PRIVACY POLICY

This Privacy Policy (“Privacy Policy”) describes what information Pushly (“we,” “us,” or “our”) collects through our website(s), applications, products, and services (collectively, the “Services”), how we use that information, and some of your privacy rights regarding that information. This Privacy Policy may change from time to time. Please check back frequently for updates. What information we collect and how we collect it. User Information; Use of Services. We collect information from you when you voluntarily provide it to us (e.g., your name, title, email address, company name, company address) or access or use our Services (“User Information”). We collect information such as (i) your computer or device identifier, capabilities and operating system, (ii) your browser identifier, (iii) how you use the Services, (iv) your IP address, (v) anonymous advertising identifiers, (vi) mobile or internet carrier, and (vii) referring URL. The information collected within the last twelve (12) months includes:

CATEGORY OF INFORMATION	EXAMPLES	INFORMATION COLLECTED
Inferences drawn from any other information	Present and past employment data.	Yes
Education information	Education records maintained by educational institutions or third parties on behalf of these institutions.	No
Professional or employment-related information	Present and past employment data.	No
Sensory information	Audio, electronic, visual, thermal, olfactory, or similar information.	No
Geolocation data	Physical location, position, and movement data.	Yes
Internet or other electronic network activity information	Browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, advertisement.	Yes
Biometric information	An individual’s physiological, biological or behavioral characteristics, including an individual’s deoxyribonucleic acid (DNA), that can be use, singly or in combination with each other or with other identifying data, to establish individual identity, including but not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.	No
Commercial Information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Yes
Characteristics of protected classifications under California or federal law	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran military status, genetic information (including familial genetic information).	No
Categories of personal information described in subdivision (e) of Section 1798.80 of the California Civil Code.	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card, or any other financial information, medical information, or health insurance information.	No
Identifiers	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.	Yes

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 publisher 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 advertisements or content (“Technology Information”). Additionally, we may use other new and evolving sources of Technology Information and information gathering in the future.

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

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 advertisements 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 advertisements or content delivered through the Services or indirectly through Publishers. Such advertisements or content will usually be displayed within one of the following vehicles:

Websites. We may set a cookie on your computer or device when you view advertisements or content displayed on Publisher websites. After a cookie is set, we may track how you interact with the advertisements or content and the Publisher website (for example, registering, purchasing, browsing, etc.).
Notifications. If you agree to allow browser-enabled push notifications (“Notifications”), we or a Publisher may send Notifications that include messages or advertisements.

1.4 Outside Information. We may lawfully receive information about you from third parties, such as information located in public databases (“Outside Information”). No Information Collected from Minors. MINORS UNDER THE AGE OF 18 SHOULD NOT PROVIDE ANY PERSONAL INFORMATION, INCLUDING THEIR 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.

1.6 Individual Information. As used herein, Individual Information means User Information, Vendor List Information, Technology Information, Outside Information, and any other information the Services lawfully obtains about you. Additional categories of Individual Information will not be collected or used for materially different purposes without first providing you with notice.

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 Publishers.

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”). 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. Additional categories of information will not be used for materially different purposes without first providing you with notice.

2.3 Targeted Advertising and Content. We may use Individual Information to target advertisements or content more effectively. When an individual is online, we may use Technology Information to associate an individual with their Individual Information and attempt to show advertisements or content to which you may respond.

2.4 Legal Process. We may disclose Individual 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. We may sell or disclose Individual Information for a business purpose. For example, we may provide your information to Publishers. 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

3.1 Storage of Individual Information. We store Individual 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 Individual Information. Notwithstanding such measures, we cannot guarantee that any security measures will prevent Individual Information from being illegally accessed, stolen or altered.

4. PRIVACY PRACTICES OF THIRD PARTIES

4.1 Third Party Cookies and Web Beacons. Publishers who use our Services may use their own cookies, web beacons and other technology to collect information about you. We do not control Publishers’ 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 Publisher. This Privacy Policy does not apply to the practices of Publishers 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 Publishers. We may disclose or transfer Individual Information to entities wholly owned or controlled by us, in our discretion.

5. YOUR RIGHTS IN INFORMATION AND USER DATA

5.1 Privacy Rights. You have several rights regarding information collected by us. These 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 on your behalf.

6. HOW YOU MAY EXERCISE YOUR RIGHTS

6.1 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.

6.2 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.

6.3 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.

6.4 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, which is created on a website-by-website basis 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 My Info” 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.

6.5 Designating an Agent. To designate an authorized agent to exercise rights on your behalf, 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.

7. MORE INFORMATION

7.1 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

4600 Madison Ave., 3rd Floor

Kansas City, Missouri 64112

USA