Privacy Policy

Updated September 1, 2020

Definitions

To make this document easier to read, we’re going to use some shorthand throughout. For example, when we say “ChOP” or “the Platform” we’re talking about the web-based online ministry application tool described and accessible at https://churchonlineplatform.com. The Platform is part of a suite of software products and services owned and operated by Life Covenant Church, Inc., which we’ll refer to as “Life.Church,” “us,” or “we” throughout this policy. The Platform is intended for use by non-profit institutions, and use of the Platform requires registration by an account administrator. We call those non-profit institutions as well as their administrators and other registered account users “Members.” Unregistered internet users that are merely browsing Platform sites are called “Visitors”. When we refer to both in this policy, we’ll use the term “you.” In using the Platform, Members are able to create websites that have their own respective users which Members may collect information directly or through third party apps. We call these Member websites “Your Websites” and the users of “Your Websites” we call “Your Users.”

Accepting the Terms

How We Use Your Information

We do not share your personal data with or sell to any third-party advertisers or ad networks for their advertising purposes. We use data that we may collect about you or that you provide to us, including any personal information, as follows:

To provide you with the Platform, and any other information, products, or services that may help you in ministry;
As described in this Privacy Policy;
To fulfill any other purpose for which you provide it;
To carry out our obligations and enforce our rights under this Privacy Policy and our Terms of Use;
In any other way we may describe when you provide the information;
For any other purpose with your consent.

Your ability to access the Platform is not contingent on you providing us with your personal information, and you may decline to submit personal information to us, however, that may inhibit us from providing you with certain Platform services and/or functionality.

Facilitating Your Use of the Platform

We use your personal data like email or church name to authorize your access to Church Online Platform. We also use your personal data to provide certain functionality of the Platform depending on the functionality you use and choose and the personal data you agree to provide. We use the data that we have about you to provide, improve, and personalize the Platform, including with the help of automated technologies discussed in this policy and the inferences that we make from information we collect.

Communications

We may contact you through email or other media to relay Platform updates and news messages. You may unsubscribe from these messages via the unsubscribe link in emails providing these messages; however, if you unsubscribe, you may miss out on important account updates that could impact your services.

Service-Related Messages

We may use your information to contact you about account, security, legal, and other service-related issues. We will do this through in-app notifications, email, or other channels. Please be aware that you cannot opt-out of receiving service messages (an example is a password reset email) from us, including security and legal notices.

Analytics and Performance

We desire to see online church engagement increase throughout the world. We use the personal data available to us to observe social, economic, and geographic trends as they pertain to online ministry. In some cases, we work with trusted third parties to perform this research, under controls that are designed to protect your privacy. We may publish or allow others to publish our insights and platform data but only in an aggregated form that does not disclose your personally identifiable information. For example, we may use your data to generate statistics about overall usage of the Platform worldwide and in specific countries and geographic regions.

We use de-identified and aggregate user data to market the Platform, such as celebrating the total number of users across the Platform. We use data, including user-provided personal information, aggregations of user data, data collected through use of the Platform, public feedback and information inferred from this data to conduct internal research and development in order to provide a better overall Platform experience, measure the performance of the Platform, and increase use of the Platform and its features.

Security and Technical Issues

We use the data (which can include your communications) to investigate, respond to and resolve complaints, legal, security and technical issues concerning the Platform. We use your data and communications if we think it is necessary for security purposes or to investigate possible fraud or violations of law or our Terms of Use or this Privacy Policy and/or attempts to harm others.

How We Use Your Users’ Information

It is your decision to collect information about Your Users through the Platform and Your Websites; we merely facilitate that collection and use through choices you make when using the Platform. Accordingly, as between you and Life.Church, it is your sole responsibility to ensure that you have a legal basis for the collection, use, dissemination, and other processing of Your Users’ information.

We do not share Your Users’ personal data with any third-party advertisers or ad networks for their advertising purposes. We use data that we collect about Your Users or that you provide to us, including any personal information, as follows:

To provide Your Users with Your Websites through the Platform and the functionality you choose to provide Your Users on Your Websites, and any other information, products, or services that Your Users request;
As described in this Privacy Policy;
To fulfill any other purpose for which Your Users provide it;
To carry out our obligations and enforce our rights under this Privacy Policy and our Terms of Use;
In any other way we may describe when Your Users provide the information; and
For any other purpose with Your Users’ consent.

Your Users’ ability to access Your Websites is not contingent on Your Users providing personal information, and they may decline to submit personal information, however, that may inhibit Your Users from being provided with certain Platform services and/or functionality.

Facilitating Your Users’ Use of Your Website

Based on choices you make concerning Your Website, we may collect and use Your Users’ personal data to authorize their access to Your Websites. We may also use Your Users’ personal data to provide certain functionality on Your Websites depending on the functionality you use and choose and the personal data you seek through Your Websites and that Your Users agree to provide. We may use the data that we have about Your Users to provide, improve, and personalize the Platform, including with the help of automated technologies discussed in this policy and the inferences that we make from information we collect.

Communications

Outside of any service-related messages, we do not contact Your Users through email or other media to relay Platform updates and news messages. It is your sole responsibility to do so if you so choose. It is your sole responsibility to ensure you have a legal basis for the communications you engage in with Your Users.

Service-Related Messages

We may use Your Users’ information to contact them about account, security, legal, and other service-related issues. We will do this through in-app notifications, email, or other channels. Please be aware that you cannot opt-out of receiving service messages (an example is a password reset email) from us, including security and legal notices.

Analytics and Performance

As noted above, we desire to see online church engagement increase throughout the world. We use Your Users’ information submitted through Your Websites on the Platform for the Analytics and Performance discussed above but only in an aggregated form that does not disclose their personally identifiable information. As discussed below, we use automated technologies such as cookies to collect certain data of Your Users to facilitate their use of Your Websites through the Platform.

Security and Technical Issues

We use the data (which can include communications) of Your Users to investigate, respond to and resolve complaints, legal, security, and technical issues concerning the Platform. We use Your Users’ data and communications if we think it is necessary for security purposes or to investigate possible fraud or violations of law or our Terms of Use or this Privacy Policy and/or attempts to harm others.

Online Chat of Your Users

The Platform will allow both You and Your Users to communicate and connect with other people via online chat functions on Your Websites. It is your choice whether to offer such communication ability to Your Users and Your Users’ choice whether to communicate with others or to allow communication between others with such functionality. Life.Church securely stores chat transcripts for 30 days, and may use pieces of conversations for marketing and promotional purposes, or to improve the Platform.

If you choose to enable communication via this chat functionality, as between you and Life.Church, you are solely responsible for all such communications and the privacy of the information shared among Your Users. Life.Church has no control over any communications of Your Users using such functionality and you agree and acknowledge that Life.Church has no liability or responsibility for any such communications or your choice to offer functionality facilitating the same.

Information We Collect and How We Collect It

Information You Provide to Us

Visitors do not need to submit personal information. to view the websites that describe our Platform. You do not have to become a Platform Member to view Your Website or another website created by another Member using the Platform.

You do need to become a Member and create a Platform account to create and administer Your Websites via the Platform. To become a Member, you are required to create an account and provide certain information such as your administrator's name and email address, your business name and website URL, and the state or country in which you are located. This information is collected, stored and used by Life.Church to facilitate your use of the Platform, maintain the security of Your Websites, prevent unauthorized administration of Your Websites, and for our other legitimate business purposes.

Beyond this required information, you have choices about whether to provide additional information to be associated with your Member account. We collect personal data from you when you provide, post, or upload it to the Platform. You do not have to provide such information; however, if you do not, it may limit our ability to personalize or fully support the Platform and your ability to use the Platform to its fullest extent.

Information You Collect from Your Users

You also have choices about what information you collect, use, share, and otherwise process about or from Your Users. We facilitate this collection, use, and sharing based on the choices you make to facilitate your use of the Platform. Your Websites may operate without Your Users’ personal information; however, use of Your Users’ information allows you to personalize Your Websites and use the Platform to its fullest extent.

Based upon the choices you make, Your Users will have options as to what information they provide through Your Websites. For example, the Platform will allow you to provide Your Users the option to link Your Websites on the Platform with other websites, applications, and services or profiles Your Users may have with third party applications. If you allow this option and Your Users choose to link with these third party applications and services, Your Users will provide you and us the personal data stored on those applications to the Platform and Life.Church. For example, Your User may create an account on Your Website by linking their Facebook account to the Platform, providing personal information they have opted to share through Facebook to you and Life.Church through the Platform. Your Users may revoke a link with such accounts and third party applications by modifying their settings with those applications. As another example, the Platform will allow you to provide Your Users the option to provide their device information and telephone number for communications about events and services. If you allow this option and Your Users provide such information to you on Your Website, it will be stored and used by Life.Church to facilitate the communications you opt to allow.

The Platform will allow you to provide Your Users the option to link to or interact with third party websites, applications, or services with which Your Users have no prior relationship. For example, You may provide a link for Your Users to fill out a form You house with a third party service or You may provide Your Users a way to give through a third party giving tool. You are responsible for any data collected, stored, or used based on those interactions, and you are responsible for your own relationship with those third parties and their subsequent data, privacy, and communication practices with Your Users.

You decide what information you seek and collect about Your Users through the Platform and Your Websites. Accordingly, as between you and Life.Church, it is your sole responsibility to ensure that you have a legal basis for the collection, use, dissemination and other processing of Your Users’ information.

Sensitive Data

We do not require that you or Your Users provide sensitive data such as religious denomination, race, ethnicity, philosophical beliefs, or physical or mental health to create or maintain a Platform account or to use Your Websites. It is your choice whether to provide such sensitive information should it be an option to do so, and your choice to seek such information about Your Users. If you choose to provide any sensitive information, it may be used by Life.Church to create a more personalized or efficient Platform experience like other non-sensitive information you provide. In any event, Life.Church will only process sensitive data provided to us for Life.Church’s legitimate activities on your behalf and will not disclose this information. We will maintain your information subject to appropriate safeguards discussed in this policy and otherwise provided by Life.Church. Should you have any questions, feel free to contact us at info@online.church.

Use For Other Services

We may combine the information you submit under your account with information you provide us through other Life.Church services and products as well as inferences we make from this information to provide you with a better experience and to improve the quality of all services and products provided to you by Life.Church.

Posts and Contributions

When the Platform allows you to provide information to be published, distributed, or displayed on Your Website or for you to allow Your Users to publish, distribute, or display information on Your Websites, we refer to that as “posted,” which can be on public areas of the Platform, Your Websites or transmitted to other users of the Platform or third parties, all of which we’ll call “User Contributions.” For example, these include activities such as posting church-specific information, contributing messages to chat, and posting video/audio/graphical assets.

Please keep in mind that if you or Your Users disclose personal information in a public manner whether through chat postings, social media, message boards, or other public online forums, this information may be collected and used by others. User Contributions are posted and transmitted at the contributor’s sole risk. We cannot control the actions of other users or third parties with whom you or Your Users choose to share User Contributions. Therefore, we cannot and do not guarantee that User Contributions will not be viewed by unauthorized persons, nor do we accept any liability associated with User Contributions.

Automatic Data Collection Technologies

Service Use. We log usage data when you use the Platform or Your Users use Your Websites, including when you view or click on content, browser type, browser language, perform a search or request, the date and time of your request, install an update, seek new functionality, or use one or more tools offered through the Platform. We use log-ins, device information, internet protocol (“IP”) addresses, and cookies and similar technologies to identify and log use.

Cookies and Other Similar Technologies. We use cookies and similar technologies (for example, web beacons, pixels, tags and device identifiers) to recognize you and/or your device(s) as well as Your Users and/or their devices on, off, and across the different applications of the Platform. Cookies and similar technologies help to facilitate the best possible user experience of the Platform as they allow us to recognize and maintain user preferences from session to session, help us keep accounts safe, and generally improve the functionality of the products and services offered through the Platform. They also help us ensure that Member information is used in association with the correct Member account. Cookies also enable us to maintain preferences of Your Users on Your Website from session to session and to ensure that Your Users’ information is used in association with their account, if any, on Your Websites. Importantly, we do not use cookies or similar technologies to facilitate interest-based ads from third parties.

Although most internet browsers accept cookies and the like by default, you can control these types of technology through your browser settings and similar tools and agree to refuse all cookies altogether. If you refuse to accept cookies and similar technologies by activating the appropriate setting on your browser or smartphone, you may be unable to access certain parts of the Platform, prohibiting us from delivering the full capability of the Platform and preventing the use of certain features and services that require these technologies. By agreeing to our Privacy Policy, you agree to the use of cookies and similar technologies as described in this policy. If you use the Platform without changing your browser or device settings to disable cookies, we'll assume that you consent to receive all cookies provided through the Platform.

Device ID and Location. When you access or leave the Platform, we may receive the URL of both the site you came from and the one you go to next. We may also get information about your IP address, proxy server, operating system, web browser and add-ons, device identifier and features, and/or ISP or your mobile carrier. We may also receive data from your devices and networks, including location data. If you use the Platform from a mobile device, that device may send us data about your device and GPS location based on your phone settings and access you have granted to the Platform.

We use this information to provide an efficient Platform experience for you and to communicate with you more effectively. The information is also collected to determine the aggregate number of unique devices using the Platform and/or parts of the Platform, track total usage, and analyze usage data to improve Platform functionality for all Members and Visitors. We may combine this information with information from third parties to provide you with a better experience and to improve the quality of our service.

We do not share any of your personally identifiable information along with your device identification or location without your explicit permission. However, we may automatically collect certain details of your use of the Platform, including traffic data, location data, logs, and other communication data and the resources that you access and use on or through the Platform. We may collect information about your computer and mobile device and internet connection, including the mobile device’s unique device identifier, IP address, operating system, browser type, and mobile network information. If you do not want us to collect this information you should cease use of the Platform.

Your Communications Directly To Us. We collect information about you when you send, receive, or engage with messages with us, including when you submit personal information or requests by emailing info@online.church. We retain those communications to process your inquiries, respond to your requests, and improve our services.

Personal Information. We may tie information we do collect automatically as described above to personal information you provide to us to tailor the Platform to you and make suggestions about other services and functionality as described above. Life.Church is consistently seeking new and improved ways to offer the Platform and improve online ministry. As we improve the Platform, this may mean the collection of new data or new ways to use data. Because the Platform is dynamic, and we continuously seek to offer new features, we may require the collection of new information. If we collect materially different personal data or materially change how we use your data, we will notify you and may also modify this Privacy Policy.

Third-party Information Collection

This Privacy Policy applies only to Church Online Platform. Please keep in mind that the Platform may contain links to other websites or apps that are owned and operated by third parties as well as Life.Church. You are responsible for reviewing the privacy statements and policies of those other websites you choose to link to or from the Platform, so that you can understand how those websites collect, use and store your information.

Life.Church cannot regulate other sites, content, or applications linked or provided from within the Platform and our various web sites and services. Some content or applications, including partner offers, on or in Platform properties may be served by third-parties, including content providers, application providers, analytics companies, your mobile device manufacturer, and your mobile service provider. These other sites may place their own cookies or other files on your computer, collect data or solicit personal information from you. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps, and other online services. They may use this information to provide you with interest-based (behavioral) targeted content. We do not control these third parties' tracking technologies or how they may be used. If you have any questions about targeted content, you should contact the responsible provider directly.

Disclosure of Your Information

Disclosure on Your Behalf

We may disclose personal information that we collect or you provide as described in this Privacy Policy to fulfill our obligations under our Terms of Use, the purpose for which you provide it, for any other purpose you request when you provide the information, or for any other purpose for which we have your consent.

Disclosure by You

When information is shared through the Platform, that information is viewable by you and by anyone else you chose to share it with. If you give access to your Platform account to other applications and services, based on your approval, those services would then have access to your shared information. The use, collection and protection of data you collect and receive through the Platform from Your Users or otherwise is your sole responsibility.

Internal Disclosure

We may share personal data received through the Platform internally within Life.Church to help combine the personal information covered across the different aspects of the Platform and our other products and services to help provide services to you in a manner that is personalized and useful to you and others. For example, we can personalize potential services to recommend to you using cookies or similar technologies that track what functionality you have already opted to receive.

Disclosure to Our Service Providers

We may disclose personal information that we collect or you provide as described in this Privacy Policy to contractors, service providers, and other third parties we use solely to support the Platform (such as cloud hosting, maintenance, analysis, audit, payments, fraud detection, communication, and development). For example, some of the services used to send emails and notifications are built and managed by third parties, so some of your information is sent securely to those services to provide such functionality. They will have access to your information as reasonably necessary to perform these tasks on our behalf and are obligated not to disclose or use it for other purposes.

Legal Process

It is possible that we will need to disclose information collected through the Platform when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with you; (3) investigate and defend ourselves against any third-party claims or allegations; (4) protect the security or integrity of the Platform; or (5) exercise or protect the rights and safety of Life.Church, our Members and/or Visitors, Your Users, personnel, or others. We attempt to notify Members about legal demands for their personal data and the personal data of users of Member Websites when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overboard, vague, or lack proper authority, but we do not promise to challenge every demand.

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Your Rights to Deleting, Accessing and Correcting Your Information

For personal data that we have about you or Your Users, you and Your Users have the following rights:

Deletion: You or Your Users may ask us to erase or delete all or some of the personal data we have about you or Your Users . Please note that doing so may limit the ability to use certain functionality of the Platform. Please note that an email address is required to have a Member account.
Correction/Modification: You or Your Users may edit some of the personal data associated with accounts on the Platform or Your Websites or ask us to change, update, or fix that data in certain cases, including if it’s inaccurate.
Object to, or Limit or Restrict, Use of Data: You or Your Users can ask us to stop using all or some of the personal data we have about you or Your Users (for example, if you have no legal basis to keep using it) or to limit our use of it (for example, if we come to believe that personal data is inaccurate or unlawfully held).
Right to Access and/or Take Your Data: You or Your Users can ask us for a copy of the personal data of you or Your Users that has been provided to us.

To make these or any other requests with respect to your personal information, you or Your Users may send us an e-mail to info@online.church. You or Your Users may also contact us at: Life Covenant Church, Inc., attn.: Church Online Platform Support, 4600 E. 2nd St., Edmond, Oklahoma 73034. We ask that individuals making requests identify themselves and identify the information requested to be accessed, corrected or removed before we process any requests. If Your Users make such a request, we may also notify you to verify the identity of the user and the accuracy of their request. We may decline to process requests if we cannot verify the requestor's identity, if we believe the request will jeopardize the privacy of others, if we believe the change would violate any law or legal requirement or cause the information to be incorrect, or for a similar legitimate purpose. In any case, where we provide information access, deletion or correction, we perform this service free of charge, except if doing so would require a disproportionate effort.

If you choose to close your account or ask that we modify or delete some or all of your personal information, we will retain your personal data if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce our Terms of Use or fulfill any others requests from you (for example, to opt-out of further messages or for a copy of your data).

Life.Church reserves the right to maintain your information, including inferences made with your information after deletion of an account. We have no control of information you have shared with others through the Platform or what information you allow Your Users to share through the Platform after you close your account or have asked to delete information or attempted to delete your account yourself. Your information and content you have shared may continue to be displayed in the services of others (for example, search engine results) until they refresh their cache.

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Notice to California Residents – California Privacy Rights

If you are a California resident and have provided us with personal information, California law requires that we provide you with a summary of your privacy rights under the California Online Privacy Protection Act (the “Act”) and the California Business and Professions Code. As required by the Act, we will provide at your request the categories of personally identifiable information that we collect through the Platform and the categories of third party persons or entities with whom such personally identifiable information may be shared for direct marketing purposes at your request. California law requires us to inform you, at your request, (1) the categories of personally identifiable information we collect and what third parties we share that information with; (2) the names and addresses of those third parties; and (3) examples of the products marketed by those companies. The Act further requires us to allow you to control who we can and cannot share that information with. To obtain this information, please send a request to info@online.church and include the phrase “California Privacy Request” in the subject line. When contacting us, please indicate your name, address, email address, and what personally identifiable information you do not want us to share with third parties. Please allow thirty (30) days for a response. Also, please note that there is no charge for controlling the sharing of your personally identifiable information or requesting this notice.

Security and Protection

We implement industry-standard security safeguards designed to protect your data. These include using encryption for your data while it is being transmitted between your device or browser and our servers.

However, given the nature of communications and information technology, and that the use of the internet has inherent risks, although we regularly monitor for possible vulnerabilities and attack, we cannot warrant or guarantee that information provided to us through the Platform or stored in our systems or otherwise will be absolutely free from unauthorized intrusion by others, nor can we warrant or guarantee that such data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. In the event of any theft, misuse, sale, or loss of data outside of the control of Life.Church, we will not be held liable for damages either material or perceived.

Users From Outside the United States

The Platform is offered in and from Oklahoma within the United States and your use of the Platform and this Privacy Policy is governed by the laws of the United States and the State of Oklahoma. If you are using the Platform from outside the United States, please be aware that your information and the information of Your Users may be transferred to, stored, and processed in the United States where our servers are located and our central database is operated. We process data both inside and outside of the United States and have contractual commitments between us and companies transferring personal data for us that require the protection and security of such data. Nevertheless, the data protection and other laws of the State of Oklahoma, the United States, and other countries might not be as comprehensive as those in your country. By using the Platform, you consent to your information being transferred to our facilities and to the facilities of those third-parties with whom we share it with as described in this Privacy Policy, and you agree that the data protection and other laws of the State of Oklahoma shall govern and take precedence over any other state or country’s laws in any legal or other proceeding regarding use of the Platform by You. You further agree that you are solely responsible for complying with the laws of your country, including those that that concern data privacy laws and behaviors between You and Your Users.

Processing of Data

We will only collect and process personal data about you and Your Users where we have lawful bases. Lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you (such as providing the Platform and Platform functionality you request and acting in accordance with this Privacy Policy and our Terms of Use) and other legitimate interests. Such legitimate interests include protection to you, us and other Members and third parties, to comply with applicable law, to enable and administer our business, to manage corporate transactions, to generally understand and improve our business and user relationships, and to enable us and other users of the Platform to connect with you to exchange information, provided that the foregoing adequately protects your rights and freedoms.

Where we rely on your consent to process your personal data, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object. If you have any questions about the lawful bases upon which we collect and use your personal data, please contact us at info@online.church.

You decide what information you seek and collect about Your Users through the Platform and Your Websites. Accordingly, as between you and Life.Church, it is your sole responsibility to ensure that you have a lawful basis for the collection, use, dissemination and other processing of Your Users’ information. Where you rely on Your Users’ consent, as between you and Life.Church, it is your sole responsibility to ensure Your Users know they have the right to withdraw or decline consent at any time and where you rely on legitimate interests, that they have the right to object.

Users From Outside the United States

Changes to Our Privacy Policy

We may update our Privacy Policy from time to time to reflect changes in our practices. We will post any changes to our Privacy Policy on this page. If we make material changes to how we treat our users’ personal information, we will provide a notice that the Privacy Policy has been updated. The date the Privacy Policy was last modified is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting this Privacy Policy to check for any changes.

Children Under the Age of 16

We assume that all administrators for Member accounts are over the age of 18. We do not collect personal information from any person we actually know is under the age of 16 without the consent of the parent or legal guardian of that minor. We assume that you do not collect information from any person you actually know is under the age of 16 without the consent of the parent or legal guardian of that minor. A parent or guardian may consent to the use of the Platform by a minor, which parent or guardian is solely responsible for providing supervision of the minor’s use of the Platform and assumes full responsibility for the interpretation and use of any information or suggestions provided through the Platform. If you believe we might have any information from or about a child under 16, please contact us at info@online.church. If we learn and have confirmation we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information.

Contact Information

To ask questions or comment about this Privacy Policy and our privacy practices, you may contact us at: Life Covenant Church, Inc., attn.: Church Online Platform Support, 4600 E. 2nd St., Edmond, Oklahoma 73034, or at info@online.church.

Church Online Platform is part of the Life.Church Open Network