This privacy notice for Publitek Limited (“we,” “us,” or “our”), describes how and why we might collect, store, use, and/or share (“process”) your information when you use our services (“Services”), such as when you:
- If you are a client of ours, or you work for a client of ours
- Visit our website at www.publitek.com, or any website of ours that links to this privacy notice
- Engage with us in other related ways, including any sales, marketing, or events
- If you provide goods or services to us
- Apply for a position with us
- Receiving help through our customer support channels;
- Participation in customer surveys or contests;
In legal terms, we are generally the “data controller” under European data protection laws of the personal information described in this privacy notice, since we determine the means and/or purposes of the data processing we perform. This privacy notice does not apply to the personal information we process as a “data processor” on behalf of our customers.
Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at [email protected].
Table of Contents
- WHAT INFORMATION DO WE COLLECT?
- HOW DO WE PROCESS YOUR INFORMATION AND WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
- WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
- IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
- HOW LONG DO WE KEEP YOUR INFORMATION?
- WHAT HAPPENS IF YOU DO NOT PROVIDE US WITH THE INFORMATION WE REQUEST OR ASK THAT WE STOP PROCESSING YOUR INFORMATION?
- DO WE MAKE AUTOMATED DECISIONS CONCERNING YOU?
- WHAT ARE YOUR PRIVACY RIGHTS?
- DO WE MAKE UPDATES TO THIS NOTICE?
- HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
- CANADIAN RESIDENTS ADDITIONAL NOTICE INFORMATION
- UNITED STATES RESIDENTS ADDITIONAL NOTICE INFORMATION
- INTERNATIONAL AND GROUP TRANSFERS DATA TRANSFERS
1. WHAT INFORMATION DO WE COLLECT?
Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:
- names
- phone numbers
- email addresses
- job titles
- contact preferences
- information you provide when submitting a job application to us (for example, the personal information contained on your CV).
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
Information automatically collected. We automatically collect certain information when you visit, use, or navigate the Services. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies. You can find out more about the information we collect via cookies, at our cookie policy.
We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising, including to help manage and display advertisements, to tailor advertisements to your interests. The third parties and service providers use their technology to provide advertising about products and services tailored to your interests which may appear either on our Services or on other websites.
The information we collect includes:
- Log and Usage Data. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called “crash dumps”), and hardware settings).
- Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services.
- Location Data. We collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address).
2. HOW DO WE PROCESS YOUR INFORMATION AND WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
We process your personal information for a variety of reasons, depending on how you interact with our Services, including:
| Purpose/Activity | Lawful basis for processing including basis of legitimate interest |
| ● To carry out our obligations arising from any contract entered into between you and us and to provide you with the information, products and services that you request from us
● To deliver and facilitate delivery of the Services to the user. We may process your information to provide you with the requested service. ● To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service. |
a) Performance of a contract with you |
| ● To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time.
● To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them. ● To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you. ● to consider you for the jobs that you have applied for. ● To administer and protect our business and this website (including troubleshooting, data analysis, testing, support, reporting and hosting of data) |
a) You have given consent
b) Necessary for our legitimate interest |
We may also rely on the following legal basis:
- Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
- Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.
3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
We may need to share your personal information in the following situations:
- We share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
- We share your personal information with third parties who perform functions on our behalf and who also provide services to us, such as professional advisors, IT consultants carrying out testing and development work on our business technology systems, research and mailing houses and function co-ordinators. These third parties comply with similar and equally stringent undertakings of privacy and confidentiality.
- Where required we share your personal information with third parties to comply with a legal obligation; when we believe in good faith that an applicable law requires it; at the request of governmental authorities conducting an investigation; to enforce any applicable policies; to detect and protect against fraud, or any technical or security vulnerabilities; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of third parties, visitors to the our website, our business or the public.
Google Analytics. We may share your information with Google Analytics to track and analyze the use of the Services. The Google Analytics Advertising Features that we may use include: Google Analytics Demographics and Interests Reporting. To opt out of being tracked by Google Analytics across the Services, visit https://tools.google.com/dlpage/gaoptout. You can opt out of Google Analytics Advertising Features through Ads Settings and Ad Settings for mobile apps. Other opt out means include https://optout.networkadvertising.org/ and http://www.networkadvertising.org/mobile-choice. For more information on the privacy practices of Google, please visit the Google Privacy & Terms page.
4. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
Our servers are located in the United States. If you are accessing our Services from outside the United States, please be aware that your information will be transferred to, stored, and processed by us in our facilities and by those third parties with whom we share your personal information (see “WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?” above), in the United Kingdom, and other countries.
When we transfer your information outside the EEA, United Kingdom or Switzerland, we ensure that there are adequate security measures in place for the transfer.
We have implemented measures to protect your personal information, including by using the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers. These clauses require all recipients to protect all personal information that they process originating from the EEA or UK in accordance with European data protection laws and regulations. Our Standard Contractual Clauses can be provided upon request. We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.
5. HOW LONG DO WE KEEP YOUR INFORMATION?
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice and in line with our internal retention policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).
6. WHAT HAPPENS IF YOU DO NOT PROVIDE US WITH THE INFORMATION WE REQUEST OR ASK THAT WE STOP PROCESSING YOUR INFORMATION?
If you do not provide the personal information necessary or withdraw your consent for the processing of your personal information, where this information is necessary for us to provide services to you, we will not be able to provide these services to you.
7. DO WE MAKE AUTOMATED DECISIONS CONCERNING YOU?
No, we do not carry out automated decision making about you.
8. WHAT ARE YOUR PRIVACY RIGHTS?
You have certain rights under applicable data protection laws. These may include the right:
- to request access and obtain a copy of your personal information,
- to request rectification or erasure;
- to restrict the processing of your personal information;
- if applicable, to data portability; and
- not to be subject to automated decision-making.
- In certain circumstances, you may also have the right to object to the processing of your personal information.
- Right to withdraw your consent.
- If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.
- If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.
Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.
If you have questions or comments about your privacy rights, you may email us at [email protected].
9. DO WE MAKE UPDATES TO THIS NOTICE?
We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date at the top of this privacy notice. 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.
10. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you are a resident in the United Kingdom, we are the “data controller” of your personal information. We have appointed Amanda Hamilton to be our representative in the UK. You can contact them directly regarding our processing of your information, by email at [email protected], by visiting www.publitek.com, by phone at +44 (0) 1225 470000, or by post to:
60 Great Portland Street
London W1W 7RT
England
If you are a resident in the European Economic Area or Switzerland, we are the “data controller” of your personal information. We have appointed Mark Herten to be our representative in the EEA and Switzerland. You can contact them directly regarding our processing of your information, by email at [email protected], by visiting www.publitek.com, by phone at +49 (0)4181 968 0980, or by post to:
Publitek GmbH
Bremer Straße 6
Buchholz 21244
Germany
11. CANADIAN RESIDENTS ADDITIONAL NOTICE INFORMATION
We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.
In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:
- If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
- For investigations and fraud detection and prevention
- For business transactions provided certain conditions are met
- If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
- For identifying injured, ill, or deceased persons and communicating with next of kin
- If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
- If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
- If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
- If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
- If the collection is solely for journalistic, artistic, or literary purposes
- If the information is publicly available and is specified by the regulations
12. UNITED STATES RESIDENTS ADDITIONAL NOTICE INFORMATION
Categories of Personal Information We Collect. We have collected the following categories of personal information in the past twelve (12) months:
| Categories | Data Elements | Third parties with whom the personal information is shared with | |
| A. Identifiers | Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name | YES | Our affiliates and subsidiaries; Vendors who provide services on our behalf; Professional services organizations, such as auditors and law firms; Our business partners; Advertising networks; Internet service providers; Data analytics providers; Operating systems and platforms; Social networks |
| B. Personal information as defined in the California Customer Records statute | Name, contact information, education, employment, employment history, and financial information | YES | Our affiliates and subsidiaries; Vendors who provide services on our behalf; Professional services organizations, such as auditors and law firms; Our business partners; Advertising networks; Internet service providers; Data analytics providers; Operating systems and platforms; Social networks |
| D. Commercial information | Transaction information, purchase history, financial details, and payment information | YES | Our affiliates and subsidiaries; Vendors who provide services on our behalf; Professional services organizations, such as auditors and law firms; Our business partners; Advertising networks; Data analytics providers; Operating systems and platforms |
| E. Biometric information | Fingerprints and voiceprints | NO | |
| F. Internet or other similar network activity | Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements | YES | Our affiliates and subsidiaries; Vendors who provide services on our behalf; Professional services organizations, such as auditors and law firms; Our business partners; Advertising networks; Internet service providers; Data analytics providers; Operating systems and platforms; Social networks |
| G. Geolocation data | Device location | YES | Our affiliates and subsidiaries; Vendors who provide services on our behalf; Professional services organizations, such as auditors and law firms; Our business partners; Advertising networks; Internet service providers; Data analytics providers; Operating systems and platforms; Social networks |
| H. Audio, electronic, sensory, or similar information | Images and audio, video or call recordings created in connection with our business activities | YES | Our affiliates and subsidiaries; Vendors who provide services on our behalf; Professional services organizations, such as auditors and law firms; Our business partners; Operating systems and platforms |
| I. Professional or employment-related information | Business contact details in order to provide you our Services at a business level | YES | Our affiliates and subsidiaries; Vendors who provide services on our behalf; Professional services organizations, such as auditors and law firms; Our business partners; Advertising networks; Internet service providers; Data analytics providers; Operating systems and platforms; Social networks |
| K. Inferences drawn from collected personal information | Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics | NO | |
| L. Sensitive personal Information | NO |
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.
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 legally necessary
- Category F – As long as the user has an account with us
- Category G – As long as the user consent is valid
- Category H – As long as necessary according to our retention schedule
- Category I – As long as legally necessary
Learn more about the sources of personal information we collect in “WHAT INFORMATION DO WE COLLECT?”
Learn about how we use your personal information in the section, “HOW DO WE PROCESS YOUR INFORMATION?”
Learn more about how we disclose personal information to in the section, “WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?”
Your Rights. You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:
- Right to know 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 the deletion of your personal data
- Right to obtain a copy of the personal data you previously shared with us
- Right to non-discrimination for exercising your rights
- Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California’s privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (“profiling”)
Depending upon the state where you live, you may also have the following rights:
- Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including California’s and Delaware’s privacy law)
- Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including Oregon’s privacy law)
- Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including California’s privacy law)
- Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including Florida’s privacy law)
To exercise these rights, you can contact us by emailing us at [email protected].
Appeals. Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at [email protected]. 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 is denied, you may submit a complaint to your state attorney general.
California “Shine The Light” Law. 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 by using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?”
Controls for DO-NOT-TRACK features. California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.
13. INTERNATIONAL AND GROUP TRANSFERS DATA TRANSFERS
As set about above, we may share your personal data within our Group. This may involve transferring your data outside of the UK and the European Economic Area (EEA). We have therefore entered into a specific intra-group contract utilising the International Data Transfer Addendum to the European Commission’s Standard Contractual clauses for international data transfers.
Although we attempt to process data in country, some of our third-party service providers and customers may be based outside of the UK or EEA.
Whenever we transfer your personal data outwith UK or the EEA to these third parties, we ensure a similar degree of protection is afforded by implementing one of the following safeguards:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission or the UK Government.
- Where we use certain service providers, we may use specific contracts approved by the European Commission or the Secretary of State for the United Kingdom as affected by the Information Commissioner’s Office, which give personal data the same protection it has in Europe and the UK.
Please contact the Data Protection and Privacy Office if you wish further information on the specific mechanisms used by us when transferring your personal data out of the UK or the EEA.