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Nashpush Privacy Policy
Published: May, 2023
Last updated: : May, 2023
Welcome to our Site, which is operated by Sartorenia LTD, having its registered address at Athinon 7, 8035, Paphos, Cyprus, with company registration number HE 410107. Throughout the Site, the terms “Company”, “we”, “us” and “our” refer to Sartorenia LTD. The Company values your privacy and has established this Privacy Policy to show commitment to these rights and to safeguard your privacy and the privacy of End Users. End Users mean users who use third-party mobile applications and sites that use our Services. If you (”you”, “your”, and “User”) use our Site or Services, then we recommend you to read this Privacy Policy. Therefore, by accessing or using the Site and Services you agree to this Privacy Policy. Any personal data we collect (hereinafter referred to as “Personal Data”) is processed in line with applicable data protection laws including California Consumer Privacy Act (CCPA), California Online Privacy Protection Act (CalOPPA), Children’s Online Privacy Protection Act (COPPA) and General Data Protection Regulation. ALL CAPITALIZED TERMS USED IN THIS PRIVACY POLICY AND NOT OTHERWISE DEFINED SHALL HAVE THE MEANINGS PROVIDED FOR THOSE TERMS IN OUR TERMS AND CONDITIONS.
- consent of the User or the End User;
- protection of vital interests of the User or another natural person;
- the legitimate interests pursued by the Company or by a third party, except where such interests are overridden by interests or fundamental rights and freedoms of the User or the End User which require protection of Personal Data;
- to take steps at the request of the User or the End User prior to entering into a contract;
- performance of a contract to which the User or the End User is a party;
- performance of a task carried out in the public interest or in the exercise of official authority vested in the Company;
- compliance with a legal obligation to which the Company is subject.
- to ask what Personal Data is being processed and the rationale for such processing;
- to obtain from us without undue delay the rectification of inaccurate Personal Data concerning you;
- to withdraw a previously given consent for the processing of your Personal Data;
- to submit a complaint with a supervisory authority;
- to ask for the deletion of your Personal Data;
- to obtain from us restriction of processing;
- to object to a decision based on automated processing;
- to object to the processing of your Personal Data;
- receive your Personal Data in a structured, commonly used, and machine-readable format and transmit it to another controller;
- get access to your Personal Data that is being processed.
1) the right to know the specific pieces of Personal Data we have collected about you;
2) the right to know the categories of:
- Personal Data the Company has collected about you;
- Personal Data the Company has disclosed to third parties for a business purpose;
- Personal Data the Company has sold;
- third parties to whom Personal Data was sold;
- recipients to whom Personal Data was disclosed;
- sources of Personal Data;
3) the right to know the business or commercial purposes for collecting or selling Personal Data;
4) the right to request deletion of Personal Data we have collected from you, subject to certain exceptions;
5) the right to opt-out of Personal Data sales to third parties;
6) the right to be free of discrimination for exercising these rights;
7) the right to receive a notice of any actual or potential privacy breach with respect to your Personal Data.
We will take all steps reasonably necessary to ensure that your Personal Data is handled securely and in accordance with this Privacy Policy, and that your Personal Data is not transferred to an organization or country unless appropriate controls are in place, including your data security.
If any processing of your Personal Data is to take place outside of the European Economic Area in a third country or international organization which does not ensure an adequate level of data protection, we may only transfer your Personal Information if appropriate safeguards have been implemented and on the condition that enforceable data subject rights and effective legal remedies for data subjects are available. The safeguards may be by way of:
- EU Standard Contractual Clauses;
- binding corporate rules;
- approved code of conduct;
- approved certification mechanism.
We keep your Personal Data for as long as we have a relationship with you. Once our relationship with you has come to an end, we will retain your Personal Data for a period of time that enables us to maintain business records for audit purposes, comply with record retention requirements under the law, and defend or bring any existing or potential legal claims.
We may share Personal Data to our sub-contractors and affiliates. We secure such transmission by including standard contractual clauses adopted by the European Commission and compliant with the data protection laws into our data processing agreements.
We may use third parties for processing Personal Data in the following circumstances:
- payment providers that we use to process your payment information (including your credit/debit card details) so that we can collect payment from you. Currently, we use Stripe provided by Stripe, Inc (its privacy policy). Our payment providers may be changed from time to time so you have to monitor such changes on your payment page. In case of processing your payment information by the payment provider, you should be governed by the privacy policy and the cookie policy of such payment provider;
- anti-fraud and credit check providers to keep us and you secure. They have access to and process your information in order to check for any fraudulent behavior. In case of processing information in order to check for any fraudulent behavior by the anti-fraud and credit check provider, you should be governed by the privacy policy and the cookie policy of such anti-fraud and credit check providers. You acknowledge that our anti-fraud and credit check providers may be changed from time to time;
- providers that help us make the Site or Services available and functional (such as hosting services);
- providers that help us make available or transmit any information we hold (such as helping us send emails, process payments, and manage customer information);
- providers that help us (including our contractors, agents, and affiliates) provide technical, customer, billing, administrative, event planning, marketing or operational services to us or our User;
- Google Analytics. We also use Google Analytics provided by Google, Inc. These tool and technologies collect and analyze certain types of information, including IP addresses, device, and software identifiers, referring and exit URLs, feature use metrics and statistics, usage and purchase history, media access control address, mobile unique device identifiers, and other similar information via the use of cookies. The information generated by Google Analytics (including your IP address) may be transmitted to and stored by Google on servers in the United States. We use the google Analytics collection of data to enhance the Site and improve our Service. Please consult Google’s privacy policy here: https://policies.google.com/privacy.
ARTICLE 1. POLICY CONCERNING AGE
Our Site does not address anyone under the age of majority in their country of residence. If we become aware that we have collected Personal Data from anyone under the age of majority in their country of residence without verification of parental consent, we take steps to remove that Personal Data from our servers. If the User uses Services for directing push notification to the End Users from the USA, the Company permits developers to use the Services in applications “directed to children under 13” but the User must meet certain obligations, including obtaining verifiable parental consent and an opportunity to opt-out prior to sending a push token, email, or other contact information to the Company. Push notifications or other messages sent to children must also be reasonably related to the content of User’s application or site. If the User uses Services for directing push notifications to the End Users from other countries, the User shall comply with the privacy laws of such countries.ARTICLE 2. COLLECTED PERSONAL DATA
Personal Data (“Personal Data”) is any information that relates to an identified or identifiable individual. For the purposes of the General Data Protection Regulation (“GDPR”), Personal Data means any information relating to a person such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.Collected Personal Data of the User
As a result of your use of this Site and our Services, we can collect the next Personal Data of the User:1) Information provided by you:- contact information (your name, email address, phone number, etc.);- other information (birth date, photos, password, billing information, credit card information, demographic information, geographical location (including GPS), and any other information you share with the Services);2) Information about your use of our Site and Services (information about your participation and actions on the Services, pages you view, how you browse the Services, your purchases and subscription purchases, functions and features that you use);3) Information from your submissions (the time, date, and place the submission was taken or uploaded (also known as metadata), and how you use them);4) Information collected automatically (when you access our Services, we and our third-party partners automatically record information from your device and its software, such as your IP address, browser type, Internet service provider, platform type, the site from which you came and the site to which you are going when you leave our Site, date and time stamp and one or more cookies that may uniquely identify your browser or your account, the unique device ID, IDFA, Google AdID and Windows Advertising ID, device type, model, if you have enabled features and functions of the Services that use your device’s location, your geographical location data (including GPS);5) Your communications with us (communications you send to us (such as emails), comments that you post on the pages we have on a third-party service, any comments, photos, messages, or other content or communications you share on the Services).Collected Personal Data of the End User
As a result of your use of this Site and our Services, we can collect the next Personal Data of the End User:- email address;- visited web pages that have implemented the Services, and information about those visits (e.g., session duration, time-stamp, referring URLs);- what push notifications were sent to the End User;- information about End User’s transactions and interactions with apps and sites;- purchases made concerning our Services;- mobile device or account identifiers;- IP address, system configuration information;- information about devices, such as device type (e.g., mobile, tablet), type and version of operating system (e.g. Android, iOS), network provider, mobile browser (e.g. Safari, Chrome, etc.), language setting, time zone, network status type (such as WiFi);- unique cookie identifiers, which may uniquely identify End Users;- precise location information, generally an End User’s lat/long data (i.e., GPS-level data) or Wi-Fi information, which we may associate with Mobile IDs (location information is only collected if the End User has granted permission to the Site to collect this).Other collected Personal Data
During your use of this Site and our Services, we can also collect and process the next Personal Data:- cookies (small, encoded text files sent between a web server and web browser when the user visits the site and which store information to make navigating the site easier, such as automatic login and other functions and preferences);- other technologies (GIFs, pixel tags, and other such cookie-like technologies to track the activities of users of the site and to compile statistics about the use of the site and e-mail response rates);- your communications with us (communications you send to us (such as emails), comments that you post on the pages we have on a third-party service, any comments, photos, messages, or other content or communications you share on the Services);- information provided by others (information relating to you or your conduct on the Services by other users of the Services, information that third-party organizations may provide to us, such as contact details, demographic information, Internet navigation details, credit reference, or fraud prevention information).We may work with third parties to employ technologies, including the application of statistical modeling tools, which attempt to recognize you across multiple devices so that we understand how you use our Service across various devices.Purposes of collecting Personal Data
We use the collected information for:- providing our Services and access to the Site to you;- responding to your requests and questions;- providing other types of user support;- supporting features provided through the Services, including those related to push notifications;- providing information and analytics to our Users about the use of these features provided through the Services;- enabling the User to make inferences about End Users classified into "data segments";- helping app developers and site operators create or enhance user profiles;- offering our Services through marketing communications;- directing you to parts of this Site or other sites that we believe may be of interest to you;- developing new features for the Site;- developing and using “predictive models”, that try to predict (on a per-device basis or across devices) End Users’ potential future behavior and interests;- resolving identities across multiple devices (for instance, to match IP addresses or hashed emails to link an End User across browsers and mobile devices);- analyzing and improving user interaction on the Site;- evaluating the effectiveness of our marketing and advertising;- managing our communications;- performing analysis of information about the use of the Site;- defending, detecting and preventing fraud and other criminal activity, claims and other liabilities;- complying with applicable legal requirements, law enforcement requests and our Company practices.ARTICLE 3. LEGAL BASIS FOR PROCESSING PERSONAL DATA
The legal basis for processing Personal Data can be:- consent of the User or the End User;
- protection of vital interests of the User or another natural person;
- the legitimate interests pursued by the Company or by a third party, except where such interests are overridden by interests or fundamental rights and freedoms of the User or the End User which require protection of Personal Data;
- to take steps at the request of the User or the End User prior to entering into a contract;
- performance of a contract to which the User or the End User is a party;
- performance of a task carried out in the public interest or in the exercise of official authority vested in the Company;
- compliance with a legal obligation to which the Company is subject.
ARTICLE 4. YOUR DATA PROTECTION RIGHTS UNDER GENERAL DATA PROTECTION REGULATION (GDPR)
If you are a resident of the European Union (EU) and European Economic Area (EEA), you have certain data protection rights, covered by GDPR. You have the following rights concerning collecting and processing your Personal Data:- to ask what Personal Data is being processed and the rationale for such processing;
- to obtain from us without undue delay the rectification of inaccurate Personal Data concerning you;
- to withdraw a previously given consent for the processing of your Personal Data;
- to submit a complaint with a supervisory authority;
- to ask for the deletion of your Personal Data;
- to obtain from us restriction of processing;
- to object to a decision based on automated processing;
- to object to the processing of your Personal Data;
- receive your Personal Data in a structured, commonly used, and machine-readable format and transmit it to another controller;
- get access to your Personal Data that is being processed.
ARTICLE 5. YOUR DATA PROTECTION RIGHTS UNDER THE LAWS OF CALIFORNIA
If you are a resident of the USA your rights concerning the collection and processing of your Personal Data may vary based on local data protection laws in your state or territory, but in general you can have the next rights:1) the right to know the specific pieces of Personal Data we have collected about you;
2) the right to know the categories of:
- Personal Data the Company has collected about you;
- Personal Data the Company has disclosed to third parties for a business purpose;
- Personal Data the Company has sold;
- third parties to whom Personal Data was sold;
- recipients to whom Personal Data was disclosed;
- sources of Personal Data;
3) the right to know the business or commercial purposes for collecting or selling Personal Data;
4) the right to request deletion of Personal Data we have collected from you, subject to certain exceptions;
5) the right to opt-out of Personal Data sales to third parties;
6) the right to be free of discrimination for exercising these rights;
7) the right to receive a notice of any actual or potential privacy breach with respect to your Personal Data.
ARTICLE 6. DATA CONTROLLER AND DATA PROCESSOR
The Company is the data controller for processing of certain Personal Data, such as the Personal Data of our Users. However, we act as a data processor (or service provider) in relation to the Services we provide to our Users, such as when a User deploys our technology in order to collect, process or transfer End User`s data. The User acknowledges and agrees that the Services enable the User to collect certain information from End-Users, which generally helps provide developers with functionality to target and personalize notifications they send to End-Users. The User shall publish privacy policies and disclosures for the End Users` Personal Data that comply with applicable law and the terms of this Privacy Policy, including, but not limited to, clearly disclosing that the Personal Data will be collected and how it may be used.ARTICLE 7. SECURITY
The Company maintains appropriate administrative, technical and physical safeguards designed to protect the collected Personal Data against unlawful or unauthorized, accidental destruction, alteration, access, disclosure, loss or use. However, the security of information transmitted through the Internet cannot be guaranteed, and you assume some risk regarding the security of any information you submit through any site, including this one.ARTICLE 8. DATA RETENTION AND TRANSFER
Personal Data is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this Personal Data may be transferred to and maintained on computers located outside of your country, state, province, or other governmental jurisdiction where the data protection laws may differ from those from your jurisdiction. Your consent to this Privacy Policy followed by your submission of such Personal Data represents your agreement to that transfer.We will take all steps reasonably necessary to ensure that your Personal Data is handled securely and in accordance with this Privacy Policy, and that your Personal Data is not transferred to an organization or country unless appropriate controls are in place, including your data security.
If any processing of your Personal Data is to take place outside of the European Economic Area in a third country or international organization which does not ensure an adequate level of data protection, we may only transfer your Personal Information if appropriate safeguards have been implemented and on the condition that enforceable data subject rights and effective legal remedies for data subjects are available. The safeguards may be by way of:
- EU Standard Contractual Clauses;
- binding corporate rules;
- approved code of conduct;
- approved certification mechanism.
We keep your Personal Data for as long as we have a relationship with you. Once our relationship with you has come to an end, we will retain your Personal Data for a period of time that enables us to maintain business records for audit purposes, comply with record retention requirements under the law, and defend or bring any existing or potential legal claims.
ARTICLE 9. THIRD PARTIES TO WHOM WE MAY TRANSFER COLLECTED PERSONAL DATA OR WHO MAY PROCESS THIS PERSONAL DATA
The Company may share Personal Data as part of a business sale, merger, consolidation, investment, change in control, transfer of substantial assets, reorganization or liquidation, or in connection with steps taken in anticipation of such an event.We may share Personal Data to our sub-contractors and affiliates. We secure such transmission by including standard contractual clauses adopted by the European Commission and compliant with the data protection laws into our data processing agreements.
We may use third parties for processing Personal Data in the following circumstances:
- payment providers that we use to process your payment information (including your credit/debit card details) so that we can collect payment from you. Currently, we use Stripe provided by Stripe, Inc (its privacy policy). Our payment providers may be changed from time to time so you have to monitor such changes on your payment page. In case of processing your payment information by the payment provider, you should be governed by the privacy policy and the cookie policy of such payment provider;
- anti-fraud and credit check providers to keep us and you secure. They have access to and process your information in order to check for any fraudulent behavior. In case of processing information in order to check for any fraudulent behavior by the anti-fraud and credit check provider, you should be governed by the privacy policy and the cookie policy of such anti-fraud and credit check providers. You acknowledge that our anti-fraud and credit check providers may be changed from time to time;
- providers that help us make the Site or Services available and functional (such as hosting services);
- providers that help us make available or transmit any information we hold (such as helping us send emails, process payments, and manage customer information);
- providers that help us (including our contractors, agents, and affiliates) provide technical, customer, billing, administrative, event planning, marketing or operational services to us or our User;
- Google Analytics. We also use Google Analytics provided by Google, Inc. These tool and technologies collect and analyze certain types of information, including IP addresses, device, and software identifiers, referring and exit URLs, feature use metrics and statistics, usage and purchase history, media access control address, mobile unique device identifiers, and other similar information via the use of cookies. The information generated by Google Analytics (including your IP address) may be transmitted to and stored by Google on servers in the United States. We use the google Analytics collection of data to enhance the Site and improve our Service. Please consult Google’s privacy policy here: https://policies.google.com/privacy.