Privacy Policy

PushKin is an internal employee connectivity platform designed for communication, confirmation, and coordination of an organization (a “Customer Organization” or “Employer”).  This Privacy Notice describes how PushKin, Inc., the creator of PushKin, and our affiliates (collectively, “PushKin,” “we,” and “us”) collect, use, disclose, transfer, store, retain or otherwise process your information when you (whether you are a person acting as a sole proprietor, on behalf of a “Customer Organization,” or as an employee, contractor and worker (“Employee”)) apply or sign up for a PushKin Enterprise Administrator account and other services through the PushKin app and the website pushkinapp.com (collectively, the “PushKin Platform”).

Employers

An Enterprise Administrator for a Customer Organization, including any designee(s) (the “Enterprise Administrator” or “you”), is responsible for determining which employees, contractors, and workers (“Employees”) will have access to the PushKin Platform.  

Privacy laws that apply in certain places, like Arkansas, treat “businesses/controllers” and “service providers/processors” differently. Under those laws, a business/controller is the company that decides why and how to process personal information. PushKin is the business/controller with respect to the personal information collected and processed relating to Enterprise Administrators. This Privacy Notice for Enterprise Administrators (this “Privacy Notice”) governs our collection and processing of the personal information of Enterprise Administrators who register and use the PushKin Platform.  Please read this Privacy Notice carefully. By continuing to interact with our PushKin Platform, you agree to our Employer Terms of Service and are consenting to the practices described in this Privacy Notice.

Employees

As stated above, privacy laws that apply in certain places, like Arkansas, treat “businesses/controllers” and “service providers/processors” differently. PushKin is the service provider/processor with respect to the personal information collected and processed relating to our Clients’ Employees.  Your Customer Organization/Employer is the business/controller.  This Privacy Notice does not apply to any of the Personal Information that we may collect and process on behalf of your Employer.  Any questions or requests relating to Employee personal information should be directed to your Employer.

Information Collected

PushKin collects the following personal information from Enterprise Administrators when you sign up and use our PushKin Platform:

• Account Creation.  Your name, Customer Organization and work telephone number, IP address, and occasionally your email address. We use this information to facilitate our service through the PushKin Platform and to provide technical support.    
• Billing Information. Information when you upgrade your Customer Organization to Core or Enterprise, such as credit card information, banking information, and/or a billing address.
• Messages You Send in the PushKin Platform or to PushKin.  Message content, including messages you send or receive within a Customer Organization or that you send to PushKin or PushKin Support.
• Content You Upload to the PushKin Platform.  User-generated content, including files you upload through the service such as images, and video.
• Device Information.  Log data, including your mobile device, screen resolution, and load time when using the mobile PushKin Platform, and operating system, browser type and version, and IP address when using our web PushKin Platform. We use the IP address to understand your general location and log data to improve the PushKin Platform functionality, performance, and user experience. Whether some or all of this information is collected frequently depends on the type of interface used and its settings.
• Limited Location Information.  The Location-Based Group feature is optional and used only to determine when Customer Organization members enter or leave a “geofenced” area, which is a certain radius of a defined point (usually the workplace) that the Enterprise Administrator sets. This feature approximates location based on information which varies by device, such as GPS, Wi-Fi connectivity, and network information. Users may disable our collection of location information through their device settings. PushKin does not collect or store precise geolocation data, and as provided below, we do not track user movement or enhance user data with location information.
• Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal information.
• Personal Information of your Employees that You Invite to Use the PushKin Platform. Information of Employees you provide to PushKin, including their name, phone number, IP address, and limited location information for the sole purpose of providing Location-Based Group functionality. We use this information to invite Employees to join the PushKin Platform on behalf of the Customer Organization.  An Important Note:  You and your Customer Organization are responsible for and must obtain any and all consents required by law (including, without limitation, verifiable consent, where applicable) from Employees before providing any Employee personal information to PushKin.

Usage of Personal Information

We use personal information to provide and improve the service through the PushKin Platform. This includes:

• Managing your information and accounts;
• Providing access to certain areas, functionalities, and features of our PushKin Platform such as certain Enterprise Administrator functions and tools;
• Communicating with you about your account and policy changes;
• Using your phone number to send you SMS messages so you can authenticate your account and individual identities, including when you request to exercise your rights under this policy;
• Researching and improving our PushKin Platform, to develop new products, services, and applications and ensure internal quality control and safety;
• Measuring interest and engagement in our PushKin Platform and tracking and analyzing trends and usage;
• Preventing fraud and abuse of our system and assuring compliance with our Terms of Service and Privacy Notices;
• Detecting security incidents, protecting against malicious, deceptive, or illegal activity, and prosecuting those responsible for that activity;
• Communicating with you about your use of the PushKin Platform and troubleshooting any problems you may have;
• Debugging to identify and repair errors with our PushKin Platform;
• Auditing relating to interactions, transactions and other compliance activities;
• Enforcing our agreements and policies; and
• Complying with our legal obligations.

We may use personal information pursuing our legitimate interests such as research and development (including marketing research), network and information security, and fraud prevention. If you turn on location sharing on your device, we record when you enter and leave the “geofenced” area for your Customer Organization. We don’t track you outside of this area. We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent. We may use personal information and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the device from which you access our PushKin Platform or other analyses we create.

When Your Personal Information May Be Shared

Each of the personal information categories we collect (as described in “Information Collected” above) may be shared in the following circumstances:

• Your Customer Organization pursuant to our enterprise agreement.
• We share personal information with third-party service providers who provide services to us including but not limited to payment processors, SMS-based communications, hosting services, and analytic services.
• We may disclose or transfer your personal information in connection with the sale, merger, bankruptcy, sale of assets, or reorganization of our company.
• We may disclose information with our affiliates and parent company to support our PushKin Platform and our services, offer you different and related services, product and service improvements and development, reporting, and other purposes as permitted or required by law.
• We may disclose your personal information if we believe that disclosure is reasonably necessary to comply with a law, regulation, valid legal process (e.g., subpoenas or warrants served on us), or governmental or regulatory request, or if we determine in our own discretion that your actions on PushKin constitute fraud, abuse, harassment, or are in violation of the Employer Terms of Service. We also may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. If we are going to release your personal information, we will make an effort to provide you with notice in advance through the PushKin Platform, unless we are prohibited by law from doing so.

Cookie Policy

We collect data from cookies and other technologies like pixel tags, web beacons, or other identifiers to improve the functionality and security of the Platform.

Do-Not-Track Signals

Some web browsers send “Do-Not-Track” (DNT) signals to websites, based on user settings within those browsers. Our Platform does not currently respond to DNT signals due to the lack of industry wide DNT standards. PushKin takes privacy seriously and will review this policy once standardized DNT technology is made available.

Data Retention Policy

We store the personal information we collect as described in this Privacy Notice for as long as you use our services, while your account is active or as necessary to fulfill the purpose(s) for which it was collected, provide our services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.  The personal information associated with an account that has not been accessed for six months will be considered inactive and deleted. The right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

Accessing or Deleting Your Information

You own your data. If you need to access or delete personal information stored on our servers, please send us a message at legal@pushkinapp.com describing your request. Identity verification may be required for security purposes. While some anonymized or aggregated information may not be available, we will review and respond to access or deletion requests as required by law.

Security

While no service is completely secure, PushKin implements administrative, technical or physical security safeguards and controls, including Transport Layer Security (“TLS”) and device-based encryption or other similar controls where available. In the event of a breach, we will notify affected users as required by law.  We take steps to ensure that your information is treated securely and in accordance with this Privacy Notice. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We have taken appropriate safeguards to require that your personal information will remain protected and require our third-party service providers and partners to have appropriate safeguards as well. PushKin cannot guarantee that information during transmission or while stored on our systems will be completely secure from intrusion by others. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.

Privacy Choices and Rights

We rely on your consent as a lawful basis for processing personal information during:

• the initial collection of Enterprise Administrator personal information through the PushKin Platform;
• collection of location information to enable the Location-Based Group feature. PushKin does not collect or store specific geolocation data, and we do not track user movement within or outside of a given geofenced area.

We process personal information in order to perform our contract with you.

Additionally, we process personal information based on our legitimate interests in providing you the Service as described in the section “Usage of Personal Information.”

In some cases, PushKin may process personal information pursuant to a legal obligation or to protect your vital interests or those of another person.

Additional Rights and Notice for California Residents

Rights

Individuals located in California have certain rights in respect of your personal information, that may include:

• The right of access to your personal data;
• The right to correct or rectify any inaccurate personal data;
• The right to restrict or oppose the processing of personal data;
• The right to erase your personal data;
• The right to personal data portability; and
• The right to withdraw your consent.

Additionally, PushKin does not “sell” personal information, nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age.

You will not receive discriminatory treatment by us for exercising your rights under the CCPA. The California “Shine the Light” law permits you to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties. To designate an authorized agent, please contact us as set forth below and provide written authorization signed by you and your designated agent.

Supplemental Notice

This supplemental California privacy notice only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information PushKin has collected about them and whether PushKin disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months. California residents can find this information below:

The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth in “Information Collected” and “Usage of Personal Information” above, respectively.

Additional Rights for Nevada Residents

• You have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that Personal Information. You can exercise this right by contacting us as set forth below.  Please note that we do not currently sell your Personal Information as sales are defined in Nevada Revised Statutes Chapter 603A.

Exercising Your Individual Rights

Enterprise Administrators located within the European Economic Area (“EEA”) and other applicable jurisdictions may access and update their personal information as follows:

• access and update personal information through their account settings directly through the PushKin Platform;
• exercise their rights to data deletion and data portability by contacting us at legal@pushkinapp.com

PushKin will process such requests in accordance with applicable laws. Please note that PushKin may request additional information from you to verify your identity before we disclose any personal or account information.

Age Limitations

The PushKin Platform is designed for professional communication in a workplace environment. PushKin does not target children under the age of 13 (or other age for children under applicable law). If you are concerned PushKin may have unknowingly collected information of your child, please contact legal@pushkinapp.com and we will remove the data upon verification.

Material Changes

We strongly believe clear, sensible policies are a matter of trust between ourselves and our users. PushKin will notify our users of material changes as required by applicable law. If you have any questions regarding the policy changes, please contact us at legal@pushkinapp.com. Continued use of the PushKin Platform after the changes go into effect constitutes consent to the changes.

International Data Transfers

All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.

If we transfer personal information to countries outside the EEA, we will put in place appropriate safeguards to ensure that this transfer complies with the applicable laws and regulations. For more information about these safeguards, please contact us as set forth below.

Contact PushKin

Need to reach us? No problem.

Privacy Agent

13240 Timberline Rd.

Bentonville, AR 72712

Email:  legal@pushkinapp.com

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