Final version — published on September 19, 2025. Compliant with Chilean Law No. 21.719 (with deferred entry into force), and aligned with international standards (EU/GDPR, Brazil/LGPD). Supersedes previous versions.

1. Data Controller

Entity: Pushd SpA
Tax ID (RUT): 77.474.857-1
Address: Robles 12652, Lo Barnechea, Santiago, Chile
Privacy contact: privacy@pushd.xyz
Data Protection Officer (DPO): to be appointed (temporary contact: privacy@pushd.xyz)

2. Data We Process

• Identification and contact: name, email, phone.
• Optional profile: month/year of birth, gender, occupation, income range.
• Interests selected in the app.
• Usage/activity: notification openings, clicks, interactions.
• Device/network: OS, model, carrier, IP, connectivity.
• Location: approximate or precise, only if permission is granted (background access is optional).
• Transactional data: balance, withdrawals, accounting/tax records.
• Communications: messages sent to support.
• Inferred data: segments/affinities created by algorithms.

We do not request sensitive data unless with explicit consent and clear purpose.

3. Purposes and Legal Bases

• Registration & Security: account creation, anti‑fraud (Contract / Legitimate Interest)
• Service delivery: sending notifications, managing balance and withdrawals (Contract)
• Personalization: message segmentation (Consent, revocable)
• Location-based campaigns (Consent)
• Support: assistance, notices (Contract / Legitimate Interest)
• Direct marketing (own): Pushd news (Consent or right to object)
• Analytics/improvements: metrics, quality (Legitimate Interest)
• Legal compliance: accounting or tax obligations (Legal Obligation)

4. Minors

Service aimed at users 18+. If access for 14–17 is enabled, verified parental consent will be required.

5. Automated Decisions

We generate segments to send more relevant messages. We do not make exclusively automated decisions with legal effects without human involvement.

6. Recipients

• Data processors (cloud, payments, support) under contract.
• Authorities, where there is a legal obligation.
• Corporate transactions (merger/sale), with legal safeguards and prior notice.
• Anonymized statistical data may be shared, without identifying individuals.

We do not sell your personal data.

7. International Transfers

We may transfer data outside Chile. Appropriate safeguards apply (contractual clauses, technical measures, risk assessments). Copies available upon request.

8. Retention

• Account data: while account is active.
• Analytics: 12–18 months, then anonymization/deletion.
• Legal records: according to statutory deadlines.
• Account deletion: data erased except for legal obligations. Unwithdrawn balance is lost upon deletion.

9. Rights

Access, rectification, deletion, objection, portability, restriction, and withdrawal of consent.
How to exercise: via app or privacy@pushd.xyz.
Response time: 30 business days or as required by law.
Supervisory authority: Personal Data Protection Agency (once operational).

10. Security

Encryption in transit and at rest, access controls, internal audits. We will notify authorities and users if a security incident affects rights.

11. Cookies/SDKs

We use necessary cookies/SDKs and, with consent, analytics or measurement tools.

12. Changes

We will publish the date of last update and notify of material changes. If new consent is required, we will request it.

Last updated: September 19, 2025