follow the different minimum age guidelines set by the laws of individual countries or territories when determining the age that children can access certain features of our Services.

Pulpit is intended to be family-friendly. However, we do not support children under the age of 13 creating accounts for Pulpit. Potential users must state that they are at least 13 years of age before they are permitted to create an account.

We encourage you to talk with your children about communicating with strangers and the risks of disclosing personal information online.

8. Your Choices and Controls

We may occasionally update this privacy policy. When we do, we will revise the “last updated” date at the top of the policy and post the new copy online.

9. Third-Party Services

Our websites and Services may contain advertising or links to third-party services. If you click on those links, including an advertisement, you will leave the Pulpit Services and go to the third-party service or site that you selected. If you visit a third-party website or use a third-party service, you should consult that service’s or site’s privacy policy as your use of third-party sites or services is governed by their privacy policies.

10. Changes to Our Policy