Publicate Privacy Policy

    If you are a visitor to a Publicate Website, a recipient of Publicate communications, a customer of a Publicate Service or a teammate of a customer's Publicate Service then except as expressly set forth below, this Privacy Policy applies to our collection of personal information (Information) through your use of such Website or Service.

    If you are a visitor to or user of a third-party website or service (“Third-Party Property”) that utilises any Publicate communication or lead capture products (such as the Publicate lead capture popup), then any Information you submit to such Third-Party Property (including via the Publicate product) is collected under the privacy policy of the owner of such Third-Party Property, and you should contact such owner with any related requests or inquiries you may have. If you have any inquiries about this Privacy Policy, please email us at hello@publicate.it.

    At Publicate, we respect the privacy rights and data protection rights of our users and recognise the importance of protecting the Information we collect about you. Our Privacy Policy is designed to help you understand what Information we collect and how we use and share that Information. This Privacy Policy applies to our Websites and Services.

    As used in this Privacy Policy, “Publicate,” “us” and “we” refers to websites of the company Startup Seeds LTD. The “Websites” means Publicate’s websites (including without limitation https://publicate.it, https://app.publicate.it, https://publicate.it/blogs and any successor URLS, mobile or localised versions and related domains and subdomains), and the “Services” means Startup Seeds LTD’s products, applications and services, in each case in whatever format they may be offered now or in the future. The Websites and Services are collectively referred to herein as the “Offerings.”

    ‍Information We Collect

    Please see the table below for more details. 
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    ‍Legal Bases.  We process your information for these purposes in reliance on our legitimate business interests (Business Purposes), in order to enter into or perform a contract with you (Contractual Reasons), with your consent (Consent), and/or for compliance with our legal obligations (Legal Reasons).  We indicate the specific processing grounds we rely on next to each purpose listed below.We retain customer information for as long as it is necessary for the purposes set out in this Policy, unless a longer retention period is required or permitted by law (such as tax law, accounting requirements or other legal or regulatory requirements). When we have no ongoing business purpose to justify the processing of your Information, we will either delete or anonymise it, or, if this is not possible (for example, because your Information has been stored in backup archives), then we will securely store your Information and isolate it from any further processing until deletion is possible.

    What data do we collect Where do we get it from Who do we provide it to (if any) What we do with it / why we need it What is the lawful basis for use
    User’s name (first and last) Registration form/other interaction with Offerings Intercom - for support communications
    Stripe - for payment processing
    To identify who we’re entering into business with and to personalise communications Business Purposes, Contractual Reasons
    User name Registration form/other interaction with Offerings - To give you an identity to use our Offerings Business Purposes, Contractual Reasons
    Email address Registration form/other interaction with Offerings - To allow us to communicate with the user Business Purpose, Contractual Reasons
    Email address Registration form/other interaction with Offerings - To allow us to communicate with the user Business Purpose, Contractual Reasons
    Company name Registration form/other interaction with Offerings - - -
    Web links Entered into URL input on website or collected via connected services (ie Feedly, Pocket, etc) Stored on Digital Ocean database in London Used to collect content for Publications Business Purpose, Contractual Reasons
    Text content for Publications Entered into editor Stored on Digital Ocean database in London Needed to save and export Publications Business Purpose, Contractual Reasons
    Uploaded files Uploaded to editor Stored with Digital Ocean in London or AWS in Ireland Needed to allow images in Publications and file attachments Business Purpose, Contractual Reasons
    Customer usage logs API and frontend event logging Shared with analytics tools: Google Analytics and Intercom Allows us to provide user appropriate messaging and support Business Purpose, Contractual Reasons
    Payment information (credit card information, billing and mailing address, and other payment-related information ) - Sent to and stored with Stripe. We keep no copy of this data. To process transactions Contractual Reasons
    AI prompts, relevant Publication content, linked article content, and associated context such as brand settings and recent AI conversation history Shared when you choose to use optional AI writing, summarisation, or newsletter creation and editing features Sent to OpenAI for processing. Data may be processed and stored outside the UK and EEA, including in the United States To generate, summarise or revise content at your request. Use of these AI features is optional Business Purpose, Contractual Reasons
    Design files supplied for AI newsletter creation, including PDFs, images and HTML files, together with filenames and selected resource content and links Uploaded or selected by you when using optional AI newsletter creation features Sent to OpenAI for processing. Data may be processed and stored outside the UK and EEA, including in the United States To create a newsletter using the design or resources you provide. Supplying these materials for AI processing is optional Business Purpose, Contractual Reasons

    Sub-processors

    Publicate uses third-party providers to host and operate the service, process payments, deliver communications, support customers and provide specific features. The tables below explain the information shared or made available and why.

    Where a provider processes personal data on our behalf, it acts as a processor, or as a sub-processor where Publicate processes that data on behalf of a customer. Some providers also process information for their own purposes under their own terms and privacy notices.

    AI features are optional. When you request an AI feature, the relevant inputs and context described below are sent to the AI provider. AI newsletter creation and editing may include generating images through Google Gemini. You can create and edit Publications without using AI. Content you supply can contain personal information, which will be included in the material processed for that feature.

    Services used to operate Publicate

    The information a provider receives depends on the features you use and the information included in your account or content.

    Provider / service Information shared or made available Why we use it When it is used
    DigitalOcean Account and workspace records, authentication data, Publications, uploaded and generated files, subscriber and contact records, comments, survey responses, campaign information and service logs. Host and operate Publicate, store content and records, and make Publications and files available. Core hosting and storage.
    Cloudflare Custom domain names and certificate-validation information; network request details and content where traffic is routed through Cloudflare. Configure HTTPS and deliver Publications and images through custom domains. Custom-domain setup and use of domains served through Cloudflare.
    SparkPost Sender and recipient names and email addresses; email subjects and content; verification, password-reset and invitation links; subscriber personalisation fields and identifiers; sending-domain details and delivery information. Deliver account emails, invitations and notifications, and send and report on campaigns through Publicate Send. Account communications and use of Publicate Send.
    Stripe Customer name and email, billing and payment details, account/workspace identifiers, subscription details and transaction information. Payment details are collected through Stripe's payment forms. Process payments, administer subscriptions and credits, and manage billing. Billing and payment features.
    Intercom Name, email address, user identifiers, account and subscription attributes, product-usage events, browser/session information, and messages or attachments you provide to support. Provide customer support, onboarding and relevant service communications. Account activity and support interactions.
    Google Analytics User identifiers, name and email address, page URLs and titles, product-usage and subscription events, and browser, device and session information. Understand use of Publicate, measure feature adoption and improve the service. When analytics runs in the app or through configured server-side event reporting.
    Hotjar / Contentsquare Pages visited, browser/device and session information, clicks, scrolling and other interactions, and page content included in recordings or heatmaps where enabled, subject to masking settings. Understand usability problems and improve the user experience. When usage recording or analysis is active.
    Sentry Error reports, diagnostic details and request context, which may include IP addresses, request URLs, headers, account identifiers and personal data contained in an error or request. Detect and diagnose application errors and improve reliability. When the server reports errors.
    Better Stack (Logtail) Server and request logs, which may include URLs, headers, network details, user/workspace identifiers, operational events and information included in diagnostic messages. Monitor service operation, investigate incidents and troubleshoot failures. Server logging when the logging service is enabled.
    OpenAI — Publication and writing tools AI prompts and instructions; relevant Publication text, structure and identifiers; brand settings; recent AI conversation history; linked article content; selected resource content and URLs; and design files, filenames and extracted content supplied for AI processing, including PDFs, images and HTML designs. Generate, summarise, rewrite and edit text and newsletter designs. Only when you request the relevant optional AI feature.
    OpenAI — optional review-writing assistance A summary of your use of Publicate, including approximate customer tenure and newsletter volume, features and integrations used, team context and role, and the recently used feature relevant to the request. Suggest a review that you can edit and choose whether to publish. Only when you choose "Help me write a review".
    Google Gemini API Image-generation prompts, including descriptions derived from your newsletter brief or requested changes, and image-format settings. Generate images and backgrounds for Publications. Optional AI image generation, including images generated as part of an AI-created or AI-edited newsletter.
    Google reCAPTCHA Device, browser, network and interaction information used for security checks, together with verification tokens and the action being assessed. Detect automated sign-ups, spam and abuse. During protected sign-up checks.
    Embedly URLs you add or use, including information in those URLs, and the page content and metadata fetched from them. Import linked content, create previews and retrieve article content used by summarisation features. Content imports, previews and relevant article-summary requests.
    ScrapingBee URLs submitted for import and the page content, images or screenshots retrieved from those URLs. Retrieve content and images for the content library when the import process uses this provider. Content imports and associated background processing.
    Restpack A Publication access URL and the text, images and other content rendered from it, together with the generated PDF. Convert a Publication into a downloadable PDF. When you export a Publication as a PDF.
    Webflow Titles, descriptions, identifiers, categories, screenshot URLs and preview links for Publications designated as public templates. Publish and maintain the public template catalogue. When Publicate synchronises public templates to its website.

    Connected services

    The following services receive information when you connect or use them, or when your organisation configures them for your account. These connections may continue to exchange information in the background while enabled. Their role depends on your relationship with the provider; they are not necessarily Publicate's sub-processors.

    Provider / service Information shared or made available Why we use it When it is used
    Google — sign-in, Gmail and Google Contacts Authorisation requests and tokens; profile information exchanged for sign-in; contact and contact-group requests; and sender/recipient addresses, subject lines and Publication content when creating drafts or sending email. Sign in with Google, select contacts and create or send emails through your connected Google account. When you use Google sign-in or connect and use Gmail.
    Microsoft — sign-in, Outlook and Microsoft 365 Authorisation requests and tokens; profile information exchanged for sign-in; contact and directory/group requests; sender/recipient addresses, subjects and Publication content used in Outlook. Sign in with Microsoft, select contacts and groups, and insert or send Publications through Outlook. When you use Microsoft sign-in, connect Outlook or use the Outlook add-in.
    Okta / your organisation's identity provider Sign-in and authorisation requests, authentication tokens and profile information exchanged to identify your account, such as name, email address and account identifier. Provide organisation-managed single sign-on. Where your organisation's sign-in connection is configured.
    Mailchimp Authorisation tokens and account information needed for the connection, plus the title and HTML content of Publications you export, including embedded links and image references. Create email templates in your connected Mailchimp account. When you connect Mailchimp and export a Publication.
    HubSpot Authorisation tokens and account information needed for the connection, plus Publication titles and HTML content, including embedded links and image references. Create email templates in your connected HubSpot account. When you connect HubSpot and export a Publication.
    Canva Authorisation tokens, selected design identifiers, and requests to list, retrieve and export your designs. Import designs and images from your connected Canva account. When you connect Canva and use the integration.
    Feedly Authorisation tokens, selected board/feed identifiers and requests for saved or recent content. Import content from your connected Feedly account into Publicate. When you connect Feedly, including subsequent scheduled imports.
    Zapier and other applications you authorise Connection tokens, account and workspace identifiers, email address, role and workspace label, and Publication or resource data exchanged through the actions and access you authorise. Run connected workflows, import resources and export Publications. When you authorise and use a connected application.

    Content, browser resources and other third parties

    These services can receive information when Publicate retrieves external content or your browser loads it. Some operate independently rather than processing information solely on Publicate's behalf.

    Provider / service Information shared or made available Why we use it When it is used
    GIPHY GIF or sticker search terms and content requests; network and browser information when GIPHY-hosted media is loaded. Find and display GIFs and stickers for Publications. When the relevant media library or GIPHY content is loaded.
    Pixabay Image search terms and content requests; network and browser information when Pixabay-hosted images or previews are loaded. Find and display stock images for Publications. When the image library or Pixabay-hosted content is used.
    Websites, RSS publishers and other content hosts you select Requests for the URLs, feeds, images or other content you add or view, including information contained in those URLs and network request details. Import, refresh and display content selected for your library or Publications. When Publicate or your browser retrieves the selected external content.

    Some providers process information internationally, which may include processing outside the United Kingdom and the European Economic Area. The applicable locations depend on the service and the provider's arrangements.

    Marketing and Product Communications
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    We may send you useful product-related communications, including feature updates, educational tips, and best practices to help you get the most out of Publicate. We rely on legitimate interest as a legal basis for processing these emails, as outlined in our [Legitimate Interest Assessment (LIA)](https://publicate.it/lia). You can opt out at any time by clicking "Unsubscribe" in any email.
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    ‍Sharing Your Information with Third Parties

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    We may share your personal information with third parties in the following circumstances:

         - We may share your personal information with our parent companies, subsidiaries and affiliates;
         - We may share your personal information with third-party service providers to permit such parties to provide services that help us with our business activities, which may include assisting us with marketing, advertising our product/service offerings, or providing, maintaining and improving the features and functionality of the Offerings, among other things. For example, we may provide personal information to our service providers for direct emailing of our newsletters or notifications of our product/service offerings. The data shared can include name, job title, email address, company information. All third parties are engaged under contract and obliged to meet appropriate security requirements and comply with all applicable legislation;
         - We may share your personal information when we have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process or enforceable governmental request, (b) enforce a Customer Agreement, including investigation of potential violations thereof, or (c) protect against imminent harm to our rights, property or safety, or that of our users or the public as required or permitted by law;
         - We may share your personal information with third parties (including our service providers and government entities) to detect, prevent, or otherwise address fraud or security or technical issues;;
         - We may share your Payment Information to process your payments, as further described below;
         - We may share and/or transfer your personal information if we become involved in a merger, acquisition, bankruptcy, or any form of sale of some or all of our assets; and
         - We may share your personal information with a third party if we have your consent to do so;
         - We may share publicly available information with our third party messenger service, Intercom, Inc (“Intercom”)  in order to allow you to interact with Intercom, including without limitation social media information, profile information, gender, company, job titles, photos, physical addresses, and website URLs based on the email addresses input into the Customer Support Messenger, you can find out more about Intercom privacy terms and how they handle this data at https://www.intercom.com/terms-and-policies#privacy

    We may also share aggregated or anonymised information with third parties for other purposes. Such information does not identify you individually, but may include usage, viewing and technical information such as the types of Offerings our customers and users generally use, the configuration of their computers, and performance metrics related to the use of Offerings which we collected through our technology.  In such circumstances we will not disclose any information which can identify you personally. 

    Access to Google Data
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    You can optionally connect your Google account in two ways:

    1. Log in with Google (optional)
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    When you log in with Google, we request access to:

    ‍a) Your Google email address — used to associate your Google account with your Publicate profile.
    b) Your basic profile information — we use your name to populate your Publicate profile.

    ‍2. Send via your Gmail account (optional)

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    If you choose to send emails through your Gmail account from within Publicate, we require the following permissions:

    ‍a) Your profile information — used to display your profile photo in the email send window.
    b) Gmail “Send” permission — allows Publicate to send emails on your behalf through your Gmail account.

    You may also optionally grant:
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    ‍c) Access to your contacts — used only to auto-complete recipient addresses when composing an email in Publicate. We do not store your contact data.

    ‍Payment Information
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    When you make a purchase on the Offerings, any credit card information you provide as part of your Payment Information is collected and processed directly by our payment processor Stripe through their Stripe Checkout service. We never receive or store your full credit card information. Stripe commits to complying with the Payment Card Industry Data Security Standard (PCI-DSS) and using industry standard security. Stripe may use your Payment Information in accordance with their own Privacy Policy here:   stripe.com

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    Other Access to or Disclosure of Your Information
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    The Offerings may also contain links to third party websites. This Privacy Policy applies solely to information collected by us. Even if the third party is affiliated with us through a business partnership or otherwise, we are not responsible for the privacy practices of such third party. We encourage you to familiarise yourself with the privacy policies of such third parties to determine how they handle any information they separately collect from you. Please be aware that we do not warn you when you choose to click through to another website when using the Offerings.

    The Websites contain features that enable you to post content, reviews, comments or other content that is publicly viewable. You should be aware that any personal information you submit as part of those posts can be read, collected, or used by other visitors to the Websites, and could be used to send you unsolicited messages. We are not responsible for the personal information you choose to publicly post on the Websites.

    ‍Your Rights and Choices
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    You will be required to give Consent to certain processing activities before we can process your information.  Where applicable, we will seek Consent from you when you first submit information to or through the Offerings.If you have previously given your Consent you may freely withdraw such Consent at any time.  You can do this by emailing hello@publicate.it or, where applicable, clicking the ‘Unsubscribe’ button that appears in mailing list communications.If you withdraw your Consent, and if we do not have another legal basis for processing your information, then we will stop processing your information.  If we do have another legal basis for processing your Information, then we may continue to do so subject to your legal rights.

    ‍Please note that if we need to process your Information in order for you to use the Offerings and you object or do not provide Consent to us processing your Information, you accept that the Offerings will no longer be available to you.

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    If you have given Consent to marketing we may contact you about our products, services, promotions and special offers.  If you no longer wish to receive such Information, you can withdraw your Consent at any time by sending an email to hello@publicate.it or unsubscribing from the communications.If you have given Consent, we may share your Information with carefully selected third party organisations and business partners and they may contact you directly.  If you would prefer to no longer receive direct marketing communications from third parties and partners after previously giving your Consent, please contact those third parties and partners directly to withdraw the Consent.Where you opt out of receiving marketing messages, this will not apply to personal data provided to us in connection with your purchase of a product or service or your involvement in other related transactions.

    ‍How We Respond to Do Not Track Signals.
    Your Web browser may have a “do not track” setting which, when enabled, causes your browser to send a do not track HTTP header file or “signal” to each site you visit. At present, the Offerings do not respond to this type of signal.

    ‍Data Subject Rights.
    You have certain rights in relation to the Information that we hold about you.  Details of these rights and how to exercise them are set out below.  Please note that we will require evidence of your identity before we are able to respond to any requests.  This is a security measure to ensure that your Information is not disclosed to a person who does not have the right to receive it.  We may also contact you to ask you for further Information in relation to your request to speed up our response.  To exercise or discuss any of your rights, please contact us via hello@publicate.it.

         - Right of Access.  You have the right at any time to ask us for a copy of the Information that we hold about you and to check that we are lawfully processing it.  Where we have good reason, and where data protection law permits, we can refuse your request for a copy of your Information, or certain elements of the request.  If we refuse your request or any element of it, we will provide you with our reason(s) for doing so.
         - Right of Correction or Completion.  If Information we hold about you is not accurate or is out of date and requires amendment or correction, you have a right to have the data rectified or completed.
         - Right of Erasure.  In certain circumstances, you have the right to request that the Information we hold about you is erased (for example, if the Information is no longer necessary for the purposes for which it was collected or processed or our processing of the Information is based only on your Consent and there are no other legal grounds on which we may process the Information).
         - Right to Object to or Restrict Processing.  In certain circumstances, you have the right to object to our processing of your Information (for example, if we are processing your Information on the basis of our legitimate interests but there are no longer any compelling legitimate grounds to justify our processing overriding your rights and interests).You may also have the right to restrict our use of your Information, for example during a period in which we are verifying the accuracy of your Information in circumstances where you have challenged the accuracy of that Information.
         - Right of Data Portability.  In certain instances, you have a right to receive the Information that we hold about you (or a portion thereof) in a structured, commonly used and machine-readable format.In such circumstances, you can ask us to transmit your Information to you or directly to a third-party organisation on your behalf.While we are happy for such requests to be made, we are not able to guarantee technical compatibility with a third-party organisation’s systems.  We are also unable to comply with requests that relate to personal Information of others without their consent.If we are relying on Consent to process your Information, you have the right to withdraw your Consent at any time.  Please note however that this will not affect the lawfulness of the processing that occurred before the withdrawal of such Consent..

    Keeping your Personal Information Safe

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    We have implemented appropriate technical and organisational security measures designed to protect the security of any Information we process.  For example, we store your personal data on secure servers and company data is stored on separate secure encrypted disks when not in use.  We have procedures in place to deal with any suspected data security breach. We will notify you and any applicable supervisory body of a suspected data breach where we are legally required to do so.However, please also remember that we cannot guarantee that the Internet itself is 100% secure.  Although we will use our reasonable endeavours to protect your Information, we cannot guarantee the security or integrity of personal Information that is transferred from you or to you via the Internet. Transmission of personal Information to and from Publicate is therefore at your own risk.  You should only access our services within a secure environment.


    Changes to the Privacy Policy

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    We reserve the right to change our Privacy Policy at any time. If we make material changes to this policy, we will notify you by email or through notice on the Offerings.

    ‍No Children Under Age 16
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    The Offerings are not intended for use by anyone under the age of 16, nor does Publicate knowingly collect or solicit personal information from anyone under the age of 16. If you are under 16, you may not attempt to register for the Offerings or send any information about yourself to us, including your name, address, telephone number, or email address. In the event that we confirm that we have collected personal information from someone under the age of 16 without verification of parental consent, we will delete that information promptly. If you are a parent or legal guardian of a child under 16 and believe that we might have any information from or about such child, please contact us at the email or mailing address provided at the end of this Privacy Policy.

    ‍Your California Privacy Rights and Disclosures

    California Shine the Light Law
    . If you are a California resident and we disclose your personally identifiable information to third parties for such third parties’ direct marketing purposes, California’s Shine the Light Law (CA Civil Code Section 1798.83) allows you to request certain information from us about such disclosures. To make a request under the Shine the Light Law, please contact us at hello@publicate.it. Please note that under California law, businesses are not required to respond to such requests more than once during any calendar year.

    ‍California Minors. At any time, you can delete or remove your posts using the same deletion or removal procedures described in Section 8 (Accessing and Updating Your Personal Information) above, or otherwise through the Offerings. If you have questions about how to remove your posts or if you would like additional assistance with deletion you can contact our support team at hello@publicate.it. Although we offer deletion capability for our Offerings, you should be aware that the removal of posts may not ensure complete or comprehensive removal of that content or information posted through the Offerings.

    ‍Location of data storage and transfers

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    The host servers on which Publicate processes and stores its databases are located exclusively within the UK and Ireland. Whenever we transfer your Information outside of the UK, we will take all reasonably practicable measures to protect your Information in accordance with this Policy and applicable laws.  To the extent that any transfer requires approved safeguards to be in place we will only transfer your Information to countries that have been deemed to provide an adequate level of protection for personal data.  Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.  Please contact us if you want further information on the specific mechanism(s) used by us when transferring your personal data out of the UK.

    Publicate will inform you immediately, to the extent we are legally authorised to do so, in case of any application or order originating from an administrative or judicial authority relating to your Information.

    ‍Publicate Gmail addon

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    Our gmail addon enables us to add our Publications directly to your gmail draft. This requires us to gain limited access to your gmail account. Specifically the following:Manage drafts and send emails when you interact with the add-onWe don't retain any information on our servers and simply use access to your draft email to enable us to add the HTML code for your Publication.

    ‍Contact Us

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    You have the right to make a complaint at any time to the Information Commissioner’s Office (the ICO), the UK supervisory authority for data protection issues (https://ico.org.uk/concerns).  We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

    We welcome your feedback and questions on this Policy. If you have questions or need to contact us about this Privacy Policy, please email us at hello@publicate.it

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