Privacy Policy

1. Who we are

Pulvi is owned and operated by PULVI LLC, a Wyoming limited liability company (“Company,” “we,” “us,” or “our”). For purposes of this Privacy Policy, “Service” means the website, web application, mobile application, platform, and related services made available by the Company under the Pulvi brand.

PULSAR LABS. may provide development, operations, or contractor support to the Company, is the publisher of record for the Pulvi mobile applications in the Apple App Store and Google Play, and acts as our service provider under a written agreement that limits its use of personal information to performing services for us, but the Company is responsible for the Service and for the personal information described in this Privacy Policy.

You can reach us at:

• Email: privacy@pulvi.co
• Privacy requests: privacy@pulvi.co
• Mail: PULVI LLC, Attn: Privacy, 30 N Gould St, Ste R, Sheridan, WY 82801

The Service helps people discover, join, organize, and manage sports games, programs, spaces, communities, rosters, memberships, waitlists, chats, payments, and related services.

This Privacy Policy covers three kinds of users: players, who discover and join games and programs; hosts and organizers, who run games under their own identity; and business accounts, which operate venues, programs, memberships, staff, and their own customers through Pulvi Business. Section 17 explains how we handle information that a business account brings to the Service about its own customers and staff.

This Privacy Policy is part of, and incorporated into, our Terms of Service, and should be read together with our Cookie Policy.

2. Information we collect

We collect information you provide directly, information created when you use the Service, information collected automatically by our systems, and information received from service providers, from other users, and from hosts, organizers, and business accounts.

• Account and profile information, such as name, email address, phone number, profile photo, date of birth, sports preferences, account settings, and login information. We collect date of birth to confirm that you meet our minimum age requirement and to apply the protections described in Section 16.
• Host and organizer verification information. Hosts and organizers must be at least 18 and complete identity and payout verification. Government identification documents and taxpayer identification numbers are collected and held by Stripe, not by the Company, as described in Section 3.
• Game and community activity, such as games you create, join, leave, save, or manage; rosters; waitlists; check-ins; attendance status; communities; teams; leagues; standings; ratings; reviews; feedback; rules; notes; and uploaded photos.
• Location information, such as ZIP code, city, venue coordinates, user-selected locations, and precise mobile device location when you allow location access. Section 10 explains how we treat precise location.
• Communications, including game chat, community chat, invites, comments, support requests, reports, complaints, and messages you send to us. If you provide a mobile number and consent, this also includes text messages, as described in Section 18.
• Payment-related information, such as transaction amounts, checkout status, payment status, refund status, payout status, receipts, the brand and last four digits of a payment card, Stripe customer IDs, Stripe account IDs, and related transaction identifiers.
• Device, app, and technical information, such as device type, operating system, browser, app version, IP address, authentication session data, push notification tokens, device identifiers, advertising identifiers where you have permitted tracking, crash logs, error logs, performance data, pages or screens viewed, and usage events. On Apple devices we access the advertising identifier only if you allow it through Apple’s App Tracking Transparency prompt.
• Information about you from others, such as when a host adds you to a roster, records your attendance or payment status, writes a note about a game, or submits a rating, review, or report concerning you.
• Cookies, pixels, SDKs, local storage, mobile secure storage, advertising identifiers where permitted, and similar technologies used for authentication, security, analytics, advertising measurement, and product improvement.

We do not use facial recognition, face geometry, fingerprints, voiceprints, or any other biometric identifier, and we do not scan, tag, or analyze uploaded photographs in order to identify any individual.

3. Payments and payouts

We use third-party payment providers, including Stripe, Inc. (“Stripe”), to process payments, saved payment methods, refunds, organizer onboarding, identity or account verification, tax reporting, fraud prevention, and payouts.

When Stripe processes payment information from players on our behalf, it acts as our service provider under our instructions and our agreement with it. When a host, organizer, or business account onboards to a Stripe connected account to receive payouts, Stripe independently collects and processes identity verification, government identification, bank account, taxpayer identification, sanctions screening, and related information for its own legal, regulatory, and risk-management purposes, and acts as an independent controller of that information. Stripe’s handling of that information is governed by its own privacy policy at stripe.com/privacy.

The Company does not store full credit card numbers, complete bank account details, government identification documents, or taxpayer identification numbers on its own servers. Stripe or other payment providers may collect and process billing information, payment method details, bank account information, identity verification information, taxpayer identification numbers, device information, transaction history, and fraud-prevention signals according to their own terms and privacy policies.

4. How we use information

We use information to operate, secure, improve, and promote the Service.

• Create and manage accounts, profiles, games, communities, rosters, waitlists, check-ins, and organizer tools.
• Confirm that users meet our minimum age requirement and that hosts meet our verification requirements.
• Show nearby games, venues, communities, and recommendations.
• Process game fees, refunds, saved payment methods, organizer payouts, and related transactions.
• Send transactional emails, push notifications, text messages you have consented to receive, reminders, chat updates, game updates, payout notices, security alerts, support messages, and permitted marketing communications.
• Provide support, respond to feedback, investigate reports, enforce our terms, and protect users, organizers, venues, the Service, and the Company.
• Analyze product usage, measure marketing performance, troubleshoot errors, improve reliability, and develop new features.
• Detect, prevent, and investigate fraud, spam, abuse, unauthorized access, security incidents, payment disputes, and misuse.
• Comply with legal, tax, accounting, regulatory, safety, and dispute-resolution obligations.

We will not use or disclose personal information for a purpose materially different from, or incompatible with, those described in this Privacy Policy without first giving you notice and, where required, obtaining your consent.

We do not use personal information to train third-party generative artificial intelligence models. We do not make decisions that produce legal or similarly significant effects about you through automated processing alone.

5. How we share information

Under California and several other state privacy laws, “sale” means disclosing personal information for monetary or other valuable consideration, and “sharing” means disclosing it for cross-context behavioral advertising. The Company does not exchange personal information for money. Because we use advertising and analytics technologies, however, our disclosures to advertising and measurement partners are treated as a sale and a share under those laws. Section 6 explains how to opt out.

We share information when needed to provide the Service, when you choose to make information visible, or when required for legal, safety, or business reasons.

• With other users, such as profile details, sports preferences, roster or waitlist status, ratings, reviews, comments, and content you choose to post.
• With hosts and game organizers, including information needed to manage a game, such as name, profile details, roster or waitlist status, payment status, check-in status, and game-related messages or notes. Hosts and organizers are independent of the Company. When a host or organizer uses your information for its own purposes, it acts as a separate and independent controller and its own privacy practices apply. Our Host Guidelines and Terms require hosts and organizers to use participant information only to operate the games and programs you have joined, to keep it confidential, and not to sell it or use it for their own marketing without your consent. If you have a concern about a host’s use of your information, contact privacy@pulvi.co and we will assist.
• With payment providers, including Stripe, as needed for payments, refunds, saved payment methods, organizer onboarding, verification, tax reporting, fraud prevention, disputes, and payouts.
• With service providers that help us operate the Service, such as cloud hosting, databases, storage, authentication, email delivery, text messaging, push notifications, analytics, error monitoring, customer support, security, fraud prevention, content delivery, and advertising measurement providers. We engage these providers under written contracts that limit them to processing personal information only for purposes we specify, prohibit them from selling or sharing it or retaining, using, or disclosing it for any other purpose, and require appropriate confidentiality and security protections.
• With analytics and advertising partners, currently Google Analytics, Google Tag Manager, Firebase, Meta business tools, and PostHog, through cookies, pixels, SDKs, device identifiers, and advertising identifiers. These partners may use the information they receive under their own privacy policies to analyze usage, measure advertising performance, create or measure audiences, and show or help show ads on other websites, apps, and platforms. We do not control how a third-party platform uses information once it is collected through that platform’s technology.
• For legal, safety, compliance, enforcement, fraud-prevention, and security reasons. Where permitted by law and consistent with the safety of others, we will make reasonable efforts to notify you before disclosing your information in response to a legal request.
• In connection with a merger, acquisition, financing, reorganization, sale of assets, bankruptcy, or similar business transaction. We will require the recipient to honor the commitments in this Privacy Policy with respect to information transferred, or to give you notice and an opportunity to exercise your choices before your information becomes subject to a materially different privacy policy.

We do not make available to analytics or advertising partners your precise geolocation, government identification information, financial account information, or the contents of your private messages. We do not disclose personal information to advertising partners for cross-context behavioral advertising after you have opted out, and we do not sell or share the personal information of any user we know to be under 18.

6. Advertising, sale, sharing, and targeted advertising

The Company does not exchange personal information for money. Because we use advertising and analytics pixels, cookies, SDKs, and advertising identifiers, we treat our disclosures to advertising and measurement partners as a sale and a share of personal information for cross-context behavioral advertising, and as targeted advertising, under U.S. state privacy laws.

The categories we sell or share are online identifiers, internet and network activity, general location, commercial information relating to purchases, and inferences drawn from that information. We sell or share them with analytics, advertising, and measurement partners. We do not sell or share precise geolocation, sensitive personal information, government identification information, financial account information, or the contents of private communications.

You may opt out of the sale of your personal information, the sharing of your personal information for cross-context behavioral advertising, targeted advertising, and profiling in furtherance of decisions that produce legal or similarly significant effects. To opt out:

• Use the “Your Privacy Choices” link in the footer of pulvi.co;
• Use Settings → Privacy in the mobile app;
• Decline optional measurement in our consent banner; or
• Enable an opt-out preference signal such as Global Privacy Control (see Section 7).

An opt-out made in a browser or app applies to that browser or device. If you are signed in when you opt out, we will also apply your choice to your account across your devices.

We do not sell or share the personal information of any user we know to be under 18. Consistent with California law, we do not sell or share the personal information of consumers between 13 and 16 without their affirmative opt-in consent, or of consumers under 13 without a parent’s or guardian’s affirmative authorization.

7. Opt-out preference signals and Do Not Track

We honor legally recognized opt-out preference signals, including Global Privacy Control. When we detect such a signal from your browser or device, we treat it as a request to opt out of the sale and sharing of personal information and of targeted advertising for that browser or device, and we apply it without requiring you to take any further step. If you are signed in to your account when we receive the signal, we apply the opt-out to your account as well.

We do not respond to legacy “Do Not Track” browser settings, because no uniform industry standard for those signals has been adopted.

8. Categories of personal information

The table below summarizes the categories of personal information we collected in the preceding twelve months, the sources, the purposes for which we use them, the categories of recipients, and whether we sell or share them.

We also disclose each category above for legal, safety and compliance purposes and in connection with a business transfer, as described in Section 5.

9. Public and user-generated content

Some content may be visible to other users or the public depending on the feature, including game listings, community content, venue photos, ratings, reviews, comments, profile information, and posts in shared areas.

Content that is public on the Service may be viewed, copied and re-shared by others, may be indexed by search engines, and may remain visible in search engine caches or in copies held by other users after you delete it or close your account. Messages you have sent to other users remain in their accounts. Avoid posting sensitive personal information in public or shared areas of the Service.

10. Mobile permissions and location

The mobile application may request location, camera, photo library, notification, and, on Apple devices, tracking permissions. We use these permissions to show nearby venues and games, upload profile or venue photos when you choose to do so, send app notifications, and, where you allow tracking, measure advertising.

You can manage permissions through your device settings. If you disable a permission, some features may not work properly. We may still use general location information, such as ZIP code, city, IP-based location, or a location you manually provide.

Precise geolocation is treated as sensitive personal information under several state privacy laws. We collect it only with your permission, only while you are using the app, and only to power nearby search, venue mapping and check-in. We do not sell or share precise geolocation, use it for targeted advertising or profiling, or disclose it to analytics or advertising partners. Any location signal we provide to those partners is general location derived from IP address or ZIP code.

11. Cookies and similar technologies

We use cookies, authentication tokens, mobile secure storage, local storage, pixels, SDKs, push notification tokens, advertising identifiers, device identifiers, and similar technologies to operate the Service, keep users signed in, remember preferences, secure accounts, analyze usage, measure advertising, prevent fraud, and improve the Service.

Strictly necessary technologies operate at all times. On our website, analytics, advertising and measurement technologies load only after you allow optional measurement in our consent banner, and we do not set analytics or advertising cookies or equivalent local storage before you make that choice. You can change your choice at any time through the “Cookie Settings” link in our website footer. In our mobile applications, these technologies operate only where permitted by your device settings and applicable law. For more detail, see our Cookie Policy.

12. Data retention

We keep personal information for as long as reasonably necessary to provide the Service, maintain accounts, preserve accurate game and payment records, comply with legal obligations, resolve disputes, enforce agreements, prevent fraud or abuse, and operate our business. The criteria we apply are the length of your relationship with us, the purpose for which the information was collected, applicable legal and tax retention requirements, and the limitations periods for potential claims.

If you delete your account, we will delete, deactivate, or de-identify personal information associated with your account within the periods above unless we need to retain certain information for legal, safety, fraud prevention, accounting, payment, dispute resolution, backup, or other permitted purposes. Some information may remain in limited form where needed to preserve historical game, roster, payment, rating, support, security, or compliance records, or where you shared it with other users before deletion.

13. Security

We maintain administrative, technical, and organizational safeguards designed to protect personal information. These include encryption of data in transit using TLS, encryption of data at rest, role-based access controls, multi-factor authentication for administrative access, secure infrastructure, network and application monitoring, logging, vulnerability management, secure development practices, and periodic review of our security program and of our service providers. We limit access to personal information to personnel and service providers who need it to perform their functions and require them to keep it confidential.

No online service, app, or method of electronic storage is completely secure, so we cannot guarantee absolute security. If we become aware of a security incident affecting your personal information, we will notify you and applicable regulators as and when required by law.

14. Your choices and privacy rights

Depending on where you live, you may have rights to access, correct, delete, or obtain a copy of personal information; request portability; object to or restrict certain processing; opt out of marketing; opt out of sale, sharing, targeted advertising, or certain profiling; limit certain uses of sensitive personal information; or appeal a privacy request decision. We honor these rights for all U.S. users, except where a right applies only under a particular state’s law.

We will not discriminate or retaliate against you for exercising a privacy right. We will not deny you goods or services, charge you a different price, or provide a different level or quality of service because you made a request.

You can manage some choices through account settings, browser settings, device permissions, location permissions, push notification settings, advertising ID settings, the “Your Privacy Choices” and “Cookie Settings” links in our website footer, and email unsubscribe links.

To make a privacy request, email privacy@pulvi.co, use Settings → Privacy in the app, or write to us at the address in Section 1.

Verification. We will verify your identity before acting on a request to know, correct, delete, or port information. For most requests we verify by confirming control of the email address or mobile number associated with your account. For sensitive requests we may ask for additional information we already maintain, such as recent game or transaction details. We will not use information provided for verification for any other purpose and will delete it as soon as practicable.

Authorized agents. You may use an authorized agent. The agent must provide signed written permission from you, and we may require you to verify your own identity with us and confirm the authorization. An agent acting under a valid power of attorney need not provide separate written permission.

Timing. We will acknowledge your request within 10 business days and respond within 45 days. Where reasonably necessary we may extend by a further 45 days and will tell you why.

Appeals. If we decline a request we will tell you why. You may appeal by replying to our response or emailing privacy@pulvi.co with the subject line “Privacy Appeal.” We will respond within 45 days with a written explanation. If we deny the appeal, we will give you a method to contact your state Attorney General or privacy regulator.

Fees. We do not charge for a request unless it is manifestly unfounded or excessive, in which case we will tell you why and give a cost estimate first.

Sensitive personal information. Sensitive personal information includes precise geolocation, account log-in credentials, government identifiers, and financial account information. We collect precise geolocation only with your permission, and account credentials and, through Stripe, government identification and financial account information only as necessary to provide the Service, verify identity, process payments and payouts, comply with law, and prevent fraud. We do not use or disclose sensitive personal information for purposes other than those permitted under Cal. Civ. Code § 1798.121 and its implementing regulations, and we do not sell or share it or use it for targeted advertising or profiling. The right to limit the use and disclosure of sensitive personal information therefore does not apply to our processing. You may still withdraw location permission at any time through your device settings.

15. State-specific disclosures

Residents of states with comprehensive privacy laws — including California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia — have the rights described in Section 14, to the extent those laws apply to the Company and to you.

16. Children’s privacy

The Service is not intended for users under 16. Users under 16 may not create an account or use the Service. We collect date of birth at registration to enforce this requirement. We do not knowingly collect personal information from anyone under 16. If we learn that a user under 16 has provided personal information, we will promptly disable the account and delete the associated information unless retention is required for legal, safety, fraud prevention, compliance, or dispute-resolution reasons.

We do not sell or share the personal information of any user we know to be under 18, and we do not serve targeted advertising to any user we know to be under 18.

Youth programs. Hosts and business accounts may offer youth clinics, classes, camps, leagues, and similar programs. Where a program is open to participants under 16, the account of record must belong to a parent, guardian, or the operating business, and any information about a minor participant is provided by that adult or business and handled as described in Section 17. We do not create accounts for, direct the Service to, or serve advertising to children under 13, and we do not knowingly collect personal information directly from a child under 13. If you believe a child under 13 has provided personal information to us, contact privacy@pulvi.co and we will act promptly.

If you are a parent or guardian and believe a user under 16 has created an account, contact privacy@pulvi.co.

17. Business accounts: customers and staff

Business accounts use Pulvi Business to manage locations, bookable resources, rentals, programs, memberships, check-ins, reporting, their own customers, and their own staff.

Where a business account uploads or generates information about its own customers, program participants, minor participants, or staff, that business is the controller of the information and determines how it is used. The Company acts as the business account’s service provider and processor for that information, processes it only on the business account’s documented instructions and as permitted by our agreement with it, and does not sell or share it or use it for our own advertising. This Privacy Policy does not govern the business account’s own privacy practices; those are described in the business’s own notice, and requests about that information should be directed to the business. We will assist a business account in responding to a request as required by our agreement and by law.

Where an individual also holds a Pulvi player, host, or organizer account, this Privacy Policy governs that account.

18. Notifications, email, and text messages

We may send account messages, security alerts, game confirmations and reminders, schedule and roster changes, chat notifications, community updates, payment and payout notices, support messages, product updates, and permitted marketing communications.

You can manage push notifications through your device settings and unsubscribe from marketing email using the link in those emails or in account settings; we will process an unsubscribe within ten business days. We may still send transactional and service-related messages.

Text messages. If you provide a mobile number and consent, we may send game reminders, roster updates, security alerts and, where you separately consent, marketing messages. Message and data rates may apply. Reply STOP to opt out or HELP for assistance. Consent to receive text messages is not a condition of using the Service or of any purchase. We do not sell, share, or otherwise disclose text messaging opt-in data or consent to any third party for its own marketing purposes.

19. Third-party services and international users

The Service may contain links to third-party websites, services, payment pages, maps, venues, app stores, or other external resources. This Privacy Policy does not apply to third-party services, and we encourage you to review their privacy policies.

The Service is intended for users in the United States, and we do not offer it to, or knowingly direct it at, individuals in the European Economic Area, the United Kingdom, or Switzerland. If you access the Service from outside the United States, information may be processed and stored in the United States or other countries where our service providers operate, which may have different data protection laws. Where we transfer personal information from a jurisdiction that restricts such transfers, we rely on an approved transfer mechanism such as the European Commission’s Standard Contractual Clauses.

20. Accessibility

We are committed to making this Privacy Policy accessible. If you use assistive technology and have difficulty accessing it, or would like a copy in an alternative format, contact privacy@pulvi.co and we will provide one at no charge.

21. Changes and contact

We may update this Privacy Policy from time to time. We will post the updated policy on the website and in the app, update the “Last updated” date, and review this Privacy Policy at least annually.

If we make material changes, we will provide notice through the website, app, or email at least 30 days before they take effect, and where required by law we will obtain your consent. Changes apply prospectively only and do not apply to information collected before the effective date except as permitted by law or with your consent.

If you have questions, requests, or concerns about this Privacy Policy or our privacy practices, contact us at: