Privacy Policy

[Last Updated: September 15, 2022]

This Privacy Policy ("Privacy Policy") is an integral part of our Terms of Use ("Terms") and governs the processing of information by Publicators Ltd. ("Publicators," "Company," "we," "us," or "our") while you ("you" or "user") access, use or interact with our Website available at: https://www.publicators.com/ ("Website") and when you use our services  including our email delivery system (“System”, and together "Services"). 

Any capitalized terms not defined herein shall have the meaning ascribed to them in the Terms. 

Publicators may update or revise this Privacy Policy from time to time. Modifications to this Policy will be posted on the Website or addressed directly to where the Company, upon its sole discretion, finds it required. 

This Privacy Policy explains how the data is collected, used, or shared with others, how it is safeguarded, and how an individual may exercise their lawful rights related, among others, and where applicable, as required according to the EU General Data Protection Regulation ("GDPR") and the California Consumer Privacy Act (“CCPA”).

Please note that this Privacy Policy applies towards the data in which we serve as a “Data Controller”, meaning the data of the Website visitors and some basic account data of our System’s Users. We are not the Processor of any data processed in the system (e.g., email recipients), and this Privacy Policy does not cover any such data. Such data is controlled by the relevant Customer of the System, and we serve merely as a Data Processor on their behalf. The Processing of any such data is subject to the terms of our agreements with the relevant Customer, including our Terms of Use and any applicable data processing agreement.

1. CONTACT DETAILS 

Publicators Ltd., registration number 513376327, 14 Michah St., Kfar Saba, Israel 
4434280 ("Controller").

If you have any questions or comments about this Privacy Policy or any concerns with respect to how your privacy and information are handled, please contact our privacy team at:  help@publicators.com or through the designated forms available on the Website. 

2. WHICH DATA DO WE COLLECT AND FOR WHAT PURPOSE?  

"Non-Personal Data": means non-identifiable, aggregated data, that is mainly technical data which is transmitted to us by your device when you access and interact with our Website, such as the type of browser, type of operating system, type of device used, the time and date you access the Website, navigation, language preference, etc. Non-Personal data is used mainly for click stream analysis to provide, maintain, develop and enhance our Website and the Services that may be provided therein (if applicable) and is not used to identify individuals.

"Personal Data": means individually identifiable information which identifies or may identify, with reasonable effort, an individual, including online identifiers, such as your name, address, phone number, billing information, and online identifiers (such as IP address). 

Please see below the table which specifies the Personal Data we collect and how we use it.

Personal Data we Collect from our Website’s visitors:

Personal Data we collect as a Controller from Users of the System:

Please note that the actual processing operation per each purpose of use and lawful basis detailed in the table above may differ. Such processing operation usually includes a set of operations, made by automated means, such as collection, storage, use, disclosure by transmission, erasure, or destruction. Transfer of personal data to third-party countries, as further detailed in the Data Transfer section, is based on the same lawful basis as stipulated in the table above. 

In addition, we may use certain Personal Data to prevent potentially prohibited or illegal activities, fraud, misappropriation, infringements, identity thefts, and any other misuse of the Website and to enforce the Terms, as well as to protect the security or integrity of our databases and Website, and to take precautions against legal liability. Such processing is based on our legitimate interests. 

3. COOKIES USAGE

We use cookies to improve your experience while you interact with our Website and use our Services including the System. We may use various types of Cookies:

• Essential Cookies – which are necessary for the Website to work properly;

• Functional Cookies – designated to save your settings on the Website - your language preference or other view preferences;

• Session Cookies – used to support the Website's functionality – such Cookies are stored only temporarily during a browsing session and are deleted from your device when you close the browser;

• Targeting Cookies - these cookies are used to collect information from you to help us improve our Services and provide you with targeted advertisements that we believe will be relevant to you (e.g., Google's Cookies). 

• Analytics Cookies - give us aggregated and statistical information to improve the Services and further developing it e.g., Google analytics, etc. 

Please note that the data collected by the use of Cookies may be linked to and combined with any other data, including Personal Data.

In addition, Cookie's data is usually collected through the use of third-party services, like Google, Facebook, etc. In those cases, your Personal Data might be transferred to those third parties, which might link it and use it together with other information they have on you from other sources. Such data is "owned" and processed separately by those third-parties under their terms and conditions and the direct accounts or subscriptions you have with those third parties. 

The specific cookies we currently use and your choices with regard to such use are detailed HERE.

4. HOW WE COLLECT INFORMATION

According to the nature of your interaction with the Website, we may collect information as follows:

• Automatically – we may use cookies and similar tracking technologies (as elaborated in the Cookies Section below) to gather some information automatically when you access the Website.

• Provided by an Admin – we may receive basic account and Users’ data from an admin user of one of our customers, when authorizing a new user in the System. 

• Provided by you voluntarily – we will collect information if and when you choose to provide us with information, such as when you contact us through the online form. 

• Provided to us by third parties – as detailed above, we receive information about users from our partners and distrusters. 

5. DATA SHARING– CATEGORIES OF RECIPIENTS WE SHARE PERSONAL DATA WITH

We share your data with third parties, including trusted partners or service providers that help us provide our Services and improve the Website: 

• Legal Requirement: We will share your information in this situation only if we are required to do so to comply with any applicable law, regulation, legal process, or governmental request (e.g., to comply with a court injunction, comply with tax authorities, etc.);

• Policy Enforcement: We will share your information, solely to the extent needed to (i) enforce our policies and agreements; or (ii) to investigate any potential violations thereof, including without limitations, detect, prevent, or take action regarding illegal activities or other wrongdoings, suspected fraud or security issues;

• Company's Rights: We will share your information to establish or exercise our rights, to prevent harm to our rights, property, or safety, and to defend ourselves against legal claims, when necessary, subject to applicable law;

• Third Party Rights: We will share your information, solely to the extent needed to prevent harm to the rights of our customers, yourself, or any third party's rights, property, or safety;

• Service Providers: we share your information with third parties that perform services on our behalf (e.g., tracking cookies, servers, marketing, and support, etc.) these third parties may be located in different jurisdictions. 

• Corporate Transaction: we may share your information in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, our affiliated companies or acquiring Company will assume the rights and obligations as described in this Privacy Policy; 

• Authorized Disclosures: we may disclose your information to third parties when you consent to a particular disclosure. Please note that once we share your information with another company, that information becomes subject to the other Company's privacy practices. 

Where we share information with service providers and partners, we ensure they only have access to such information that is strictly necessary in order for us to provide the Services. These parties are required to secure the data they receive and to use the data for pre-agreed purposes only, while ensuring compliance with all applicable data protection regulations.

Sharing of data with a relevant Customer as an account owner in the System: if you act as a User under one of our System’s customers, your Personal Data as a User will be accessible to your account owner, as the owner and controller of such data; 

6. DATA TRANSFER

Any information you provide us may be transferred to and processed in countries other than the country from which you accessed the Website. If you are a resident of the European Economic Area ("EEA") we will take appropriate measures to ensure that your Personal Data receives an adequate level of data protection upon its transfer outside of the EEA. If you are a resident of a jurisdiction where the transferring of your Personal Data requires your consent, then your consent to this Privacy Policy includes your express consent for such data transfer.

7. USER RIGHTS

We acknowledge that different people have different privacy concerns and preferences. Our goal is to be clear about what information we collect so that you can make meaningful choices about how it is used. We provide you with the ability to exercise certain choices, rights, and controls in connection with your information. Depending on your relationship with Publicators, data protection and privacy laws provide you with some of the following principal rights regarding your Personal Data, including (and depending on your jurisdiction): The right to access your Personal Data that we process; The right to ensure your Personal Data is accurate, complete and up to date; The right to have your Personal Data amended (by correcting, deleting or adding information); The right to object to the processing of your Personal Data, to the extent applicable; The right to send or "port" your Personal Data; The right to file a complaint with a supervisory authority in your jurisdiction;  The right to withdraw consent, subject to legal or contractual restrictions and reasonable notice; Right to Non-Discrimination, etc. 

You may exercise any or all of your above rights in relation to your Personal Data by contacting us at: help@publicators.com.

Where we are not able to provide you with the information for which you have asked, we will endeavor to explain the reasoning for this and inform you of your rights, including the right to complain to the supervisor authority (in the event you are an EEA resident). We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any such information in accordance with applicable law. 

8. RETENTION 

In general, we retain the Personal Data we collect for as long as it remains necessary for the purposes set forth above, all under the applicable regulation, or until you will express your preference to opt-out, where applicable. 

The criteria used by us to determine our retention periods are as follows: 

• We retain Personal Data for the periods needed in order to achieve the purpose for which Personal Data was collected.

• System’s Users data will be processed as long we have an engagement (contract) with the relevant Customer, and even further, for record keeping purposes.

• We retain Personal Data for the periods needed in order to comply with our obligations under applicable laws. 

• If you have a dispute with us, we may retain certain types of Personal Data as necessary and applicable to your claims, including any legal proceedings between us, until such dispute was resolved, and following, if we find it necessary, in accordance with applicable statutory limitation periods. In addition, in the event you request to exercise your rights, we will maintain the applicable correspondence for as long as needed to demonstrate compliance. 

We may at our sole discretion, rectify or erase information from our systems, without prior notice to you, once we deem it is no longer necessary for such purposes.

9. SECURITY

We implement extensive security measures to reduce the risks of damage, loss of information, and unauthorized access or misuse of Personal Data. We implement appropriate data collection, storage, and processing practices and security tools to protect Personal Data against unauthorized access, alteration, disclosure, or destruction. You should be aware that no security measures are completely fail-proof, and it is impossible to prevent any and all threats to the security of data and systems. Therefore, you should be aware that any processing of digital Personal Data holds certain inherent risks, and we cannot guarantee that our services and databases will be immune to any wrongdoings, malfunctions, unauthorized interceptions or access, malware attacks or other kinds of abuse and misuse.