Publica, LLC

Privacy Policy

Last Updated: November 17th, 2023

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This Privacy Policy (“Policy”) explains our practices related to personal information collected, used, disclosed, and otherwise processed by Publica, LLC (“Publica, LLC,” “we,” “us,” or “our”) in connection with our website, getpublica.com (“Website”). This Policy does not apply to our privacy practices relating to job applicants, employees, or any of our solutions provided to customers.

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1) Personal Information Collected

We, or our vendors, collect the following personal information from visitors to our Website (whether we collect a specific category of information about you depends on your interaction with us): 

• Identifiers & Personal Records. This includes email address and Internet Protocol (IP) address.
• Internet or Other Electronic Network Activity. This includes Internet Protocol address, device identifiers, browser identifiers, operating system details, language preferences, referring URLs, length of visits, traffic data, pages viewed, and information regarding interactions with our Website.
• Geolocation Data. This includes approximate location. 
• Inferences. This includes inferences used to create a profile reflecting your preferences, characteristics, or behavior.

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2) Sources of Personal Information

We, or our vendors, collect the personal information identified above from the following sources (whether we collected it from a specific source depends on the nature of your interaction with us):

• Directly from you. We collect personal information from you when you provide it to us, such as while interacting with our Website. 
• Through Tracking Technologies. We collect personal information through tracking technologies, such as cookies, when you use our Website ( seeTracking Technologies section below for more information).
• Service Providers. We collect personal information about you from certain service providers that provide information to help us run our business.
• Affiliates. We share personal information among the companies within Publica and its affiliates. We receive information from within Publica and its affiliates, as permitted, to enable us to manage our business.
• External sources. We may receive information from data resellers or government publicly available records. This does not include our vendors.
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3) Tracking Technologies

Our Website uses use cookies, pixels, tags, trackers, and similar digital technologies to help operate the Website and provide us information to improve our services. Cookies on our websites are used to store your preferences and settings, provide interest-based advertising, combat fraud, analyze how our Website performs, personalize your experience and the content you see on our Website (such as by conveniently auto-filling data fields in online forms), and fulfill other business purposes.

You can manage certain tracking technologies through your browser, including by clearing your browser cache history or by changing your browser’s “Do Not Track” setting, if available. 

Certain online behavioral advertising vendors may participate in the Digital Advertising Alliance (“DAA”) AdChoices Program and may display an Advertising Option Icon for Interest-based Ads that links to an opt-out tool which allows you to exercise certain choices regarding targeting. You can learn more about the DAA AdChoices Program at http://www.youradchoices.com/ if you are located in the U.S., https://youradchoices.ca/en/tools if you are in Canada, or http://www.youronlinechoices.com if you are based in Europe. In addition, certain advertising networks and exchanges may participate in the Network Advertising Initiative (“NAI”). NAI has developed a tool that allows consumers to opt out of certain interest-based ads delivered by NAI members’ ad networks. To learn more about opting out of such targeted advertising or to use the NAI tool, see http://www.networkadvertising.org/choices/. 

Please be aware that, even if you are able to opt out of certain kinds of interest-based ads, you will continue to receive non-targeted ads. We are not responsible for the effectiveness of, or compliance with, external-parties’ opt-out options or programs or the accuracy of their statements regarding their programs.

For more information on how Google Analytics uses data collected through our Website, visit: google.com/policies/privacy/partners. To opt out of Google Analytics tracking technologies, visit: google.com/settings/ads and tools.google.com/dlpage/gaoptout.

Through the use of certain tracking technologies, we or external parties may collect information about your online activities over time and across different online services and combine certain information with other information about you.

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4) Our Use and Disclosure of Personal Information
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We use and disclose personal information (such as to vendors, affiliated entities, and other external parties) in the following ways:

• Provide Services You Request, including providing you information about the services we offer and responding to your requests and questions.
• Security and Integrity, including protecting our Website from cyber risks; preventing, identifying, investigating, and responding to fraud, illegal or malicious activities, and other liabilities; enforcing our policies and terms; protecting our rights; protecting health and safety; and generally providing you with a secure experience when using our Website.
• Quality, Safety, and Internal Research, including evaluating how our Website performs; repairing or improving the quality of our Website; tracking and responding to quality and security issues; and developing new or enhanced offerings.
• Advertising and Marketing, including measuring the use of our Website and effectiveness of our advertising and marketing; and uncovering insights to improve our Website and provide our users with enhanced features and functionalities, such as personalized experiences.

• Business Transactions. In the event of a business transaction, we may disclose personal information to prospective or actual purchasers, investors, or successor entities in connection with a contemplated reorganization or an actual reorganization of our business, in connection with financing, a sale, or other transactions involving the disposal of all or part of our business or assets, including for the purpose of permitting the due diligence required to decide whether to proceed with a transaction, pursuant to assurances of sufficient data handling practices and safeguards.
• Legal Claims & Compliance. We may also disclose personal information for legal compliance, and law enforcement or public safety purposes. For example, to law enforcement, government or regulatory bodies, or other authorized parties in order to comply with laws, regulations, court orders, or other legal obligations or to assist in an investigation, to protect and defend our rights and property, or the rights or safety of other parties, to enforce our terms, this Privacy Policy, or agreements with other parties, to establish claims, or for crime-prevention purposes.

We may also disclose personal information as otherwise permitted or required by law or at your direction.
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5) External Online Services

Our Website may include links to external online services. We may also engage vendors to provide certain interactive features on our Website. Your use of these interactive features is voluntary, and we may retain the information that you submit through these features. For example, we may offer an interactive chat feature on the Website to assist you and for other customer service purposes. When you participate in the interactive chat, either with a virtual or live agent, the contents of the chat may be captured and kept as a transcript. By using these features, you understand that our vendors may process the information obtained through the feature to provide the service on our behalf. 

This Policy does not apply to the practices of external online services that we do not own or control. We provide external links merely for your convenience and we have no control over, do not review, and are not responsible for external online services. To learn about the personal information practices of external online services, please visit their respective privacy policies.

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6) Data Retention

We keep the categories of personal information described above for as long as is necessary for the purposes described in this Privacy Policy, to achieve the purposes for which the information was collected, or as may be permitted under applicable law. This generally means holding the information for as long as one of the following apply:

• Your personal information is reasonably necessary to manage our operations, to manage your relationship with us, or to satisfy another purpose for which we collected the information 
• Your personal information is reasonably necessary to carry out a disclosed purpose that is reasonably compatible with the context in which the personal information was collected

To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the information; the potential risk of harm from unauthorized use or disclosure of the information; the purposes for which we process the information and whether we can achieve those purposes through other means; and the applicable legal requirements. 

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7) Data Security

We take the security and privacy of the information we collect or otherwise process pursuant to this Policy very seriously. Accordingly, we implement reasonable and appropriate security measures to protect personal information from loss, misuse, unauthorized access or disclosure, alteration or destruction, taking into account the risks involved in processing and the nature of the personal information and compliance with applicable laws. Although we use reasonable efforts to safeguard your information, transmission via the Internet is not completely secure and we cannot guarantee the security of your information collected through our website.

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8) U.S. State Privacy Rights

Residents of California and Virginia have certain rights related to the personal information that we have collected about you. We will comply with your request as soon as reasonably practicable, subject to legal requirements. Requests to exercise your rights may be granted in whole, in part, or not at all, depending on the scope and nature of the request and applicable law. 

To prevent unauthorized requests related to your personal information, we take steps to verify that you are the person that is the subject of the request. Following verification of your identity, we will process your request, and if we are unable to fulfill it, we will let you know why.

You may exercise your rights to your personal information by submitting your requests via email at privacy@publica-project.com. If you have questions about this process, including reexamining requests we are unable to fulfill, you may contact privacy@publica-project.com.

We will not discriminate against you for choosing to exercise any of your privacy rights.

Right to Confirm, Know, or Access: You have the right to confirm that we process your personal information, know details concerning that processing, and to access your personal information. 

These rights cover information regarding:

• Your personal information confirmed to be processed by us
• Our purposes for processing and disclosing your personal information
• The categories of personal information we disclose to external parties 
• The categories of external parties to which we disclose, and from which we receive your personal information

You also have the right to request a copy of your personal information in a transportable format.

Right to Correct Personal Information: You may request that we correct personal information that we maintain about you if you believe such personal information is inaccurate. Upon receipt of a verifiable request to correct inaccurate personal information, we will use commercially reasonable efforts to correct the information as you direct. 

Right to Request Deletion of Personal Information: You may request that we delete your personal information. Please note that we may retain certain personal information as permitted by applicable law. 

• Opt-Out Rights: You have the right to opt out of selling (for monetary or nonmonetary exchange of benefit), sharing for cross-context behavioral advertising (also known as targeted advertising), or profiling by clicking on the “Do Not Sell or Share My Personal Information” link at the footer of the Website.
• You may use external-party platforms, technologies, or mechanisms to indicate your opt out preferences, such as a browser or device setting, extension, or signal. Please note that we do not control these external-party tools, and that you may need to enable these tools across browsers, devices, or other methods of accessing the website. 

Depending on your state of residency, you may have the right to designate an authorized agent to make certain privacy rights requests on your behalf. We will subject privacy rights requests we receive from agents to our verification process, which includes verifying the identity of the agent and their authorization to make the request.

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9) International Cross-Border Transfers

If you are located outside of the United States, please be aware that we collect, process, and store personal information in the United States, and that the data protection laws in the United States may not offer the same level of protection as those in your jurisdiction. Where we transfer your personal information to another country, we take steps to safeguard your personal data and to comply with the data protection laws applicable to the transfer. If you have questions regarding the safeguards applicable to personal data transfers, you may contact us using the contact information at the end of this Privacy Policy.

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10) Additional Information For Those Located in EEA/UK

This section provides additional information on our processing of personal information related to individuals located in the EEA and the UK.

Legal Basis for Processing. When we process EEA/UK personal information, we rely on the following legal bases: 

• The processing is necessary to provide you with services or information you request or permit or to respond to your inquiries. 

• We have a legal obligation to process your personal information, such as to comply with applicable tax and other government regulations or to comply with a court order or binding law enforcement request.

• We have a legitimate interest in carrying out the processing activity, which you may request more information about using the contact information at the end of this Privacy Policy. In particular, we have a legitimate interest in the following cases:

• To analyze and improve the safety and security of the website. This includes implementing and enhancing security measures and protections and protecting against fraud, spam, and abuse.
• To operate, maintain, and improve the website and our services. 
• When we process or disclose personal information in the event of an actual or contemplated sale of assets or other business transaction.

• You have consented to the processing of your personal information. When you consent, you can change your mind at any time. 

EEA/UK Privacy Rights. You have certain rights to the personal information that we collect about you, and you may exercise those rights independently or through an authorized agent. We will comply with your request as soon as reasonably practicable. Requests to exercise your rights may be granted in whole, in part, or not at all, depending on the scope and nature of the request and applicable law. To prevent unauthorized requests related to your personal information, we take steps to verify that you are the person who is the subject of the requested personal information. Following verification of your identity, we will notify you if we are able to fulfill your request and if we are not, we will explain why.

You may ask us to take the following actions in relation to your personal information:

• Provide you with information about our processing of your personal information and give you access to your personal information
• Update or correct inaccuracies in your personal information
• Delete your personal information
• Transfer a machine-readable copy of your personal information to you or another party of your choice
• Restrict or object to the processing of your personal information

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You may exercise your rights to your personal information by submitting your requests by email to privacy@publica-project.com.

If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us at privacy@publica-project.com. You also have the right to lodge a complaint with a supervisory authority, if you believe that our processing of personal information relating to you is in violation of applicable data protection laws or if we have not resolved a request or complaint to your satisfaction. Contact details for European supervisory authorities are available here. Details for the UK supervisory authority is available here.

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11) Changes To This Policy

We may make changes to this Privacy Policy from time to time. If we make changes, we will notify you by revising the “Last Updated” date at the top of this Privacy Policy. 

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12) Contact Us

If you have any questions or concerns in connection with this Privacy Policy or other privacy-related matters, please send an email to privacy@publica-project.com.

Alternatively, inquiries may be addressed to:

Publica, LLC
12 East 49th Street, 20th Fl,
New York, NY

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