Publica, LLC Privacy Policy
ADDITIONAL CALIFORNIA PRIVACY DISCLOSURES
Date of last revision: December 14th, 2020
This Privacy Policy explains how we collect, use, disclose, and otherwise process personal information in connection with our services. This Privacy Policy is not a contract and does not create any legal rights or obligations.
Scope of Disclosures
These Additional California Privacy Disclosures (the “CA Disclosures”) supplement the information contained in our Privacy Policy and apply solely to individual residents of the State of California (“consumers” or “you”). These CA Disclosures provide additional information about how we collect, use, disclose and otherwise process personal information of individual residents of the State of California, either online or offline, within the scope of the California Consumer Privacy Act of 2018 (“CCPA"). Unless otherwise expressly stated, all terms in these CA Disclosures have the same meaning as defined in our Privacy Notice or as otherwise defined in the CCPA.
Personal Information Disclosures
When we use the term “personal information” in these CA Disclosures, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
For the purposes of these Disclosures, personal information does not include:
- Publicly available information from government records.
- Deidentified, aggregated or anonymized information that is maintained in a form that is not capable of being associated with or linked to you.
- Information excluded from the CCPA's scope, such as:
- Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
- Information relating to our job applicants, employees, contractors and other personnel.
Collection and Use of Personal Information
In the last 12 months, we have collected the following categories of personal information from the categories of sources and for the purposes set forth below, which reference the personal information, sources and purposes described in the Our Collection of Personal Information and Our Use of Personal Information sections of our Privacy Policy:
Category of Personal Information
Collected
Categories of Sources
Commercial or Business Purpose
Identifiers, such as cookies, device ids, and IP address
X
• Common Sources Described Below
• Log data
• Location data
• Common Purposes Described Below
• Personalized advertising
California Customer Records (Cal. Civ. Code § 1798.80(e))
Protected Classification Characteristics
Commercial Information
Biometric Information
Internet/Network Information
Geolocation Data
X
Sensory Information
Professional/Employment Information
Non-Public Education Information (20 U.S.C. § 1232g, 34 C.F.R. Part 99)
Other Personal Information
Inferences
Disclosure and Sale of Personal Information
In the last 12 months, [[we have not sold personal information about you, but we have disclosed for a business purpose the following categories of personal information] or [we have disclosed for a business purpose and sold the following categories of personal information], which reference the categories of personal information described above:
Category of Personal Information
Disclosure for a Business Purpose
Sold*
Identifiers, such as cookies, device ids, and IP address
X
California Customer Records (Cal. Civ. Code § 1798.80(e))
Protected Classification Characteristics
Commercial Information
Biometric Information
Internet/Network Information
Geolocation Data
X
Sensory Information
Professional/Employment Information
Non-Public Education Information (20 U.S.C. § 1232g, 34 C.F.R. Part 99)
Other Personal Information
Inferences
Note about “Sales”: We do not “sell” personal information as most people would typically understand that term. However, we do allow certain third-party partners and providers to collect information about consumers directly through our services for purposes of analyzing and optimizing our services, delivering ads, providing content and ads that are more relevant, measuring statistics and the success of ad campaigns, and detecting and reporting fraud. To the extent this practice is interpreted to constitute a “sale” under the CCPA, please see our Cookie Notice for more information including how to exercise your rights to opt-out of cookies, analytics and personalized advertising.
Recipients of Personal Information
As described in the Our Disclosure of Personal Information section of the Privacy Policy, we share personal information [within Publica, LLC and with a variety of third parties] for business purposes, or we may sell your personal information to third parties, subject to your right to opt out of those sales.
In addition to the categories of third parties identified in the Our Disclosure of Personal Information section of the Privacy Policy, we disclose personal information to the following categories of third parties: SSPs, DSPs, and advertisers
Your California Privacy Rights
As a California resident, you may be able to exercise the following rights in relation to the Personal Information about you that we have collected (subject to certain limitations at law):
The Right to Know
You have the right to request any or all of the following information relating to the personal information we have collected about you or disclosed in the last 12 months, upon verification of your identity:
• The specific pieces of personal information we have collected about you;
• The categories of personal information we have collected about you;
• The categories of sources of the personal information we have collected about you;
• The categories of personal information that we have disclosed about you to third parties for a business purpose, and the categories of recipients to whom this information was disclosed;
• The categories of personal information we have sold about you (if any), and the categories of third parties to whom this information was sold; and
• The business or commercial purposes for collecting or, if applicable, selling personal information about you.
The Right to Request Deletion
You have the right to request the deletion of personal information that we have collected from you, subject to certain exceptions.
The Right to Opt Out of Personal Information Sales
You have the right to direct us not to sell personal information we have collected about you to third parties now or in the future.
If you are under the age of 16, you have the right to opt in, or to have a parent or guardian opt in on your behalf, to such sales.
The Right to Non-Discrimination
You have the right not to receive discriminatory treatment for exercising any of the rights described above.However, please note that if the exercise of the rights described above limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products or services or engage with you in the same manner.
How to Exercise Your California Privacy Rights
To Exercise Your Right to Know or Right to Deletion
To exercise your right to know and/or right to deletion, please submit a request by:
- Emailing privacy@publica-project.com with the subject line “California Rights Request,”
- Filling out our California Resident Rights Request Form
We will need to verify your identity before processing your request. In order to verify your identity, we will generally either require the successful login to your account or the matching of sufficient information you provide us to the information we maintain about you in our systems. Although we try to limit the personal information collected in connection with a request to exercise the right to know and/or the right to deletion to that personal information identified on the California Resident Rights Request Form, certain requests may require us to obtain additional personal information from you. In certain circumstances, we may decline a request to exercise the right to know and/or right to deletion, particularly where we are unable to verify your identity.
To Exercise Your Right to Opt Out of Personal Information Sales
You do not need to create an account with us to exercise your Right to Opt Out of Personal Information Sales. However, we may ask you to provide additional personal information so that we can properly identify you in our dataset and to track compliance with your opt out request. We will only use personal information provided in an opt out request to review and comply with the request. If you chose not to provide this information, we may only be able to process your request to the extent we are able to identify you in our data systems.
Once you make an opt-out request, you may change your mind and opt back in to personal information sales at any time by contacting us at privacy@publica-project.com
As noted above, we do not “sell” personal information as most people think of that term. You may, however, exercise your right to opt out of any future potential sales by clicking the link below and following the instructions:
Do Not Sell My Personal Information
You do not need to create an account with us to exercise your Right to Opt Out of Personal Information Sales. However, we may ask you to provide additional personal information so that we can properly identify you in our dataset and to track compliance with your opt out request. We will only use personal information provided in an opt out request to review and comply with the request. If you chose not to provide this information, we may only be able to process your request to the extent we are able to identify you in our data systems.
Once you make an opt-out request, you may change your mind and opt back in to personal information sales at any time by contacting us at privacy@publica-project.com.
Cookies, Analytics and Personalized Advertising As noted above, we do not “sell” personal information as most people would typically understand that term. However, we do allow certain third-party partners and providers to collect information about consumers directly through our services for purposes of analyzing and optimizing our services and ads, providing content and ads that are more relevant, measuring statistics and the success of ad campaigns, and detecting and reporting fraud. To the extent this practice is interpreted to constitute a “sale” under the CCPA, please see our Cookie Notice for more information including how to exercise your rights to opt-out of cookies, analytics and personalized advertising.
Minors Under Age 16
We do not sell the personal information of consumers we know to be less than 16 years of age, unless we receive affirmative authorization (the “Right to Opt In”) from either the minor who is between 13 and 16 years of age, or the parent or guardian of a minor less than 13 years of age.
“Shine the Light”
In addition to the rights described above, California's "Shine the Light" law (Civil Code Section §1798.83) permits California residents that have an established business relationship with us to request certain information regarding our disclosure of certain types of personal information to third parties for their direct marketing purposes during the immediately preceding calendar year. To make such a request, please send an email to privacy@publica-project.com.
Do Not Sell My Personal Information
PLEASE NOTE: to opt-out of all disclosures to third parties for direct marketing purposes, you must provide your personal information to be added to our suppression list
Authorized Agent
In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf where (i) you provide sufficient evidence to show that the requestor is an authorized agent with written permission to act on your behalf and (ii) you successfully verify your own identity with us.
Request Statistics
Click here for annual statistics about the requests to exercise California privacy rights we receive, fulfill and deny.
Updates to These CA Disclosures
We will update these CA Disclosures from time to time. When we make changes to these CA Disclosures, we will change the "Last Updated" date at the beginning of these CA Disclosures. If we make material changes to these CA Disclosures, we will notify you by email to your registered email address, by prominent posting on our online services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided in the notification.
Contact Us
If you have any questions or requests in connection with this Notice or other privacy-related matters, please send an email to privacy@publica-project.com.
Alternatively, inquiries may be addressed to:
Publica, LLC
76 Roosevelt Circle,
Palo Alto, CA, 94306