Notice on EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF)

Effective Date: June 30, 2025

At Pushwoosh, Inc. (“Pushwoosh”, “Us”, “Our”, or “We”), we are committed to protecting Your privacy. This Notice sets out the privacy principles We follow with respect to transfers of personal information from the European Union (EU), United Kingdom (UK), and Switzerland to the United States, including personal information We receive from individuals who visit Our web and mobile sites or apps and/or who use any of Our services or otherwise interact with Us (“You”).

Pushwoosh, Inc. complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Pushwoosh, Inc. has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. Pushwoosh, Inc. has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

1. Participation in the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF)

   We adhere to the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF), as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the EU, UK and Switzerland to the United States. Pushwoosh, Inc. commits to apply the DPF Principles to all personal information received in reliance on the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF).

2. Handling of Inquiries and Complaints

   In compliance with the DPF Principles, Pushwoosh, Inc. commits to resolve complaints about Our collection or use of Your personal information. EU, UK, and Swiss individuals with inquiries or complaints regarding Our DPF policy should first contact Us at: .

   Pushwoosh, Inc. has further committed to cooperate with the panel established by the EU data protection authorities (DPAs), the UK Information Commissioner’s Office (ICO), and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning data transferred under the DPF.

3. Regulatory Oversight

   Pushwoosh, Inc. is subject to the investigatory and enforcement authority of the United States Federal Trade Commission (FTC) with regard to its compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF).

   For more information about the DPF, and to view Our certification, please visit the U.S. Department of Commerce’s DPF website at: www.dataprivacyframework.gov.

4. Types of Personal Information Collected and Purposes of Use

   The categories of personal information We may receive in the United States, as well as the purposes for which We collect and use this information, are set out in Our Website and Services Privacy Policies, accessible here: https://www.pushwoosh.com/privacy-policy/.

   We will process personal information only in ways compatible with the purposes for which it was collected, or as You later authorize. If We intend to use Your personal information for a materially different purpose, We will provide You the opportunity to opt out.

5. Disclosure of Personal Information to Third Parties

   Pushwoosh, Inc. may disclose personal information to certain third parties, including:

   • Service Providers and Vendors: We may share personal information with trusted service providers and vendors who assist us in operating our services, conducting our business, or servicing you. These providers may offer services such as data hosting, payment processing, customer support, analytics, and email delivery.
   • Business Partners: We may share information with business partners or affiliates for joint marketing and promotional activities, or to provide co-branded services or features.
   • Public Authorities: We may disclose information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
   • Other Third Parties: We may disclose information to other third parties as required by law, or in connection with a merger, acquisition, restructuring, or sale of assets.
   The purposes of such disclosures include providing and improving our services, fulfilling contractual obligations, complying with legal requirements, protecting our rights and interests, and enabling service-related communications and analytics. We do not sell personal information to third parties.
   
   For a current list of our main service providers and partners please visit Sub-processors, or for more information about our third-party disclosures, please contact us at .

6. Liability for Onward Transfers

   Under the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF), Pushwoosh, Inc. may be liable in cases of onward transfers of personal data to third parties if such parties process personal information in a manner inconsistent with the DPF Principles, unless Pushwoosh, Inc. proves that it is not responsible for the event giving rise to the damage. For more information, please visit: DPF Article 3 and DPF Article 10.

7. Disclosure to Public Authorities

   Pushwoosh, Inc. may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, in accordance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF). For more information about disclosures to public authorities under the DPF, please visit: https://www.dataprivacyframework.gov/framework-article/16–Access-Requests-by-Public-Authorities .

8. Access Rights

   Under the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF), EU, UK, and Swiss individuals have the right to access the personal data that Pushwoosh, Inc. holds about them. Individuals may request confirmation as to whether or not we process their personal data, and, where that is the case, may request access to their personal data, or request that it be corrected, amended, or deleted if it is inaccurate or processed in violation of the DPF Principles. These access rights may be subject to certain limitations.
   
   To exercise your access rights, please contact us at , by mail at 3413 Dupont Ave, Kensington, MD 20895, United States, or via our contact form.
   
   For more information about your right of access under the Data Privacy Framework, please visit Article 6 and Article 8 of the DPF.

9. Your Choices and Means to Limit Use and Disclosure

   Under the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF), EU, UK, and Swiss individuals have the right to choose (opt out of) certain uses and disclosures of their personal data. Pushwoosh, Inc. offers individuals the opportunity to opt out of (a) the disclosure of their personal data to a third party (other than our agents or service providers performing tasks on our behalf), or (b) the use of their personal data for a purpose that is materially different from the purpose(s) for which it was originally collected or subsequently authorized by the individual.
   
   To exercise these choices, you may follow the opt-out instructions provided in our communications, or contact us at , by mail at 3413 Dupont Ave, Kensington, MD 20895, United States, or via our contact form.
   
   Please note that certain communications, such as those regarding your account or transactions, are considered necessary and you may not opt out of receiving them.
   
   For more information about your choice and opt-out rights under the Data Privacy Framework, please visit: DPF Article 2 and DPF Article 12.

10. Questions or Complaints

    In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, Pushwoosh, Inc. commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU, UK, and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF should first contact Pushwoosh, Inc. at: , by mail at 3413 Dupont Ave, Kensington, MD 20895, United States, or by submitting a request via our contact form.

    You can direct any questions or complaints about the DPF to Us at or by regular mail addressed to: 3413 Dupont Ave, Kensington, MD 20895, United States.

    We will respond to DPF-related complaints or disputes within forty-five (45) days of receipt. If You have an unresolved DPF concern, please contact Your EU, UK, or Swiss data protection authority, as applicable. The contact details of the EU DPAs can be found here.

    Under certain conditions, individuals may be able to invoke binding arbitration to resolve complaints regarding compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) that have not been resolved by other means. Pushwoosh, Inc. is obligated to arbitrate claims and follow the terms set forth in Annex I of the DPF Principles, provided that an individual has invoked binding arbitration by delivering notice to Pushwoosh, Inc. and following the procedures and subject to the conditions set forth in Annex I. For more information, please see Annex I of the DPF Principles available at https://www.dataprivacyframework.gov/framework-article/ANNEX-I-introduction.

11. Changes to this Notice

    We reserve the right to amend this Notice from time to time consistent with DPF requirements. The updated version will be posted on Our website with a revised effective date.

    If You have any questions about this policy or Pushwoosh’s personal data practices, You may contact Us by using our contact form or emailing Us at . We will use reasonable efforts to respond promptly to requests, questions, or concerns regarding Our use of Your personal data.