Our Commitment to Privacy
Introduction and Background
OneSignal is a customer engagement platform for companies around the world to enable relationships for them and their customers. This is primarily done by leveraging first party data to personalize and automate messaging through first party channels, such as email, SMS, mobile push notifications, web push notifications, and in-app messaging.
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, if provided to us.
- 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).
Information Collected About End Users by Our Mobile SDKs
- How a user has used the App (e.g., session duration, time-stamp)
- Purchases made within an app.
- Information about End User’s transactions and interactions with the app
- Mobile device or account identifiers. 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. (Location information is only collected the user has granted permission to the App to collect this, and the app chooses to send this data to OneSignal)
- Email address, if provided to us.
- 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 on behalf of our Clients, 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 enable clients to create inferences about End Users categorized into “Data Segments”. 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 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 to perform any of the above functions, or other 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 deploy online cookies to track users across websites, or to associate users (and these cookies) with Mobile IDs. We may do this to resolve user identifies across platforms, and to better or more accurately target messages to. You can learn more about cookies and similar technologies, such as web beacons and SDKs, in the Section titled “Cookies, Pixel Tags and SDKs .”
3. How and Why We Share the SDK Information.
To Provide Services to Websites and Apps Using the SDKs
- We share the SDK Information on our Clients’ behalf 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.
OneSignal does not share SDK information with third parties except those who process the data on behalf of OneSignal. Data is only shared with third parties if:
- 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, phone number, 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
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 identify users through mobile applications and browsers based on information associated with your mobile device. We do not collect advertising identifiers such as IDFAs or Android Advertising IDs.
Do Not Track Signals. OneSignal currently does not respond to browser do not track (DNT) signals, so we may not be aware of, or may be unable to respond to, such signals.
6. Data Controller for Personal Data and Data Processor for Clients
OneSignal is the data controller for processing of certain Personal Data, such as the Personal Data of our client business contacts or the OneSignal Website Information. However, we act as a data processor (or service provider) in relation to the Services we provide to our Clients, such as when a Client deploys our technology in order to collect, process or transfer first party data.
7. Consumer Control and Opt Out Options
You may have the following privacy rights;
- If you wish to access, correct, update or request deletion of your Personal Data, you can do so at any time by contacting us at Privacy@OneSignal.com.
- In addition, if you are a resident of the European Economic Area, the United Kingdom or Switzerland, you can object to processing of your Personal Data, ask us to restrict processing of your Personal Data or request portability of your Personal Data. Again, you can exercise these rights by contacting us at Privacy@OneSignal.com.
- You have the right to opt-out of marketing communications (including, emails) we send you at any time. You can exercise this right by clicking on the “opt-out” link in the marketing communications we send you or by contacting us at Privacy@OneSignal.com.
- You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects ("Automated Decision-Making"). Automated Decision-Making currently does not take place on our Website or in our Services;
- Similarly, if we have collected and processed your Personal Data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Data conducted in reliance on lawful processing grounds other than consent.
- You have the right to complain to a data protection authority about our collection and use of your Personal Data. For more information, please contact your local supervisory authority.
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 and specific to each browser, 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.
Clients 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.
Where you wish to enforce any of these rights in respect of our Services, you should contact the Client who provides you with the website or mobile application. We will then help them to fulfill that request in accordance with their instructions and applicable legal requirements.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
8. Processing Personal Information (EEA, Switzerland and UK Visitors Only)
If you are a visitor to our Website from the EEA, Switzerland or the United Kingdom, our legal basis for collecting and using the Personal Data described above will depend on the Personal Data concerned and the specific context in which we collect it.
However, we will normally collect Personal Data from you only where we have your consent to do so, where we need the Personal Data to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect Personal Data from you or may otherwise need the Personal Data to protect your vital interests or those of another person.
If we ask you to provide Personal Data to comply with a legal requirement or to perform a contract with you, where we process your Personal Data on behalf of a Client, we will make this clear at the relevant time and advise you whether the provision of your Personal Data is mandatory or not (as well as of the possible consequences if you do not provide your Personal Data).
Similarly, if we collect and use your Personal Data in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.
If we process your Personal Data on behalf of a Client, we rely on our Client’s legal basis for processing your Personal Data on their behalf.
If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Data, please contact us at Privacy@OneSignal.com.
9. Processing Personal Information (California Residents Only)
As a California resident, you may have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.
You can make the following requests regarding your Personal Information:
- Access . You can request a copy of the following:
- The categories of personal information we collected about you,
- The categories of sources for the personal information we collected about you,
- Our business or commercial purpose for collecting that personal information,
- The categories of third parties with whom we share that personal information,
- Whether we have disclosed your personal information for a business purpose and the categories of recipients,
- Whether we have sold your personal information and the categories of recipients, and
- The specific pieces of personal information we collected about you (which will also allow you to exercise your data portability right).
- Portability. You have the right request that we provide you with access to the information above in a readily useable format that allows you to transmit (i.e., port) the information to another entity without hindrance.
- Deletion. You can ask us to delete the Personal Information that we have collected from you.
Non-discrimination. You are entitled to exercise the rights described above free from discrimination. This means that we will not penalize you for exercising your rights by taking actions such as denying you services, increasing the price/rate of services, decreasing service quality, or suggesting that we may penalize you as described above for exercising your rights. You can exercise these rights by contacting us at Privacy@OneSignal.com. We will need to confirm your identity and California residency to process your information, access or deletion requests, and we reserve the right to confirm your California residency. Government identification may be required. If you wish to designate an authorized agent to make a request on your behalf, we will need to verify both your and your agent’s identities and your agent must provide valid power of attorney or other proof of authority acceptable to us in our reasonable discretion. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.
In cases where we process your information on behalf of a Client, you will need to exercise your rights directly with the Client, unless the Client allows us to respond to you directly.
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.
12. Third-Party Websites and Apps
13. Users From Outside the United States
The Website and our Services are provided, supported in Europe and the United States. Our data is hosted and stored in Europe and our operation of them is governed by EU General Data Protection Regulations. If you are using the Site from outside the United States, be aware that your Information may be transferred to, stored and processed in Europe and accessed in the United States as well as other countries where our facilities are located. The data protection and other laws of the United States and Europe 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.
If you are located in the European Economic Area, the UK or Switzerland, we will protect your personal information when it is transferred outside of your jurisdiction by (a) processing it in a territory that provides an adequate level of protection based on its data protection laws; or (b) implementing appropriate safeguards to protect your personal information, such as relying on the European standard contractual clauses (and the UK addendum, if applicable). OneSignal currently relies on these European standard contractual clauses (“Model Clauses”) for data transfers.
As of July 16, 2020, the European Court of Justice issued a judgement declaring Privacy Shield invalid. OneSignal now relies on other transfer mechanisms, such as the Model Clauses described above, for the cross-border transfer of data.
OneSignal continues to comply with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. OneSignal has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/. In compliance with the Privacy Shield Principles, OneSignal commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact OneSignal at: privacy@OneSignal.com.
OneSignal has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved Privacy Shield complaints concerning data transferred from the EU and Switzerland.
In the event we are unable to resolve your concern, a binding arbitration option may also be available to you in order to address residual complaints not resolved by any other means. OneSignal is subject to the investigatory and enforcement powers of the United States Federal Trade Commission ("FTC").