PushEngage understands that Your privacy is important to You and that You care about how Your information is used and shared online. We respect and value the privacy of everyone who visits Our Site and will only collect and use information in ways that are useful to You and in a manner consistent with Your rights and Our obligations under the law.

This Policy applies to Our use of any and all data collected by Us in relation to Your use of Our Site. Please read this Privacy Policy carefully and ensure that You understand it. Your acceptance of Our Privacy Policy is deemed to occur upon Your first use of Our Site. If You do not accept and agree with this Privacy Policy, You must stop using Our Site immediately.

1. DEFINITIONS AND INTERPRETATION

In this Policy the following terms shall have the following meanings:

“Account”means an account required to access and/or use certain areas and features of Our Site.
“Cookie”means a small text file placed on Your computer or device by Our Site when You visit certain parts of Our Site and/or when You use certain features of Our Site. Details of the Cookies used by Our Site are set out in Section 11, below.
“Our Site”means this website, https://www.pushengage.com, its subdomains, and https://www.pushengage.dk, and its subdomains.
“Privacy Law”where You are established in a member state of the European Union, means (i) prior to 25th May 2018, the Directive 95/46/EC on the protection of individuals with regard to the Processing of Personal Data and on the free movement of such data and (ii) after 25th May, 2018, the EU Regulation 2016/679 (General Data Protection Regulation) and any applicable national laws made under it; where You are established in Switzerland, means the Swiss Federal Act of 19 June 1992 on Data Protection (as may be amended or superseded); and where You are established in any other territory, means data protection laws that are applicable in that territory.
“We/Us/Our”means Push Engage LLC., a Florida Limited Liability Company, registered in Florida USA whose address is Push Engage LLC. 2701 W Okeechobee Blvd Suite 200, West Palm Beach, FL 33409.
“You/Your/User”whenever the context so requires, for the purposes of this Privacy Policy, shall mean any natural or legal person who may create by registration, membership account on Our Site or agree to avail Our Services through Our Site, or otherwise access Our Site.
“Privacy Policy”shall mean and refer to this is privacy policy of [PushEngage] for handling of Your Personal Date.
“Personal Data”means data relating to a living individual who is or can be identified either from the data or from the data in conjunction with other information that is in, or is likely to come into, the possession of the data controller.
“GDPR”shall mean the EU Regulation 2016/679 (General Data Protection Regulation) and any applicable national laws made under it.
“Services”shall mean Your use of the Our Site and any products, channels, software, data feeds and services, including Our Site.

2. INFORMATION ABOUT US

2.1.1
Our Sites, www.pushengage.com, www.pushengage.dk and its subdomains are owned and operated by Push Engage LLC, a Florida Limited Liability Company registered in the State of Florida, United States of America.

3. SCOPE – WHAT DOES THIS POLICY COVER?

3.1.1
This Privacy Policy applies only to Your use of Our Site. It does not extend to any websites that are linked to Our Site, whether We provide those links or whether they are shared by other users. We have no control over how Your data is collected, stored or used by other websites and We advise You to check the privacy policies of any such websites before providing any data to them.

4. WHAT DATA DO WE COLLECT?

4.1.1
Some data will be collected automatically by Our Site (for further details, please see Section 11 on Our use of Cookies and https://www.pushengage.com/cookies, other data will only be collected if You voluntarily submit it and consent to Us using it for the purposes set out in Section 5, for example, when signing up for an Account.

4.1.2
Depending upon Your use of Our Site, We may collect some or all of the following data, when You sign-up on Our Site:

4.1.2.a.1 Your name;
4.1.2.a.2 Website URL;
4.1.2.a.3 contact information such as email addresses and telephone numbers;
4.1.2.a.4 web browser type and version (automatically collected);
4.1.2.a.5 IP address of signup (automatically collected);
4.1.2.a.6 operating system (automatically collected).

4.1.3
If You subscribe to web push notifications provided by us on any controller’s website, We gather:

4.1.3.a.1 device ID or device token for web push subscription, which is a pseudonymous identifier if You ‘Allow’ web push notifications on that site;
4.1.3.a.2 Web browser type and version (automatically collected);
4.1.3.a.3 Optional – city, state and country of the place of access, if this information is available and enabled by the controller;
4.1.3.a.4 Optional: any other extra information like product browsed, categories of product, user preferences, on the website of the controller, if configured by controller; and
4.1.3.a.5 Optional: any segmentation or extra information passed by the controller for personalizing notification.

5. HOW DO WE USE YOUR DATA?

5.1.1
All personal data is stored securely in compliance with the applicable Privacy Law and the US – EU Privacy Shield requirements, if US-EU Privacy Shield is applicable.

5.1.2
We use Your data to provide the best possible products and services to You. This includes:

5.1.2.a.1 Providing and managing Your Account;
5.1.2.a.2 Providing and managing Your access to Our Site;
5.1.2.a.3 Personalising and tailoring Your experience on Our Site;
5.1.2.a.4 Supplying Our products and Services to You;
5.1.2.a.5 Personalising and tailoring Our products and Services for You;
5.1.2.a.6 Sending and responding to communications from You;

5.1.3
In some cases, the collection of data may be a statutory or contractual requirement, and We will be limited in the products and services We can provide You, without Your consent for Us to be able to use such data.

5.1.4
In some cases, the collection of data may be a statutory or contractual requirement, and We will be limited in the products and services We can provide You, without Your consent for Us to be able to use such data.

5.1.5
Under GDPR, We will ensure that Your personal data is processed lawfully, fairly, and transparently, without adversely affecting Your rights. We will only process Your personal data if at least one of the following basis applies:

  1.  You have given consent to the processing of Your personal data for one or more specific purposes;
  2. processing is necessary for the performance of a contract to which You are a party or in order to take steps at the request of You prior to entering into a contract;
  3. processing is necessary for compliance with a legal obligation to which We are subject to;
  4. processing is necessary to protect the vital interests of You or of another natural person;
  5.  processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
  6.  processing is necessary for the purposes of the legitimate interests pursued by Us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

6. HOW AND WHERE DO WE STORE AND SECURE YOUR DATA?

6.1.1
We only keep Your data for as long as We need to in order to use it as described above in Section 5, and/or for as long as We have Your permission to keep it. In any event, We will conduct an annual review to ascertain whether We need to keep Your data.

6.1.2
Some or all of Your data may be stored or transferred outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein).

6.1.3
You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store or transfer data outside the EEA, We will take all reasonable steps to ensure that Your data is treated as safely and securely as it would be within the EEA and under the GDPR. Such steps may include, but not be limited to, the use of legally binding contractual terms between Us and any third-parties.

6.1.4
Data security is of great importance to Us, and to protect Your data. We use appropriate technical and organizational measures to protect the Personal Data that We collect and process. The measures We use, are designed to provide a level of security appropriate to the risk of processing Your Personal Data.

7. DO WE SHARE YOUR DATA?

7.1.1
We may contract with third parties to supply products and services to You on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of Your data. Where any of Your data is required for such a purpose, We will take all reasonable steps to ensure that Your data will be handled safely, securely, and in accordance with Your rights, Our obligations, and the obligations of the third party under the law.
We currently contract with the below sub-processors:

Sub-ProcessorPurposePrivacy Notice
Amazon Web ServicesCloud Infrastructure for hosting and offering our serviceshttps://aws.amazon.com/privacy/

7.1.2
In certain circumstances We may be legally required to share certain data held by Us, which may include Your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from You in order to share Your data in such circumstances and will comply as required with any legally binding request that is made of Us.

8. WHAT HAPPENS IF OUR BUSINESS CHANGES HANDS?

8.1.1 
We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Data provided by You will, where it is relevant to any part of Our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use the data for the purposes for which it was originally collected by Us.

9. HOW CAN YOU CONTROL YOUR DATA?

9.1.1
When You submit information via Our Site, You may be given options to restrict Our use of Your data. We aim to give You controls on Our use of Your data including the ability to opt-out of receiving emails from Us which You may do by unsubscribing using the links provided in Our emails and by managing it through Your preferences in Your account. Further, if You are a web push subscriber at any of Our customers (or controller websites), We offer instructions and widgets which Our customers can offer to unsubscribe You, and where You can control the level of use of Your data.

10. YOUR RIGHT TO WITHHOLD INFORMATION AND YOUR RIGHT TO WITHDRAW INFORMATION AFTER YOU HAVE GIVEN IT

10.1.1
We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Data provided by You will, where it is relevant to any part of Our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use the data for the purposes for which it was originally collected by Us.

10.1.2
You may restrict Your internet browser’s use of Cookies. For more information, see Section 11 and our cookie policy at https://www.pushengage.com/cookies

10.1.3
You may withdraw Your consent for Us to use Your personal data as set out in Section in 5 at any time by contacting Us using the details set out in Section 17, and We will delete Your data from our systems, and/or share steps on how to unsubscribe. However, you acknowledge this may limit Our ability to provide the best possible products and services to You.

11. HOW CAN YOU ACCESS YOUR DATA?

11.1.1
You have the legal right to ask for a copy of any of your personal data held by Us (where such data is held). Please contact Us for more details at care@pushengage.com, or using the contact details below in Section 13. If You are a web push subscriber to Our service, please refer to Your controller i.e. website at which You subscribed to web push notifications, to provide You these details.

11.1.2
Cookies: Our Site may place and access certain first party Cookies on Your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve Your experience of Our Site and to provide and improve Our products and services. By using Our Site You may also receive certain third-party Cookies on Your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. For more details, please refer to Our Cookie Policy at https://www.pushengage.com/cookies including a more in-depth explanation of what cookies are, the different types of cookies used, and how to change and delete them.

12. EEA SPECIFIC RIGHTS – SUMMARY OF YOUR RIGHTS UNDER GDPR

12.1.1
Under the GDPR, you have:

12.1.1.a.1 the right to request access to, deletion of or correction of, Your personal data held by Us;
12.1.1.a.2 the right to complain to a supervisory authority in event of breach of any of Our obligations towards the Personal Data under the applicable Privacy Law;
12.1.1.a.3 be informed of what data processing is taking place;
12.1.1.a.4 the right to restrict processing;
12.1.1.a.5 the right to data portability;
12.1.1.a.6 object to processing of Your personal data;
12.1.1.a.7 rights with respect to automated decision-making and profiling (see Section 13 below).

12.1.2
To enforce any of the foregoing rights or if You have any other questions about Our Site or this Privacy Policy, please contact Us using the details set out in Section 17 below.

12.1.3
If You seek access to, or wish to correct, update, modify or delete Personal Data (hereinafter referred to as a “Request”) which forms a part of Collected Data, please contact us at care@pushengage.com. We respond to all requests We receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

12.1.4
If You seek access to, or wish to correct, update, modify or delete Personal Data (hereinafter referred to as a “Request”) which is part of the Data and processed by us on behalf of our customer, You should direct Your query to our customer, that is, the controller or website owners who use our product. If You are a customer of our service(s) and wish to raise a Request on behalf of Your users and/or end-users in connection with service data, You may raise a ticket.

13. AUTOMATED DECISION-MAKING AND PROFILING

13.1.1
In the event that We use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on You, You have the right to challenge to such decisions under GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from Us.

13.1.1
The right described in Section 13.1 does not apply in the following circumstances:

a. The decision is necessary for the entry into, or performance of, a contract between the You and Us;
b. The decision is authorised by law; or
c. You have given Your direct consent.

13.1.3
We currently make the following automated decisions, based on how the controller has configured Our product for You:

13.1.3.a.1 show You targeted web push notifications, based on the product You browsed, or Your interests and preferences.

14. WHAT IS OUR LEGAL BASIS FOR PROCESSING PERSONAL DATA (EEA VISITORS ONLY)?

14.1.1
If You are a visitor from the European Economic Area, our legal basis for collecting and using the Personal Data described above will depend on the Personal Data concerned and the specific context in which We collect it;

14.1.2
However, We will normally collect Personal Data from You only where We need the Personal Data to perform a contract with You, or where the processing is in our legitimate interests or rely upon Your consent where We are legally required to do so and not overridden by Your data protection interests or fundamental rights and freedoms. In some cases, We may also have a legal obligation to collect Personal Data from You or may otherwise need the Personal Data to protect Your vital interests or those of another person;

14.1.3
If We ask You to provide Personal Data to comply with a legal requirement or to perform a contract with You, We will make this clear at the relevant time and advise You whether the provision of Your Personal Data is mandatory or not (as well as of the possible consequences if You do not provide Your Personal Data);

14.1.4
Similarly, if We collect and use Your Personal Data in reliance on our legitimate interests (or those of any third party), We will make clear to You at the relevant time what those legitimate interests are; and

14.1.5
If You have questions about or need further information concerning the legal basis on which We collect and use Your Personal Data, please contact us using the contact details provided below (as under Section 17).

15. CHILDREN’S PERSONAL DATA

15.1.1
PushEngage services are not intended for use by children. PushEngage does not knowingly collect any Personal Data from children under the age of 16. If You are under the age of 16, please do not submit any Personal Data through Our Site or Service(s). We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this notice by instructing their children never to provide Personal Data through Our Service(s) or Our Sites without their permission. If You have reason to believe that a child under the age of 16 has provided Personal Data to Us through Our Site or Service(s), please contact Us and We will delete that information and terminate the child’s account from Our databases and if it is discovered that We have collected Personal Data from someone under the age of 16, we will delete that information immediately.

16. US-EU PRIVACY SHIELD COMPLIANCE

16.1.1
PushEngage participates in and has certified our compliance with the EU-U.S. and Swiss-US Privacy Shield Framework. We are committed to subjecting all Personal Data received from European Union (EU) member countries and Switzerland, in reliance on the US-EU Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the US-EU Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List https://www.privacyshield.gov/list.

16.1.2
We are responsible for the Personal Data it receives, under the US-EU Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. PushEngage complies with the US-EU Privacy Shield Principles for all onward transfers of personal data from the EU, and Switzerland including the onward transfer liability provisions. PushEngage further commits to cooperate with EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and comply with the advice given by such authorities with regard to data transferred from the EU and Switzerland.

16.1.3
With respect to Personal Data received or transferred pursuant to the US-EU Privacy Shield Framework, We are subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, We may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

16.1.4
You can direct any questions or complaints about the US-EU Privacy Shield to Us at by email at privacy@pushengage.com (must include “Privacy Policy” in the subject line), or by post at Push Engage LLC, 2701 W Okeechobee Blvd Suite 200, West Palm Beach, FL 33409. If You have an unresolved US-EU Privacy Shield concern that We have not addressed satisfactorily, please contact Your EU DPA or the Swiss Federal Data Protection and Information Commissioner, as applicable. The contact details of the EU DPAs can be found here: ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities.

16.1.5
Under certain conditions, more fully described on the US-EU Privacy Shield website https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, You may invoke binding arbitration when other dispute resolution procedures have been exhausted.

17. Your California Privacy Rights

In addition to the rights as explained in this Privacy Policy, under California’s “Shine the Light” law, California residents who provide personal information to obtain products or services for personal, family, or household use are entitled to request and obtain from us, once a calendar year, information about the personal information we shared, if any, with other businesses for marketing uses during the immediately preceding calendar year. If applicable, this information would include the categories of personal information and the names and addresses of those businesses with which we shared such personal information for the immediately prior calendar year. To obtain this information please write to us at the address set in Section 18 Contact Us below.

18. CONTACTING US

18.1.1
If You have any complaint, concern or question about Our privacy practices, please contact Us by email at privacy@pushengage.com (must include “Privacy Policy” in the subject line), or by post at Push Engage LLC, 2701 W Okeechobee Blvd Suite 200, West Palm Beach, FL 33409 and we will respond within a reasonable timeframe after receiving Your request. Please ensure that Your query is clear, particularly if it is a request for information about the data We hold about You (as under Section 11, above).

18.1.2
If You have any support requests, please contact us at care@pushengage.com.

19. CHANGES TO OUR PRIVACY POLICY

Our business changes constantly, and our Privacy Policy will change also, as we may deem necessary from time to time, or as may be required by law. We recommend that you check this page regularly to keep up-to-date. Your continued use of the website following posting of amended policy shall constitute your acceptance to any such changes.

Last updated: December 21, 2020