Privacy policy

PublishDrive Inc.

Last modified: May 14, 2018

This Privacy Policy (the “Policy”) explains how PublishDrive Inc. (“PublishDrive”, “Company”, “we”, or “us”) collects, stores, uses, and discloses personal information from our users (“you”, “user”) in connection with the website located at www.publishdrive.com (the “Website”).

Please read and make sure you understand this Policy. If you do not agree with this Policy or our practices, you may not use our Website. This Policy may change from time to time and is incorporated into our Website Terms of Use . Your continued use of our Website constitutes your acceptance of those changes. We encourage you to review this Policy periodically.

PublishDrive may from time to time handle personal data collected from individuals located within the European Union (“EU”) member countries. Consistent with the regulation 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (“General Data Protection Regulation” or “GDPR”) PublishDrive grants the enhanced data protection for the individuals located within the EU. Our adherence to the GDPR regarding the personal data collected from individuals located within the EU is detailed in this Policy.

Furthermore PublishDrive complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, onward transfer and retention of personal data transferred from EU member countries and Switzerland to the United States, respectively. PublishDrive has certified to the U.S. Department of Commerce that it adheres to the Privacy Shield principles (“Privacy Shield Principles”) of:

  • Notice
  • Choice
  • Accountability of onward transfer
  • Security
  • Data integrity and purpose limitation
  • Access
  • Recourse, enforcement and liability

Our adherence to each of these principles is detailed in this Policy. If there is any conflict between the terms of the Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. If you want to learn more about the Privacy Shield program or view PublishDrive’s certification, please visit https://www.privacyshield.gov.

PublishDrive is under the jurisdiction as well as the investigatory and enforcement powers of the US Federal Trade Commission for purposes of the EU-US Privacy Shield framework and the Swiss-US Privacy Shield Framework.

1. What does this Privacy Policy cover?

This Policy covers PublishDrive's treatment of information that PublishDrive gathers when you are accessing PublishDrive's Website as a user and when you use PublishDrive services (the "Services"). Also, this Policy covers PublishDrive's treatment of your information that PublishDrive shares with PublishDrive’s business partners. This Policy does not apply to the practices of third parties that PublishDrive does not own or control (such as third-party websites that you may access from the Website), or to individuals that PublishDrive does not employ or manage.

2. What information does PublishDrive collect?

The information we gather from users enables PublishDrive to personalize and improve our services and to allow our users to set up accounts on the Website. In connection with the Website, we request and display some information to other users and visitors of the Website, which allows users to identify authors and goods on the Website. We collect the following types of information from our users:

2.1 Information You Provide to Us:

We receive and store any information you enter on our Website or provide to us in any other way. The types of information collected include, without limitation, your full name, email address, mailing address (optional), phone number (optional), password, contact information and content consumed on the Website, including, but not limited to content (including eBooks) and book metadata (including pen name, biography, author information etc.) uploaded and shared. Some of this information is not mandatory but is necessary to use all of our functions.

In addition, we collect the following financial data: account holder name, bank name, account number, currency of account. For taxation reasons, we need to collect Tax ID (US: tin: SSIN/EIN), citizenship, country of residence. In some cases, we’ll need to ask for a government ID, Green Card, or other proof of address or proof of residency status as regulated by taxation law.

2.2 Information Collected Automatically:

We receive and store certain types of information whenever you interact with our Website or Services. PublishDrive automatically receives and records information on our server logs from your browser including your IP address, unique device identifier, browser characteristics, domain and other system settings, search queries, device characteristics, operating system type, language preferences, referring URLs, actions taken on our Website, page requested, content consumed (e.g., viewed, uploaded, and shared), dates and times of Website visits, metadata and other information associated with other files stored on your device. We receive and collect sales-relevant data from our book retailers, which data then we make available to our users.

3. What About Cookies?

The Company collects mainly anonymous data from the Website, such as searches. The anonymized data can include user session data such as IP address, web browser type, the time spent on the page by the user, and user-clicked buttons. The Company processes anonymous data in order to improve the page, to bring it to perfection. During this procedure PublishDrive can incorporate “cookies”, which collect the visitor’s first level domain name, the date and the exact time of access. The “cookie” alone can’t be used to reveal the identity of the visitor. The “cookie” is a file, which is sent to the browser of the visitor and stored on the hard drive of visitor. Cookies don’t damage the computer of the visitor. The browser can be set to indicate when a cookie is received, so the visitor can decide to accept the so-called cookie or not. The Company does not use cookies to collect or manage any information that would allow the identification of the User.

4. How Does PublishDrive Use My Information?

We may use your information, including your personal information - based on diverse purposes as well as the legal basis of the processing - as follows:

4.1. We process the following personal data for the purpose and on the legal basis of the performance of the contract, product and service fulfillment:
  • Full name
  • Email address
  • Mailing address (optional)
  • Phone number (optional)
  • Taxation related data: Tax ID (US: tin: SSIN/EIN), citizenship, country of residence, various proof of address or proof of residency status, like government ID, Green Card
  • Financial data: account holder name, bank name, account number, currency of account
  • Content (including eBooks) and book metadata (including pen name, biography, author information etc.) uploaded and shared
  • Metadata
  • Sales-relevant data

The information you provide is used for purposes such as responding to your requests for certain products and services, customizing the content you see, communicating with you about specials, sales offers, and new features, and responding to problems with our services. It is also used to fulfill and manage payments or requests for information, or to otherwise serve you, provide any requested services and administer sweepstakes and contests.

4.2. We process the following personal information based on your consent (as the legal basis of this processing) for marketing purposes, to deliver coupons, mobile coupons, newsletters, receipt messages, e-mails, and mobile messages . We also send marketing communications and other information regarding services and promotions based on your consent and administer promotions:
  • Full name
  • Email address
  • Mailing address (optional)
  • Phone number (optional)

You shall always have the right to withdraw your consent at any time.

4.3. We process personal data for the purpose and on the legal basis of compliance with legal obligations to prevent fraudulent transactions, monitor against theft and otherwise protect our customers and our business. We also process personal data for the purpose and on the legal basis of legal compliance and to assist law enforcement and respond to subpoenas.

This means that in some cases the data processing is stipulated by the applicable laws and we have an obligation to process and keep this data for the required time. This includes employment data, billing data, data which is necessary to assist law enforcement etc.

4.4. We process the following personal data for the purpose and on the legal basis of the legitimate interests of the Company, to improve the effectiveness of the Website, mobile experience, and marketing efforts, to conduct research and analysis, including focus groups and surveys and to perform other business activities as needed, or as described elsewhere in this Policy:
  • IP address
  • browser information
  • password
  • contact information
  • content consumed on the Website
  • content (including eBooks) and book metadata uploaded and shared
  • unique device identifier
  • browser characteristics
  • domain and other system settings
  • search queries
  • device characteristics
  • operating system type
  • language preferences
  • referring URLs
  • actions taken on our Website
  • page requested
  • content consumed (e.g., viewed, uploaded, and shared)
  • dates and times of Website visits
  • metadata
  • other information associated with other files stored on your device

Where it is feasible we anonymize personal data or use non-identifiable statistical data. We do not collect personal data in advance and store it for potential future purposes unless required or permitted by the applicable laws.

For collecting anonymously the above-mentioned data and making statistics and analysis we may use the following software and programs:

Name

Registered seat

Country

Google Analytics and Google AdWords (Google LLC.)

1600 Amphitheatre Parkway Mountain View, CA 94043

United States

Hotjar (Hotjar Ltd.)

Level 2, St Julian’s Business Centre, 3, Elia Zammit Street, St Julian’s STJ 1000

Malta

HubSpot Inc.

25 First Street 2nd Floor Cambridge, MA 02141 United States

United States of America

Disqus (Disqus Inc.)

301 Howard Street Suite 300, San Francisco, CA 94105

United States of America

Facebook pixel (Facebook Inc.)

1601 Willow Road Menlo Park, CA 94025

United States of America

InnoCraft Ltd (Matomo)

150 Willis St, 6011 Wellington

New Zealand

Mixpanel Inc.

405 Howard Street, Floor 2 San Francisco, CA 94105

United States of America

4.5. Cookies: PublishDrive may use automatically collected information and cookies information to: (a) remember your information so that you will not have to re-enter it during your visit or the next time you visit the Website; (b) provide custom, personalized advertisements, content, and information; (c) monitor the effectiveness of our marketing campaigns; and (d) monitor aggregate usage metrics such as total number of visitors and pages viewed.
4.6. Data integrity and purpose limitation: PublishDrive will only collect and retain personal data which is relevant to the purposes for which the data is collected, and we will not use it in a way that is incompatible with such purposes unless such use has been subsequently authorized by you. We will take reasonable steps to ensure that personal data is reliable for its intended use, accurate, complete and current. We may occasionally contact you to determine that your data is still accurate and current. To secure your personal information processed we save your personal information to backup archives in every 24 hours. The data stored in our backup archives will be deleted in every half a year.
5. How Long We Retain Your Personal Data?

We will retain your personal data for so long as it is needed to fulfill the purposes outlined in this Policy or until you withdraw your consent, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). When we have no longer or no legal basis to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

6. Will PublishDrive share any of the information it receives?

Information about our users is an integral part of our business, and we may share such information with our affiliated entities. Except as expressly described below, we neither rent nor sell your information to other people or nonaffiliated companies unless we have your permission.

6.1. Third Party Service Providers:

We may share certain personal information with third party vendors who supply software applications, web hosting and other technologies for the Website. We will only provide these third parties with access to information that is reasonably necessary to perform their work or comply with the law. Those third parties will never use such information for any other purpose except to provide services in connection with the Website. We may also share aggregated or de-identified information, which cannot reasonably be used to identify you. We may also request data process service for processing the personal data. During the service of data process, the data processor shall abide under the present Policy, relevant legislations in force, furthermore the provisions of the existing contracts of the PublishDrive. PublishDrive uses the data process service of the following companies:

Name

Registered seat

Country

Activity (data processing service)

PayPal Inc.

2211 North 1st Street San Jose, CA 95131

United States of America

Online money transfer.

TransferWise Ltd.

186-188 City Road London, EC1V 2NT

United Kingdom

Online money transfer.

Zendesk Inc.

1019 Market Street, San Francisco, CA 94103

United States of America

We share your IP address and the country of origin of the message.

We use Zendesk Chat Widget to enable fast and simple support for the visitors and users of our Website.

Sendgrid Inc.

1801 California Street Suite 500, Denver, CO 80202

United States of America

We share e-mail addresses with SendGrid to provide mail marketing and newsletter services.

Tipalti Inc.

1810 San Mateo, Gateway Dr., Suite 260 CA 94404

United States of America

We use it to collect bank and tax information, email addresses and to provide online money transfer service.

6.2. Third Party Book Retailers:

PublishDrive may also share personal information with the book retailers acting as a data processor agent selected by the user in order to fulfill the services and perform the contract.

PublishDrive is in partnership with book retailers and stores all around the world, some of them located inside the territory of the EU, while others located outside the EU. The list of partners and stores available worldwide is accessible from the user account.

6.3. Transfer of Personal Data collected from individuals located within the EU:

If we transfer personal data collected from individuals located within the EU to a third-party acting as a data processor, and such third-party agent processes your personal information in a manner inconsistent with the GDPR or – having a registered seat in the United States of America – with the Privacy Shield Principles, we may be responsible under the rules of the GDPR and / or under Privacy Shield Principles.

We only transfer personal data collected from individuals located within the EU to a third-party having a registered seat outside the EU or the United States of America acting as a data processor without the appropriate safeguards set out in the GDPR when it is necessary for the performance of the contract. PublishDrive will make every effort to ensure that the personal data transferred is safe and secure and that the personal data is processed in a manner consistent with the GDPR.

6.4. PublishDrive may release your information:

(a) in response to subpoenas, court orders or legal process, to the extent permitted and as restricted by law;

(b) when disclosure is required to maintain the security and integrity of the Website, or to protect any user’s security or the security of other persons, consistent with applicable laws;

(c) when disclosure is directed or consented to by the user who has input the personal information; or

(d) in the event that we go through a business transition, such as a merger, divestiture, acquisition, liquidation or sale of all or a portion of its assets, your information will, in most instances, be part of the assets transferred.

6.5. Opt-In for Promotions:

We do not share personally identifiable information with other third-party organizations for their marketing or promotional use without your consent or except as part of a specific program or feature for which you will have the ability to opt-in.

6.6. With Your Consent:

Except as set forth above, you will be notified when your information may be shared with third parties and will have the option of preventing the sharing of this information.

6.7. Data retention and aggregated data processing

Please note that we may retain certain personal information after your account has been terminated. We reserve the right to use your information in any aggregated data collection after you have terminated your account, however we will ensure that the use of such information will not identify you personally.

6.8. Accountability for onward transfer:

PublishDrive will not transfer personal data originating in the EU or Switzerland to third parties unless such third parties have entered into an agreement in writing with us requiring them to provide at least the same level of privacy protection to your personal data as required by the GDPR and / or Privacy Shield Principles. We acknowledge our liability for such data transfers to third parties.

By registration on the Website you give your express consent to the transfer of the personal data as detailed above.

7. Is information about me secure?

We take commercially reasonable measures to protect all collected information from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Please understand that you can help keep your information secure by choosing and protecting your password appropriately, not sharing your password and preventing others from using your computer. Please understand that no security system is perfect and, as such, we cannot guarantee the security of the Website, or that your information won’t be intercepted while being transmitted to us. If we learn of a security systems breach, then we may either post a notice, or attempt to notify you by email and will take reasonable steps to remedy the breach.

8. Children's Privacy

Our Website is not directed to children under 18 and we do not knowingly collect personal information from children under 18. If we learn that we have collected personal information of a child under 18 we will take steps to delete such information from our files as soon as possible. If you are aware of anyone under 18 using the Website, please contact us at support@publishdrive.com.

9. Links to Third Party Sites and Services

This Website may contain links to third party websites operated by individuals or companies unrelated to us. Please be aware that we are not responsible for the privacy practices of such third party websites. We provide links to these websites for your convenience only and you access them at your own risk. We recommend that you review the privacy policies and terms of use posted on and applicable to such third party websites prior to utilizing them.

10. Your Privacy Rights
10.1. Access and Retention:

If you have a Website account, you can log in to view and update your account information. You have the right to obtain confirmation of whether or not we are processing personal data relating to you, have communicated to you such data so that you could verify its accuracy and the lawfulness of the processing and have the data corrected, amended or deleted where it is inaccurate or processed in violation of the Privacy Shield Principles.

We encourage you to contact us at support@publishdrive.com with your questions or concerns, or to request edits to your personal information, or to have it removed from our database. Requests to access, change or remove your personal data will be handled within 30 days.

10.2. Additional Rights for EU Territory:

If you are from the territory of the EU, you may have the right to exercise additional rights available to you under applicable laws, including:

(a) Right of Erasure: In certain circumstances, you may have a broader right to erasure of personal information that we hold about you – for example, if it is no longer necessary in relation to the purposes for which it was originally collected. Please note, however, that we may need to retain certain information for record keeping purposes, to complete transactions or to comply with our legal obligations.

(b) Right to Object to Processing: You may have the right to request PublishDrive to stop processing your personal information and/or to stop sending you marketing communications.

(c) Right to Restrict Processing: You may have the right to request that we restrict processing of your personal information in certain circumstances (for example, where you believe that the personal information we hold about you is inaccurate or unlawfully held).

(d) Right to Data Portability: In certain circumstances, you may have the right to be provided with your personal information in a structured, machine readable and commonly used format and to request that we transfer the personal information to another data controller without hindrance.

If you would like to exercise such rights, please contact us at support@publishdrive.com. We will consider your request in accordance with applicable laws. To protect your privacy and security, we may take steps to verify your identity before complying with the request.

You also have the right to complain to the EU Data Protection Authority about our collection and use of your personal data. For more information, please contact your local EU Data Protection Authority.

11. Recourse, Enforcement and Liability
11.1 PublishDrive is committed to protecting your personal data as set forth in this Policy. If you think we are not in compliance with our Policy, or if you have any question or if you wish to take any other action concerning this Policy, contact us at support@publishdrive.com. You can also contact us at our contact office at 541 Jefferson Ave., Suite 100 Redwood City, CA 94063. We will investigate your complaint, take the appropriate action and report back to you within 30 days. In addition, if you are from the territory of the EU, you also have the right to complain to the EU Data Protection Authority about our collection and use of your personal data. For more information, please contact your local EU Data Protection Authority.
11.2 If your personal data in question was transferred from the EU or Switzerland to the United States and you are not satisfied with our response, we have further committed to refer unresolved Privacy Shield complaints to the dispute resolution procedures of the EU Data Protection Authorities. PublishDrive will cooperate with the appropriate EU Data Protection Authorities during investigation and resolution of complaints concerning personal data that is transferred from the EU to the United States brought under Privacy Shield. For complaints involving personal data transferred from Switzerland, we commit to cooperate with the Swiss Federal Data Protection and Information Commissioner (“FDPIC”) and comply with the advice given by the FDPIC. Complaints regarding processing of personal data pertaining to data subjects located in the EU and Switzerland may be reported by the individual to the relevant Data Protection Authority.

These recourse mechanisms are available at no cost to you. Damages may be awarded in the accordance with the applicable law.

You may be able to invoke binding arbitration under certain conditions with the arbitrational mechanism of the American Arbitration Association, if you are not satisfied with the above recourse mechanism. The arbitration is available to you to determine, for residual claims, whether PublishDrive has violated its obligations under the Principles as to you, and whether any such violation remains fully or partially unremedied.

Your decision to invoke the binding arbitration option is entirely voluntary. The arbitral decisions will be binding on all parties to the arbitration.

12. Modifications to this Policy

We will modify this Policy if our privacy practices change. We will notify you of such changes by posting the modified version on our Website and indicating the date it was last modified, and, if the changes are significant, we will provide a more prominent notice (including by email in certain instances). The date this Policy was last modified is at the top of this page. Please periodically review this Policy so that you are familiar with the current Policy and aware of any changes.

13. Questions

If you have any questions concerning this Policy or the Services, please contact us at support@publishdrive.com. You can also contact us at our contact office at 541 Jefferson Ave., Suite 100 Redwood City, CA 94063.

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