This Application collects some Personal Data from its Users.
Personal Data collected for the following purposes and using the following services:
Managing contacts and sending messages
Owner and Data Controller
Types of Data collected
Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Cookies; Usage Data; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); email address; geographic position; language.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.
Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Users are responsible for any third-party Personal Data obtained, published or shared through this Application and confirm that they have the third party’s consent to provide the Data to the Owner.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
processing is necessary for compliance with a legal obligation to which the Owner is subject;
processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located.
Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Managing contacts and sending messages.
Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
Managing contacts and sending messages
This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.
OneSignal (Lilomi, Inc.)
Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then changing those settings for some or all of the apps on the particular device. Interest-based advertising opt-out
Users may opt-out of OneSignal advertising features through applicable device settings, such as the device advertising settings for mobile phones. Different device configurations, or updates to devices, may affect or change how these indicated settings work.
The rights of Users
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following:
Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.
Additional information about Data collection and processing
The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User’s Personal Data
System logs and maintenance
For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) use other Personal Data (such as the IP Address) for this purpose.
Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
How “Do Not Track” requests are handled
This Application does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
Definitions and legal references
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Information collected automatically through this Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.
The individual using this Application who, unless otherwise specified, coincides with the Data Subject.
The natural person to whom the Personal Data refers.
Data Processor (or Data Supervisor)
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.
The means by which the Personal Data of the User is collected and processed.
The service provided by this Application as described in the relative terms (if available) and on this site/application.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Small sets of data stored in the User’s device.
This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).
Latest update: June 20, 2019
Last updated May 2, 2018
We’ve also provided a section about the choices that you have with respect to “interest based advertising,”, and we encourage you to read that section and exercise your “opt out” rights if you’re inclined to do that. (But because interest based advertising leads to more relevant (and thus, less annoying) advertising, we hope you won’t do that.)
Introduction and Background
We encourage consumers to learn about how information (including information we collect) can be used to market to them, and how to exercise their choices to permit or, if they prefer, to limit such marketing. We describe some ways consumers can exercise that choice or opt out of marketing in Section 6, below, titled Consumer Control & Opt Out Options .
1. Our SDKs: Information We Collect and Services We Provide
We refer to the information we collect from our SDKs as the ‘SDK Information .” The SDK Information includes (or may include) the following:
Information Collected About End Users by Our Web SDKs
Web pages visited that have implemented the SDK , and information about those visits (e.g., session duration, time-stamp, referring URLs)
What push notifications an End User has been sent
Information about End User’s transactions and interactions with apps and websites
IP address, from which geographic location may be inferred, as well as system configuration information
Email address which we may (in our discretion) hash or otherwise deidentify
Information about an End User’s browser, such as, browser language type and version of operating system (e.g., Android, iOS); network provider; language setting; time zone
A unique cookie identifier, which may uniquely identify an End User (such as in de-identified or anonymous form). These cookies may be associated with other Information, including with Data Segments, which we describe in Section 3.
Information Collected About End Users by Our Mobile SDKs
When permitted by the operating system, OneSignal may check to see if the device has specific applications installed, based on a limited list, for purposes that include attribution, relevancy of ads, and relevancy of notifications related to those applications.
Purchases made within an app.
Information about End User’s transactions and interactions with apps and websites
Mobile advertising identifiers, such as iOS IDFAs and Android Advertising IDs (“Mobile IDs”). These Mobile IDs may be associated with other Information, including with Data Segments.
Precise Location information, generally an End User’s lat/long data (i.e., GPS-level data) or WiFi information, which we may associate with Mobile IDs, and which may be collected whether or not an app is in use.
Email address, which we may (in our discretion) hash or otherwise deidentify.
IP address as well as system configuration information
Information associated with or related to 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; and network status type (such as WiFi).
As noted above, we refer to all of the above collectively as the “SDK Information .”
2. How We Use the SDK Information
We use the SDK Information to provide a variety of Services to our Clients. This includes:
To Provide Our App and Website Services. We use the SDK Information to offer and support app and website features provided through the SDKs, including those related to push notifications. This includes, for instance, providing customer, technical and operational support for these features, detecting and protecting against errors, fraud, or other criminal activity; resolving disputes and enforcing our EULA and other rights we may have. It also includes analyzing, customizing, and improving the features we offer Clients.
To provide information and analytics to our Clients about the use of these app and website features provided through the SDKs, or to help app developers and website operators create or enhance user profiles.
To create inferences about End Users categorized into “Data Segments” or to help Clients do so. For instance, if SDK Information indicates that a particular device is frequently seen at restaurants, we might categorize a user for targeting of local restaurant offers. Or, if a user is frequently seen at sports stadiums, we might categorize the user as a “Sports Fan.”
To develop and use “predictive models” – data models that try to predict End Users’ potential future behavior and interests on a per-device basis or across devices
To analyze ad performance, for instance, by attributing End Users’ app installations, web visits, or store visits to ad campaigns.
Sometimes, the SDK Information may be used (by us or ad and data platforms we work with) to resolve identities across multiple devices, such as to match IP addresses or hashed emails to link an End User across (for instance) browsers, mobile devices, tablets, set top boxes, or other devices.
Sometimes the SDK Information may be combined (by us or ad and data platforms we work with), to perform any of the above functions, or other advertising, marketing or analytics services. Or, we may aggregate and create data “models” to do this – creating algorithms in order to predict certain trends and things that different End Users might have in common, for instance.
We may provide End Users’ email addresses (which we generally “hash” or render non-human readable) to online data platforms that “match” this information to online cookies or Mobile IDs in their system, and tie the information (or associated IDs) to further interest-based or demographic data about End Users. This may be done, for instance, to target advertising or provide analytics to brands and other companies.
We, or ad and data platforms we work with, may deploy online cookies to track users across websites, or to associate users (and these cookies) with Mobile IDs. We or they may do this to resolve user identifies across platforms, and to better or more accurately target relevant ads to users (such as to a brand’s customers). You can learn more about cookies and similar technologies, such as web beacons and SDKs, in the Section titled “Cookies, Pixel Tags and SDKs .” We may also “append” or combine certain SDK Information (such as hashed email addresses) to other information provided by third party data providers, to learn more about End Users or to provide advertising and analytics services.
3. How and Why We Share the SDK Information.
To Provide Services to Websites and Apps Using the SDKs
We share the SDK Information with service providers, contractors and other companies to fulfill your orders, operate our business, communicate with you and make available our Services and this Website. These service providers may help us perform any of the activities set forth in Section 2. For instance, we may share certain of the information we collect or receive with companies that help us with billing and payment, marketing, advertising and email marketing,
data enhancement (e.g., to provide more relevant offers), website hosting, technology and customer support, web and marketing analytics, anti-fraud or security operations, and other operational, marketing or business support.
We likewise may share the SDK Information or Data Segments we create with website operators and app developers (for instance, related to push notifications they send) for their advertising, analytics, or other purposes.
To Provide Services to Marketers, Advertisers and Platforms They Work With
We also share SDK Information to provide or help us to provide advertising and marketing services as we have described in Section 3, including as follows:
With advertisers and their marketing providers, so they may provide targeted content and advertising to you on websites and mobile applications With other third parties that target advertising. For those familiar with the online ad ecosystem, these may include demand-side and supply-side advertising platforms, data management platforms, advertising agency trading desks, proximity solution providers, and other advertising technology providers, so they may provide targeted content and advertising to End Users and others on third-party websites, mobile applications, and other advertising mediums (email, direct mail, display media), and so that they may measure the effectiveness of this marketing.
Similarly, we may work with service providers who, to enhance consumer privacy, use a non-human readable “hashed” version of Information such as an email address when sending advertising offers by email or display advertising (which may be linked to a cookie as described above).
Sometimes we provide information (such as IP address, but excluding precise lat/long coordinates) to third party platforms to help advertisers identify common users across different devices or browsers – for instance, to identify a common set of users on both mobile devices and tablets, as well as the web.
The processes we’ve described above often involves cookies or similar technologies, which may be associated with other information about you, e.g., your interests, demographics or transactions. This is known generally as “Interest-Based Advertising.” We encourage users who are interested in controlling or learning about this type of “interest-based advertising” to go to Section 6, titled “Consumer Control & Opt-Out Options , or go to this this page operated by the online ad industry trade association.
We may also share the SDK Information with third parties:
If an End User or Client requests or authorizes
If the disclosure is done as part of, including as part of due diligence for, a purchase, transfer, or sale of services or assets (e.g., in the event that substantially all of our assets are acquired by another party, any information we have may be one of the transferred assets) or in the event of bankruptcy
4. How we Use and Share Information Collected on the OneSignal Website(s)
Website Information We Collect
Volunteered: You may share information with us on the OneSignal Websites when you request information from us, fill out a form on our website, or interact with us in other ways. This information may include personal information, such as your name, email address, and other contact information.
Passively Collected (e.g., Cookies and Unique IDs): We use automated mechanisms, such as cookies, pixels, and other locally stored objects (such as “IndexedDB)”) that we associate with unique identifiers in order to keep track of visitor interactions with the OneSignal Websites. (You can learn more about these technologies below in the Section titled “Cookies, Pixel Tags and SDKs”)). We may use third party-services such as Google Analytics, in which case those third parties gather information such as your IP address, browser type, the webpage from which you came to our website, and the times of your access to the OneSignal Website. In addition, as you browse our website, advertising cookies may be placed on your computer so that we can understand what you are interested in. Our display advertising partners may then help us retarget ads to you on other sites based on your interactions with the OneSignal Website. To “opt out” of having your information used to tailor ads to you in this way by third party ad platforms that we may work with or provide data to, please review the Section below titled “Consumer Control and Opt Out Options” to learn how to opt-out of these services and instead receive generic, non-tailored ads.
How We Use the OneSignal Website Information
In addition to the uses described above, we use the OneSignal Website Information (alone or in combination) to provide, market, and operate the OneSignal Websites and Services. Among other things, by collecting the OneSignal Website Information, we are able to
Maintain and offer access to the OneSignal Websites and Services and optimize how they’re offered to our Clients.
Send information about our products and services, including marketing communications.
Respond to your questions, concerns, or customer service inquiries.
Customize the content and advertising you see on the OneSignal Websites, across the Internet, and elsewhere.
How We Share the OneSignal Website Information
We may share the OneSignal Website Information as follows:
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 (e.g., due diligence).
With our corporate affiliates.
With third parties that help us to provide the OneSignal Websites or Services, such as entities that help us make the OneSignal Websites or Services available and functional (such as hosting services); entities that help us make available or transmit any information we hold (such as helping us send emails, process payments, and manage customer information); and entities that help us (including our contractors, agents, and affiliates) provide technical, customer, billing, administrative, event planning, marketing or operational services to us or our Clients.
When required by law or in response to lawful process, such as a subpoena, or to cooperate in good faith with a request from a government or law enforcement agency or official.
If we believe sharing the information may prevent physical, financial or other harm, injury or loss; or we believe is necessary to protect our, or any other person’s or entity’s, interests; or in connection with an investigation of suspected or actual unlawful activity.
We also may disclose your information under circumstances not mentioned here with your prior consent.
5. Cookies, Pixel Tags and SDKs
Cookies and Pixel Tags.
Mobile Device Identifiers and SDKs.
We may use or work with partners who use mobile SDKs (including our own SDKs, which are described in more detail in this Policy) to collect information, such as mobile identifiers (e.g., IDFAs and Android Advertising IDs), and information related to how mobile devices and their users interact with our Services and those using our Services. The SDK is computer code that app developers can include in their apps to enable ads to be shown, data to be collected, and related services to be implemented. We may use this technology, for instance, to analyze or measure certain advertising through mobile applications and browsers based on information associated with your mobile device. If you would like to opt-out from having ads tailored to you in this way on your mobile device, please follow the instructions in the below Section titled “Consumer Control and Opt-Out Options .”
As described in Section 4 our Clients or Partners may use the above technologies (sometimes, in combination with each other or other data such as IP addresses or hashed or de-identified data files) to coordinate identifiers across platforms, browsers or devices, to more efficiently analyze or target advertising.
6. Consumer Control & Opt-Out Options.
In most cases, consumers have control over whether or not they would like to receive relevant advertisements and marketing email from our Clients.
Opting Out of OneSignal Push Notifications
You may in most cases opt out of receiving push notifications by going to your device “Settings” and clicking on “Notifications,” and then changing those settings for some or all of the apps on your device. (Different device configurations, or updates to devices, may affect or change how these settings work.)
Your choice to opt out of “Notifications” from the OneSignal platform will not affect ads placed by any other organization.
Opting Out of Online Interest-Based Advertising You can opt out of many of the platforms and service providers that facilitate online interest-based advertising by visiting the Digital Advertising Alliance’s consumer education and opt-out page, at http://www.aboutads.info/. This type of opt out is cookie based, which means that if you replace or upgrade your browser, or delete your cookies, you will need to opt out again. Opting out in this way will not prevent you from receiving ads – it will just make the ads you see less customized to you.
Opting Out of “Cross-App” Advertising on Mobile Devices
You can opt out of having your mobile advertising identifiers used for certain types of interest-based (also called “cross-app”) mobile behavioral advertising, by accessing the “settings” on your Apple or Android mobile device, as follows:
Apple Devices: If you have an Apple device, you can opt out of most app-based tracking for interest-based advertising by setting Limit Ad Tracking to ‘ON.’ You can do this by clicking on Settings -> Privacy -> Advertising and toggling Limit Ad Tracking to ‘ON.’
Android Devices: If you have an Android device, you can opt out of most app-based tracking for interest-based advertising by opening the Google Settings app on your device, selecting Ads, and then selecting the option to opt-out of interest-based ads.
Please note that these platforms control how these settings work, so the above may change. Likewise, if your device uses other platforms not described above, you should check the settings for those devices.
Advertisers may also provide ways for you to opt out from or limit their collection of information from and about you. Please refer to the privacy policies for retailers, applications and websites to learn more about their privacy practices.
You may opt not to receive promotional emails from us by contacting us as indicated below or by following the “unsubscribe” instructions in any promotional email you receive from us. Please note, however, that we may still send you non-promotional emails about your relationship with us.
7. Data Access and Retention
8. Data Security
We have administrative, technical, and physical safeguards in place in our physical facilities and in our computer systems, databases, and communications networks that are designed to protect information contained within our systems from loss, misuse, or alteration. No method of electronic transmission or storage is 100% secure. Therefore, we cannot guarantee absolute security of your Personal Information and Non-Personal Information.
9. Third Party Websites and Apps
10. Users From Outside the United States
The Website and our Services are provided, supported and hosted in the United States, and our operation of them is governed by United States law. If you are using the Site from outside the United States, be aware that your Information may be transferred to, stored and processed in the United States and other countries where our facilities are located. The data protection and other laws of the United States might not be as comprehensive as those in your country. By using the Site you consent to your information being transferred to our facilities and to the facilities of those third parties with whom we share it as described in this Policy.
11. Contacting Us