Last updated 30 May 2021,
This privacy policy (“ Policy ”) describes how Publisto Ltd. , and their related companies (“ Company ”) collect, use and share personal information of consumer users of this website, www.publisto.com (the “ Site ”). This Policy also applies to any of our other websites that post this Policy. This Policy does not apply to websites that post different policy statements.

Data protection law
The EU General Data Protection Regulation (GDPR) that came into force in May 2018 describes how organisations — including Publisto — must collect, handle and store personal information.
These rules apply regardless of whether data is stored electronically, on paper or on other materials.
To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully.

GDPR is underpinned by eight important principles. These say that personal data must:

• Be processed fairly and lawfully.
• Be obtained only for specific, lawful purposes.
• Be adequate, relevant and not excessive.
• Be accurate and kept up to date.
• Not be held for any longer than necessary.
• Processed in accordance with the rights of data subjects.
• Be protected in appropriate ways.
• Not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection.

People, risks and responsibilities

Policy scope
This policy applies to:

• All office areas of Publisto.
• All staff and volunteers of Publisto.
• All contractors, suppliers and other people working on behalf of Publisto on data.

It applies to all the data the company holds relating to identifiable individuals, even if that information technically falls outside of the GDPR. This can include:

• Names of individuals.
• Postal addresses.
• Email addresses.
• Telephone numbers.
• And, any other information relating to individuals..

Data protection risks
This policy helps to protect Publisto from some very real data security risks, including:

• Breaches of confidentiality: information being given out inappropriately.
• Failing to offer choice: all individuals should be free to choose how the company uses the data relating to them.
• Reputational damage: the company might suffer if hackers successfully gain access to sensitive data.

Responsibilities
Everyone who works for or with Publisto has a certain degree of responsibility for ensuring data is collected, stored and handled appropriately.
Each team that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles.

General staff guidelines

• The only people able to access data covered by this policy should be those who need it for their work.
• Data should not be shared informally. When access to confidential information is required, employees can request it from their line managers.
• Publisto has provided training to all employees to help them understand their responsibilities when handling data.
• Employees should keep all data secure, by taking sensible precautions and following the guidelines below.
• In particular, strong passwords must be used and they should never be shared.
• Personal data should not be disclosed to unauthorised people, either within the company or externally.
• Data should be regularly reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and disposed of.
• Employees should request help from their line manager or the data protection officer if they are unsure about any aspect of data protection.

Data storage

When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it.

These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:

• When not required, the paper or files should be kept in a locked drawer or filing cabinet.
• Employees should make sure paper and printouts are not left where unauthorised people might see them, like on a printer.
• Data printouts should be shredded and disposed of securely when no longer required.

When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:

• Data should be protected by strong passwords that are changed regularly and never shared between employees.
• If data is stored on removable media (like a USB drive), these should be kept locked away securely when not used.
• Data should only be stored on designated drives and servers, and should only be uploaded to approved cloud computing services.
• Servers containing personal data should be sited in a secure location, away from general office space.
• Data should be backed up frequently. These backups should be tested regularly, in line with the company’s standard backup procedures.
• Data should never be saved directly to laptops or other mobile devices like tablets or smartphones.
• All servers and computers containing data should be protected by an approved security software and a firewall.

Data use

Personal data has no value for Publisto unless it is used for business. However, when personal data is accessed and used it may be at the greatest risk of loss, corruption or theft:

• When working with personal data, employees should ensure the screens of their computers are always locked when left unattended.
• Personal data should not be shared informally. In particular, it should never be sent by email, since it is an insecure form of communication.
• Data must be encrypted before it is transferred electronically. The Head of Engineering can explain how to send data to authorised external contacts.
• Personal data should never be transferred outside the European Union.
• Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data.

Data accuracy

The law requires Publisto to take reasonable steps to ensure data is kept accurate and up to date.

• Data will be held in as few places as necessary. Staff should not create any unnecessary additional data sets.
• Staff should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call.
• Publisto will make it easy for data subjects to update the information Publisto holds about them, complying to all access requests.
• Data should be updated or erased as inaccuracies are discovered.
• It is the marketing manager’s responsibility to ensure marketing databases are checked against industry suppression files every six months.

Subject access requests

All individuals who are the subject of personal data held by Publisto are entitled to:

• Ask what nformation the company holds about them and why.
• Request to gain access to it.
• Be informed of how to keep it up to date.
• Be informed of how the company is complying with its data protection obligations.

If an individual contacts the company requesting this information, this is called a subject access request.
Subject access requests from individuals should be made by email, addressed to the data controller at policy@publisto.com. The data controller can supply a standard request form, although individuals do not have to use this.
Individuals will not be charged for subject access requests. The data controller will try and provide the relevant data within 14 days.
The data controller will always verify the identity of anyone making a subject access request before handing over any information.

Disclosing data for other reasons

In certain circumstances, the General Data Protection Regulation and national privacy acts allow personal data to be disclosed to law enforcement agencies without the consent of the data subject.

Under these circumstances, Publisto will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisers where necessary.