Last Updated: January 04, 2026

SUMMARY OF KEY POINTS

This summary highlights the key points of this Privacy Policy. It is provided for convenience only and does not replace the full Privacy Policy below. You can find more detailed explanations by referring to the relevant sections in this document.

What personal data do we process? When Merchants install and use the Uppush application, and when End Users interact with marketing campaigns created via Uppush, we process personal data necessary to provide marketing automation services. This may include contact details, order and cart data, engagement data, and technical usage information, depending on how the Services are used.

Do we process sensitive personal data? No. Uppush does not intentionally collect or process special categories of personal data as defined under GDPR (such as health data, biometric data, or religious beliefs).

Do we receive personal data from third parties? Yes, in a limited and controlled manner. We primarily receive End User data from Shopify and merchant-configured opt-in sources (such as pop-ups or forms) solely to deliver the Services. We do not purchase personal data from data brokers.

How do we use personal data? We process personal data to operate, provide, and improve our marketing automation Services, including campaign delivery, personalization, analytics, security, fraud prevention, and legal compliance. We process personal data only when we have a valid legal basis under applicable data protection laws.

When and with whom do we share personal data? We do not sell personal data. We may share personal data with carefully selected sub-processors (such as hosting, messaging delivery, and analytics providers) only where necessary to provide the Services and subject to strict contractual data protection obligations.

How do we keep personal data secure? We implement appropriate technical and organizational security measures to protect personal data. However, no system can be guaranteed to be completely secure, and we cannot guarantee absolute security against unauthorized access or misuse.

What rights do individuals have? Depending on applicable law (such as GDPR, UK GDPR, or CCPA), individuals may have rights to access, correct, delete, restrict, or object to the processing of their personal data, as well as to withdraw consent for marketing communications.

How can these rights be exercised? End Users should primarily submit requests through the relevant Merchant, who acts as the Data Controller. Merchants may also contact Uppush for assistance. We respond to all valid requests in accordance with applicable data protection laws.

To learn more about how Uppush collects, uses, and protects personal data, please review the full Privacy Policy below.

1. INTRODUCTION AND SCOPE

This Privacy Notice explains how Uppush (“we”, “us”, or “our”) collects, uses, and discloses information in connection with the Uppush marketing automation application for Shopify.

This policy applies to:

Merchants: Any business or legal entity that installs and uses the Uppush application on their Shopify store.

Merchants’ Customers: Individuals who interact with a Merchant’s store and marketing assets created via Uppush (collectively referred to as “End Users”).

Under applicable data protection laws:

• Merchants act as the Data Controller with respect to End User personal data.
• Uppush acts as a Data Processor, processing personal data solely on the documented instructions of the Merchant.

This Privacy Policy is designed to comply with global data protection standards, including the GDPR (EU), UK GDPR, and, where applicable, the CCPA.

2. INFORMATION WE COLLECT

In the context of marketing automation, we collect and process data through the following categories.

2.1 Information from Merchants

• Account Information: Name, business email address, company name, billing address, and payment-related metadata.
• Store Information: Shopify store domain, store currency, Shopify plan type, and app configuration settings.
• Support Communications: Information provided when Merchants contact our support team.

2.2 Information about End Users (Customer Data)

To provide marketing application  features, Uppush synchronizes data from Shopify and merchant-configured opt-in sources, which may include:

Identifiers: Name, email address, phone number (if provided), IP address, device identifiers, and Shopify customer IDs.

Commercial Information: Order history, cart contents, abandoned checkout data, products viewed, purchase frequency, and lifetime value (LTV).

Engagement Data: Interactions with emails, web push notifications, pop-ups, and campaigns (such as opens, clicks, and conversions).

Uppush does not intentionally collect special categories of personal data as defined under GDPR.

2.3 Automatically Collected Information

Usage and Log Data: IP addresses, browser type, operating system, device information, timestamps, and feature usage data, collected for security, performance monitoring, and system optimization.

3. HOW WE USE INFORMATION?

We process personal data exclusively to deliver and improve specialized marketing automation services, including:

Marketing Automation: Enabling workflows such as abandoned cart recovery, welcome messages, post-purchase follow-ups, re-engagement campaigns, and automated email marketing sequences.

Email Marketing Campaigns: Creating, sending, and optimizing email marketing campaigns on behalf of Merchants, including newsletters, promotional emails, lifecycle emails, and transactional-related communications where applicable.

Personalization and Segmentation: Creating audience segments based on shopping behavior, engagement patterns, or merchant-defined criteria to deliver relevant content.

Analytics and Attribution: Measuring campaign performance, conversions, and return on investment (ROI).

Service Improvement: Using aggregated and de-identified data to enhance platform performance, reliability, and predictive marketing capabilities.

4. GLOBAL DATA TRANSFERS AND GDPR COMPLIANCE

4.1 International Data Transfers

Uppush operates on a global infrastructure. Personal data may be transferred to and processed in countries outside the European Economic Area (EEA), including the United States, where our sub-processors and infrastructure providers are located.

4.2 EU–US Data Privacy Framework

Where applicable, Uppush relies on the EU–US Data Privacy Framework, the UK Extension to the EU–US Data Privacy Framework, and the Swiss–US Data Privacy Framework, as administered by the U.S. Department of Commerce. These frameworks ensure lawful and secure transfers of personal data from the EEA, UK, and Switzerland to the United States

4.3 Standard Contractual Clauses (SCCs)

For transfers not covered by an adequacy decision, we rely on Standard Contractual Clauses (pursuant to Art. 46(2) and (3) GDPR). These are model templates provided by the EU Commission (specifically Decision 2021/914) to ensure data protection standards remain consistent across borders.

• You can view the specific SCC framework here: EUR-Lex 32021D0914.

5. SUB-PROCESSORS AND THIRD-PARTY DISCLOSURE

We do not sell personal data. We only share information with vetted third-party service providers (Sub-processors) who assist in our marketing operations:

• Cloud Infrastructure: (e.g., AWS, Google Cloud) for data storage.

• Analytics: (e.g., Mixpanel or Google Analytics) to monitor app performance.

All sub-processors are contractually bound to process data only according to our instructions and in compliance with GDPR.

6. DATA RETENTION AND DELETION

• Retention Period: We retain personal data as long as the Merchant maintains an active account with us.

• App Uninstallation: Upon uninstallation from a Shopify store, we initiate a data deletion process for all synced Customer Data within 48 hours, in accordance with Shopify’s Mandatory Webhooks.

• Exceptions: We may retain certain data as required by law or for legitimate business purposes (e.g., tax records or fraud prevention).

7. DATA SUBJECT RIGHTS

Under GDPR, UK GDPR, and applicable privacy laws, End Users have the right to:

Access and Portability: Request access to personal data and receive a copy.

Rectification: Correct inaccurate or incomplete data.

Erasure: Request deletion of personal data (“right to be forgotten”).

Restriction or Objection: Limit or object to certain processing activities.

Withdrawal of Consent: Opt out of marketing communications at any time.

Merchants are responsible for managing and responding to End User requests as Data Controllers. Uppush supports Merchants in fulfilling these requests where required.

8. SECURITY MEASURES

Uppush applies Privacy by Design and Privacy by Default principles and implements appropriate technical and organizational safeguards, including:

Encryption: Industry-standard encryption for data in transit and at rest.

Access Controls: Role-based access controls and authentication mechanisms for internal systems.

Monitoring and Testing: Continuous monitoring, logging, and regular security reviews to protect against unauthorized access, loss, or misuse of data.

9. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

10. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).

CCPA Privacy Notice

The California Code of Regulations defines a “resident” as:

• every individual who is in the State of California for other than a temporary or transitory purpose and
• every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose

All other individuals are defined as “non-residents.”

If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information.

What categories of personal information do we collect?

We have collected the following categories of personal information in the past twelve (12) months:

We will use and retain the collected personal information as needed to provide the Services or for:

• Category A – As long as the user has an account with us
• Category B – As long as the user has an account with us
• Category D – As long as the user has an account with us

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

• Receiving help through our customer support channels;
• Participation in customer surveys or contests; and
• Facilitation in the delivery of our Services and to respond to your inquiries. How do we use and share your personal information?

More information about our data collection and sharing practices can be found in this privacy notice.

You may contact us by email at admin@uppush.io, or by referring to the contact details at the bottom of this document.

If you are using an authorized agent to exercise your right to opt out we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf, following the same strict privacy protection obligations mandated by the CCPA.

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” of your personal information.

Uppush.io has not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. Uppush.io will not sell or share personal information in the future belonging to website visitors, users, and other consumers.

Your rights with respect to your personal data

Right to request deletion of the data — Request to delete

You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.

Right to be informed — Request to know

Depending on the circumstances, you have a right to know:

• whether we collect and use your personal information;
• the categories of personal information that we collect;
• the purposes for which the collected personal information is used;
• whether we sell or share personal information to third parties;
• the categories of personal information that we sold, shared, or disclosed for a business purpose;
• the categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose;
• the business or commercial purpose for collecting, selling, or sharing personal information; and
• the specific pieces of personal information we collected about you.

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

We will not discriminate against you if you exercise your privacy rights.

Right to Limit Use and Disclosure of Sensitive Personal Information

We do not process consumer’s sensitive personal information.

Verification process

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

Other privacy rights

• You may object to the processing of your personal information.
• You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information.
• You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
• You may request to opt out from future selling or sharing of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission.

To exercise these rights, you can contact us by email at admin@uppush.io, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.

11. DO VIRGINIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you are a resident of Virginia, you may be granted specific rights regarding access to and use of your personal information.

Virginia CDPA Privacy Notice

Under the Virginia Consumer Data Protection Act (CDPA):

“Consumer” means a natural person who is a resident of the Commonwealth acting only in an individual or household context. It does not include a natural person acting in a commercial or employment context.

“Personal data” means any information that is linked or reasonably linkable to an identified or identifiable natural person. “Personal data” does not include de-identified data or publicly available information.

“Sale of personal data” means the exchange of personal data for monetary consideration.

If this definition “consumer” applies to you, we must adhere to certain rights and obligations regarding your personal data.

The information we collect, use, and disclose about you will vary depending on how you interact with Uppush.io and our Services. To find out more, please visit the following links:

• Personal data we collect
• How we use your personal data
• When and with whom we share your personal data

Your rights with respect to your personal data

• Right to be informed whether or not we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (“profiling”)

Uppush.io has not sold any personal data to third parties for business or commercial purposes. Uppush.io will not sell personal data in the future belonging to website visitors, users, and other consumers.

Exercise your rights provided under the Virginia CDPA

More information about our data collection and sharing practices can be found in this privacy notice.

You may contact us by email at admin@uppush.io, by submitting a data subject access request, or by referring to the contact details at the bottom of this document.

If you are using an authorized agent to exercise your rights, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

Verification process

We may request that you provide additional information reasonably necessary to verify you and your consumer’s request. If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request.

Upon receiving your request, we will respond without undue delay, but in all cases, within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary. We will inform you of any such extension within the initial 45-day response period, together with the reason for the extension.

Right to appeal

If we decline to take action regarding your request, we will inform you of our decision and reasoning behind it. If you wish to appeal our decision, please email us at admin@uppush.io. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal if denied, you may contact the Attorney General to submit a complaint.

12. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

13. EU-US DATA PRIVACY FRAMEWORK, UK EXTENSION, AND SWISS-US DATA PRIVACY FRAMEWORK

Uppush complies with the EU–US Data Privacy Framework (“EU–US DPF”), the UK Extension to the EU–US DPF, and the Swiss–US Data Privacy Framework (“Swiss–US DPF”) as set forth by the U.S. Department of Commerce, where applicable.

Uppush has certified, or relies on certified service providers, to the U.S. Department of Commerce that it adheres to the EU–US Data Privacy Framework Principles with regard to the processing of personal data received from the European Union in reliance on the EU–US DPF, from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU–US DPF, and from Switzerland in reliance on the Swiss–US DPF.

In the event of any conflict between the terms of this Privacy Policy and the EU–US DPF Principles, the UK Extension principles, or the Swiss–US DPF Principles, the applicable Data Privacy Framework Principles shall prevail.

To learn more about the Data Privacy Framework program, please visit the official website at https://www.dataprivacyframework.gov/.

The relevant regulatory authority, including the U.S. Federal Trade Commission, has jurisdiction over Uppush’s compliance with the EU–US DPF, the UK Extension to the EU–US DPF, and the Swiss–US DPF, where applicable.

In the context of onward transfers, Uppush remains responsible for the processing of personal data it receives under the Data Privacy Framework and subsequently transfers to third parties acting as sub-processors on its behalf, unless Uppush demonstrates that it is not responsible for the event giving rise to any alleged damage.

In compliance with the EU–US DPF, the UK Extension to the EU–US DPF, and the Swiss–US DPF Principles, Uppush commits to resolving complaints regarding the collection or use of personal data transferred to the United States under these frameworks.

EU, UK, and Swiss individuals may submit privacy-related inquiries or complaints by contacting:

Email: support@uppush.io
If a complaint cannot be resolved directly with Uppush, individuals may have the right to seek independent dispute resolution through an appropriate Data Privacy Framework dispute resolution mechanism, as required under the applicable DPF Principles. In certain circumstances, binding arbitration may be available in accordance with the Data Privacy Framework Principles.

14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at admin@uppush.io or contact us by post at:
Uppush.io

Linh Dam

Hanoi, Hanoi 100000

Vietnam