Privacy Policy

OTAPush's Promise

1. Policy Application:

· Attendees: Individuals who provide their information to OTAPush or OTAPush representatives when they attend or register to attend OTAPush-sponsored events or other events at which OTAPush participates.

· Website Visitors: Individuals who visit our Websites and who may opt to provide an email address to receive communications from OTAPush. For the purposes of this Policy, "Websites" shall refer collectively to OTAPush.com as well as any other websites OTAPush owns and that link to this Policy. For clarity, "Websites" does not include any sites owned or operated by our Customers.

· Customers: Those who register on their own or on behalf of an entity or organization to use any of the OTAPush Services (as defined below), including administrators on a Customer account. For the purposes of this Policy, "Services" shall refer to all cloud services marketed for subscription at OTAPush.com, including when Services are sold by an authorized partner or reseller.

· End Users: Individuals who visit our Customers’ websites and opt-into receiving web push notifications, on-site messaging, marketing automation and whose information we process in order to provide the Services to our Customers pursuant to our agreements with them.

This Policy does not apply to our Customers’ websites, which may have their own terms and privacy policies. Our Customers are solely responsible for establishing policies for and ensuring compliance with all applicable laws and regulations, including those relating to the collection of personal information in connection with the use of our Services by End Users with whom our Customers interact.

OTAPush’s Websites and Services are not intended for, nor designed to attract, individuals under the age of sixteen. OTAPush does not knowingly collect personally identifiable information from any person under the age of sixteen (16). If any parent or guardian comes to the knowledge that data has been shared by a child under the age of sixteen (16), they can reach out to us directly to get the data removed from our systems.

2. Information We Collect

· We may ask for and collect personal information such as your name, address, phone number and email address when you register for or attend a sponsored event or other events at which OTAPush (and/or its representatives) participates.

· Name, email address, and other contact information . We ask for and—at your option—collect personal information from you when you submit web forms on our Websites, including opportunities to sign up for and agree to receive email communications from us. We also may ask you to submit such personal information if you choose to use interactive features of the Websites, including participation in surveys, contests, promotions, sweepstakes, requesting customer support, or otherwise communicating with us. We will send such communications in accordance with applicable law.

· Log Files . Just as when you visit and interact with most websites and services delivered via the Internet, when you visit our Websites, including the OTAPush Support Ticketing System, we gather certain information and store it in log files. This information may include but is not limited to anonymized Internet Protocol (IP) addresses (last octet removed), system configuration information, URLs of referring pages, and locale and language preferences.

· Cookies and Other Tracking Technologies . We may use cookies and other information gathering technologies for a variety of purposes, such as providing us with information about how you interact with our Websites and assisting us in our marketing efforts. You can control how websites use cookies by configuring your browser's privacy settings (please refer to your browser's help function to learn more about cookie controls). Note that if you disable cookies entirely, OTAPush’s Websites may not function properly. We may also use cookies and similar technologies to provide you advertising on third-party sites based upon your browsing activities and interests. If you wish not to have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here (or if located in the European Union, click here). For more information about the cookies OTAPush uses, please see our Cookie Policy .

· Interactive Areas . The Websites may offer publicly accessible blogs, community forums, comments sections, discussion forums, or other interactive features ("Interactive Areas"). If you choose to participate in any of these Interactive Areas, please be aware that that any information that you post in an Interactive Area might be read, collected, and used by others who access it. If you wish to remove your personal information from any of our Interactive Areas, please see the section below entitled, Your Data Rights.

· Customer Account Information . When you register for a OTAPush account, we collect your email address. We will also ask you to enter your website domain in order to participate in the Services. We refer to this information as "Customer Account Information" for the purposes of this Policy. Customer Account Information is required to identify you as a Customer and permit you to access your account(s). By voluntarily providing us with such Customer Account Information, you represent that you are the owner of such personal data or otherwise have the requisite consent to provide it to us.

· Payment Information . You are not required to enter your credit card information unless and until you decide to continue with a paid subscription to our Services. When you sign up for one of our paid Services, you must provide billing information. The information you will need to submit depends on which billing method you choose. For example, if you pay with a credit card, we will collect your billing address and our PCI DSS compliant payment processors ("Payment Processors") keep the credit card on record, we at OTAPush do not store credit card numbers or personal account numbers.

· OTAPush provides web push notification, onsite messaging and marketing automation services that our Customers use to engage with end users of their website. Web Push is based on informed consent and no data is collected from end-users without them first opting into web push notifications on their browsers. The next points relate to data collection, only after consent is provided.

· We collect End Users’ information when they use our Customers’ websites, web applications, and APIs. This information may include but is not limited to anonymized IP addresses (last octet removed), location, system configuration information, and URLs of Customer’s website accessed by end user (collectively, "Log Data"). We collect and use Log Data to operate, maintain, and improve our Services in performance of our obligations under our Customer agreements.

· For ecommerce automation we may also collect cart and order information including but not limited to cart identifier, order identifier, customer name. This data is only collected if our ecommerce marketing features or APIs are enabled. This data is used to provide order and product updates to end users to which they have subscribed to. It is our Customers who are responsible for establishing policies for and ensuring compliance with all applicable laws and regulations including those relating to the collection of personal information from their end-users to enable and use these features.

· Cookies. We use functional cookies and browser local storage to keep track of end-user subscription and these are only created after interacting with web push opt-in or onsite-messaging features. These functional cookies and browser local storage data are not shared with any third-party and do not contain any personally identifiable information. No third-party cookies are stored on end-user devices. You can control how websites use cookies by configuring your browser's privacy settings (please refer to your browser's help function to learn more about cookie controls). Note that if you disable cookies entirely, we will not be able to provide you with the Service, as intended. For more information about the cookies OTAPush uses, please see our Cookie Policy .

Legal Basis for Processing (EEA only)

If you are an individual from the European Economic Area (EEA), please note that our legal basis for collecting and using your personal information will depend on the personal information collected and the specific context in which we collect it. We normally will collect personal information from you only where: (a) we have your consent to do so, (b) where we need your personal information to perform a contract with you (e.g. to deliver the OTAPush Services you have requested), or (c) where the processing is in our legitimate interests. Please note that in most cases, if you do not provide the requested information, OTAPush will not be able to provide the requested service to you.

In some cases, we may also have a legal obligation to collect personal information from you, or may otherwise need the personal information to protect your vital interests or those of another person.

Where we rely on your consent to process your personal data, you have the right to withdraw or decline consent at any time. Where we rely on our legitimate interests to process your personal data, you have the right to object.

If you have any questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us at support@OTAPush.com .

3. How We Use Information We Collect

OTAPush only processes personal information in a way that is compatible with and relevant for the purpose for which it was collected or authorized. As a general matter, for all categories of data we collect except End User data, we may use the information we collect (including personal information, to the extent applicable) to:

· provide, operate, maintain, improve, and promote the Website and Services; enable you to access and use the Website and Services; process and complete transactions, and send you related information, including purchase confirmations and invoices;

· send transactional messages, including responses to your comments, questions, and requests; provide customer service and support; and send you technical notices, updates, security alerts, and support and administrative messages;

· send commercial communications, in accordance with your communication preferences, such as providing you with information about products and services, features, surveys, newsletters, offers, promotions, contests, and events about us and our partners; and send other news or information about us and our partners. See Section 11 below for information on managing your communication preferences.

· monitor and analyze trends, usage, and activities in connection with the Websites and Services and for marketing or advertising purposes;

· comply with legal obligations as well as to investigate and prevent fraudulent transactions, unauthorized access to the Services, and other illegal activities;

· personalize the Websites and Services, including by providing features or content that match your interests and preferences; and

· process for other purposes for which we obtain your consent.

Information from Third Party Services

We may combine information we collect as described above with personal information we obtain from third parties. For example, we may combine information entered on a OTAPush sales submission form with information we receive from a third-party sales intelligence platform vendor to enhance our ability to market our Services to Customers or potential Customers.

End Users

We do not sell, rent, share, or otherwise disclose our Customers’ End User data to any third party. Nor is the End User data used for any marketing purpose by OTAPush. We may use the information we collect from End Users (including personal information, to the extent applicable) to:

· provide, operate, maintain, and improve the Website and Services;

· enable you to access and use the Website and Services;

· process for other purposes for which we obtain your consent.

4. Information Sharing

We work with other companies who help us run our business ("Service Providers"). These companies provide services to help us deliver customer support, process credit card payments, manage and contact our existing Customers as well as sales leads, provide marketing support, and otherwise operate and improve our Services. These Service Providers may only process personal information pursuant to our instructions and in compliance both with this Privacy Policy and other applicable confidentiality and security measures and regulations.

Specifically, we do not permit our Service Providers to use any personal information we share with them for their own marketing purposes or for any other purpose than in connection with the services they provide to us. Your end-user data is not shared with any Service Provider.

In addition to sharing with Service Providers as described above, we may also share your information with others in the following circumstances:

· With our resellers and other sales partners who may help us distribute the Services to Customers;

· In the event of a merger, sale, change in control, or reorganization of all our part of our business;

· When we are required to disclose personal information to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims.

· Where we have a good-faith belief sharing is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Service Agreement, or as otherwise required to comply with our legal obligations; or

· as you may otherwise consent from time to time.

We do not sell, rent, or share personal information with third parties for their direct marketing purposes.

5. Data Aggregation

OTAPush may aggregate data we acquire about our Customers and their End Users, including the Log Data described above. For example, we may assemble data to determine traffic patterns on a website to compile statistics and help with usage analytics. Such non-personally identifiable, aggregated data is also not shared with any third-party.

6. International Information Transfers

OTAPush is an India-based, global company. We primarily store your information in the United States. To facilitate our global operations, we may transfer and access such information from around the world, including from other countries in which OTAPush has operations for the purposes described in this Policy.

If you are accessing or using our Websites or Services or otherwise providing information to us, you are agreeing to the transfer of your personal information to the United States and other jurisdictions in which we operate.

7. Data Subject Rights (Applicable to EEA)

Attendees, Website Visitors, and Customers : You have the right to access, correct, update, export, or delete your personal information. You may email us at support@OTAPush.com with any such subject access requests ("SAR"), and we will respond within thirty (30) days. Customers also can access, correct, export, or update their Account Information by editing their profile or organization record at OTAPush.com.

End Users : You have the right to access, correct, update, export, or delete your personal information. You can delete your information stored with us by unsubscribing from notifications. OTAPush automatically removes expired endpoints and associated data. You may also email us at support@OTAPush.com with any such subject access requests ("SAR") with your Subscription Key, and we will respond within thirty (30) days. For our onsite messaging and marketing automation platform you can send the subject access requests ("SAR") to support@OTAPush.com as well. In case our Customers receive a SAR from an end-user regarding our service, OTAPush will unequivocally comply with the request.

For any SAR, we will need to verify a requestor is inquiring about their own information before we can assist. Where a SAR may implicate the personal data of another individual, we must balance the request against the risk of violating another person’s privacy rights. We will comply with SARs to the extent required by applicable law. In the EU, you also have the right to lodge a complaint with a supervisory authority.

8. California Privacy Rights (CCPA)

The CCPA, California Civil Code Sections 1798.100 et seq., provides certain rights, if you are a California resident. For example, California residents may have a right, following a verifiable request, to:

· access the specific personal information collected about them during the twelve (12) months prior to their request.

· know a business’s data collection practices, including the categories of personal information collected, the source of the information, the use and disclosure of such information by the business.

· deletion of such personal information.

· prohibit sale of personal information to third parties.

· anti-discrimination for exercising a right.

To request access to your personal information or request that we delete your personal information, you may contact us on the information provided at the end of this privacy policy under Section 16. Please specify in your request the details of what personal information you would like to access or delete.

Given the nature of anonymization of end user subscription, we may require you to provide further information such as the browser endpoint address or OTAPush subscriber ID to access the information available.

9. Data Portability

We strive for data portability. You can export all the endpoints and associated data required for web push and move to a different service pursuant to the conditions mentioned below. If you require data portability please make sure you use your own FCM/GCM/VAPID configuration, while registering for OTAPush or while adding a new website to your OTAPush account and also use your own HTTPS domain/subdomain.

Technical Limitations:

If you use HTTP integration method then the subscriptions are bound to a OTAPush subdomain, so you cannot move this subscription data to a different service due to technical limitations. Similarly, if you use the HTTPS method of integration but do not use your own FCM/GCM/VAPID configuration, your subscriptions will be tied to OTAPush, and you cannot move this subscription data to a different service. Additional technical limitations apply to Safari desktop and to legacy products.

You can request for a data export by reaching out to support@OTAPush.com.

10. Data Retention

We retain your personal information to provide services to you and as otherwise necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We will retain your personal information for no more 90 days following the date on which you terminate your use of the Services, unless we are otherwise required by law or regulation to retain your personal information for longer.

11. Communication Preferences

You may manage your receipt of commercial communications by clicking on the "unsubscribe" link located on the bottom of such emails, through your account settings if you have a OTAPush account, or you may send a request to support@OTAPush.com.

12. Data Security, Data Integrity

We take all reasonable steps to protect information we receive from you from loss, misuse or unauthorized access, disclosure, alteration, and/or destruction. We have put in place appropriate physical, technical, and administrative measures to safeguard and secure your information, and we make use of privacy-enhancing technologies such as encryption. Please be aware that, despite our efforts, no security system is impenetrable. In the event of a security breach, we will promptly notify you and the proper authorities if required by law. If you have any questions about the security of your personal information, you can contact us at support@OTAPush.com.

13. Notification Of Changes

If we make changes to this Policy that we believe materially impact the privacy of your personal data, we will promptly provide notice of any such changes (and, where necessary, obtain consent), as well as post the updated Policy on this website noting the effective date of any changes.

14. Business Transactions

We may assign or transfer this Policy, as well as information covered by this Policy, in the event of a merger, sale, change in control, or reorganization of all our part of our business.

15. English Language Controls

Non-English translations of this Policy are provided for convenience only. In the event of any ambiguity or conflict between translations, the English version is authoritative and controls.

16. Contact Information

Registered Office

OTAPush (Bizsmart Technology Private Limited)
52A, Jalan Raja Uda
Butterworth – 12300
Pulau Pinang (Malaysia)
Attention: Data Protection Officer
support@OTAPush.com

Last Updated: February 14, 2024

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