Last updated: April 2024
PUBLIFT PERSONAL DATA COLLECTION STATEMENT
The primary purposes for which we collect your personal data is to provide you with the services you have requested, enable our publisher customers to sell advertising space on their digital properties and to optimise our publisher customers’ advertising opportunities. You agree we may use and disclose your personal data and other data for these purposes and also for secondary purposes, including to personalise your user experience and to promote Publift and third-party products and services to you. Our Privacy Notice (see directly below) explains how we collect, share and use your personal data, the extent to which your personal data may be disclosed to overseas recipients and how to access, correct, update, request deletion or complain about the handling of your personal data.
PUBLIFT PRIVACY NOTICE
Table of Contents
- What does Publift do?
- How does Publift protect your privacy?
- Personal data we collect and process
- How we use your personal data (our purposes) and our legal basis for processing it
- Who we share your personal data with
- Cookies and similar tracking technology
- International data transfers
- Data retention
- Your data protection rights
- Updates to this Privacy Notice
- How to contact us
We recommend that you read this Privacy Notice in full to ensure you understand how we use your personal data. However, if you only want to access a particular section of this Privacy Notice, then you can click on the relevant link above to jump to that section.
Publift respects your right to privacy. This Privacy Notice explains who we are, how we collect, share and use personal data about you and how you can exercise your privacy rights. This Privacy Notice applies to personal data that we collect through our website at https://www.publift.com/privacy-policy ("Website") and that we control in connection with the provision of our Fuse Tag service to our publisher customers ("Publishers"). Publift Pty Limited (or "Publift") is the controller of this data.
If you have any questions or concerns about our use of your personal data or about this Privacy Notice, then please contact us using the contact details under the "How to contact us" heading below.
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1. What does Publift do?
Publift is a programmatic advertising platform. Through the provision of its Fuse Platform (comprised of the "Fuse Tag"), it provides Publishers with access to a variety of advertising services (including provided via third parties) by packaging them up into a single piece of code. In particular, the Fuse Tag facilitates the collection of information from devices of users visiting Publisher properties by both Publift and its third party advertising partners, such as ad networks. This enables Publishers to sell advertising space on their digital properties and to optimise their advertising opportunities. Publift is headquartered in Australia but services Publishers all around the world. For more information about Publift, please see the "About Publift" section of our Website. For more information about the Fuse Platform and our Fuse Tag, see the "What is Fuse" section of our Website.
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2. How does Publift protect your privacy?
Publift respects the importance of your privacy and is bound by applicable privacy laws and applicable privacy regulations. Publift is committed to protecting your privacy when managing your personal data and has policies and procedures to ensure that personal data is handled in accordance with applicable laws and applicable regulations.
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3. Personal data we collect and process
a) The personal data we, Publift, collect from you, either directly or indirectly, will depend on how you interact with us, our Website and the digital properties of Publishers that use the Fuse Tag. We collect personal data about you from the following different sources:
Personal data collected via the Website, social media and service interactions
- Information that you provide directly
We collect personal data directly from you when you choose to provide us with this information online via our Website, through your other interactions with us (such as data collected via social media, surveys, when you become a Publift customer and through customer service communications). Certain parts of our Website will ask you to provide personal data, such as the "Let's Talk" or "Contact Us" pages for the purposes of enquiries in relation to our services. If you are a Publift customer, we will also ask you to provide personal data to create an account in order to access your Publift account and Publift Dashboard.
- Information that we collect indirectly
We collect your personal data indirectly from you, including through automated means from your device when you visit and use our Website. Some of the information we collect indirectly is captured using cookies and other tracking technologies, as explained further in the "Cookies and similar tracking technology" section below.
Personal data collected via the Fuse Tag
- Information that we collect indirectly
We will also collect (or facilitate the collection of) personal data indirectly from you, through automated means when you visit digital properties of Publishers that use our Fuse Tag. Some of the personal data we collect indirectly (through the use of third-party processors), whilst other information we facilitate the indirect collection of by our third party partners ("Data Partners"). As at the date of publication of this Privacy Notice, most of the data described in this section is not considered “personal information” as defined in the Australian Privacy Act 1988 (Cth).
b) The table below describes the categories of personal data we process about you:
- through our Website and via any social media or other service related interactions with us; and
- in connection with our provision of Fuse Tag services to Publishers.
Personal data collected via the Website and our social media and service interactions
Identity and Contact Data / Account Data such as your name, email address and password, telephone number if you are a Publisher customer (or prospect).
Communications Data such as your feedback on our products and services or the performance of our Website or our Fuse Tag and other communications with us (including when you interact with our customer service or sales teams), any queries you raise, chat, email or call history. This will include information as to how you contact customer services and the channel of communication that you use or any information that you send to us (for example, if you complain about the performance of our Website or our Fuse Tag and send us screenshots).
- Directly from you (online via our Website or social media channels or offline via calls with our customer services or sales teams)
- Automatic collection
Website Usage Data such as activity and Website and page interaction, information that we capture using cookies and similar technologies (see the
"Cookies and similar tracking technology" section. This will include page views and searches, log-in information, browser type, version and language, referring website address, clicks, operating system, information about content viewed, watched or downloaded for offline access, length of visits to certain pages, length of Website use and other functional information on Website performance (for example, application version information, diagnostics, and crash logs).
Personal data collected in connection with the Fuse Tag
Location Data collected via the Fuse Tag which interfaces with third party providers such as Akamai and Google, from which we can identify your approximate geographic location, including by means of a version of your IP address.
Device Data collected via other third party processors and Data Partners whose code is embedded within the Fuse Tag, including IP addresses, identifiers for smart devices, IP browser user agent, cookie IDs, third party cookies, web beacons / tags, clickstream data, device identifiers, unique online identifiers, metadata, approximate geolocation data, the browser you use to visit the Publisher website, device type and information, advertising identifiers, signals indicating your consent preferences as communicated via a consent management platform, usage information such as date and time of access, internet service provider and information, computer and internet connection information, deidentified information, online and offline activity such as web browsing history, end user engagement information and behavior, user content data, URLs or app screens, statistics, internal search queries, ad reporting and delivery information, mobile advertising IDs, pseudonymous ID of audience segmentation, device sensor data and streaming data.
Bid Request Data collected by Data Partners whose code is embedded within the Fuse Tag, including details about the ad unit (e.g. the website), the digital content, device type and identifier, a unique advertising identifier, approximate geolocation data, information about your interaction with the Publisher web property that you are visiting and signals indicating your consent preferences as communicated via a consent management platform.
We do not collect any sensitive personal data about you, such as health-related information or information about your race or ethnicity, or sexual orientation.
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4. How we use your personal data (our purposes) and our legal basis for processing it
We use the personal data that we collect from and about you only for the purposes described in this Privacy Notice or for purposes that we explain to you at the time we collect your information. Depending on our purpose for collecting your information, we rely on one of the following legal bases:
- Contract - we require certain personal data in order to provide our Fuse Tag services to you and to support those services;
- Consent – in certain circumstances, we may ask for your consent (separately from any contract between us) before we collect, use, or disclose your personal data, in which case you can voluntarily choose to give or deny your consent without any negative consequences to you;
- Legitimate interests – we will use or disclose your personal data for the legitimate business interests of either Publift or a third party, but only when we are confident that your privacy rights will remain appropriately protected. If we rely on our (or a third party's) legitimate interests, these interests will normally be to: operate, provide and improve our business, including our Website and our Fuse Tag; communicate with you and respond to your questions about our Website and Fuse Tag; improve our Website and/or Fuse Tag, or use the insights to improve or develop marketing activities and promote our products and services; detect or prevent illegal activities (for example, advertising fraud or malicious ads); and/or to manage the security of our IT infrastructure, and the safety and security of our employees, customers, vendors and visitors. Where we require your data to pursue our legitimate interests or the legitimate interests of a third party, it will be in a way which is reasonable for you to expect as part of the running of our business and which does not materially affect your rights and freedoms; or
- Legal obligation – there may be instances where we must process and retain your personal data to comply with laws or to fulfil certain legal obligations.
The following table provides more details on our purposes for processing your personal data and the related legal bases. The legal basis under which your personal data is processed will depend on the data concerned and the specific context in which we use it.
Personal data collected via the Website and our social media and service interactions
Register your Fuse Platform account on our Website or our related websites for service interaction purposes and to manage and administer your account.
- Identity and Contact Data / Account Data
- Communication Data
- Performance of a contract with you.
Provide and deliver the Website and Fuse Tag services to you.
- Identity and Contact Data / Account Data
- Communication Data
- Performance of a contract with you.
Respond to your communications regarding our Website and Fuse Tag services, send you service updates, confirmations, invoices, technical notices, updates, security alerts, support and administrator messages, respond to your enquiries, requests or complaints.
- Identity and Contact Data / Account Data
- Communication Data
- Performance of a contract with you.
- Otherwise, as necessary for our legitimate interests (to operate, provide and improve our business; to communicate with you) – where our communications are not necessary to perform or enter into a contract with you.
Reviewing communications with you for customer support and quality assurance and training purposes, and related record keeping.
- Identity and Contact Data / Account Data
- Communication Data
- Necessary for our legitimate interests (to operate, provide and improve our business; to communicate with you) – where our communications are not necessary to perform or enter into a contract with you.
Keep our business, including our Website, and Fuse Tag services, our employees, customers, vendors, and visitors secure and address threats to your safety or the safety of others; to detect and prevent fraud (online and in office). For example, online we use malware and spyware monitoring tools to detect suspicious activity and algorithms to detect unauthorised access.
- Identity and Contact Data / Account Data
- Communication Data
- Website Usage Data
- Necessary for our and our third parties' legitimate interests (to operate and provide our business, including our Website and Fuse Tag services; to detect or prevent illegal activities (e.g. fraud) and/or to manage the security of our IT infrastructure, and the safety and security of our employees, customers, vendors, and visitors).
Manage compliance with our terms of service.
- Identity and Contact Data / Account Data
- Communication Data
- Website Usage Data
- Performance of a contract with you.
- Otherwise, as necessary for our legitimate interests (to operate, provide and improve our business, including our Website and Fuse Tag services; to detect or prevent illegal activities (e.g. fraud) and/or to manage the security of our IT infrastructure, and the safety and security of our employees, customers, vendors, and visitors.
To administer and maintain our Website and Fuse Tag services and our IT systems (including monitoring, troubleshooting, data analysis, testing, system maintenance, repair and support, reporting and hosting of data).
- Identity and Contact Data / Account Data
- Communication Data
- Website Usage Data
- Our and our third parties' legitimate interests (to operate, provide and improve our business, including our Website and Fuse Tag services; to detect or prevent illegal activities (e.g. fraud) and/or to manage the security of our IT infrastructure).
Manage our use of tracking technologies such as cookies(including enabling you to manage your cookie preferences) and analyse collected data to learn about our Website, and to improve our Website. This includes website analytics, identifying browsing trends and patterns and evaluating this information on an aggregated, group(s) basis and individual basis.
- Consent (where required under applicable law – see cookie consent tool on our website).
- Otherwise (for strictly necessary cookies) our legitimate interests (to operate, provide and improve our business, including our Website or use the insights to improve or develop marketing activities and promote our products and services).
Contact current and prospective customers about our products and services, and events we think may be of interest, including newsletters and other promotional mailers and electronic communications.
- Identity and Contact Data / Account Data
- Communication Data
- Website Usage Data
- Consent (where required under applicable law).
- Otherwise our legitimate interests (to operate, provide and improve our business; to communicate with you and to develop marketing activities and promote our products and services).
Personalise and customise your Website experience, including to provide local or otherwise targeted content and information for customers, and to tailor the content on our Website.
- Identity and Contact Data / Account Data
- Website Usage Data
- Consent (where required under applicable law).
- Otherwise our legitimate interests (to operate, provide and improve our business, including our Website, to use the insights to improve or develop marketing activities and promote our products and services).
Comply with legal and regulatory obligations to which we are subject, including our obligations to respond to your requests under data protection law.
- Identity and Contact Data / Account Data
- Website Usage Data
- Communication Data
Protect our legal rights (including where necessary, to share information with law enforcement and others), for example to defend claims against us and to conduct litigation to defend our interests.
- Identity and Contact Data / Account Data
- Website Usage Data
- Communication Data
- Our legitimate interests (to protect our business interests).
Personal data collected via the Fuse Tag (in some cases by Publift processors)
To determine whether to serve visitors to Publisher properties using the Fuse Tag, with a consent management platform (in order to obtain any legally required consents), based on your location.
- Our legitimate interests (to operate and provide our Fuse Tag services in a legally compliant manner).
To measure the performance of advertisements displayed on Publisher properties via the Fuse Tag (TCF Purpose 8).
- Location Data
- Website Usage Data
- Bid Request Data
- Consent (where required under applicable law).
- Otherwise, our legitimate interests (to measure the success of advertising campaigns delivered via the Fuse Tag and to and improve our services).
To develop and improve our products / services (i.e. to develop and improve the Fuse Tag service) (TCF Purpose 10).
- Location Data
- Website Usage Data
- Bid Request Data
- Consent (where required under applicable law).
- Otherwise, our legitimate interests (to measure the success of advertising campaigns delivered via the Fuse Tag and to improve our services).
To ensure security, prevent fraud, and debug (TCF Special Purpose 1).
- Device Data
- Location Data
- Website Usage Data
- Consent (where required under applicable law).
- Otherwise, our legitimate interests (to ensure the security and integrity of our Fuse Tag services).
To facilitate the collection and transmission of Device Data and Bid Request Data to Data Partners** (TCF Purpose 1), in order for such Data Partners to provide their advertising services in accordance with their respective Privacy Policies and the preferences you indicate via the consent management platform displayed to you via Publisher properties. - Device Data
- Bid Request Data
- Consent (where required under applicable law).
** Joint controllership with Data Partners. Please note that, Publift acts as a joint controller (with some of its Data Partners and Publishers) in facilitating the collection and transmission of Device Data and Bid Request Data to Data Partners. This is because, through provision of the Fuse Tag services to Publishers, Publift and its Publishers provide Data Partners with the opportunity to collect Device Data and Bid Request Data from Publisher digital properties and therefore have a degree of influence over its collection and transmission. However, neither Publift, nor its Publishers, have any influence over the subsequent processing of Device Data and Bid Request Data by Data Partners. This subsequent processing will be carried out by Data Partners in accordance with the terms of their respective Privacy Notices and the preferences you indicate via the consent management platform displayed to you via Publisher web properties.
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5. Who we share your personal data with
We will share your personal data with the following categories of recipients:
- our group companies, who provide data processing services necessary to provide our services to you (for example, to support the sales and delivery of our Fuse Tag services to you, provide functionality on, or help to enhance the security of our Website, or who otherwise process personal data for purposes described in this Privacy Notice);
- any competent law enforcement body, regulatory, government agency, court or other third party (such as our professional advisers) where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
- a buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal data only for the purposes disclosed in this Privacy Notice; or
- any other person with your consent to the disclosure (obtained separately from any contract between us).
In addition, with respect to, personal data collected via the Website and our social media and service interactions, we will share your personal data with the following categories of recipients:
- third party service providers who provide data processing services to us as necessary to provide you with services (for example, to support the sales and delivery of our Fuse Tag services, provide functionality on, or help to enhance the security of our Website), or who otherwise process personal data for purposes described in this Privacy Notice. The following table lists the main third party service providers we engage to process your personal data, the categories of services they provide, and the types of personal data they receive in order to provide us these services:
Google – Ad Manager
Programmatic services and ad serving
- Location Data
- Website Usage Data
- Bid Request Data
Google Cloud
Data Warehouse
- Location Data
- Website Usage Data
- Device Data
- Bid Request Data
Akamai
Compute, performance and security services
- Location Data
- Device Data
- Website Usage Data
- Bid Request Data
Auth0
Identity and access management and related services
- Identity and Contact Data
- Location Data
- Website Usage Data
- Bid Request Data
In addition, with respect to personal data collected via the Fuse Tag, personal data is collected via the Fuse Tag by:
- our third party service providers who provide advertising services to us in connection with our provision of the Fuse Tag, and
- our third party Data Partners who provide their own advertising services via the Fuse Tag.
The following table lists the main third party service providers and third party Data Partners involved in the collection and processing of personal data via the Fuse Tag, the categories of services they provide, and the types of personal data they receive in order to provide us these services:
Adagio
Programmatic advertising services.
- Device Data
- Bid Request Data
AppMonet (dba “Adapt MX”)
Programmatic advertising services.
- Device Data
- Bid Request Data
Azerion (Formerly Inskin)
Programmatic advertising services.
- Device Data
- Bid Request Data
ConnectAd
Programmatic advertising services.
- Device Data
- Bid Request Data
Conversant
Programmatic advertising services.
- Device Data
- Bid Request Data
Criteo
Programmatic advertising services.
- Device Data
- Bid Request Data
Gum Gum
Programmatic advertising services.
- Device Data
- Bid Request Data
Equativ (Formerly Smart AdServer)
Adserver services, supporting access to Publisher inventory made available via Google’s Open Bidding Platform.
- Device Data
- Bid Request Data
Index Exchange
Programmatic advertising services.
- Device Data
- Bid Request Data
Inmobi
Programmatic advertising services.
- Device Data
- Bid Request Data
Kargo
Programmatic advertising services.
- Device Data
- Bid Request Data
Magnite
Programmatic advertising services.
- Device Data
- Bid Request Data
NoBid
Programmatic advertising services.
- Device Data
- Bid Request Data
OpenX
Programmatic advertising services.
- Device Data
- Bid Request Data
Playground XYZ
Programmatic advertising services.
- Device Data
- Bid Request Data
Pubmatic
Programmatic advertising services.
- Device Data
- Bid Request Data
Sharethrough (Formerly District M)
Programmatic advertising services.
- Device Data
- Bid Request Data
Sovrn, Inc.
Programmatic advertising services.
- Device Data
- Bid Request Data
Teads
Programmatic advertising services.
- Device Data
- Bid Request Data
Triplelift
Programmatic advertising services.
- Device Data
- Bid Request Data
Xandr (acquired by Microsoft)
Programmatic advertising services.
- Device Data
- Bid Request Data
33Across
Ad network and insight services.
- Device Data
- Bid Request Data
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6. Cookies and similar tracking technology
We use cookies and similar tracking technology (collectively, "Cookies") to collect and use personal data about you via the Fuse Tag, including to serve interest based advertising. For further information about the types of Cookies we use, why, and how you can control Cookies, please see our Cookie Notice.
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7. International data transfers
In some cases, your personal data will be processed by Publift in countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).
Specifically, our servers are located worldwide, and we have offices in Sydney, Dublin, Melbourne and San Francisco. Our third party service providers and Data Partners also operate around the world including in Australia, the European Economic Area, the United States, Canada, the United Kingdom, Singapore, Brazil, Japan, India, Philippines, Indonesia, China, Mexico, Colombia, Brazil, Turkey, South Korea, Israel and the Middle East. This means that when we collect your personal data, we may process it in any of these countries.
Where we transfer your personal data to countries and territories outside of the European Economic Area and the United Kingdom, which have been formally recognised as providing an adequate level of protection for personal data, we rely on the relevant "adequacy decisions" from the European Commission and "adequacy regulations" (data bridges) from the Secretary of State in the United Kingdom.
Where we transfer your personal data to a territory that outside of the European Economic Area or the United Kingdom that is not subject to an adequacy decision or regulations, we have taken appropriate safeguards to ensure that your personal data will remain protected in accordance with this Privacy Notice and applicable laws. The safeguards we may use to transfer personal data are, in the case of both our group companies and third party service providers and Data Partners, the European Commission’s Standard Contractual Clauses as issued on 4 June 2021 under Article 46(2) using module(s) for controller to controller and controller to processor transfers, including the UK Addendum and the UK International Data Transfer Agreement permitted under Article 46(2) of the UK GDPR for the transfer of data originating in the United Kingdom.
Should you have any questions about international transfers of your personal data, or the safeguards that we use, please contact us using the contact details under the “How to contact us” heading below.
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8. Data retention
We retain the personal data we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).
In certain circumstances, we will need to keep your information for legal reasons after our contractual relationship has ended and your Fuse Platform user account has been deleted. The specific retention periods depend on the nature of the information and why it is collected and processed and the nature of the legal requirement. For example: We keep your information when we have a legal obligation to do so (for example if a court order is received about your account, we would retain your data for longer than the usual retention period when an account is deleted); to deal with and resolve requests and complaints (for example, if there is an ongoing complaint with respect to the Fuse Tag service), to protect individuals' rights and property (for example we may retain information about a data subject access request for a period after the request is dealt with in case there is a subsequent complaint and the information is needed to demonstrate how the request was handled) and for litigation or regulatory matters (for example we would retain your information if there was an ongoing legal claim and the information was relevant to the claim. This information would be retained until the legal claim had been concluded).
When we have no ongoing legitimate business need or legal reason to process your personal data, we will either delete or anonymise it or, if this is not possible (for example, because your personal data has been stored in backup archives), then we will securely store your personal data and isolate it from any further processing until deletion is possible.
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9. Your data protection rights
Individuals located in the United Kingdom and the European Economic Area have the following data protection rights. To exercise any of your data protection rights if you are located in the United Kingdom or European Economic Area, see specific instructions below or contact us using the contact details provided under the "How to contact us" heading below.
- You may access, correct, update or request deletion of your personal data.
- You can object to processing of your personal data, ask us to restrict processing of your personal data or request portability of your personal data, (i.e. your data to be transferred in a readable and standardised format.
- You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the "unsubscribe" or "opt-out" link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), please contact us using the contact details provided under the "How to contact us" heading below. If you choose to opt out of marketing communications, we will still send you non-promotional emails, such as emails about your account or our ongoing business relations.
- If we have collected and processed your personal data with your consent, then you can withdraw your consent at any time by using the contact details provided under the "How to contact us" heading below. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent.
- You have the right to complain to a supervisory authority about our collection and use of your personal data. For more information, please contact your local supervisory authority. Contact details for supervisory authorities in Europe are available here and for the United Kingdom here. Certain supervisory authorities may require that you exhaust our own internal complaints process before looking into your complaint.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. Generally, there will be no charge for this service, however you may be required to verify your identity before any information is released to you. Depending on the volume, type or method of access to the information you request, Publift may charge you some fees, however, these will not be excessive, will be notified in advance, and will not apply to the making of the request. Please note that depending on the volume or nature of the information required, it may take a number of days to fulfil the request. Publift may destroy or de-identify personal data once the data is no longer deemed required by the business or by applicable laws.
You may deal with Publift anonymously by using a pseudonym, unless Publift is reasonably required or authorised by law to deal only with an identified person, or it is reasonably impracticable for us to respond to you if you have not identified yourself.
If you are in a location other than the United Kingdom and European Economic Area, you may have certain data protection rights. If you have a problem or request about your personal information or wish to enquire about your privacy, please submit a request or contact us at legal@publift.com.
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10. Updates to this Privacy Notice
We may update this Privacy Notice from time to time in response to changing legal, regulatory, technical or business developments. All changes will be published on this website and will only apply to personal data that has been collected after the date you accept the new privacy policy. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Notice changes if, and where, required by applicable data protection laws.
You can see when this Privacy Notice was last updated by checking the "last updated" date displayed at the top of this Privacy Notice.
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11. How to contact us
If you have any questions or concerns about our use of your personal data, please contact us using the following details:
Email: legal@publift.com
For individuals who reside in the United Kingdom, we have appointed Law Squared as our Article 27 representative under the United Kingdom GDPR. If you want to exercise your rights under the United Kingdom GDPR, please use the details below:
privacyrep.publift@lawsquared.com
Law Squared
c/o Publift Pty Ltd
The Stanley Building
7 Pancras Square,
King's Cross, London
United Kingdom
N1C 4AG
The data controller of your personal data is Publift Pty Limited.
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