Date last updated: September 3, 2023.
Greetings from Pubwish!
By choosing to use our services, you’re implicitly placing confidence in our methods and practices. We deeply value this trust and, in return, pledge to uphold the highest standards of data protection. This policy not only elucidates your rights concerning your personal information but also guides you on how you can exercise them.
Interpretation and Definitions
The words in which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in the plural.
Collecting and Using Your Personal Data
Who we are
This website is operated by Pubwish Inc, a company registered in the United States under company registration number 6039757, the registered office of which is at 16192 Coastal Highway, in the city of Lewes, County of Sussex, Delaware trading as Pubwish. We are providers of tools and application software that help writers with their projects. For more information, please go to https://pubwish.com.
We collect, use, and are responsible for certain personal information about you. When we do so we are regulated under the General Data Protection Regulation which applies across the European Union (including the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
The Services offered by us include the ability for you to create Individualised Spaces (as defined in the Terms and Conditions) and in respect of those Individualised Spaces, you may be acting as data controller or processor of personal data and/or providing information society services. We are not responsible for data processed by you or services provided via Individualised Spaces and you are advised to take your own legal advice and include your own notices and policies in such Individualised Spaces.
Types of Data Collected
While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:
Our collection and use of your personal information
We collect personal information about you when you visit our website, create an account, contact us, subscribe to our mailing list or make a purchase on our website.
We collect this information from you either directly, such as when you create an account, contact us, subscribe to our mailing list, post material to our website or make a purchase via our website, or indirectly, such as your browsing activity whilst on our website (see ‘Cookies’ below).
The personal information we collect about you depends on the particular activities carried out through our website. This information includes:
Purpose of Data Collection
We use the collected data to:
Usage Data is collected automatically when using the Service. Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.
We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.
Information Collected while Using the Application
While using Our Application, in order to provide features of Our Application, We may collect, with Your prior permission:
You can enable or disable access to this information at any time, through Your Device settings.
Use of Your Personal Data
The Company may use Personal Data for the following purposes:
We may share Your personal information in the following situations:
Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Other legal requirements
The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:
Our legal basis for processing your personal information
|When information is collected||What information we ask for/record||How and why we use your information|
|When you browse our site||Information about your web browser, IP address, time zone and cookies that are installed on your device.||Our cookies divide between necessary and optional cookies, and the plug-in installed on our site gives further information about what each cookie does and why we need it.|
|When you make an account on our site||Your name, your mobile number, your email ID or your Facebook ID, your email address or your Facebook email address, your profile image, your country, your interests, your favorite books/movies, your writing goals, your words typed per minute, your educational level achieved, professional writing achievements, group chat history in writing challenge rooms to help resolve user conflicts/block requests/user bans or account deletion||Account administration. We store this information on our database. When you sign-up or log-in on the Site we validate your identity using the Facebook and Google API to match with our database.|
|When you purchase one of our products or services||[email details and details required to fulfil orders such as postal address.]||To fulfil your order and handle queries and follow ups relating to that order. We store this information on our database.|
|When you make a post on our site||IP address, time zone, posting history||To administer the list, deal with user conflicts and complaints and handle queries. We store this information on our database.|
|When you create user generated content on our site||Your profile details (above), your social media details (optional) and any content which you upload to the website via our site.||Site management.|
Who we share your personal information with
Whether information has to be provided by you, and if so why
Retention of Your Personal Data
The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.
Transfer of Your Personal Data
Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.
Transfer of your information out of the EEA
Disclosure of Your Personal Data
Security of Your Personal Data
The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.
Detailed Information on the Processing of Your Personal Data
The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies.
We may use third-party Service providers to monitor and analyze the use of our Service.
We may use Your Personal Data to contact You with newsletters, marketing or promotional materials, and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us.
Keeping your personal information secure
How to complain
Accessing and modifying your data
If you have any questions or want to know which personal data we have about you, please contact us. Please make sure to always clearly state who you are, so that we can be certain that we do not modify or delete any data of the wrong person. We shall provide the requested information only upon receipt of a verifiable consumer request. You can contact us by using the information below.
You have the following rights with respect to your personal data
Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please Contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.
If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent’s consent before We collect and use that information.
Links to Other Websites
We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.
Cookies and other tracking technologies
We do not sell or share personal information to third parties for monetary consideration; however, we may disclose certain personal information to third parties under circumstances that might be deemed a “sale” or ”Sharing” for residents of California (DNSMPI, CPRA), Colorado (CPA), Connecticut (CTDPA), Nevada (NRS 603A), Utah (UCPA) and Virginia (CDPA). We respect and understand that you may want to be sure that your personal information is not being sold or shared. You may request that we exclude your personal information from such arrangements, or direct us to limit the use and disclosure of possible sensitive personal information, by entering your name and email address below. You may need to provide additional identifying information before we can process your request.
When you visit our website it can be necessary to store and/or read certain data from your device by using technologies such as cookies.
2.1 Technical or functional cookies
Some cookies ensure that certain parts of the website work properly and that your user preferences remain known. By placing functional cookies, we make it easier for you to visit our website. This way, you do not need to repeatedly enter the same information when visiting our website and, for example, the items remain in your shopping cart until you have paid. We may place these cookies without your consent.
2.2 Statistics cookies
We use statistics cookies to optimize the website experience for our users. With these statistics cookies we get insights in the usage of our website.
2.3 Marketing/Tracking cookies
Marketing/Tracking cookies are cookies or any other form of local storage, used to create user profiles to display advertising or to track the user on this website or across several websites for similar marketing purposes.
2.4 Social media
On our website, we have included content from Facebook, Twitter, WhatsApp, Instagram, TikTok and Pinterest to promote web pages (e.g. “like”, “pin”) or share (e.g. “tweet”) on social networks like Facebook, Twitter, WhatsApp, Instagram, TikTok and Pinterest. This content is embedded with code derived from Facebook, Twitter, WhatsApp, Instagram, TikTok and Pinterest and places cookies. This content might store and process certain information for personalized advertising.
Please read the privacy statement of these social networks (which can change regularly) to read what they do with your (personal) data which they process using these cookies. The data that is retrieved is anonymized as much as possible. Facebook, Twitter, WhatsApp, Instagram, TikTok and Pinterest are located in the United States.
3. Placed cookies
Most of these technologies have a function, a purpose, and an expiration period.
DATA SECURITY POLICY
Here at Pubwish Inc, we collect, process and store personal data for a range of business purposes. Data subjects include customers, suppliers, partners, employees, clients and other stakeholders and individuals.
Bearing in mind Pubwish Inc’s commitment to uphold the rights of the individual as enshrined in law, our data security policy is designed to protect all past, current and future employees, customers, or partners, from illegal or damaging activity conducted by others using their personal data.
Our data security policy outlines how Pubwish Inc will endeavour to guard and protect all personal data. It also sets out to raise the awareness of staff members in relation to the ways in which GDPR impacts their use of individual’s personal data.
This policy applies to all data processing activities involving Pubwish Inc, and includes activities or systems related to both internal business operations, as well as external relations and any third-party agreements.
Please note that Pubwish Inc’s data security policy applies to all employees, and this policy may be subject to review and amendment on a regular basis. For more information about this policy and its overall implementation, consult our Data Protection Officer.
This document is subject to regular review to ensure ongoing regulatory compliance.
Data security policy definitions
Personal data encompasses any type of information that relates to an identifiable individual. Various types of personal data Pubwish Inc. may collect, store and process could include:
The above list is by no means exhaustive, and should be used merely as a point of reference from which a working definition of personal data can be established and further developed.
Sensitive personal data
Under GDPR, sensitive personal data is defined as encompassing any of the following:
It is paramount that all sensitive personal data is kept under stringent control as part of the implementation of our data security policy.
Purposes of personal data
Pubwish Inc uses personal data for a range of various purposes. These purposes may include:
Please note the above list is by no means exhaustive, and should merely be used as a reference point from which a working definition of purpose can be established.
Pubwish Inc must carry out a range of functions and processes as part of our operational activity. Data kept in relation to these activities falls under the category of data for business purposes, which includes information of the following nature:
The above list is by no means exhaustive, and should be used merely as a point of reference from which a working definition of business purposes can be established and further developed.
At Pubwish Inc, there will be occasions when employees will need to process personal data; however, processing activities must always be carried out in a fair and lawful manner that is compatible with the rights of each corresponding individual. Consequently, we should avoid processing the personal data of any individual who has not provided us with explicit consent.
Our company must strive to obtain explicit consent at all costs, and we must clearly identify to the individual what data is being processed, why we need to use it and who will have access to their data. These factors must be identified and clearly reiterated to the individual at the point of request for consent.
It’s worth noting there may be exceptional circumstances in which we are asked to process sensitive personal data without consent. An example of an exceptional circumstance could include legal obligations we may need to carry out to comply with health and safety regulations.
Pubwish Inc endeavours to take all actions necessary to ensure that all personal data we obtain, process and store is accurate, relevant and adequate in relation to the reason in which we asked for that information. We should not hold excessive or irrelevant data on any individuals, and we will not process any personal data for a purpose unrelated to the purpose in which the relevant individual has consented to the processing of their data.
Our roles and responsibilities
Data security is a critical component of our business. It falls on everyone at Pubwish Inc to take responsibility for data security, and all employees must familiarise themselves with our data security policy and do everything within their power to uphold that policy on a day-to-day basis.
Please note that Pubwish Inc takes data protection incredibly seriously, and we expect all staff members to adhere to this data security policy. Any failure and refusal to comply with this policy could ultimately place our company at risk.
Bearing that in mind, personal non-compliance with this data security policy could lead to disciplinary action as they relate to ordinary personnel procedures. Please contact your line manager with any further questions concerning data protection at Pubwish Inc.
As a staff member at Pubwish Inc, you can expect to receive data protection training in line with our data security policy. All incoming employees will be provided training as an aspect of the wider staff induction process, and all staff members can anticipate the requirement to undergo additional training as a result of subsequent regulatory updates to GDPR or other relevant legislation as it relates to data security.
Data security will inevitably encompass a range of additional responsibilities for various roles within the company. These roles and their responsibilities include (but are not limited to):
Data Protection Officer
GDPR stipulates our company must appoint a Data Protection Officer. It is our Data Protection Officer’s responsibility to:
Information technology plays a crucial role in the way our company operates. Any processes relating to IT and the processing and storage of data must be carefully monitored, assessed and guided by an IT Manager.
It is the responsibility of Pubwish Inc’s IT Manager to:
A significant proportion of our marketing activities involve the collection, storage and processing of data. Consequently, our Marketing Manager must oversee the following responsibilities:
Our data security policies
Pubwish Inc takes data security extremely seriously, and we place the rights of the individual and regulatory adherence at the heart of everything we do as a company.
We are committed to the security of personal data. We take appropriate security measures to limit abuse of and unauthorized access to personal data. This ensures that only the necessary persons have access to your data, that access to the data is protected, and that our security measures are regularly reviewed.
The security measures we use consist of:
• Username and Password
• TLS / SSL
• Physical security measures of systems which contain personal data.
• Security software
• Content Security Policy
This privacy statement does not apply to third-party websites connected by links on our website. We cannot guarantee that these third parties handle your personal data in a reliable or secure manner. We recommend you read the privacy statements of these websites prior to making use of these websites.
Activities that are prohibited
Unless otherwise noted or informed, employees are strictly forbidden from using company equipment, tools or systems for any purpose unrelated to their role responsibilities, excluding any previously mentioned exceptions. This policy also relates to any relevant systems, tools or equipment belonging to a company client or partner.
Bearing that in mind, the following activities should be deemed forbidden with no exceptions:
Please note that any violation of this policy can lead to disciplinary action, alongside legal action where deemed prudent or necessary.
In light of our commitments, it is mandatory all staff members must observe and adhere to the following data security policies:
Data storage policy
Please note that Pubwish Inc will carry out regular system audits to monitor and ensure ongoing compliance with this data security policy and all regulatory requirements as outlined under GDPR.
Data retention policy
While Pubwish Inc must routinely collect and store data, we are committed to the rights of individuals. That’s why we retain all information and personal data for no longer than we need to.
The necessary length of retention will often be decided on a case-for-case basis, bearing in mind the rationale and original purpose surrounding data collection and retention. Decisions of this nature must be made in a way that is compatible with our existing data retention guidelines under GDPR.
International data transfer policy
Employees must observe a series of restrictions that apply towards the international transfer of data or personal information. Employees are not permitted to transfer personal information or data outside of the United Kingdom without having obtained explicit permission in the first instance from the company’s Data Protection Officer.
Data encryption and anonymisation policy
Pubwish Inc deploys encryption to secure and protect data that is stored on devices from unlawful processing or unauthorised access. Encryption is also used to protect information that is in transit.
We also use the anonymisation of personal data wherever deemed prudent to ensure the rights of the individual are fully protected and observed.
In line with these principles, we are committed to the use both encryption and anonymisation as a risk management tool alongside existing systems, to protect the company from accidental loss, as well as from the damage or destruction of data or personal information.
Reporting security issues
If you encounter any incidents or issues relating to the security or protection of information or data, you must report this immediately to company management. Management will subsequently take and record any action deemed necessary to prevent damage or loss in relation to a security threat.
If necessary, it is the responsibility of company management to report relevant incidents relating to a data breach or information security threat to regulators or the authorities. Under GDPR, it also falls upon management to contact the individuals involved in any breach or security threat.
Our website uses plugins from YouTube, which is operated by Google. The operator of the pages is YouTube LLC, 901 Cherry Ave., San Bruno, CA 94066, USA.
If you visit one of our pages featuring a YouTube plugin, a connection to the YouTube servers is established. Here the YouTube server is informed about which of our pages you have visited.
If you’re logged in to your YouTube account, YouTube allows you to associate your browsing behavior directly with your personal profile. You can prevent this by logging out of your YouTube account.
YouTube is used to help make our website appealing. This constitutes a justified interest pursuant to Art. 6 (1) (f) DSGVO.
Further information about handling user data, can be found in the data protection declaration of YouTube under https://www.google.de/intl/de/policies/privacy.
Google Web Fonts
For uniform representation of fonts, this page uses web fonts provided by Google. When you open a page, your browser loads the required web fonts into your browser cache to display texts and fonts correctly.
For this purpose your browser has to establish a direct connection to Google servers. Google thus becomes aware that our web page was accessed via your IP address. The use of Google Web fonts is done in the interest of a uniform and attractive presentation of our plugin. This constitutes a justified interest pursuant to Art. 6 (1) (f) DSGVO.
If your browser does not support web fonts, a standard font is used by your computer.
Please contact us if you have any questions about this privacy notice or the information we hold about you.