PUBLISCHE PRIVACY POLICY
Last updated: 19 July, 2020
Publische Pty Ltd and its related entities (Publische) is genuine in its concern to maintain the security of all personal information provided to us. This Privacy Policy details what personal information we receive and how we go about Processing it.
1. What do we mean by some of the words used in this Policy?
Content means any information or data that you upload, submit, post, create, transmit, store or display with Publische.
End User means a meeting participant.
Information means all of the different forms of data, content, and information collected by us as described in this Privacy Policy.
Personal Information means information or an opinion, whether true or not, and whether recorded in a material form or not, about an identified or reasonably identifiable individual that may be used for Publische to deliver the service readily identify or contact you, such as: name, address, email address, phone number, chat content, meeting recordings (if you record a meeting), video content of live-streamed meetings (to buffer), and/or images and links that you upload. Personal Information does not include information that has been anonymized such that it does not allow for the ready identification of specific individuals.
Processing means using cookies on a computer or using or accessing such information in any way, including, but not limited to, collecting, storing, deleting, using, combining and also means disclosing or releasing information, all of which may take place in Singapore, the United States, European Union or Australia. It also outlines the choices available to you regarding any personal information involving you used or held by us.
Subscriber means the party authorised to subscribe to, or administer an account for, or host a meeting enabled by, a Publische Service.
2. Scope of this Privacy Policy
This Privacy Policy applies to Publische’s website and video communications applications (Services). By using any part of our Services you are consenting to our Processing of your information as set forth in this Privacy Policy now and as amended by us.
This Privacy Policy also applies to Publische whether in our role as the data controller for the personal data you provide to us through our website or when you register and use the Publische Service as a Subscribe or End User or in our role as the data processor for the personal data you provide to us when you activate and use the Publische Service or Licensed Products or software whether directly or via an authorised third party. When Publische acts as the data processor, all processing by Publische of your personal data will be governed by a data processing contract between Publische and the authorised third party.
Our business is distributed globally but headquartered in Australia. If you choose to use the Service from the European Union, United States or other regions of the world with laws governing data collection and use that may differ from Australian law, then please note that your personally identifiable information may be transferred to Australia and be Processed under Australian privacy standards which are among the most stringent in the world. Also, we may transfer your data from Australia to other countries or regions in connection with the Processing of data, fulfilling your requests, and operating the Service. By using our Services and providing information to us, you consent to such transfer to, and Processing in, Australia.
This Privacy Policy does not apply to any third party applications or software that integrate with the Services through the Publische platform (Third Party Services), or any other third party products, services or businesses. In addition, this Privacy Policy does not apply to any of our products or services that have a separate privacy policy.
3. Information we collect and receive
Our primary goals in collecting information from you are to provide you with the services made available through the Service, to communicate with you, and to manage your registered Subscriber account, if you have one or to administer End Users. We may also use your information to operate, maintain, and enhance the Service and its features (such as bug fixes, better video quality, or other directly related improvements), and to provide customer support.
4. Information collected upon registration
Unsurprisingly, we collect more information from meeting hosts/Subscribers than we do from meeting participants/ End Users and visitors to our Site. You provide us with information when you register for an account, use the Service, make a purchase on the Site, or send us customer service-related requests. If you seek access to certain restricted sections of our website, such as when you sign up to receive a white paper or further information, or provide your social media info so that you can be identified in a video meeting, you submit certain personally identifiable information to Publische. We might collect things like your IP address, link to your social profile, full user name, password, email address, city, time zone, telephone number, and other information that you decide to provide us with. We may link such information with other information you provide about yourself.
5. Social media
Publische does not engage in data enhancement unless you consent to it. If you choose to connect a Google+, Facebook, LinkedIn, Instagram, YouTube or other social media page or profile to your Publische account, we may access certain information regarding that account. We collect this information so that other End Users can see who you are when you are on a video call or for collaboration purposes. We may store your name and email address as well as the link to the particular social page or profile you connect, but this data will only be used by Publische to provide you with the service you expect and will never be shared with any third party for a different purpose. You can delete it at any time.
6. Use of contact information
In addition, we may use your contact information to market to you. If you decide at any time that you no longer wish to receive such information or communications from us, please un-follow us, or follow the unsubscribe instructions provided in any of the communications. You may also opt out from receiving commercial email from us by sending your request to us by email at support@publische.com. Please be aware that if you opt out of receiving commercial email from us or otherwise modify the nature or frequency of promotional communications you receive from us, it may take up to ten business days for us to process your request, and you may continue receiving promotional communications from us during that period.
7. Log Data
When you visit the Site, our servers automatically record information such as your IP address, browser type or the domain from which you are visiting, the web-pages you visit, the search terms you use, and any advertisements you click on so that, if you are a Subscriber, we can recognise your browser and associate it with your registered account. This is called Log Data and we use it to monitor the use of our Service and improve your user experience. If you are not a Subscriber, we do not associate your IP address with any other personally identifiable information to identify you personally, except where you have voluntarily provided us with your social media profile. If you are not a Subscriber, we may use log data to understand your preferences, and to compile aggregate data that helps us to personalise and improve user experience.
8. Cookies, analytics information and automatically collected information
Our Site also uses log information or cookies (a small data file that we transfer to your computer’s hard disk). We do not use cookies to collect personally identifiable information. Publische may use both session cookies and persistent cookies to better understand how you interact with our website and Services, to monitor aggregate usage by our users and web traffic routing on the website, and to improve our Services. You can delete, or choose not to accept, cookies from the Service, but you may not be able to utilise the features of the Service to their fullest potential. Publische does not process or respond to web browsers’ “do not track” signals or other similar transmissions that indicate a request to disable online tracking of users who use our Service.
We may also automatically record certain information including collect analytics information from your device by using various types of technology, including clear gifs or web beacons. This automatically collected information may include your domain name, username (including Personal Information if you have included Personal Information in the username), physical location, IP address or other device address or ID, type of web browser and/or device, the web pages or sites that you visit just before or just after you use the Service (which helps to tell us how you found our website or why you just totally left), the pages or other content you view or otherwise interact with on the Service, and the dates and times that you visit, access, or use the Service. We also may use these technologies to collect information regarding your interaction with email messages, such as whether you opened, clicked on, or forwarded a message. This information is gathered from all users, and may be connected with other information about you. Many browsers include their own management tools for removing these kinds of local storage objects.
For Subscribers, cookies help us to check that it’s you, so that you do not have login manually to each page once you have signed in. Cookies also help us to detect fraud or suspicious activities and help us to keep our Services secure. We never sell cookie and other log file data to third parties.
9. Third party web beacons and third party buttons
We may display third-party content on the Service, including third-party advertising and media releases. Third-party content may use cookies, web beacons, or other mechanisms for obtaining data in connection with your viewing of the third party content on the Service. Additionally, we may implement third party share buttons that may function as web beacons even when you do not interact with the button. Information collected through third-party web beacons and buttons is collected directly by these third parties, not by Publische. Information collected by a third party in this manner is subject to that third party’s own data collection, use, and disclosure policies.
10. How we use the data that we collect
Our primary purpose for using your information is to provide you with our agreed services and the Service. In addition, we may share and disclose your information for the following reasons:
To enable and deliver the Service – Publische needs certain information for a user to become a Subscriber and to operate, secure, support and improve the Services we deliver. Some data we use for communications or compliance.
Employers or School Sponsors of Service – If a Subscriber or End User is using our Service in a work capacity, be aware that the systems administrators at Subscriber’s workplace or school could have permissions to see information about meetings you host or participate in. The Subscriber is obliged by our terms of service to advise End Users of contact information for an administrator of the Service at their sponsor organisation, school or workplace upon request.
Hosts and presenters – Publische may collect and share the name, and any contact information including social media details disclosed by a video-conference Service attendee/End User with the host, Subscriber or presenter on their request.
Service Providers – We engage certain trusted third parties to perform functions and provide services to us, including, without limitation, hosting and maintenance, analytics (such as Google Analytics), billing (Xero, Stripe), customer relationship management (Zoho), database storage and management, direct marketing campaigns, and provide interoperative technologies that enable the Services (such as Jitsi and YouTube). We will share your personally identifiable information with these third parties, but only to the extent necessary to perform these functions and provide our Services, and only pursuant to binding contractual obligations requiring such third parties to maintain the privacy and security of your data and to only use it to perform the agreed services.
Compliance with Laws and Law Enforcement – Publische cooperates with government, national security and law enforcement officials or private parties to enforce and comply with the law. We may disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to investigate, respond to, and defend against claims, for legal process (including subpoenas), to protect the property and rights of Publische or a third party, to protect Publische against liability, for the safety of the public or any person, to prevent or stop any illegal, unethical, fraudulent, abusive, or legally actionable activity, to protect the security or integrity of the Service and any equipment used to make the Service available, or to comply with the law. If we detect unlawful activity or creeps that appear to be using the Services for nefarious purposes, we reserve the right to speak up. We do not transfer, store or disclose information to any jurisdiction that may engages in arbitrary punishment or that does not respect rule of law.
Business Transfers – Publische may sell, transfer or otherwise share some or all of its assets, including your personally identifiable information, in connection with a merger, acquisition, reorganisation, sale of assets, or similar transaction, or in the event of insolvency or bankruptcy. You will have the opportunity to opt out of any such transfer if the new entity’s planned processing of your information differs materially from that set forth in this Privacy Policy.
Other Third Parties – We may make certain aggregated, automatically-collected, or otherwise non-personal information available to third parties for various purposes, including for business or marketing purposes or to assist third parties in understanding our users’ interest, habits, and usage patterns for certain programs, content, services, advertisements, promotions, and/or functionality available through the Service. In each case, their independent privacy policy will apply.
11. Security
Publische will respect and safeguard the confidentiality of your personally identifiable information. We employ administrative, physical and electronic measures designed to protect your information from unauthorized access. Please be aware that no security measures are perfect or impenetrable. We cannot and do not guarantee that information about you will not be accessed, viewed, disclosed, altered, or destroyed by breach of any of our administrative, physical, and electronic safeguards. Any legally-required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored personal data will be made to you via email or conspicuous posting on this website in the most expedient time possible and without unreasonable delay, consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
12. Links to other websites
Our Site contains links to other websites. The fact that we link to a website is not an endorsement, authorisation or representation of our affiliation with that third party. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit personally identifiable information from you. Other sites follow different rules regarding the use or disclosure of the personally identifiable information you submit to them. We are not responsible for the content, privacy and security practices, and policies of third-party sites or services to which links or access are provided through the Service. We encourage you to read the privacy policies or statements of the other websites you visit.
13. Our policy towards children
The Site is not directed to persons under 13 and our Services are not intended for use by minors (as defined in your relevant jurisdiction). By using our Services, you represent and confirm to us that you are not under the age of 13 and/or not a minor and we will rely on that representation.
Minors are not permitted to directly sign up for their own Publische account. Registration of a “K-12/Primary and Secondary Account” is required by a minor’s primary or secondary schools or school district to use our Services. The terms of the K-12/Primary and Secondary Privacy Policy take precedence over the terms of this Privacy Policy in the event of a conflict of policy concerning minors. Publische’s K-12/Primary and Secondary Privacy Statement is available here.
If you are a minor, please do not submit any information through the Services. We encourage parents and legal guardians to help enforce our Privacy Policy by instructing the children under your supervision to not provide any information via our Services without permission. If a parent or guardian becomes aware that his or her child has provided us with personally identifiable information without their consent, he or she should contact us at privacy@publische.com. We do not knowingly collect personally identifiable information from minors without appropriate parental or guardian consent. If we become aware that a child under 13 has provided us with personal identifiable Information, we will delete such information from our files. Compliance with the Children’s Online Privacy Protection Act for users in the USA under the age of 13 years is important to us.
If the Services or links on this Site direct users to third party websites and content, the Privacy Policy of those third parties applies. Publische has no control over, or responsibility for, and does not endorse the information practices of any third party website or third party served content.
14. Accessing your personal information, or requesting a correction
You may access your Personal Information, or seek to have Information corrected if you believe that it is incorrect, at any time.
To request access, or to correct your personal information, please contact the Publische Privacy Officer at privacy@publische.com. The privacy team will then get in contact with you (either by phone or via email) and will work with you to provide you with access to your information or to determine whether it requires correction.
Alternatively, visitors who have chosen to register with the Service (for example, to receive a white paper) may access their user profile, correct and update their details, or unsubscribe at any time. Visitors who have any problem accessing their profiles, or would like to request a copy of their personal information should contact the Publische Privacy Officer at privacy@publische.com.
15. International data transfers
Publische may store and process any personal data collects in any common law or European country in which Publische and its service providers maintain facilities.
By registering for and using Publische services, you are accepting to the transfer of data to any common law or European country in which Publische and its service providers maintain facilities, as well as the use and disclosure of your personal data as described in this privacy notice.
Australia – Since Publische is headquartered in Australia, we are governed by Australia’s Privacy Act 1988 (Cth), including the Australian Privacy Principles (APPs), and complies with the APPs as both a data controller and data processor. If Publische transfers or discloses Personal Information of an Australian national with a third party located outside of Australia, Publische will operate in a manner materially consistent with the applicable Australian Privacy Principles and seek to ensure that the third party recipient holds and uses the personal information consistently with the applicable Australian Privacy Principle and other applicable privacy laws.
APEC Countries – This Publische Privacy policy also complies with the Asia Pacific Economic Cooperation (APEC) Cross-Border Privacy Rules System (CBPRs) and Privacy Recognition for Processors (PRP). The APEC CBPR system and PRP provides a framework for organisations to ensure protection of personal information transferred among participating APEC economies. However, it is our policy to not store or transfer Personal Information to servers located in mainland China or Hong Kong SAR.
EU, UK and Swiss-US Privacy Shields – Publische also observes the EU’s general data protection regulation (“GDPR”) (EU Regulation 2016/679) as both a data controller and a data processor. Some information we hold may be stored on servers that may be located outside of the European Economic Area (EEA). With certain service providers, including providers based in the U.S., we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
California, U.S.A. Privacy Rights – Residents of the U.S. State of California have the right under the California Consumer Privacy Act (“CCPA”) to request access to and deletion of the information Publische holds about them. Publische will not discriminate against you for exercising your rights under CCPA. Specifically, we will not deny access to our Services, charge a different rate for the use of our Services; or provide a different quality of service. Under California’s ‘Shine the Light’ law (CA Civil Code § 1798.83), residents of the State of California also have the right to request from companies conducting business in California a list of all third parties to which the company has disclosed personal information during the preceding year for direct marketing purposes. Alternatively, the law provides that if the company has a privacy policy that gives either an opt-out or opt-in choice for use of your personal information by third parties (such as advertisers) for marketing purposes, the company may instead provide you with information on how to exercise your disclosure choice options. Publische qualifies for the alternative option. We have a comprehensive Privacy Policy, and provide you with details on how you may either opt-out or opt-in to the use of your personal information by third parties for direct marketing purposes. Therefore, we are not required to maintain or disclose a list of the third parties that received your personal information for marketing purposes during the preceding year.
If you would like to find out more about these safeguards or to submit a request, please contact us by writing to privacy@publische.com
16. Changes to this Policy
This Privacy Policy may be updated from time to time for any reason; each version will apply to information collected while it was in place. We will notify you of any modifications to our Privacy Policy by posting the new Privacy Policy on our Site and indicating the date of the latest revision. You are advised to consult this Privacy Policy regularly for any changes. In the event that the modifications materially alter your rights or obligations hereunder, we will make reasonable efforts to notify you of the change. For example, we may send a message to your email address or generate a pop-up or similar notification when you access the Service for the first time after such material changes are made. Your continued use of the Services after any change in this Privacy Policy will constitute your consent to such change. This document is version 002 last updated 2 August 2020.
17. Questions or complaints
If you have any questions or concerns or complaints regarding your privacy, please contact the Publische Privacy Officer at:
Privacy Officer
Publische Pty. Ltd.
Level 4, 90 William Street
Melbourne Vic 3000 Australia
privacy@publische.com
We take all privacy communications we receive seriously and will work with you to promptly resolve any major concerns.