A. Introduction
ePublishing, Inc. ("we", "us" or "ePublishing") provides enterprise level publishing solutions. ePublishing collects, and uses including any information that may be used, either alone or in combination with other information, to personally identify a natural person ("Personal Data"), in several ways, as described herein. ePublishing is committed to protecting and respecting your privacy. This Privacy Policy ("Policy"), describes how ePublishing treats personal data when you, the user, access the ePublishing website located at https://www.ePublishing.com (the "Website"), or if you otherwise communicate with us, for example by requesting information related to our services or signing up to receive emails and newsletters.
If you choose not to provide any requested Personal Data, you may be unable to access certain areas of the Website, register to use or purchase our products or services, or receive communications from us regarding our products or services or the Website.
Our Site may contain links to third-party websites and services that are not owned or controlled by ePublishing. We are not responsible for the privacy practices or the content of third party websites, services and advertisements, and you visit them at your own risk. This Policy only applies to Personal Data collected by ePublishing, and does not apply to any Personal Data collected by any third party. We encourage you to familiarize yourself with privacy policies applicable to any websites and services operated by third parties as we are not responsible for the privacy practices of any third parties.
For purposes of European Union data protection law, ePublishing is the Data Controller for your Personal Data collected through the Services.
Owner and Data Controller
ePublishing, Inc
27863 Network Place
Chicago, IL 60673
PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY ACCESSING OR USING THE WEBSITE, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTAND AND AGREE TO BE BOUND BY ALL OF THE TERMS OF THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THESE TERMS, DO NOT ACCESS OR USE THE WEBSITE.
B. Type of Information ePublishing Collects
We may receive and/or collect information, including Personal Data, in the following ways:
Personal Data in Connection with User Account Registration and User Account-Related Activities: Certain areas and features of the Website, such as registration of a user account or profile for purposes of opting to receive further information about ePublishing products or services may require you to provide ePublishing with certain Personal Data such as your name, email address, address, company name, job title, phone number, and other business or contact information. No transaction payment data is collected or stored by ePublishing.
Your Activities On and Use of the Website: ePublishing may automatically collect information about your activities on and/or usage of the Website. Activity information we automatically collect may include which web pages you visited, the Uniform Resource Locator ("URL") identifying the website you came from or visit after you leave the Website, the average time you spent on the Website, information, including Personal Data, you’ve previously shared with ePublishing, your domain, your computer’s Internet Protocol("IP") address, etc. (defined below). In addition, if you are logged into a password protected area, we may associate that information with your account. To accomplish this we may use the following:
Web Beacons - Web Beacons are strings of code placed on a webpage in conjunction with Cookies (defined below). Web Beacons are able to track the number of users that visit a website and, in conjunction with cookies, identify the IP address and personalize the website experience. Web Beacons may also be used to collect anonymous and/or aggregate, unidentifiable information such as how many users attended a virtual event.
IP Address - The IP address is the numerical label associated with the location of your computing device.
Cookies - In some cases, ePublishing may use HTTP cookies (web cookies, Internet cookies, browser cookies), Flash Cookies (cookies that are not related to a specific browser, further described below), clear GIFs (a.k.a. web beacons), and log file information (a file that records either events that occur in an operating system or other software runs, or messages between different users of a communication software) to: (a) store information so that you will not have to re-enter it during your visit or the next time you visit the event; (b) provide customer, personalized content and information; or (c) monitor aggregate metrics such as total number of visitors, pages, viewed, and similar information. A cookie is a small amount of data, which often includes a unique identifier that is placed on your computer or on your mobile phone/tablet (collectively referred to herein as a "device") browser from a website’s computer and is stored on your device’s hard drive. There are two different types of cookies: session cookies and persistent cookies. Session cookies are held temporarily and disappear when you close your browser. Persistent cookies may be used by your browser on subsequent visits. Cookies are widely used to provide certain features of website, to make websites perform more efficiently, and to provide information to the owners of the website. Users have the opportunity to set their devices to accept all cookies, to notify them when a cookie is issued or not to receive cookies at any time. If you do not opt in to receiving cookies and/or set your device to not receive cookies, certain personalized features cannot be provided to you, and accordingly you may not be able to take full advantage of the Website’s features.
Third-Party Cookies - You may be presented with cookies from third-party websites and providers that are not related to ePublishing. For example, when you view a webpage with content embedded from a third-party provider, you may be presented with cookies from such provider. ePublishing does not control the dissemination of these third-party cookies. In general, you should check the third-party websites for more information regarding that third-party’s data practices and policies. In addition, ePublishing provides an optional single sign-on using social networks including, but not limited to, Facebook, Twitter, LinkedIn and Google. If you are logging into the Website using a social network credential, the applicable third party, and not ePublishing, will set cookies. ePublishing does not control or have any access to the cookie information these social networks may set.
Local Shared Objects (Flash Cookies) - To improve the user experience, Local Shared Objects (otherwise known as Flash Cookies or LSOs) may be used to provide features that enhance your experience. Flash Cookies are stored on a user’s device much the same as cookies are, however it is not possible to manage them at browser level in the same way. To disable or delete flash cookies, see https://www.adobe.com/products/flashplayer/security. Please be aware that removal or restricting the use of cookies may affect the features available to you for applications from the Website or for our products or services.
Local Storage - ePublishing may use browser local storage on personal computers and mobile devices to deliver its services.
Content: Any Personal Data or content that you voluntarily upload or otherwise disclose while on the Website, including but not limited to information disclosed on discussion boards, in messages and chat areas, within a profile page, or images or any other content you provide ("Content"), becomes publicly available and can be collected and used by others. In addition, if you are given the ability to log into your account with any social networking website, or post Content on such site, other third-party website, or through the Website, such Content may be made available to other parties and associated with your Personal Data. Data that is in an aggregate, de-identified form that is no longer considered Personal Data and does not allow the identification of individual users may be used by ePublishing for purposes of research and analysis.
Customer service information: Name, signature, address, telephone number, customer number; we also may collect the communications that we exchange with you through online forms, by email, over the phone or by post, and summaries or voice recordings of your interactions with our customer service team;
Device Information: We may collect and/or use third-party website analytics tools that collect information about visitor traffic on our websites and Services, including IP address, unique personal identifiers, device ID, device type, and browser and operating system type;
Location Information and Internet or other Network Activity Information: we use cookies, log files, local storage objects, and other tracking technologies to automatically collect information about your activities, such as your searches, page views, date and time of your visit, and other information about your use of the Services. We also collect information that your computer or mobile device provides to us in connection with your use of the Services such as your browser type, type of computer or mobile device, browser language, IP address, mobile carrier, unique device identifier, location, and requested and referring URLs. We also receive information when you view content on or otherwise interact with the Services, even if you have not created an account. We may use internal and third-party analytics tools. The third-party analytics companies we work with may combine the information collected with other information they have independently collected from other websites and/or other online products and services. Their collection and use of information is subject to their own privacy policies;
Professional or employment-related information: if you become a User through your employment on behalf of your employer.
C. Purposes for Which ePublishing Collects Information
We do not sell your personal data – such as your name and contact information – to third parties to use for their own marketing purposes. We use the information we collect for our legitimate interests which include the following:
Operation, Maintenance and Flagging: If you submit Personal Data through the Website, ePublishing may use it to operate, maintain, and provide you with the general and personalized features and functionality of the Website, provide you with the ePublishing products and services you request or order, complete transactions, or communicate with you. We may also use such Personal Data to process any flagging activity or correspondence you send to us.
Messaging: Your user account registration information may be displayed in password protected areas to other users. If you choose to receive email from ePublishing, we may use clear GIFs (a.k.a. web beacons) in HTML-based emails sent to you to track which emails are opened by recipients.
No Commercial Marketing: ePublishing will not use your email address or other Personal Data to send commercial or marketing messages for our benefit without your consent, except as part of a specific program or feature or other business relationship for which you opt in. We will not share your Personal Data with third-party marketers.
Non-Marketing or Administrative Uses: ePublishing may use your email address without your consent for non-marketing or administrative purposes, such as notifying you for customer service reasons.
Quality & Features: ePublishing may use Personal Data and certain non-personally identifiable information in furtherance of its legitimate interest to improve the quality and design of the Website and to create new features, promotions, functionality, and services by storing, tracking, analyzing, and processing user preferences and trends, as well as user activity and communications, to improve or personalize your experience, to improve or manage the Website or products and services, to provide features available on the Website, to operate and improve our products and services, for market research, to analyze the Website, and to ensure the technical functionality and security of the Website.
URLs & IP Address: When you visit the Website through a referral, ePublishing automatically receives the URL of the site from which you came. We also receive the Internet protocol (IP) address of your computer, your computer operating system and type of web browser you are using, as well as the name of your Internet service provider ("ISP"). This information may be used by ePublishing in furtherance of its legitimate interests to analyze overall trends, determine the domain from which you came, who visits the Website, to understand the needs of Website visitors, or to help us improve the ePublishing service.
Comply with Law: To comply with legal obligations, as part of our general business operations, and for other business administration purposes.
Prevent Misuse. Where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of our Terms of Use or those of our clients.
We will only use the Personal Data we collect from and about you for the purposes described in this Privacy Policy and when the law allows us to do so. We will generally use your Personal Data on the following lawful grounds:
- Where the use of your personal information is necessary for the performance of a contract we are about to enter into or have entered into with you;
- Where the use is necessary for the purposes of our legitimate interests (or those of a third party);
- Where we need to comply with a legal or regulatory obligation; or
- Where you have provided your consent, which can be withdrawn at any time.
D. Processing of Personal Data
Methods of processing: The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Personal Data may be accessible to certain types of persons in charge, involved with the operation of ePublishing (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Location: The Personal Data is processed at the Owner's operating offices and in any other locations where the parties involved in the processing are located. Our customers may transfer Personal Data outside of your country of origin.
If any such transfer takes place, you can find out more by checking the relevant sections of this document or inquire with ePublishing using the information provided in the contact section.
E. Access to Your Information
You have the following rights with respect to the Personal Data we hold about you:
(1) The right to know what Personal Data we hold about you. If you would like to know what personal data we hold about you, please contact us at privacy@ePublishing.com;
(2) The right to correct, amend, change and delete Personal Data about you. If you have questions regarding the correction, deletion, or updating of the personal data we hold about you, please contact us at privacy@ePublishing.com;
(3) The right to opt out of receiving electronic direct marketing communications from us. All electronic direct marketing communications that you may receive from us, such as e-mail messages and SMS-messages, give you an option of not receiving such communications from us in the future. If you have any additional questions about electronic direct marketing received from us, please contact us at privacy@ePublishing.com; and
(4) If you are a resident of the European Union (the "EU"), you may have the right to lodge a complaint relating to our processing of personal data about with a data protection authority ("DPA") of the EU Member State in which you reside.
F. Sharing of Personal Data With Third Parties
We share Personal Data about you with third parties for the purposes detailed below. Please note that this Policy does not apply to third parties, ePublishing is not responsible for the privacy practices of third parties, and that you should consult the respective privacy policies of third parties for more information on their practices.
To Conduct Our Business: ePublishing shares Personal Data with your consent or as necessary with third-party service providers to complete any transaction or provide any product or service requested or authorized. ePublishing also shares Personal Data with third-party service providers, suppliers, or agents working with ePublishing or on ePublishing’s behalf, such as data storage service providers, human resources service providers, marketing automation services, and data analysis companies, including Google.
Law Enforcement: ePublishing may disclose Personal Data about you to public authorities, such as law enforcement, if we believe in good faith that we are required to do so in order to comply with laws or regulations, a subpoena, a search warrant, a court or regulatory order, or other valid legal process. We may disclose Personal Data in special circumstances when we have reason to believe that disclosing Personal Data is necessary to identify, contact or bring legal action against someone who may be violating our Terms of Use or other user agreement, or to protect the safety or security of our users, the Website or the general public.
Sale of Business: We reserve the right to transfer Personal Data to a third-party such as a subsidiary, parent company, co-owner or cooperator of the Website and/or ePublishing, or a successor entity in the event of a sale, merger or other transfer of all or substantially all of our assets, provided that the third-party agrees to adhere to the terms of this Privacy Policy and ePublishing provides you with notice of the same.
For Metrics: We may share with our advertisers or publishers aggregate statistics, metrics and other reports about the performance of their ads or content in the Services such as the number of unique user views, demographics about the users who saw their ads or content, conversion rates, and date and time information.
Anonymized and Aggregated Data: We may share aggregate or de-identified information with third parties for research, administrative, marketing, analytics and other purposes, provided such information does not identify a particular individual.
G. Security & Data Integrity
ePublishing takes reasonable steps to prevent the loss, misuse and unauthorized access, disclosure, alteration and destruction of Personal Data about you. In addition, ePublishing takes appropriate security measures to safeguard Personal Data about you once we have received it. Despite these efforts to store Personal Data collected on and through the Website and otherwise by us in a secure operating environment that is not available to the public, we cannot guarantee the security of Personal Data during its transmission or its storage on our systems. Further, while we attempt to ensure the integrity and security of Personal Data, we cannot guarantee that our security measures will prevent third-parties such as so-called hackers from illegally obtaining access to Personal Data. We do not warrant or represent that Personal Data about you will be protected against, loss, misuse, or alteration by third parties.
H. Data Retention
ePublishing will not keep Personal Data longer than is necessary for the purpose or purposes for which they were collected. ePublishing will take all reasonable steps to destroy, or erase from our systems, all data which is no longer required. ePublishing retains most Personal Data for up to five (5) years from the date it is no longer used and may retain some personal data for a longer period, to comply with our legal obligations, in relation to that Personal Data.
I. Notice to Residents of the European Union
Under data privacy laws of the European Union, including without limitation the General Data Protection Regulation (“GDPR”), citizens and residents of the European Union have additional rights regarding their Personal Data. Please review this section to learn more.
Legal basis of processing of Personal Data Protected by the GDPR: The Owner may process Personal Data relating to Users if one of the following applies:
- Users have given their consent for one or more specific purposes. Note: Under some legislations, the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European Union personal data protection law;
- as necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
- as necessary for compliance with a legal obligation to which the Owner is subject;
- if the processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
- as necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
J. The Rights of Users under the GDPR
Users may exercise certain rights regarding their Personal Data processed by the Owner.
In particular, Users have the right to do the following:
- Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
- Object to processing of their Data. Users have the right to object to the processing of their Personal Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
- Access their Data. Users have the right to learn if Personal Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Personal Data undergoing processing.
- Verify and seek rectification. Users have the right to verify the accuracy of their Personal Data and ask for it to be updated or corrected.
- Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Personal Data. In this case, the Owner will not process their Personal Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Personal Data from the Owner.
- Receive their Personal Data and have it transferred to another Data Controller. Users have the right to receive their Personal Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Personal Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Details about the right to object to processing: Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights: Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.
K. Notice to California Customers - Your California Privacy Rights
Under California law, specific disclosures are required and California residents have additional rights regarding their personal information. Please review this section to learn more.
Categories of Personal Information: refer to the categories listed above.
Under the California Consumer Protection Act of 2018 (“CCPA”), a California consumer has the following special rights:
- right to request that the business disclose what personal information it collects, uses, discloses, and sells;
- right to request the deletion of their personal information collected by the business; and
- the right, at any time, to direct a business that sells personal information about the consumer to third parties not to sell the consumer’s personal information (“right to opt-out”).
Over the past twelve (12) months, the Personal Information to service providers or other parties for business purposes may have included:
Personal Identifiers, Commercial Information, Usage Data and Network Activity Information.
Based on our understanding of the term "sell" under the CCPA, we do not sell your Personal Information.
For any of the above-mentioned rights, you may designate an authorized agent to make a request on your behalf. In the request, you or your authorized agent must provide including information sufficient for us to confirm the identity of an authorized agent. We are required to verify that your agent has been properly authorized to request information on your behalf and this may take additional time to fulfill your request.
To exercise their rights and request copies of the data collected about them in the past 12 months, that their personal information collected by ePublishing be deleted or to exercise their right of opt out, California residents may make a request at privacy@ePublishing.com or use the online request form located here. Such request must include sufficient information to allow us to verify that you are the person about whom we have collected Personal Information, and describes your request in sufficient detail to allow us to understand, evaluate, and respond to it. Opt-Out Requests may be cancelled by making an Opt-In Request.
We will work to respond to your valid request within 45 days of receipt. We will not charge you a fee for making a valid request unless your valid request(s) is excessive, repetitive, or manifestly unfounded. If we determine that your valid request warrants a fee, we will notify you of the fee and explain that decision before completing your request
We will use the information you provide to make your CCPA rights requests to verify your identity, identify the personal information we may hold about you and act upon your request. We strongly recommend that you submit the email that you used when you registered with the Services. After you submit a CCPA rights requests using one of our forms, you will be required to verify access to the email address you submitted. You are required to verify your email in order for us to proceed with your CCPA rights requests. Please check your spam or junk folder in case you can't see the verification email in your inbox. If you are a California resident and have any questions regarding your CCPA rights under this Privacy Notice, please contact us at privacy@ePublishing.com.
The California Online Privacy Protection Act ("CalOPPA") requires ePublishing to disclose how it responds to Do Not Track Signals in your web browser. ePublishing does not interpret or respond to Do Not Track Signals. You may set your web browser to not accept new cookies or web beacons or disable cookies altogether. Please note that doing so may hinder your experience on the Website. Please see the Help section of your browser for instructions on managing security preferences. For information about Do Not Track, please visit: www.allaboutdnt.org. See more at: http://consumercal.org/california-online-privacy-protection-act-caloppa/#sthash.0FdRbT51.dpuf
California’s "Shine the Light" law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the business' practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes. If you wish to opt-out of our sharing of your information with third parties for the third parties’ direct marketing purposes or to find out more about your opt-out rights, please contact us.
L. Children’s Privacy
The Website is not directed to children younger than thirteen (13) years of age. We do not intend to collect Personal Data from children under 13. If you are under 13, please do not use the Website and do not send any information about yourself to us.
M. International Transfers of Personal Data
Some elements of the Website and/or our products and services may be hosted on servers located in countries outside the United States. The laws applicable to the protection of Personal Data in such countries may be different from those applicable in your home country. In particular, if you are located within the European Union (the "EU")/European Economic Area (the "EEA") or Switzerland, please note that Personal Data collected by us may be transferred outside those countries. By using the Website or our products or services, you consent to Personal Data about you being transferred outside your own country and, where applicable, outside the EU, EEA or Switzerland.
N. Changes to the Policy
From time to time we may change this Policy with or without prior notice to you. You can tell when changes have been made to the Policy by referring to the "Last Updated" legend on top of this page. Please review this Policy regularly to ensure that you are aware of any changes. If we materially change the ways in which we use and disclose Personal Data, we will post a notice on the Website and send an e-mail to our registered users. Your continued use of the Website and/or our products and services following any changes to this Policy constitutes your acceptance of any such changes made.
O. Contacting Us and Our Privacy Officer
Any comments, concerns, complaints, or questions regarding our Privacy Policy may be addressed to the ePublishing Privacy Officer ("Privacy Officer") at:
ePublishing, Inc.
27863 Network Place
Chicago, IL 60673-1278
Phone: 312-768-6800
Email: privacy@epublishing.com