We value and respect your right to privacy, and to this end are committed to protecting your personal data provided to us directly or indirectly. This Privacy Policy sets out our commitment and explains in detail what information we may gather from your visit to our https://push.org/ including https://wallet.push.org, https://portal.push.org, or other subdomains of push (the Website or Platform) and, why and how your personal data may be processed when you use our Services.This Policy (the Policy) outlines how we collect, use, store and disclose your ("you", "your", "user") Personal Data. By accessing the Website, you agree and consent to Push Labs Ltd., (the Company), its related corporations, business units and affiliates, as well as their respective representatives and/or agents (collectively referred to herein as Push, ("us", "we", or "our")), collecting, using, disclosing and sharing amongst themselves the personal data, and to disclosing such personal data to relevant third-party providers. This Policy supplements but does not supersede nor replace any other consent which you may have previously provided to us nor does it affect any rights that we may have at law in connection with the collection, use and/or disclosure of your personal data. We may from time to time update this Policy to ensure that this Policy is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements. Subject to your rights at law, the prevailing terms of this Policy shall apply. For the avoidance of doubt, this Policy forms part of the terms and conditions governing your relationship with us and should be read in conjunction with such terms and conditions.The terms of this Policy are applicable to you for accessing our various Services as detailed in our 'Terms of Services' document that can be accessed through the Website and is available at Terms of Service.This Policy describes how Push may collect, use, disclose, process and manage your personal data, and applies to any individual’s personal data which is in our possession or under our control. The capitalized terms not defined in this Privacy Policy shall have the meanings defined in Terms of Service.1. Introduction
Push Chain is a shared state blockchain for shared app experiences. It is a Proof of Stake (PoS) chain built to allow developers to create Universal Apps and act as a shared settlement layer for multiple layer 1, layer 2 and layer 3. It allows transactions from any chain, uses gas abstraction to ensure no hassle for interaction from other chains and provides wallet abstraction for seamless onboarding and signing for existing users. To summarize, it is a shared-state blockchain that eliminates fragmentation and makes apps universal.
Deploy once on Push. Users on any chain — EVM or non-EVM — use your app with their existing wallets and tokens; fees are handled under the hood.2. What personal data is collected by Push?
2.1. “Personal data” means data, whether true or not, about an individual who can be identified (i) from that data, or (ii) other information to which Push has or is likely to have access. Some examples of Personal Data that Push may collect are:2.2. Information you provide to us directly2.2.1. personal particulars for account (e.g., name, contact details, residential address, date of birth, identity card/passport details,);2.2.3. images and voice recordings of our conversations with you,;2.2.4. information about your use of our Services and Website;2.1.4. financial details (e.g., account numbers and banking transactions private or public cryptographic key relating to addresses on distributed ledger networks and/or similar information); and/or2.3. Your use of Platform and other Services2.3.1. personal opinions made known to us (e.g., feedback or responses to surveys).2.3.2. correspondence data which is provided directly to us via email, social media or another channel.2.3.3. other transaction information and details associated with your activities on our Services, including to deliver you your rewards associated with your use of the Services2.3. We may post job openings and opportunities on our Website. If you reply to one of these postings by submitting your application, CV and/or cover letter to us, we will collect and use this information to assess your qualifications.
2.4. Personal data may be collected when you interact with our services or use the Website, or may be received by Push from third-party databases or service providers that provide business information.3. Purpose of Collection of Data
3.1. At Push, we prioritize the privacy, security, and transparency of the user’s data. By using Push platform and services, you agree to allow us to collect, store, process, and use data related to your activities on our systems. The purpose of collection your Personal Data shall assist Push in:3.2. Provide our Services
3.2.1. Managing your information3.2.2. Providing access to certain areas, functionalities, and features of our Services3.2.3. Communicating with you about your activities on our Services, terms of service and Policy changes
3.3. Administrative Purpose
3.3.1. Enhancing your experience on our platform.3.3.2. Develop new products and service3.3.3. Conducting research and surveys3.3.4. Auditing relating to interactions, transfers and other compliance activities3.3.5. Improving the functionality, reliability, and efficiency of our services.3.3.6. Conducting analytics and research.3.3.7. Facilitating marketing, promotional efforts, and service updates.3.3.8. Ensuring compliance with legal and regulatory obligations.3.3.9. Ensuring internal quality control and safety.3.3.10. Other uses as required to comply with our legal obligations.3.3.11. Sharing information with third parties as needed to provide the Services
3.4. Marketing and Advertising our Services: We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law. Some of the ways we may market to you include email campaigns, custom audiences advertising, and “interest-based” or “personalized advertising,” including through cross-device tracking. If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time as set forth in “Contact Us” below.3.4.1. Security purpose
3.4.1.1 We may use personal information for fraud and security purposes, such as monitoring to detect and prevent cyberattacks or identity theft attempts.
3.4.1.1 Prevention of criminal activity or harm to users, such as illegal or harmful content being posted on our Platform and/or reward board.
3.4.2. Business transactions
3.4.2.1. In connection with a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings). You will be notified of any such business transaction and possible changes to the processing of your personal information in accordance with applicable law.
4. Disclosure of Personal Data
4.1. For the provision of the Services and as set out under Clause 4, you understand and accept that we may disclose your Personal Data to:4.1.1 our employees, contractors and/or related entities,4.1.2 our existing or potential agents or business partners,4.1.3. sponsors or promoters of any competition we run,4.1.4. anyone to whom our business or assets are, or may be, transferred,4.1.5. credit reporting agencies, courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you,4.1.6. courts, tribunals, regulatory authorities and law enforcement officers, as required by law, or in order to establish, exercise or defend our legal rights;4.1.7. third parties, including agents or sub-contractors, who assist us in providing information, products, services or direct marketing to you,4.1.8. third parties to collect and process data, such as Google Analytics or other relevant businesses,4.1.9. operate and maintain the security or integrity of the Services, including to prevent or stop an attack on our computer systems or networks,4.1.10. protect the rights, interests, or property of our or third parties,4.1.11. prevent or investigate possible wrongdoing in connection with the Services, or enforce our Terms of Services
5. International Data Transfer
5.1. Upon your consent, all information processed by us 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 endeavour to safeguard your information consistent with the requirements of applicable laws.6. Sensitive Personal Information (SPI)
6.1. SPI is Personal Data consisting of racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning health or data concerning a natural person's sex life or sexual orientation. SPI may only be used and disclosed for purposes for which the SPI was collected, as permitted by the provider of the SPI and if required by law.7. Biometric Information
7.1. Please note that the Company does not collect, access, or store any biometric information of users. In certain cases, depending on how you use our Services, your device’s biometric authentication may be used to facilitate secure login or encryption processes. Any biometric data used for such purposes is processed and stored locally on your device through your device’s native authentication mechanisms and is never transmitted to or retained by the Company. In limited circumstances, a non-personal, encrypted identifier derived from your biometric data may be stored solely for the purpose of enabling secure access or authentication. This encrypted identifier cannot be reverse-engineered or used to identify you personally. The Company does not share, sell, or disclose any such encrypted identifiers or biometric-related information to any third parties.8. Information Automatically Collected
8.1. We automatically collect certain types of usage information when you visit our Website or use our Service. When you visit the Service, we may send one or more cookies a small text file containing a string of alphanumeric characters to your computer that uniquely identifies your browser and lets us help you log in faster and enhance your navigation through the site. A cookie may also convey information to us about how you use the Service (e.g., the pages you view, the links you click and other actions you take on the Service), and allow us to track your usage of the Service over time. We may collect log file information from your browser or mobile device each time you access the Service. Log file information may include anonymous information such as your web request, Internet Protocol ("IP") address, browser type, identity of your internet service provider, information about your mobile device, referring / exit pages and URLs, the number and duration of page views, number of clicks and how you interact with links on the Service, domain names, landing pages, and other such information.8.2. When you access our Website through a mobile device, we may receive or collect and store a unique identification number associated with your device and other device information. We may also employ clear gifs (also known as web beacons) which are used to anonymously track the online usage patterns of our Users. In addition, we may also use clear gifs in HTML-based emails sent to our users to track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of the Service. We may also collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for the Service. These tools collect information sent by your browser or mobile device, including the pages you visit, your use of third-party applications, and other information that assists us in analysing and improving the Service.9. The Website uses cookies.
9.1. A cookie is a small text file placed on your computer or mobile device when you visit a Website or use an app. Cookies collect information about users and their visit to the Website or use of the app, such as their Internet protocol (IP) address, how they arrived at the Website (for example, through a search engine or a link from another Website), how they navigate within the Website or app, browser information, computer or device type, operating system, internet service provider, Website usage, referring/exit pages, platform type, date/time stamp, number of clicks, and ads viewed. We use cookies and other technologies to facilitate your internet sessions and use of our apps, offer you products and/or services according to your preferred settings, track use of our Website and apps and to compile statistics about activities carried out on our Website.9.2. You may set up your web browser to block cookies from monitoring your Website visit. You may also remove cookies stored from your computer or mobile device. However, if you do block cookies you may not be able to use certain features and functions of our web sites.10. Data Security
10.1. We employ a variety of measures to safeguard the collection, transmission, and storage of the information we collect. These measures vary based on the sensitivity of the information that we collect, process, and store, and the current state of technology. All data is hosted on third-party servers as decided by the Company. We employ industry standard data security practices to keep your personal information safe from cyber-attacks and threats. Without prejudice to the inherent risk of sharing and accessing data over the internet, we will use appropriate security measures (organizational and technical) to prevent your Personal Data from being accidentally lost, used, damaged, or accessed in an unauthorised or unlawful way, altered, or disclosed. Please note that no system can be guaranteed to be 100% secure. In addition, we will allow access to your Personal Data only to those employees, agents, contractors and other third parties who have a legitimate business need to know and are subject to a duty of confidentiality. Despite the fact that we have implemented appropriate security measures, we cannot guarantee that the Personal Data we collect will not be shared/disclosed in a way that is inconsistent with this Privacy Policy. Where we have given you (or where you have chosen) a credential which enables you to access certain parts of our Platform, you are responsible for keeping this password confidential. We ask you not to share a credential with anyone. We have internal policies to respond to personal information breaches and will notify you and applicable regulators as required by law.10.2. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the Contact Details section below.11. Data Retention
11.1. We will retain your Personal Data if you are using the Services, have an account with us or required for the purpose provided in this Privacy Policy. Further, we may retain Personal Data for an additional period permitted or required under applicable laws, for legal, tax, or regulatory reasons, or for legitimate and lawful business purposes.11.2. The criteria to determine our retention periods include:11.2.1. The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services);11.2.2. Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or11.2.3. Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations)11.2.4. Where a legal obligation arises or retention is advisable in light of our legal position, in some circumstances, we will retain certain Personal Information, even after your account has been deleted and/or we no longer provide the Services to you; for example:
11.2.4.1. To cooperate with law enforcement or public, regulatory and government authorities: If we receive a preservation order or search warrant, related to your Services or account, we will preserve personal information subject to such order or warrant after you delete your Services or account.
11.2.4.2. To comply with legal provisions on tax and accounting: We may retain your personal information, such as name, email address, account information, after you delete your account, as required by tax law and to comply with bookkeeping requirements. Please note the length of time may vary by country.
11.2.4.3. For fraud and security purposes: We may retain your personal information for fraud or security purposes. In the event you have acted fraudulently through the use of the Services) we may retain Name and email details, account information, and IP address.
11.3. To pursue or defend a legal action: We may retain relevant personal information in the event of a legal claim or complaint, including regulatory investigations or legal proceedings about a claim related to your personal information, or if we reasonably believe there is a prospect of litigation (whether in respect of our relationship with you or otherwise) after the dispute has been settled or decided by a court or tribunal from which there is no further right of appeal. The criteria for determining the length of time we will retain this information include: a. whether there is a legal obligation to which we are subject (for example, if the settlement or decision requires us to keep the records for a certain period of time before we can delete them); or b. whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).12. Your Rights
This Privacy Policy grants you certain rights with respect to your Personal Data as set out below:12.1. Right to Consent: By using our Services and/or providing your Personal Data, you agree to allow us to collect, hold, use, and disclose such data in accordance with this Privacy Policy. You have the right not to consent/provide us any such data, however, if you do so, we may not be able to provide you with the Services, or the products and/or services offered through the Platform.12.2. Access: You have the right to request details of your Personal Data from us.12.3. Data Erasure: You can request for deletion of your Personal Data. However, if such data is required for the provision of the Services, you may be required to delete your profile and/or may not be able to use our Services.12.4. Correction: If you believe any Personal Data held by us is inaccurate, out of date, incomplete, irrelevant, or misleading, please contact us to correct such information, or update the same via your account, if allowed.12.5. Concerns and Queries: If you have any concerns and queries on how we process, handle, and keep your Personal Data, please contact us with full details of your concerns and queries. We will take appropriate steps to address them.12.6. Object and Restriction to processing: Subject to data processing such as profiling, You may upon giving written notice to withdraw your consent to collect, use or disclose your personal data. Upon receipt of such withdrawal request, the Company shall, within thirty (30) days or within a reasonable period thereafter, make reasonable efforts to cease the collection, use, and disclosure of your personal data, however, if you do so, we may not be able to provide you with the Services, or the products and/or services offered through the Platform.12.7. Data Portability: You may obtain your personal data in a structured, machine readable format for transfer to another service.12.8. Right to Lodge a Complaint: You may lodge a complaint with the respective data protection authority for your country or region where you have your habitual residence or place of work or where an alleged infringement of applicable data protection law occurs.13. Additional Rights
13.1.General Data Protection Regulation (GDPR) Data Protection Rights: The Company invites you to be fully aware of all your personal data protection rights if you are a resident where the GDPR is applicable. Every such user is entitled to the following:13.1.1 The right to access: The user has the right to request copies of your personal data. The Company may charge additional costs for the same.13.1.2. The right to rectification: The user has the right to request that we correct any information you believe is inaccurate. The user additionally has the right to request that we complete the information the user believes is incomplete.13.1.3. The right to erasure: The user has the right to request that the Company erases your personal data, under certain circumstances.13.1.4. The right to restrict processing: The user has the right to request that the Company restricts the processing of your personal data, under certain circumstances.13.1.5. The right to object to processing: The user has the right to object to the Company’s processing of your personal data, under certain circumstances.13.1.6. The right to data portability: The user has the right to request that the Company transfers the data that the Company has collected to another Company/ organization, or directly to you, under certain circumstances.13.1.7. If the GDPR is applicable to you, you may make a request, and the Company will endeavour to respond to you within the timeline as per applicable law.
14. Queries, Access/Correction Requests and Withdrawal of Consent
14.1. If you:14.1.1. have queries about our data protection processes and practices;14.1.2. wish to request access to and/or make corrections to your personal data in our possession or under our control; or14.1.3. wish to withdraw your consent to our collection, use or disclosure of your personal data,
14.2. Please submit a written request (with supporting documents, (if any) to our Compliance Officer at: support@push.org. Our Compliance Officer shall endeavour to respond to you within 30 days of your submission. As part of our response process, we may conduct a basic background verification to confirm that the requester is a genuine user and to determine whether any breach, misuse, or unauthorised disclosure of personal data has occurred. This verification is carried out solely for security and compliance purposes. Please note that if you withdraw your consent to any or all use or disclosure of your personal data, depending on the nature of your request, we may not be in a position to continue to provide our services or products to you or administer any contractual relationship in place. Such withdrawal may also result in the termination of any agreement you may have with us. Our legal rights and remedies are expressly reserved in such an event.14.3. We may charge you a fee for processing your request for access. Such a fee depends on the nature and complexity of your access request. Information on the processing fee will be made available to you.15. Links to Other Sites
15.1. The Platform may contain links to other Websites. Those Websites are not governed by this Privacy Policy. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. Please read the Privacy Policy and Terms and Conditions of such Websites before using such Websites. We have no control over and shall not be responsible for the content, privacy policies or practices of any third-party sites or services.16. Changes to our Privacy Policy
16.1. We reserve the right to update this Privacy Policy at any time and at our sole discretion. Any changes to or modifications of this Privacy Policy shall be in effect as of the “Last Updated Date” referred to at the top of this page. We will notify you of such changes prominently either by posting a notice of such changes before they take effect, or by sending you a notification directly. The amended Privacy Policy is effective once we notify you of the change. We encourage you to periodically review this Privacy Policy.17. Minor
17.1. As provided in our Terms of Service, our Service is not intended for anyone under the age of 18 (eighteen) years or minor under the law of the country where the Services are accessed (“Minor”). We do not intend to or knowingly collect any Personal Data related to a Minor. If you believe that Personal Data of any minor has been collected or provided to us, please contact us.18. Contact Details
18.1. For queries on any aspect of this Privacy Policy or to provide any feedback please contact our office at: support@push.org