Marketing Push Messaging Policy

Publication date

2026-10-09

Effective date

2026-10-09

Version 2.11-PUSH-EN.
Publication and effective date: 9 October 2026.

1. Purpose and definitions

This Policy governs optional OwnCup marketing push messages and campaigns initiated by business clients through the OwnCup platform.

In this Policy:

• OwnCup means KICO GLOBAL EOOD, the platform operator and technical sender of the notification;
• Client means a legal entity or sole trader that has entered into an agreement with OwnCup and operates one or more Locations;
• Location means a specific physical place of business operated by the Client and verified in OwnCup; in the user interface, a Location may be called a café or venue;
• Guest means a user of the OwnCup application;
• Recipient means a Guest with an active selection of the relevant message category whom OwnCup includes in a send under the platform's uniform rules;
• Material means the campaign title, text, image, link, period, terms and other information supplied by the Client;
• Campaign means a Client-initiated transmission of approved Material to Recipients formed by OwnCup.

The Client does not select specific Recipients, upload contact lists or receive the Recipients' personal and technical data listed in section 10.2 of the Business Client Terms of Service.

2. Voluntary selection categories

OwnCup provides three independent categories that are off by default:

1. Café offers and promotions — campaigns by cafés whose programmes the Guest participates in and automatic OwnCup reminders about visits, progress and rewards in those programmes;
2. Offers from OwnCup — OwnCup's own optional offers;
3. OwnCup news and updates — optional product news and updates that are not mandatory service messages.

Selecting one category does not enable the others. An iOS or Android system permission, registration, participation in a loyalty Programme, acceptance of terms and the existence of a push identifier do not constitute marketing consent.

A message is allocated by its purpose. A campaign by the relevant café and an automatic OwnCup reminder about that café's Programme belong to the Café offers and promotions category. An OwnCup offer that is unrelated to a particular café's Programme belongs to the Offers from OwnCup category.

Refusal or withdrawal does not restrict the Account's core functions, the loyalty programme or mandatory service messages. The selection may be changed free of charge in the application settings; withdrawal blocks new messages in the relevant category without undue delay.

3. Confirmation of legal entitlement

After selecting at least one marketing category and before it is activated, the Guest separately confirms:

I confirm that I am legally entitled to give this consent independently under the law applicable to me.

The confirmation is off by default. Without it, marketing categories are not activated, while registration and the service's core functions remain available.

OwnCup records the fact of confirmation, date and time, language, text version and technical source. This is the user's statement that they are legally entitled to give the specific consent independently, not documentary age verification. OwnCup does not collect a date of birth or copy of an identity document for this purpose. If the Guest is not legally entitled to give consent independently, the marketing category is not activated; the current model does not permit activation on the basis of permission from a parent or holder of parental responsibility.

An age rating or target audience in the App Store or Google Play does not replace this selection and is not treated by OwnCup as verification of a particular Guest's age.

4. Campaign initiation and management

Before first accessing the creation of a Client-initiated campaign, an authorised user separately confirms the Client's acknowledgement and acceptance of the applicable versions of the Business Client Terms of Service, this Policy, the Privacy Notice, and the allocation of responsibilities under Article 26 GDPR set out in them. Without that confirmation, campaign creation is unavailable. A material change to the allocation of responsibilities requires a new confirmation before campaign-creation access continues.

The Client initiates a Campaign and supplies the Material. A Campaign relates to one or more verified Client Locations.

OwnCup is the technical sender of the notification and applies uniform rules for determining the Recipients, frequency and sending time. The Client does not identify a particular Guest and cannot create arbitrary segments, upload contacts, use a geographical radius or lookalike audience, or use results from opening previous push messages.

Message geography is determined by the city of the verified Location to which the programme or offer relates. The Guest does not select the campaign city and the device's current geolocation is not used for this purpose. Message language is determined by the available localisation of the Material and the application's language setting.

A Recipient must have a confirmed connection with the programme of the relevant Client or Location: participation, a confirmed visit, progress or a reward. The Guest's city of residence or presence alone is not a basis for inclusion in a Campaign. If a Campaign relates to Locations in different cities, OwnCup creates separate city send jobs or applies an equivalent technical separation.

5. Material and offer period

The Client specifies:

• one or more Locations;
• campaign category and type;
• title, text, image and an allowed link or deep link;
• local start and end date and time if the offer is time-limited;
• how to obtain the offer and all material terms;
• price, required purchase, quantity, exclusions and restrictions where applicable.

The Client does not enter the time zone separately: OwnCup determines it from the Location's verified address. Immediately before transmission to FCM or APNs, OwnCup checks that a time-limited offer has not ended. After the end, OwnCup does not initiate a new send for that Campaign.

A push message is not automatically a price offer. If Material contains a price, discount, price comparison or price-reduction statement, the Client is responsible for its legality and substantiation, including applicable prior-price rules. OwnCup does not set or control the Client's prices.

6. Automatic Programme reminders

For the Café offers and promotions category, OwnCup may use confirmed events from the relevant programme, for example:

• the period since the last confirmed visit;
• the number of confirmed visits remaining before a reward;
• the availability or status of a reward already obtained.

OwnCup applies these criteria under uniform platform rules. An automatic reminder is not a Client-initiated campaign: the Client does not enable it for a particular Guest, select the trigger, Recipient, Material, period or sending time, or receive a criterion at the level of a particular Guest. If the Client is offered any ability to influence those parameters, that ability will not be activated until the parties' roles have been reassessed and this Policy and the related documents updated.

An open, view, delivery or click from a previous push is not used to form a future audience. OwnCup does not enable open, impression or click analytics for this function unless a separate decision, disclosure and legal basis are approved in a future version.

7. Frequency, time and plan quota

OwnCup applies a protective frequency cap for one Guest across all commercial categories: as a general rule, no more than one commercial push in 24 hours and no more than two in seven consecutive days. Commercial messages are not sent between 20:00 and 09:00 in the Location's time zone. OwnCup may apply a stricter cap, and these rules do not give the Client a right to demand sending at a chosen time.

A plan or separate offer may limit the number of Client campaigns in a billing period. The campaign quota does not replace the Guest frequency cap: even a paid campaign or one available under a plan may be deferred, combined, limited or rejected to comply with the Guest's selection, offer period, frequency rules and law.

A plan does not guarantee a number of Recipients, deliveries, opens, clicks, visits, sales or revenue.

8. OwnCup review and decisions

OwnCup may, but is not obliged to, carry out prior and subsequent review of Material and may reject, suspend or terminate a Campaign where law, the agreement, this Policy or other OwnCup rules are breached.

OwnCup review is a platform-management measure and does not replace the Client's legal, tax, advertising, pricing or sector-specific review. OwnCup may request supporting material or a correction where necessary.

A restriction decision may be reviewed under the Report Illegal Content & Support procedure.

9. Prohibited content

The following are prohibited:

• illegal goods, services or activities;
• goods, services and materials designated as or available only to persons aged 18+, including alcohol, tobacco and nicotine products, gambling, pornography and sexual services;
• drugs, weapons and dangerous instructions;
• fraud, false prices, sham discounts and concealed material terms;
• discrimination, hatred, violence and political campaigning;
• unsubstantiated medical claims and prohibited food or health claims;
• malicious, deceptive or tracking links;
• infringement of copyright, trade marks, privacy or image rights;
• collection of personal data through external forms or links;
• spam, circumvention of moderation and resubmission of rejected Material without correction;
• manipulation of children and unlawful denigration of competitors.

OwnCup does not use an age gate to permit 18+ content: that content is excluded from the service entirely.

10. Responsibility and roles of the parties

The Client is responsible for the legality, accuracy and completeness of information about goods, services, prices, period and other offer terms, its rights to the Material and performance of the offer for the Guest.

OwnCup is not the seller or provider under the Client's offer and does not warrant the accuracy of factual information supplied by the Client. This does not exclude OwnCup's liability for its own acts or omissions, including sending without the required consent, breaching the rules for determining the Recipients, distorting Material, or cases where exclusion of liability is prohibited by law.

OwnCup acts as an independent controller for the Account, obtaining and logging selections, push registration, suppression, security and uniform platform rules.

The Client acts as an independent controller for the content, price, terms and performance of its offer.

For the limited operation of forming and conducting a Client-initiated Campaign, OwnCup and the Client are joint controllers under Article 26 GDPR: the Client determines the commercial purpose, Material, Locations and period; OwnCup determines the technical means and applies the Guest's selection and uniform rules for determining the Recipients, frequency and sending time.

For the subsequent operation of generating and sending an automatic Programme reminder under uniform platform rules, OwnCup acts as an independent controller. This does not alter the joint nature of the preceding loyalty operation from which the visit, progress or reward information arose.

OwnCup publishes the information, obtains and logs the category selection, applies suppression, determines the Recipients and acts as the primary technical contact point. The Client provides accurate information about itself, the Material and the offer, does not require sending to persons without an active selection, and forwards requests and incident reports it receives to OwnCup. The full allocation of responsibilities is set out in section 10.5 of the Business Client Terms of Service, and its essence in section 9 of the Privacy Notice. The Guest may contact either party to the joint operation.

11. Complaints

A complaint about a message may be sent to support@owncup.eu, stating the Location's name, date and approximate time, text or screenshot, and reason for the complaint.

Personal-data requests should be sent to privacy@owncup.eu. Reports of allegedly illegal Material are handled under the Report Illegal Content & Support procedure.