Privacy

Your privacy is important to Pulsar. We developed this Privacy Policy to provide you with information on how we process your personal data when you use XGate Satellite Email and Data Services.

"Personal data" is information relating to an identified or identifiable natural person. Additional information specific to your jurisdiction may be provided in a separate document. Please scroll to the "Your Rights" section to view our supplemental policies that may apply to you. The legal grounds for processing personal data specified in this Privacy Policy are based on the EU General Data Protection Regulation ("GDPR") and laws in other jurisdictions that have similar grounds.

XGate Satellite Email and Data Services Application (the "App") are brought to you by Pivotel IP LLC. (the "Data Controller" of your personal data). Consequently, "We", "Us" and "Ours" refers to the Data Controller.

We collect certain information about you when you provide it directly to us or use our App. We only obtain information necessary to provide you with our services.

Email address: As an email client, the core functionality of our Product is based on providing you with the ability to manage your email. For this reason, Pulsar access your email account when you start using the App. Your email address is a unique identifier of you as a user within our system and allows us to secure your data. Your email address will also be used as a primary means of communication for us on anything related to changes to the App such as Privacy Policy, Terms of Use, or core functionality of our App. We may also occasionally contact you for marketing purposes and it will be in our legitimate interests to do so, but you will always have a chance to opt out of such marketing communications for similar products and/or services anytime by unsubscribing in our marketing emails.

Login or mail server credentials: Pulsar requires your credentials to log into the mail system in order to receive, search, compose and send email messages and other communication. Without such access, our Product won’t be able to provide you with the necessary communication experience.

Email content while using Pulsar Services: We provide a method for you share information such as email conversations and shared email drafts. This information is stored and processed on our secure servers in order to make XGate email features available to you.

IP address: Core functionality of our Product is based on connection to the Internet. That is why our App won’t properly function without Internet connection. Your IP address is a unique identifier that lets you connect to the Internet and our service will log connections for security and troubleshooting purposes.

Device, App version, iOS version information: We need to have this information, so the App functions properly on your specific device.

Statistical information with regards to App usage: In order to better understand general app usage patterns, improve the Product and its user experience, Pulsar collects general statistical information about the usage of the Product. Collecting such data helps us optimize the App in future updates and such usage does not affect your rights and freedoms and does not disclose any personal data of yourself or your contacts.

Recently accessed email messages and shared inboxes: We need this information to provide XGate app feature services to you such as private discussions around email, shared drafts, shared email conversations and shared inboxes. By collecting and storing this data, we are able to present emails through your XGate app and provide better communication experience.

Logs: We collect this information to prevent fraud and potential unauthorized access to your personal information, ensuring the technical availability and security of the App. The server that hosts the App may record requests your device makes to the server, the details on device and browser you use, your IP address, date and time of access, city and country, operating system, browser type, mobile network information. This data is used only for technical purposes – that is, to ensure the proper functioning and security of the App and to investigate possible security incidents.

Location Based Services: If you choose to use location-based services, such as weather on your XGate app, then the physical location of your device will be collected in order for Pulsar or our providers to provide you with such location-based services.

Customer Support communication: When you interact with our customer support representatives by email or telephone, online, or in person, we collect personal data, such as your name, mailing address, phone number, email address, and contact preferences, and information about the Pulsar products you own, such as their serial numbers and dates of purchase, and subscriptions you've purchased. We also may create event logs that are useful in diagnosing product or app performance-related issues and capture information relating to the support or service issue. To improve customer service, subject to applicable laws, we may also record and review conversations with customer support representatives and analyze any feedback provided to us through voluntary customer surveys. With your consent, our customer support representatives may sign into your XGate account, if appropriate, to help troubleshoot and resolve your issue.

Your personal data is used to provide you our App and services, and to improve the Product. Your personal data is not used for marketing purposes. Unless you have asked us not to, We may rarely contact you by email about similar products and services to the App. Whenever We contact you, We would always give you the right to opt out at any time (see the section "Your Rights" below).

As stated in above, We only process personal data for the purposes strictly necessary to provide you with the service. Some of the purposes for processing the data provided by you include:

Providing you with the services

Fraud prevention

Improving our services

Notifying you of any changes in our services

We will retain your personal data as long as your XGate account is considered to be active or in accordance with applicable law and regulatory obligations (see the section "Your Rights" below).

Your data is stored on secure servers that we rent and We use the recommended industry practices to keep your data secure. We use appropriate level of technical and organizational measures to prevent accidental or unlawful destruction, loss, alteration, unauthorized disclosure of or access to personal data transmitted, stored or otherwise processed.

Protective measures for system access control:Each employee has access to the systems/services only via his/her own employee access. The access rights involved are limited to the responsibilities of the respective employee and/or team. Our systems are protected by firewalls that reject all incoming connections by default. Only connection types defined by exception are accepted.

Protective measures for data access control: All servers and services are subject to continuous monitoring. This includes the logging of personal access in the user interface.

Protective measures for transfer control: The handling of local data storage devices, e.g. USB sticks, is regulated via agreements. Access to the systems from outside the company network is possible only via secure VPN access.

Protective measures for separation control: To separate data, We use logically separate databases so that no accidental reading of data by unauthorized persons can occur.

Access to the data itself is also restricted by the fact that employees use services (applications) which control access.

We do not rent, sell or share your personal data with any third parties, except where We have to comply with Our legal obligation. Some of the data of our users is aggregated for statistical purposes and processed in the legitimate interests as stated above.

This does not mean that We blindly follow disclosure orders. We will check each request to ensure it satisfies the relevant safeguards, contains a court order or is issued under a legislative measure for the prevention, investigation, detection or prosecution of criminal offences. If We employ a processor to act on our behalf, We ensure that there are adequate contractual measures to ensure responsibility, security and liability to the same level as expected of Us.

In any case where a third party accesses your data on our behalf or upon our instructions (be it inside or outside the EEA), We use the relevant legal basis to comply with the data protection legislation. In cases where there is no finding of an adequacy decision by the European Commission, we use model contracts approved by the European Commission to safeguard your rights and data.

We partly use services by subcontractors who behalf of us perform development and support tasks to operate and maintain the XGate platform. These subcontractors’ process any data exclusively for development and support purposes according to our instructions (order processing). The legal basis for the data processing described in this section 4 is Art. 6 (1) sentence 1 lit. b GDPR (performance of contract and pre-contractual measures) and Art. 28 GDPR (order processing).

Pulsar is a subject of various data privacy regulations including the General Data Protection Regulation and the California Consumer Privacy Act. You are entitled to the full spectrum of the rights under those regulations. We will go out of our way to accommodate any valid request. You can either exercise your rights by deleting your account and all information associated with it from your device or by emailing us at support@pulsarbeyond.com

Pulsar under no circumstances sell your data and performs only lawful processing of your personal data. You have a wide array of rights that we respect. Among those the right to: • Require access to your personal data; • Require rectification of your personal data (this is less relevant since otherwise we could not provide you with the service); • Require erasure of your personal data; • Withdraw consent to the processing of your personal data, where applicable, otherwise we could not provide you with the service; • Lodge a complaint with your national supervisory authority (in the EEA) if you believe that your privacy rights have been breached. If your personal data is erased at your request or in accordance with our data retention policy, We only retain such information that is necessary to protect our legitimate interests or to comply with a legal obligation.

If you are a California resident, you have rights under the California Consumer Privacy Act of 2018 ("the CCPA"). Below, we provide a description of your rights and disclosures about your personal information.

Right to know about the personal information we collect and share: The CCPA gives you the right to request that we disclose the specific pieces of personal information we have collected about you. The categories of personal information we collect about you and the sources from which we collect such personal information are described above. Pulsar does not sell, and has not sold, your personal information. However, we disclose and have disclosed in the past 12 months certain categories of personal information for a specified business purpose to certain categories of third parties, all as described in the main Privacy Policy from which you were directed to this supplementary policy.

Right of deletion: You have the right to request that we delete your personal information, subject to certain exceptions.

How to exercise your rights: To request access to or deletion of your personal information, or to delete your XGate account, contact Pulsar at support@pulsarbeyond.com or +1-(954)-763-8650. No one else can request access to or deletion of your personal information without providing sufficient evidence of your authorization.

Categories of information we collect and disclose for a business purpose: We collect the categories of personal information from you in connection with the Services, as defined in the CCPA, that are described above.

Nondiscrimination: will not discriminate against you for exercising any of your CCPA rights.

We request individuals under the age of 13 in the U.S. and under the age of 16 in the rest of the world not provide personal data to Pulsar. If we learn that we have collected personal data from a child under the age of 13 in the U.S. or under 16 in the rest of the world, we will take steps to delete the information as soon as possible.

• We will only collect and use your data where We have a legal basis to do so.
• We will always be transparent and tell you about how we use your information.
• When We collect your data for a particular purpose, we will not use it for anything else without your consent, unless other legal basis applies;
• We will not ask for more data than needed for the purposes of providing our services.
• We will adhere to the data retention policies and ensure that your information is securely disposed of at the end of such retention period.
• We will observe and respect Your rights by ensuring that queries relating to privacy issues are dealt with promptly and transparently.
• We will keep our staff trained in privacy and security obligations.
• We will ensure to have appropriate technological and organizational measures in place to protect your data regardless of where it is held.
• We will also ensure that all our data processors have appropriate security measures in place with contractual provisions requiring them to comply with Our commitment.
• We will obtain your consent and ensure that suitable safeguards are in place before personal data is transferred to other countries.

We will always notify you via email or otherwise should we update this privacy policy. We will update the "last modified" date at the bottom of this privacy policy to indicate the latest revision, as well as the changes were made.

Pivotel IP LLC. (Pulsar)
2 Oakwood Blvd.
Suite 200
Hollywood, FL 33020 United States of America Phone: +1-(954)-763-8650 Website: pulsarbeyond.com
Email: support@pulsarbeyond.com

Last modified August 4, 2022