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Effective June 2026.

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Data zones

OneSignal classifies data into three zones based on who controls it and what governs it.

Zone 1

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Customer-provided

Customer owns · DPA governs

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Customer Content

  • Messages and notifications
  • AI prompts and outputs
  • Campaign analytics
  • MCP-accessed external data

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Subscriber Data

  • Names, emails, phones
  • Custom attributes

Zone 2

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OneSignal Collected

OneSignal collects · Internal only

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Usage Data

  • API activity logs
  • Server delivery infrastructure
  • SDK performance
  • IP addresses and device IDs
  • Service performance data
  • AI infrastructure metrics
  • Engagement predictions (ML-derived)
No external disclosure.
The only path out of Zone 2 is transformation into Zone 3.

Zone 3

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OneSignal Analytics

OneSignal owns · External-shareable

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De-identified and aggregated across all customers.

  • Platform-wide delivery benchmarks
  • Feature usage statistics
  • Service performance benchmarks
External disclosure permitted. AI training permitted (this zone only).
Customer Content and Subscriber Data together are Customer Personal Data, the scope of the DPA. OneSignal Analytics Data is the only form in which Usage Data can leave OneSignal’s systems.

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Data flows

DataLands in
AI promptsZone 1 (Customer Content)
AI outputsZone 1 (Customer Content)
Campaign open rates / CTRsZone 1 (Customer Content)
MCP external dataZone 1 (Customer Content)
AI evaluation and annotation logsZone 1 (Customer Personal Data)
AI infrastructure metricsZone 2 (Usage Data)
Engagement predictions (ML-derived)Zone 2 (Usage Data)
AI evaluation and annotation logs are retained up to 90 days in BigQuery (europe-west4), are accessible only to authorized OneSignal personnel for service quality review, are not used for model training, and are auto-purged at 90 days.
AI training is prohibited from Zone 1 data. External disclosure is prohibited from Zone 2 data.

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Detailed reference

Customer-Provided Data

You control · OneSignal processesCustomer Content: Messages and notifications you create and send through OneSignal, plus AI-generated content, Agent Conversation prompts, campaign performance analytics, and data accessed from external systems via MCP connections.
  • Push notifications
  • In-app messages
  • Email and SMS content
  • AI prompts and outputs
  • Campaign analytics (open rates, CTRs, delivery rates for specific campaigns)
  • MCP-accessed external data (from systems you authorize)
Subscriber Data: Audience data you explicitly upload or provide to target and personalize messaging.
  • Names
  • Email addresses
  • Phone numbers
  • Custom attributes
Does not include system-generated identifiers (IPs, device IDs). Those are Usage Data.Customer Content + Subscriber Data = Customer Personal Data (DPA scope). DPA applies. OneSignal acts as your data processor, subject to GDPR, CCPA, and applicable data protection law.

OneSignal-Collected Data

OneSignal controlsUsage Data: Platform operational telemetry generated automatically by OneSignal’s systems. Does not include campaign-specific performance data (that is Customer Content) or Subscriber Data.
  • IP addresses
  • Device identifiers
  • Advertising IDs
  • API activity logs
  • Service performance data
  • SDK performance data
  • AI infrastructure metrics
  • Engagement predictions (ML-derived outputs)
No external disclosure. The only path to external use is transformation into OneSignal Analytics Data.OneSignal Analytics Data: Aggregated, de-identified benchmarks and analytics, de-identified and aggregated across all customers. Never contains Customer Content or Subscriber Data. OneSignal’s property.
  • Platform benchmarks
  • Delivery statistics
  • Service performance
Sole external-shareable form. AI training permitted. DPA does not apply to Usage Data or OneSignal Analytics Data. OneSignal processes them as a controller, governed exclusively by the Agreement.

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AI features and MCP data

AI and MCP data is not a separate category. It flows through the existing zones based on what the data is.

What flows in (inputs)

  • Customer Content used as AI prompts
  • Subscriber attributes for targeting
  • MCP context from external systems → Customer Content

What comes out (outputs)

  • AI-drafted message copy → Customer Content
  • Suggested segments → Subscriber Data
  • Campaign open rates / CTRs → Customer Content
  • AI infrastructure metrics → Usage Data (Zone 2)
  • Engagement predictions (ML-derived) → Usage Data (Zone 2)
Key protection: OneSignal will not use Customer Content or Subscriber Data to train or fine-tune any machine learning or artificial intelligence model. OneSignal may use OneSignal Analytics Data for AI training, because that data is derived from platform operational data only, never from Customer Content or Subscriber Data. AI inputs drawn from Customer Content or Subscriber Data remain Customer Personal Data. DPA protections follow the data, not the technology used to process it.
AI Agent conversation data retained in evaluation and annotation logs (up to 90 days, BigQuery, europe-west4) remains Zone 1, Customer Personal Data. These logs may be reviewed by authorized OneSignal personnel for service quality purposes only. They are not used for model training and are not shared externally. Deletion rights are governed by DPA section 8.3 (automatic 90-day purge, not subject to individual deletion requests). For more detail, see AI Agent data practices.

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Confidential Information

Confidential Information spans both customers and OneSignal and is governed by the confidentiality terms of the Agreement, not by the DPA.

Customer's CI examples

  • Business strategies and roadmaps
  • Contract and pricing terms
  • Internal analytics and KPIs
  • Marketing campaign details
  • Technical architecture
  • Audience size and volumes

OneSignal's CI examples

  • API architecture and source code
  • Security documentation
  • Pricing and discount structures
  • Product roadmap
  • Subprocessor details
  • Audit reports
Personal Data is explicitly excluded from Confidential Information. Customer Personal Data, Subscriber Data, and Customer Content are governed by the DPA and applicable data protection law, not by contractual confidentiality obligations. Names, email addresses, phone numbers, custom audience attributes, and message content involving personal data are not treated as Confidential Information.
Standard exclusions also apply. Confidentiality obligations do not cover information that is or becomes publicly available, is independently developed by the receiving party, is received without restriction from a third party, or is required to be disclosed by law.

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Legend

  • Customer Content: Zone 1, Customer owns, DPA governs
  • Subscriber Data: Zone 1, Customer owns, DPA governs
  • Customer Personal Data: Zone 1, Customer Content + Subscriber Data, DPA scope
  • Usage Data: Zone 2, OneSignal controls, internal only
  • OneSignal Analytics Data: Zone 3, OneSignal owns, external-shareable
  • AI / MCP: Flows through existing zones, not a separate category
  • Confidential Information: Spans both sides, governed by confidentiality terms

AI Agent data practices

What data the AI Agent uses, how long it is retained, and the controls you have.

Handling personal data

How OneSignal handles personal data and how you can meet GDPR and CCPA requirements.