It certainly includes that, yes. In fact, mobile push notifications is one case that I hadn't even thought of. If you use a third party to perform push notifica

It certainly includes that, yes. In fact, mobile push notifications is one case that I hadn't even thought of. If you use a third party to perform push notifications, you are "accessing" data through a third party application. (I'm presuming the word "accessing" is used here to mean any use of a third party server, regardless of whether read or write - because the whole idea is pointless if transmitting is not included in the definition) It also includes any email client with a built-in VPN, or potentially any client that can use a VPN (remember, it's at Google's discretion)