In short: We collect the information you give us in our forms and when you work with us as a publisher, plus basic server logs. We use it to review applications, run our service, pay publishers and keep our systems secure. Our website shows no ads and uses no tracking or advertising cookies. We do not sell your personal information. You can ask to access, correct or delete your information by emailing legal@publisherzera.com.
1. Who we are
PublisherZera is a monetization and ad-operations service for independent digital publishers. We review publishers who apply, help them set up and manage advertising on their websites, provide reporting, brand safety and invalid-traffic protection, and pay publishers their share of ad revenue.
The service is operated by PublisherZera LLC (pending formation), a limited liability company organized in New Mexico, USA, with its address at Business address (US mailing address to be added). In this policy, "PublisherZera", "we", "us" and "our" mean PublisherZera LLC (pending formation). "You" means any person whose information we handle, including website visitors, applicants and publishers.
For personal information covered by this policy, we act as the "controller" (under EU and UK data protection law) or the "business" (under California law). This means we decide why and how the information is used.
2. What this policy covers
This policy explains how we handle personal information when you:
- visit our website at https://publisherzera.com;
- send us a publisher application or a contact form;
- email us or communicate with us in other ways; and
- work with us as a publisher (or as a contact person for a publisher).
This policy does not cover how publishers handle the personal information of visitors to their own websites. Each publisher is responsible for its own website and its own privacy policy. See section 16.
This policy should be read together with our Website Terms, our Publisher Terms and our Cookie Policy.
3. Information we collect
Information you give us through our website
Publisher application. When you apply on our application page, we collect your name, email address, company name (optional), website URL, monthly pageviews range, top traffic countries, content category, current ad setup, traffic sources, any message you write, and your confirmation of the agreement checkbox.
Contact form. When you use our contact page, we collect your name, email address, the topic you choose and your message.
Form submissions are sent to our team by email. A backup copy is stored on our web server.
Information we collect when you work with us as a publisher
If we accept your application and you use our service, we also collect:
- Contact and identity details: names, email addresses, phone numbers, business name and address of you and your contact persons.
- Payment details: bank account details, PayPal or Payoneer account details, and payment history.
- Tax information: tax forms (for example, IRS Form W-8BEN, W-8BEN-E or W-9), tax identification numbers and country of tax residence.
- Website information: the websites you manage with us, their content, traffic sources, ad setup and account access details you choose to share with us.
- Ad performance data: impressions, clicks, revenue, fill rates, invalid-traffic signals and similar reports from ad platforms and demand partners. This data is mostly aggregated, but it is linked to your account.
- Communications: emails, support requests and other messages between you and us.
Information collected automatically
Like most websites, our web server keeps standard access logs. These logs record your IP address, browser user agent (browser and device type), the pages you request, the date and time of the request, and the referring page. We use these logs for security and troubleshooting. We keep them for up to 90 days, unless we need them longer to investigate a security issue.
Our website does not use advertising or tracking cookies. It stores one small item in your browser to remember that you dismissed the cookie notice. See our Cookie Policy for details.
Information from other sources
We may receive information about publishers from ad platforms and demand partners (for example, performance reports and invalid-traffic notices), from payment providers (for example, payment confirmations) and from public sources (for example, publicly available information about your website).
Sensitive information
We do not ask for sensitive personal information such as health data, religious beliefs or biometric data. Please do not include it in forms or messages. Tax identification numbers and financial account details are used only to pay you and meet legal obligations.
4. How we use information and our legal bases
The table below explains what we use information for. It also shows the "legal basis" we rely on under the EU General Data Protection Regulation (GDPR) and the UK GDPR. If you are not in the EEA, UK or Switzerland, the legal basis column is for information only.
| Category of information | Purpose | Legal basis (GDPR / UK GDPR) |
|---|---|---|
| Application form data | To review your application, check whether your website meets our requirements, and reply to you | Steps taken at your request before entering into a contract |
| Contact form data and emails | To answer your questions and keep a record of our communications | Legitimate interests (responding to enquiries and running our business); contract, where the message relates to our service |
| Publisher contact and website information | To set up and manage ads on your website, provide reporting and support, and deliver the service | Performance of a contract |
| Ad performance and invalid-traffic data | To provide reports, calculate revenue, protect brand safety and detect invalid traffic or fraud | Performance of a contract; legitimate interests (protecting advertisers, publishers and our service) |
| Payment details | To pay publishers their share of ad revenue | Performance of a contract |
| Tax forms and payment records | To meet tax, accounting and reporting duties | Legal obligation |
| Server access logs | To keep our website secure, prevent abuse and fix technical problems | Legitimate interests (security and reliability) |
| Business communications | To send service notices and important updates about our terms or policies | Performance of a contract; legitimate interests |
| Any information, as needed | To comply with law, respond to lawful requests, enforce our terms and defend legal claims | Legal obligation; legitimate interests |
| Optional information or activities | Anything else we ask your permission for | Consent (you may withdraw it at any time) |
When we rely on legitimate interests, we balance our interests against your rights. You can object to this processing (see section 11).
We do not use automated decision-making that produces legal or similarly significant effects on you without human involvement. Our team reviews every application.
We do not send marketing emails without a lawful basis. If we send you marketing messages, you can unsubscribe at any time.
5. How we share information
We share personal information only when needed and only with:
- Service providers that work for us, such as our web hosting provider, email providers, payment providers (such as banks, PayPal or Payoneer), and accounting and tax advisers. They may use the information only to provide services to us.
- Ad platforms and demand partners that we need to deliver the service, such as Google Ad Manager. For example, we may share your website details and business information so ads can be served on your website, and we receive performance data from them. These partners handle information under their own privacy policies.
- Legal authorities and others when the law requires it, or when we believe in good faith that disclosure is needed to protect rights, safety or property, to prevent fraud, or to respond to a valid legal request.
- Professional advisers, such as lawyers and auditors, under a duty of confidentiality.
- A buyer or successor if we are involved in a merger, sale of assets or reorganisation. We will tell you if this happens and your information becomes subject to a different policy.
We do not sell your personal information. We do not "share" it for cross-context behavioural advertising, as those terms are defined under California law.
6. Cookies and similar technologies
Our website does not show ads and does not use advertising or tracking cookies. It does not set any cookies itself. It stores one item in your browser's local storage (named pz_cookie_ok) to remember that you dismissed the cookie notice. Our fonts are hosted on our own server, so no font provider receives your IP address when you visit.
We may in future add privacy-friendly analytics that counts visits in aggregate without cookies. If we do, we will update our policies first. We will not use any non-essential cookies without updating our policies, and we will ask for your consent where the law requires it. Read our Cookie Policy for full details.
7. International data transfers
We are based in the United States. Your information is processed in the United States and in other countries where our service providers and partners operate. These countries may have data protection laws that are different from the laws of your country.
When we transfer personal information from the EEA, the UK or Switzerland to other countries, we use appropriate safeguards where required. These include the European Commission's Standard Contractual Clauses (and the UK Addendum or Swiss equivalents), or a recognised adequacy decision or framework. You can ask for more information about these safeguards by contacting legal@publisherzera.com.
8. How long we keep information
We keep personal information only as long as we need it for the purposes described in this policy, or as long as the law requires.
| Information | How long we keep it |
|---|---|
| Applications that are not accepted | Up to 24 months after the decision, so we can handle re-applications and questions |
| Publisher account information | For the duration of our relationship, and then as long as needed for the purposes below |
| Payment records and tax forms | For the duration of our relationship, plus the period required for tax and accounting (typically up to 7 years) |
| Contact form messages and general emails | Up to 24 months |
| Server access logs | Up to 90 days, unless needed longer for a security investigation |
We may keep information longer if we need it to resolve a dispute, enforce our agreements or meet a legal requirement. When we no longer need information, we delete it or make it anonymous.
9. How we protect information
We use reasonable technical and organisational measures to protect personal information. These include encrypted connections (HTTPS), access controls that limit who can see information, and careful choice of service providers.
However, no method of sending or storing data is 100% secure. We cannot guarantee absolute security. If you believe your information with us is no longer safe, please contact us right away at legal@publisherzera.com. If a data breach affects your rights, we will notify you and the authorities as the law requires.
10. Your privacy rights
Depending on where you live, you may have rights over your personal information. We explain these rights in the next sections. We will not treat you differently for using your rights.
Even if no specific law applies to you, you can still ask us to access, correct or delete your information. We will try to help where we reasonably can.
11. Rights in the EEA, UK and Switzerland
If the GDPR, the UK GDPR or the Swiss data protection law applies to you, you have the right to:
- Access: ask for a copy of your personal information and details about how we use it.
- Rectification: ask us to correct information that is wrong or incomplete.
- Erasure: ask us to delete your information in certain cases.
- Restriction: ask us to limit how we use your information in certain cases.
- Portability: ask for information you gave us in a structured, commonly used, machine-readable format, or ask us to send it to another organisation.
- Objection: object to processing based on our legitimate interests. You can always object to direct marketing.
- Withdraw consent: where we rely on your consent, you can withdraw it at any time. This does not affect processing that happened before.
- Complain: lodge a complaint with your local data protection supervisory authority. In the UK this is the Information Commissioner's Office (ICO). We would appreciate the chance to resolve your concern first.
Some rights have limits. For example, we may need to keep payment and tax records to meet legal duties even if you ask us to delete them. If we cannot fully meet your request, we will explain why.
We will respond within one month. If your request is complex, we may extend this by up to two more months and will tell you if we do.
12. Notice for California and other US states
This section applies to residents of California under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (together, "CCPA"). It also applies, where relevant, to residents of other US states with similar privacy laws.
Notice at collection
In the past 12 months, we have collected the following categories of personal information. We collect them for the purposes described in section 4 and keep them for the periods in section 8.
| CCPA category | Examples | Disclosed for a business purpose to |
|---|---|---|
| Identifiers | Name, email address, postal address, IP address, account details | Hosting and email providers; ad platforms and demand partners; payment providers |
| Customer records (Cal. Civ. Code 1798.80(e)) | Name, address, phone number, bank or payment account details | Payment providers; accounting and tax advisers |
| Commercial information | Service history, revenue earned, payments made | Payment providers; accounting and tax advisers |
| Internet or other electronic network activity | Server log data such as browser type, pages viewed and referrer | Hosting provider |
| Professional or employment-related information | Company name, your role, website and business details | Ad platforms and demand partners |
| Sensitive personal information | Tax identification numbers and financial account details, used only to pay you and meet legal duties | Payment providers; accounting and tax advisers; authorities where required |
Sources: directly from you, automatically from your browser, from ad platforms and demand partners, from payment providers and from public sources.
Sale and sharing: we do not sell personal information and we do not share it for cross-context behavioural advertising. We have not done so in the past 12 months. We do not knowingly sell or share the personal information of consumers under 16.
Sensitive personal information: we use it only for purposes allowed by the CCPA, such as providing the service you asked for and meeting legal duties. We do not use it to infer characteristics about you. For this reason we do not offer a separate "limit the use" link.
Your California rights
- Right to know: ask what personal information we collected, the sources, the purposes, and the categories of third parties we disclosed it to, and ask for a copy of the specific pieces of information.
- Right to delete: ask us to delete personal information we collected from you, subject to legal exceptions.
- Right to correct: ask us to correct inaccurate personal information.
- Right to opt out of sale or sharing: we do not sell or share personal information, so there is nothing to opt out of. If this changes, we will update this policy and provide an opt-out method.
- Right to limit use of sensitive personal information: we do not use sensitive personal information for purposes that would trigger this right.
- Right to non-discrimination: we will not deny you service, charge you a different price or give you a lower quality of service because you used your rights.
We will confirm receipt of your request within 10 business days and respond within 45 days. If we need more time, we may extend this by up to another 45 days and will tell you why.
Other US states
Residents of other US states, such as Colorado, Connecticut, Virginia, Utah, Texas, Oregon and others with consumer privacy laws, may have similar rights. These can include rights to access, correct, delete and get a copy of your information, and to opt out of targeted advertising, sale or certain profiling. We do not sell personal information, use it for targeted advertising or use it for profiling with legal or similarly significant effects. If we deny your request, you may appeal by replying to our decision or emailing legal@publisherzera.com with the subject "Privacy appeal". We will respond to your appeal within the time the law requires. If you are not satisfied, you may contact your state Attorney General.
13. How to exercise your rights
To make a request, email legal@publisherzera.com. Please tell us:
- which right you want to use;
- your name and the email address you used with us; and
- where you live, so we know which laws apply.
Verification. To protect your information, we need to confirm your identity before we act on a request. We will usually do this by matching the information you give us with information we already hold, or by asking you to confirm from the email address we have on file. For requests about sensitive information, we may ask for more details. We will only use this information to verify your request.
Authorised agents. You may ask someone else to make a request for you. We may ask the agent for signed written permission from you, and we may still ask you to verify your identity directly with us, unless the agent holds a valid power of attorney.
Timing. We respond within the time required by law. This is generally one month under the GDPR and UK GDPR and 45 days under the CCPA, with extensions allowed in some cases.
Cost. Requests are free. We may charge a reasonable fee, or refuse a request, if it is clearly unfounded, excessive or repeated, as the law allows.
14. EEA and UK representative
If you are in the European Economic Area, the United Kingdom or Switzerland and have a question or request about your personal information, please contact us at legal@publisherzera.com. We will update this section with the details of any representative we appoint.
15. Children
Our website and service are for businesses and adults. They are not directed to children under 16. We do not knowingly collect personal information from children under 16. If you believe a child has given us personal information, please contact legal@publisherzera.com and we will delete it.
16. Publisher websites and third-party sites
We help publishers show ads on their websites. On those websites, ad platforms and demand partners may collect information from visitors, for example through cookies. Each publisher is responsible for its own privacy policy, for telling its visitors how their information is used, and for getting consent where the law requires it. Visitors to a publisher's website should read that website's privacy policy. Our Cookie Policy explains more.
Our website may also link to other websites. We are not responsible for the privacy practices of other websites. Please read their privacy policies.
17. Changes to this policy
We may update this policy from time to time, for example when our service changes or the law changes. We will post the new version on this page and update the "Effective" date at the top. If changes are significant, we will give you more notice, such as by email to publishers.
18. Contact us
If you have questions about this policy or how we handle personal information, please contact us:
- Privacy and legal requests: legal@publisherzera.com
- General support: support@publisherzera.com
- Post: PublisherZera LLC (pending formation), Business address (US mailing address to be added)