Privacy Policy

Last Updated: December 9, 2024

Information We Collect

We collect information about you only when we have a legitimate reason to do so — for instance, to deliver our Services, communicate with you, or improve your experience with our Services.

The information we gather comes from three primary sources: directly from you when you provide it, automatically through your use of our Services, and from third-party sources. Here’s a breakdown of the types of information we collect and why we collect it.

Information You Provide to Us

We collect information that you provide directly to us. Here are some examples of the types of information we may collect:

• Basic Account Information: To set up your pwpush.com account, we require basic details like your email address, password, and a username or name — that’s it. While you have the option to provide additional information, such as your address or other details, none of this is required to create a pwpush.com account.
• Payment and Contact Information: If you make a purchase, such as subscribing to a pwpush.com plan, acquiring a premium theme, registering a custom domain, or buying Password Pusher swag, we’ll collect personal and payment details. This may include your name, contact information, and credit card information. We also maintain a record of your purchase history for account management and customer service purposes.
• Content Information: You may provide information about yourself in content you draft or publish. This includes comments, form submissions, or any other content containing biographical details, as well as media or files you upload.
• Communications with Us: When you communicate with us — for example, by responding to surveys, reaching out for support, posting in public forums, or subscribing to newsletters like those we send via Buttondown or Brevo — we may collect and store a copy of our communications. This includes emails, forms, comments, and phone calls (recorded where permitted by law).
• Job Applicant Information: If you apply for a job with us (thank you!), you may provide details such as your name, contact information, resume or CV, professional references, and work authorization verification. During the hiring process, we may collect additional information, such as background and credit checks (where permitted by law and applicable to certain roles). Additionally, you may voluntarily provide demographic information, such as gender, racial or ethnic origin, veteran status, or disability status, where required by law or to support our workplace diversity initiatives. We collect demographic information in compliance with applicable laws and use it only for purposes such as accommodating disabilities, ensuring legal compliance, protecting employee health and safety, or advancing diversity and anti-discrimination efforts.

Information We Collect Automatically

We also collect certain information automatically when you use our Services:

• Log Information: Like many online service providers, we collect information that web browsers, mobile devices, and servers typically make available. This includes browser type, IP address, unique device identifiers, language preference, referring site, date and time of access, operating system, and mobile network information. For example, we collect log information when you access our Services or make changes to your pushes on pwpush.com.
• Transactional Information: When you make a purchase through our Services, we collect details about the transaction, such as product information, purchase price, and the date and time of the transaction. This applies whether you purchase from us directly or use our Services to facilitate a transaction.
• Usage Information: We collect data about how you interact with our Services. This includes actions performed by team administrators and users on pwpush.com (e.g., "[username] expired push at [time/date]"), as well as broader usage patterns, such as page views, feature interactions, support document searches, and engagement with our admin areas. We also collect information about your device, such as screen size, mobile network, and device manufacturer. This information helps us deliver and improve our Services, understand user behavior, and make informed predictions about user retention.
• Location Information: We may estimate your device's approximate location using your IP address to understand geographic trends in service usage (e.g., the number of visitors from specific regions). If you use our mobile apps and grant location permissions via your device's operating system, we may also collect precise location data.
• Information from Cookies and Other Technologies: Cookies are small data files stored on your device by a website, and pixel tags (also known as web beacons) are tiny code blocks embedded in websites or emails. We use cookies and similar technologies to identify and track visitors, analyze usage patterns, manage access preferences, evaluate email campaign effectiveness, and deliver targeted advertisements. For more details about our use of cookies and tracking technologies, including how to manage your cookie preferences, please see our Cookie Policy.

Information We Collect from Other Sources

We may also receive information about you from other sources. For example:

• Third-Party Login: If you create or log in to your pwpush.com account using a third-party service (like Google), we receive associated login information, such as a connection token, your username, and your email address.
• Financial Account Information: If you pay for a subscription, we may receive payment-related information through our payment processor (e.g., Stripe), including your email address and phone number.

The specific information we receive depends on the services you use or authorize and the options provided by those services.

Additionally, third-party services may provide us with information, such as mailing addresses for individuals who are not yet pwpush.com users. We use this information for marketing purposes, such as sending postcards or other mailers to promote our Services.

How and Why We Use Information

Purposes for Using Information

We use the information we collect about you for the following purposes:

• To provide our Services. This includes setting up and maintaining your account, providing customer support, processing payments and orders, and verifying user information.
• To ensure quality, maintain safety, and improve our Services. For example, we provide automatic upgrades and new versions of our Services. We also monitor and analyze user interactions to develop new features, improve usability, and help users manage their pushes and data more efficiently.
• To market our Services and measure, gauge, and improve the effectiveness of our marketing efforts. For example, we tailor marketing messages to specific user groups (such as those with a particular plan or length of service), advertise our Services, analyze marketing campaign performance (e.g., how many users purchase a paid plan after receiving a marketing message), and forecast user retention trends.
• To protect our Services, our users, and the public. This includes detecting and preventing security incidents, fraudulent activity, spam, and other malicious behavior. We also comply with legal obligations and protect the rights and property of Apnotic and others, which may include declining transactions or terminating access to our Services.
• To fix problems with our Services. We monitor, debug, and repair issues to ensure the reliability and performance of our Services.
• To customize the user experience. We personalize your experience by serving relevant notifications and advertisements for our Services.
• To communicate with you. This includes sending emails to request feedback, share tips, or provide updates about Apnotic; texting you to verify payments; or calling to share offers and promotions we believe may interest you. If you opt out of marketing communications, we will still send important updates related to your account.
• To recruit and hire new team members. We use applicant information to evaluate qualifications, verify identity and experience, and communicate through email, phone, or social media. If the application progresses, we may collect interview details, background check information, and data necessary to initiate employment, such as work authorization, payroll setup, and compliance with legal reporting requirements.

Legal Bases for Collecting and Using Information

For those in the European Union, here’s an explanation of our legal grounds for processing your information under EU data protection laws. Our use of your information is based on one or more of the following grounds:

1. Contractual Necessity: The use is necessary to fulfill our commitments to you under the applicable terms of service or other agreements, or to administer your account. For example, this includes enabling access to our Services on your device or processing payments for a paid plan.
2. Legal Obligation: The use is necessary to comply with a legal obligation, such as fulfilling statutory reporting requirements.
3. Vital Interests: The use is necessary to protect your vital interests or those of another person.
4. Consent: You have given us your consent. For instance, we rely on your consent before placing certain cookies on your device and analyzing them as described in our Cookie Policy.
5. Legitimate Interest: We have a legitimate interest in using your information. For example:

• To provide, maintain, and improve our Services;
• To enhance your user experience;
• To safeguard our Services and ensure security;
• To communicate with you;
• To measure, gauge, and improve the effectiveness of our advertising;
• To understand user retention and attrition trends; and
• To monitor and address any issues with our Services, as well as personalize your experience.

Sharing Information

How We Share Information

We share information about you only in limited circumstances and with safeguards in place to protect your privacy. Below are the specific instances where information may be shared, as well as in the section titled Ads and Analytics Services Provided by Others:

• Subsidiaries and Independent Contractors: We may share information with our subsidiaries and independent contractors who need it to assist in providing our Services or processing data on our behalf. These parties are required to adhere to this Privacy Policy when handling personal information.

• Third-Party Vendors: We may share information with third-party vendors who need it to provide services to us or to you. These include:

  • Vendors that support our Services, such as payment processors (e.g., Stripe), fraud prevention services, cloud storage providers, and email and postal delivery services.
  • Vendors that assist with marketing efforts, such as tools for identifying target audiences, improving campaigns, or placing ads to promote our Services.
  • Vendors that provide analytics to help us understand and improve our Services.
  • Tools that support our operations, such as software for task management, scheduling, word processing, communications, and team collaboration.
  • Companies that offer products or services on our websites, such as technical support or other assistance.

These vendors are required to agree to privacy commitments before we share information with them. Additional details about vendors can be found in specific policies, such as our Cookie Policy.

• Legal and Regulatory Requirements: We may disclose information in response to a subpoena, court order, or other governmental request, but only when legally obligated to do so.
• To Protect Rights, Property, and Others: We may disclose information when we believe in good faith that it is reasonably necessary to protect the rights, property, or safety of Apnotic, third parties, or the public. For example, we may share information in emergencies where there is an imminent risk of death or serious physical injury.
• Business Transfers: In the event of a merger, acquisition, sale of company assets, or bankruptcy, user information may be transferred or acquired by a third party. In such cases, this Privacy Policy would continue to apply to your information, and the receiving party would only use your information in accordance with this policy.
• With Your Consent: We may share information with your consent or at your direction. For instance, if you connect your account to a third-party service or social media platform, we may share information as authorized by you.
• Aggregated or De-Identified Information: We may share information that has been aggregated or de-identified so that it cannot reasonably be used to identify you. For example, we may publish statistics about Service usage or share hashed email addresses to support customized ad campaigns.
• Published Support Requests: If you send us a support request (e.g., via email or other feedback mechanisms), we reserve the right to publish the request to respond to it or assist other users with similar issues.

Information Shared Privately Through Pushes or Requests

Information you post to a push or request is shared only with those who have access to the secret URL you provide. Unlike traditional public posting, pwpush does not allow users to make content publicly available.

For example, when you create a push or request, the content is only accessible to the individuals with whom you choose to share the secret URL. Your content is not indexed or discoverable by others unless they have the specific link. This ensures a private and secure sharing experience.

Please keep in mind that while pwpush provides a secure way to share information, the individuals you share the secret URL with can still choose to share it further. Always be thoughtful about what you post and who you share it with.

How Long We Keep Information

We retain information about you only as long as necessary to fulfill the purposes for which it was collected — as described in the section How and Why We Use Information — unless we are legally required to keep it for a longer period.

For example: - Web Server Logs: We retain logs that record information about visitors to Apnotic’s websites (such as IP address, browser type, and operating system) for approximately 30 days. These logs help us analyze website traffic and investigate issues if something goes wrong. - Pushes and Requests: When a push or request expires, the encrypted sensitive data is destroyed immediately. However, it may remain encrypted in our backups or caches for a limited period until those systems are purged.

If you are a job applicant, we retain your personal data during the application process and for a period afterward. The retention period is determined based on factors like our legal and regulatory obligations (e.g., equal opportunity requirements) and our internal business needs, such as analyzing the applicant pool for future hiring purposes.

Security

While no online service can be entirely secure, we take significant steps to protect your information from unauthorized access, use, alteration, or destruction. We implement reasonable security measures and continuously monitor our Services for potential vulnerabilities and attacks to safeguard your data.

Choices

You have several choices available when it comes to managing your information:

• Limit the Information You Provide: If you have an account with us, you can choose not to provide optional account information, profile information, and transaction or billing details. Keep in mind that if you don’t provide this information, certain features of our Services — such as premium features or additional functionality — may not be accessible. If you are a job applicant and choose not to provide certain data, we may be unable to proceed with the recruitment process.
• Limit Access to Information on Your Mobile Device: Your mobile device’s operating system should provide options to limit our ability to collect stored information or location data through our mobile apps. However, limiting access may affect the functionality of certain features.
• Opt Out of Marketing Communications: You can opt out of receiving promotional communications from us by following the instructions provided in those communications or contacting us directly. Even if you opt out of marketing, we may still send you important account-related communications and legal notices.
• Set Your Browser to Reject Cookies: At this time, Apnotic does not respond to "Do Not Track" signals across all of our Services. However, you can configure your browser to remove or reject cookies. Note that certain features of our websites may not function properly without cookies.
• Opt Out of Our Internal Analytics Program: You can opt out through your user settings. Once opted out, no further information about events or actions will be shared with our analytics tool while you're logged in to your pwpush.com account. For details, please see our Cookie Policy.

• Delete Your Account: If you no longer wish to use our Services, you can delete your account at any time by clicking the Delete My Account button on the account settings page. Deleting your account will:

  • Cancel all subscriptions.
  • Permanently delete all sub-accounts you’ve created.
  • Permanently delete all pushes and requests associated with your account.

This action is irreversible, and once completed, your account and all associated data cannot be recovered. Please note that we may continue to retain some information after your account has been deleted, as outlined in How Long We Keep Information — for example, to comply with legal obligations, fulfill law enforcement requests, or protect our legitimate business interests.

Your Rights

If you are located in certain parts of the world, including some US states and countries that fall under the scope of the European General Data Protection Regulation (aka the "GDPR"), you may have certain rights regarding your personal information, like the right to request access to or deletion of your data.

European General Data Protection Regulation (GDPR)

If you are located in a country that falls under the scope of the GDPR, data protection laws give you certain rights with respect to your personal data, subject to any exemptions provided by the law, including the rights to:

• Request access to your personal data;
• Request correction or deletion of your personal data;
• Object to our use and processing of your personal data;
• Request that we limit our use and processing of your personal data; and
• Request portability of your personal data.

You also have the right to make a complaint to a government supervisory authority.

US Privacy Laws

Some US states, including California, Colorado, Connecticut, Utah, and Virginia, require us to provide additional information about the categories of personal information we collect, where it comes from, how we use it, and with whom we share it. This section provides those details. (If you are a California resident, consider this the Notice at Collection required under California law.)

In the last 12 months, we have collected the following categories of personal information, depending on your use of our Services:

• Identifiers (e.g., your name, contact information, and device or online identifiers);
• Commercial Information (e.g., your billing information and purchase history);
• Characteristics Protected by Law (e.g., you may voluntarily disclose your race or veteran status as part of a job application);
• Internet or Other Electronic Network Activity (e.g., your interactions with our Services, such as actions taken on pwpush.com);
• Geolocation Data (e.g., your approximate location based on your IP address);
• Audio, Electronic, Visual, or Similar Information (e.g., profile pictures you upload, if applicable);
• Professional or Employment-Related Information (e.g., information provided during job applications); and
• Inferences (e.g., predictions about user retention or attrition).

For job applicants, we may also collect education information (e.g., details disclosed in your application).

You can find more details about the information we collect and its sources in the Information We Collect section. We use this information for the purposes described in the How and Why We Use Information section and share it as outlined in the Sharing Information section. Retention periods are covered in the How Long We Keep Information section.

Your Privacy Rights

Depending on your state’s laws, you may have the following rights:

• Access Your Information: Request a copy of the specific personal information we have collected about you. California residents may also request details about the categories of information collected, its purposes, and third parties with whom we share it.
• Delete Your Information: Request the deletion of your personal information.
• Correct Your Information: Request corrections to inaccurate personal information.
• Opt Out of Sale or Sharing: Opt out of the "sale" or "sharing" of personal information, as defined by state laws.
• Data Portability: Receive a copy of your information in a portable format.
• Non-Discrimination: You have the right not to face discrimination for exercising your privacy rights.

Right to Opt Out

We do not sell personal information in the conventional sense (i.e., for monetary compensation). However, some sharing with advertising, marketing, or analytics providers may qualify as a "sale" or "sharing" under certain state laws. To opt out:

1. Click the "Do Not Sell My Personal Information" link in our website footer or visit the settings page within our apps.
2. Note: This option may only be visible to users in relevant states.

Our opt-out mechanism relies on cookies. If you delete cookies or use a different browser, you'll need to opt out again. We also respect the GPC (Global Privacy Control) signal to process opt-out requests.

We do not knowingly sell or share personal information of users under 16 years old. Additionally, we process sensitive personal information only where necessary to provide our Services and in compliance with applicable laws.

Contacting Us About Your Rights

Most of your personal data can be accessed, corrected, or deleted using your account settings. If you need help or want to exercise other rights, please see How to Reach Us.

To process requests, we may need to verify your identity. For example, we may require you to contact us from the email address associated with your account. You may also designate an authorized agent to make requests on your behalf by providing written authorization. Verification may still be required.

Appeals Process for Rights Request Denials

If we deny your request, we will explain why in writing. You may appeal by responding to our denial email, and your appeal will be reviewed by an independent internal expert. If the appeal is also denied, you may refer the matter to your state’s attorney general if applicable (e.g., in Colorado, Connecticut, or Virginia). Instructions will be included in the denial notice.

Controllers and Responsible Companies

Apnotic’s Services operate globally. The specific Apnotic entity acting as the controller of your personal information depends on the Services you use and your location. Generally:

• If you reside outside the Designated Countries (Australia, Canada, Japan, Mexico, New Zealand, Russia, and Europe, including the UK and ROI):
  Apnotic, LLC
  P.O. Box 3938
  Peabody, MA 01961
  USA

How to Reach Us

If you have questions about this Privacy Policy or wish to exercise your rights, you can contact us via our web form or by email. These are the quickest ways to receive a response.

Other Things You Should Know

Transferring Information

Because Apnotic’s Services are available worldwide, information about you may be used, stored, and accessed by individuals or entities operating outside the European Economic Area (EEA), including our team members, subsidiaries, or third-party data processors. This may occur for the purposes described in the How and Why We Use Information section.

When transferring personal information outside the EEA, we take appropriate measures to protect your data in accordance with applicable laws. These measures include entering into European Commission-approved standard contractual clauses with recipients located in countries that lack adequate data protection laws.

If you have questions about how we protect your data when transferring it outside the EU, feel free to contact us.

Ads and Analytics Services Provided by Others

Ads shown on our Services may be provided by advertising networks, and analytics services may also be provided by third parties. These providers may use tracking technologies (like cookies) to collect information about your use of our Services and other websites. These technologies enable third parties to recognize your device, gather data about usage patterns, and deliver ads tailored to your interests.

This Privacy Policy applies only to information collected by Apnotic. We recommend reviewing the privacy policies of any third-party advertisers or analytics providers to understand how they handle your information.

Third-Party Software and Services

If you choose to use third-party plugins, embeds, software, or services in conjunction with our Services, please note that these interactions may involve sharing your data (or data about your users or customers) with those third parties. For example, a third-party service may use pixels or cookies to collect data about you or your audience.

Your data will be subject to the privacy practices of the third party, which we do not own or control. We recommend carefully reviewing their privacy policies before using such services.

Privacy Policy Changes

We may update this Privacy Policy from time to time. Most changes will be minor, but we encourage you to review this page regularly to stay informed about any updates. If we make significant changes, we’ll notify you by:

• Revising the change log below,
• Adding a statement to our homepage or blog, or
• Sending you a notification through email or your pwpush.com dashboard.

Your continued use of our Services after changes to this Privacy Policy indicates your acceptance of the updated policy.

Translation

This Privacy Policy was originally written in English (US). We may translate it into other languages for your convenience.

In the event of a conflict between a translated version and the English version, the English version will prevail.

That’s it! Thanks for taking the time to read our Privacy Policy.