PRIVACY POLICY

The categories of information described above are collected from the following categories of sources:

 

• Directly from you or your agents, such as through your submissions to the Services.

 

• Directly and indirectly from activity through the Services, such as through your interaction with the Services.

 

• From third parties that work with us to provide the Services.

 

1.2 Information. Pushly may obtain information about you after you provide information to a third party (such as a customer of Pushly that uses the Services) and you permit that party to share the information.

 

1.3 Technology Information; User Behaviors Collected with Cookies, Web Beacons, and Other Information. We use cookie and web beacon technology to associate certain Internet-related information about you, such as your Internet Protocol address and what Web browser you are using, with certain of your online behaviors, such as clicking on particular content (“Technology Information”).

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(A) Cookies. A cookie is a small amount of data stored on your computer or device that allows us and/or our customers with whom we contract (“Customers”) to identify your IP address with corresponding information in our Services database. We and/or our Customers may use cookies to track clicks on or views of content. To learn more about how we use cookies and how you can remove cookies placed on your computer or device or prevent placement of cookies on your computer or device, please see Section 6.2 below and our Cookie Policy available at URL[ME1] . To learn more about cookies in general, please visit http://www.cookiecentral.com

 

(B) Web beacons. A web beacon is programming code used to display an image on a web page and can also transfer an individual’s user identification to a database and associate the individual with previously acquired information about the individual. Web beacons enable us to track certain websites you visit or content you view online. Web beacons help determine products or services in which you may be interested and help track online behaviors for marketing purposes. More information about web beacons is available at http://www.webopedia.com/TERM/W/Web_beacon.html.

 

(C) Where Technology Information is Collected. Technology Information is collected directly from content delivered through the Services or indirectly through Customers. We may set a cookie on your computer or device when you view content displayed on Customer websites. After a cookie is set, we may track how you interact with the content and the Customer website (for example, browsing). If you agree to allow browser-enabled push notifications (“Notifications”), we or a Customer may send Notifications that include Customer messages.

 

1.4 No Information Collected from Minors. MINORS UNDER THE AGE OF 18 SHOULD NOT PROVIDE ANY PERSONAL INFORMATION, INCLUDING EMAIL ADDRESS, TO US. If we are notified that we have personal information about a minor under the age of 18, that information will be promptly deleted from our database.

 

2. How we Use and Share the Information we Collect

 

2.1 Discretion to Use Information. Information voluntarily provided to us or lawfully obtained by us is our property and may be used by us for any lawful purpose, including the sale, lease, or transfer of the information to Customers.

 

2.2 General Uses of Information. Information collected by us is used to:

 

• Fulfill the purpose for which the information was provided by you.

• Perform activities described to you when collecting your information or as set forth in the California Consumer Privacy Act (“CCPA”) or other applicable law.

• Provide you with information, products, or services that have been requested.

• Perform internal and external marketing, including delivery of content and information.

• Carry out obligations and enforce contractual rights.

• Improve the Services, such as through testing, research, analysis, and development.

• Respond to requests from law enforcement and government organizations as required by law, court order, or government regulation.

• Evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, sale, or other transfer of some or all of our assets whether on an ongoing basis or as part of a discrete transaction in which collected information is among the assets transferred.

 

2.3 Targeted Advertising and Content. We may use information to target content more effectively. When an individual is online, we may use Technology Information to associate an individual with other of the individual’s information and attempt to show content to which the individual may respond.

 

2.4 Legal Process. We may disclose information to respond to subpoenas, court orders, and other legal process as required by law.

 

2.5 Summary Data. We may sell or transfer non-individualized information, such as summary or aggregated anonymous information about all persons or sub-groups of persons.

 

2.6 Disclosure and Sale of Information. Our disclosure and transfer of information (for example, to Customers) may be considered a sale under applicable law.  We may sell or disclose information for a business purpose. In the past twelve (12) months, the following categories of information have been sold or disclosed for a business purpose:

• Identifiers

• Inferences drawn from any other information
   

3. How we Store and Protect the Information we Receive

 

We store information on servers or other equipment that have data security measures designed to protect against the loss, misuse, and alteration of the information under our control. We also maintain physical and procedural safeguards designed to protect information. Notwithstanding such measures, we cannot guarantee that any security measures will prevent information from being illegally accessed, stolen or altered.

 

4. Privacy Practices of Third Parties

 

4.1 Third Party Cookies and Web Beacons. Customers who use our Services may use their own cookies, web beacons and other technology to collect information about you. We do not control Customers’ use of such technology. For Notifications, cookies may be placed at the time you open and/or click within a Notification sent through the Services by a Customer. This Privacy Policy does not apply to the practices of Customers or other companies that we do not own or control or to people that we do not employ or manage.
 

4.2 Affiliated Companies that are not Customers. We may disclose or transfer information to entities wholly owned or controlled by us, in our discretion.

 

5. Your Rights in Information and User Data

 

You may have several rights under applicable law regarding information collected by us. These may include:

 

• The right to know what categories and specific pieces of information are collected, disclosed for a business purpose, or sold by requesting this information from us.

• The right to request deletion of information collected or maintained by us.

• The right to opt-out of the sale of collected information.

• The right not to receive discriminatory treatment by us for choosing to exercise your privacy rights.

• The right to designate an authorized agent for making requests under the CCPA or other applicable law on your behalf.

 

6. EU and UK Residents Rights in Information and User Data

 

6.1 In this section we have listed the rights that EU and UK residents have under data protection law.

 

6.2 Your principal rights under data protection law are:

 

(a)         the right to access - you can ask for copies of your personal data; 

(b)        the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data; 

(c)         the right to erasure - you can ask us to erase your personal data; 

(d)        the right to restrict processing - you can ask us to restrict the processing of your personal data; 

(e)        the right to object to processing - you can object to the processing of your personal data; 

(f)         the right to data portability - you can ask that we transfer your personal data to another organisation or to you; 

(g)         the right to complain to a supervisory authority - you can complain about our processing of your personal data; and 

(h)        the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent. 

 

6.3 These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://edpb.europa.eu/our-work-tools/general-guidance/gdpr-guidelines-recommendations-best-practices_en and https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/individual-rights/individual-rights/.

 

7. How You May Exercise Your Rights

 

7.1 Websites. To prevent us from tracking your behavior on a website, turn off cookies from that website and do not click on or interact with any content. Please note that we do not have a mechanism or process to respond to any “do not track” signals which a web browser may send or receive, other than as described in this section.

 

7.2 Cookies. Check instructions about your web browser to learn how to prevent placement of, or how to remove, cookies placed on your computer or device by us. You can opt-out of receiving cookies from a variety of ad providers and ad servers by visiting the following sites and following the instructions provided: http://www.youronlinechoices.com/ and http://www.aboutads.info/choices.

 

7.3 Notifications. If you no longer wish to receive Notifications from the Services, you may opt-out by turning them off within the settings of your mobile device or browser. These settings may vary depending upon the brand and type of device and/or browser you are using. If you have enabled Notifications on more than one device (such as your phone and your laptop), you will need to opt-out on each device.

 

7.4 Collected Information. Due to the nature of information collected, we cannot verify your identity to the degree of certainty required to fulfill requests to know or delete your collected information. We cannot fulfill these requests because information collected from you is associated with only one static identifier and cannot be linked to other information collected from you. All other information collected from you does not provide a reliable method for verifying your identity. Any requests for deletion of your information will instead be treated as requests to opt-out of the sale of your information. You may opt-out of the sale of personal information by (i) visiting our homepage at https://pushly.com/ and submitting requested information through the “Do Not Sell or Share My Personal Information” link, (ii) emailing us at privacy@pushly.com, or (iii) indicating that you do not wish to have your information sold prior to submitting it through the Services.

 

7.5 You may exercise any of your rights in relation to your personal data. Please email us at privacy@pushly.com. We may request information from you in order to verify your identity when designating an authorized agent. We may also ask for your authorized agent to provide a written permission from you giving them authorization and verify their own identity by submitting information requested by us.

 

8. EU and UK Representatives

 

8.1 Our representative within the EU with respect to our obligations under data protection law is IT Governance Europe Limited (ITG EU).

 

8.2 You can contact them using the details below:

 

Email: eurep@itgovernance.eu

Post to: ITG EU

6th Floor

South Bank House

Barrow Street

Dublin 4

 

8.3 Our representative within the UK with respect to our obligations under data protection law is GRCI Law.

 

8.4 You can contact them using the details below:

 

Email: ukrep@grcilaw.com

Telephone: 0333 800 7000
Post to: GRCI Law
Unit 3 Clive Court
Bartholomew’s Walk
Cambridgeshire Business Park
Ely, CB7 4EA

 

9. Data Protection Officer

 

We have appointed GRCI Law as our Data Protection Officer and if you have any questions about this Privacy Policy or our handling of your personal data you can contact them using the details set out below:

 

Email: dpoaas@grcilaw.com
Telephone: 0333 800 7000
Post to: GRCI Law
Unit 3 Clive Court
Bartholomew’s Walk
Cambridgeshire Business Park
Ely, CB7 4EA
 

10. More Information

 

For more information about protecting your privacy, you may wish to visit http://www.privacyalliance.org. If you wish to be notified of any updates to this Privacy Policy, please check back frequently as any updates will be posted to this website with a new last updated date. If you have questions about this Privacy Policy and your rights under this Privacy Policy, please email us at privacy@pushly.com or write to us at:

 

Pushly

Attn: Privacy

420 Nichols Rd., 2nd Floor

Kansas City, Missouri 64112

USA

 

 Cookie Policy URL.