Egmont Publishing UK – Privacy Notice
- About Us
- Information we may collect about you
- How we use information about you and recipients of your information
- Who we might share your information with
- How we look after your information and how long we keep it for
- Transfer of personal data
- International transfers of your information
- Your rights to information we hold about you
- Changes to this Privacy Notice
1.2 We are the data controller which means that we are responsible for deciding how your data is gathered, used and protected. We take your rights and our responsibility seriously and have set out further details in the privacy Notice detailed below:
2. ABOUT US
2.1 We are a company registered in England under company number 449706, with our registered address as set out below:
Egmont UK Ltd
2 Minster Court
London EC3R 7BB
2.2 You can contact us as follows:
- Email: firstname.lastname@example.org
- Phone: 0141 306 3100
HarperCollins Publishers Limited
103 Westerhill Road
3. INFORMATION WE MAY COLLECT ABOUT YOU
3.1 Information that you provide to us:
3.1.1 We will collect any information that you provide to us when you:
(a) are making an enquiry, or complaint, over the phone or via our website;
(b) participate in a contest, promotion or competition;
(c) subscribe to our mailing lists;
(d) subscribe to our B2B invite mailing list;
(e) submit work or content to us by post, email or via our website;
(f) enter into a contract with us to a) publish your work in our publication(s), and/or b) license the right to use content from our publications;
(g) submit an application to a job vacancy;
(h) order books or other products from our website;
(i) are notified about changes to our services;
3.1.2 The information you provide to us might include your name, address, email address, IP address, phone number, if you are ordering products you will also provide your payment details, if you are submitting work, content or a job application you may also provide additional information about your academic and work history, references and any other such similar information as may be supplied.
3.1.3 From time to time we might ask if you would be willing to participate in our surveys or research days; if you agree, we will also collect any information that you provide as part of that survey or research.
3.2 How we collect information about you
3.2.1 We will collect any information contained in any correspondence between us. For example, if you contact us using a link on our website or by email or telephone, we will keep a record of that correspondence.
3.3 Children’s Data
3.3.1 We do not knowingly process personal data of children under the age of 13 unless we have the explicit consent of a parent or guardian. In case we discover that we process personal data of minors without parental consent we will delete that data.
3.4 Information we receive from third parties
3.4.1 In certain circumstances, we will receive information about you from third parties. For example,
(a) if you choose to register for a website user account you may choose to link this account to your social media account (such as Twitter or Facebook). By providing your social media account details you are authorising that third-party provider to share with us certain information about you;
(b) we may use third party providers to verify information provided by you in connection with any work or content you submit to us for publication. For example, we will use third-party databases or websites to confirm your publication history;
(c) we will receive information about you from third parties if they are referring you to us for publication. For example, if you are the co-author of a manuscript, your co-author will be required to provide us with information about you. Or if you have an agent making submissions on your behalf, your agent will provide us with information about you;
(d) if you are a job applicant we may contact your referees to provide information about you.
3.4.2 We might also receive information about you from third parties if you have indicated to such third party that you would like to hear from us.
4. HOW WE USE INFORMATION ABOUT YOU AND RECIPIENTS OF YOUR INFORMATION
4.1 We will use your information for the purposes listed below either on the basis of:
4.1.1 performance of our obligations under our contract with you and the provision of our services to you;
4.1.2 your consent (where we request it); or
4.1.3 our legitimate interests (see paragraph 4.3 below).
4.2 We may use your information for the following purposes:
4.2.1 to provide you with access to our website in a manner convenient and optimal and with personalised content relevant to you including sharing your information with our website hosts and developers (on the basis of our legitimate interest to ensure our website is presented in an effective and optimal manner);
4.2.2 to enable receipt, review, editing, production and publication of your work or content including sharing your information with our editorial and production service providers, peer-reviewers, third-party readers and reviewers (on the basis of performing our contract with you);
4.2.3 to administer your contract, including but not limited to invoicing, payment of fees and/or advances and royalties and sharing your information with our royalty system software provider, payment service provider (on the basis of performing our obligations under our contract with you);
4.2.4 to administer orders made from our website and sharing your information with our warehousing and delivery service providers (on the basis of performing our contract with you);
4.2.5 to process any job applications you submit to us including sharing this with any third party recruitment agency;
4.2.6 to keep in contact with you about our news, events, new website features or services or new books that we believe may interest you, provided that we have the requisite permission to do so, and sharing your information with our marketing services provider (either on the basis of your consent where we have requested it, or our legitimate interests to provide you with marketing communications where we may lawfully do so);
4.2.7 to share your information with selected third parties such as publishing partners, to enable them to contact you with information about things that may interest you (where we have your consent to do so);
4.2.8 to provide customer service and support (on the basis of our contract with you), deal with enquiries or complaints via the website and share your information with our book printing services, website developer, IT support provider, warehouse and delivery service provider, payment services provider as necessary to provide customer support (on the basis of our legitimate interest in providing the correct products and services to our website users);
4.2.9 to carry out aggregated and anonymised research about general engagement with our website (on the basis of our legitimate interest in providing the right kinds of products and services to our website users);
4.2.10 to protect, investigate, and deter against fraudulent, unauthorised, or illegal activity, including without limitation plagiarism and identity fraud (on the basis of our legitimate interests to operate a safe and lawful business or where we have a legal obligation to do so); and
4.2.11 to enable us to comply with our policies and procedures and enforce our legal rights, or to protect the rights, property or safety of our employees and share your information with our technical and legal advisors (on the basis of our legitimate interests to operate a safe and lawful business or where we have a legal obligation to do so).
4.3 Where we refer to using your information on the basis of our “legitimate interests”, we mean our legitimate business interests in conducting and managing our business and our relationship with you, including the legitimate interest we have in:
4.3.1 personalising, enhancing, modifying or otherwise improving the services and/or communications that we provide to you;
4.3.2 detecting and preventing fraud and operating a safe and lawful business;
4.3.3 improving security and optimisation of our network, sites and services;
4.4 Where we use your information for our legitimate interests, we make sure that we take into account any potential impact that such use may have on you. Our legitimate interests will not automatically override yours and we won’t use your information if we believe your interests should override ours unless we have other grounds to do so (such as your consent or a legal obligation). If you have any concerns about our processing please refer to details of “Your Rights” in paragraph 9 below.
5. WHO WE MIGHT SHARE YOUR INFORMATION WITH
5.1 In connection with the purposes and on the lawful grounds described above and in addition to the recipients of your information as described above, we may share your personal information with third parties that we work with such as:
5.1.1 third parties we work with to deliver our business (including for example, hosting or operating the website and our databases, site analytics, providing editorial production services, providing technical assistance and support and providing fraud and plagiarism detection services);
5.1.2 any selected third party that you consent to our sharing your information with for marketing purposes;
5.1.3 any prospective seller or buyer of such business or assets, only in the event that we decide to sell or buy any business or assets; and
5.1.4 any other third parties (including legal or other advisors, regulatory authorities, courts and government agencies) where necessary to enable us to enforce our legal rights, or to protect the rights, property or safety of our employees or where such disclosure may be permitted or required by law.
5.2 We require third parties to maintain appropriate security to protect your information from unauthorised access or processing.
6. HOW WE LOOK AFTER YOUR INFORMATION AND HOW LONG WE KEEP IT FOR
6.1 We operate a policy of “privacy by design” by looking for opportunities to minimise the amount of personal information we hold about you. We use appropriate technological and operational security measures to protect your information against any unauthorised access or unlawful use, such as:
6.1.1 ensuring the physical security of our offices, warehouses or other sites;
6.1.2 ensuring the physical and digital security of our equipment and devices by using appropriate password protection and encryption;
6.1.3 maintaining a data protection policy for, and delivering data protection training to, our employees;
6.2 limiting access to your personal information to those in our company who need to use it in the course of their work.
6.3 We will retain your information for as long as is necessary to provide you with the services that you have requested from us or for as long as we reasonably require to retain the information for our lawful business purposes, such as for the purposes of exercising our legal rights or where we are permitted to do so for purposes of academic, literary expression and research purposes. We operate a data retention policy and look to find ways to reduce the amount of information we hold about you and the length of time that we need to keep it. For example,
6.3.1 we conduct regular reviews and destroy or delete documents and e:mails in line with our retention policies;
6.3.2 we archive our email and paper correspondence regularly and destroy unnecessary information;
6.3.3 we retain information relating to orders, refunds and financial information for approximately 7 years;
6.3.4 we destroy unpublished work or content and related correspondence after 18 months, however we may permanently keep a log recording brief details of these in the event of a legal claim;
6.3.5 we maintain a suppression list of email addresses of individuals who no longer wish to be contacted by us. So that we can comply with their wishes we must store this information permanently;
6.3.6 we destroy all job applications and diversity information after 6 months of receipt;
6.3.7 we retain customer complaints and customer queries for approximately 2 years, however we may permanently keep a log recording brief details of these in the event of a legal claim;
6.3.8 deleted e:mails are auto-deleted periodically.
7. TRANSFER OF PERSONAL DATA
7.1 We may disclose personal data to affiliate or subsidiary companies, as well as professional advisors in accordance with applicable data protection laws.
7.2 Our employees, agents, business partners, vendors and/or suppliers may have access to your personal data on a limited as needed basis in order to deliver a service to us or to enable them to act on our behalf in accordance with applicable data protection laws.
7.3 We reserve the right to use or disclose any information as needed to satisfy any law, regulation or legal request, to conduct investigations of consumer complaints or possible breaches of law, to protect the integrity of the website, to fulfil your requests or to co-operate with any legal investigation.
7.4 Transfer of personal data is conducted in compliance with legal requirements, including concluding appropriate data processor agreements with our data processors, to ensure that personal data is not processed for other purposes than clearly stated and to ensure adequate security measures.
8. INTERNATIONAL TRANSFERS OF YOUR INFORMATION
8.1 Our company is located in the UK.
8.2 Your information will be processed outside of the European Economic Area (EEA) in the circumstances listed below and we will take all steps necessary to ensure that any of your information is adequately protected and processed in accordance with this Privacy Notice. When transferring or storing your data at a location outside of the European Economic Area (EEA) we ensure an adequate level of security by transferring to countries approved by the European Commission as having an adequate level of protection, or by entering into all appropriate cross-border transfer solutions such as the European Commission’s Standard Contractual Clauses or the EU-US Privacy Shield Framework:
8.2.1 we supply your name, address and payment details to our invoice and expenses provider in India via the Standard Contractual Clauses when we receive an invoice or expenses claim for processing.
8.2.2 if you are an author, we supply your name and royalty account information to our royalty software system provide in the USA, via the EU-US Privacy Shield Framework
8.2.3 we supply your name and email address to a marketing campaign service provider in the USA via the EU-US Privacy Shield Framework and Australia via the Standard Contractual Clauses when we are permitted to send you marketing emails;
9. YOUR RIGHTS TO THE INFORMATION WE HOLD ABOUT YOU
9.1 You have certain rights in respect of the information that we hold about you, including:
9.1.1 the right to ask us not to process your personal data for marketing purposes;
9.1.2 the right to request access to the information that we hold about you; and
9.1.3 in certain circumstances, the right to ask us to stop processing information about you.
9.2 You may exercise your rights above by contacting us using the details in paragraph 2 of this Privacy Notice, or in the case of preventing processing for marketing activities also by checking certain boxes on forms that we use to collect your data to tell us that you don’t want to be involved in marketing.
9.3 Please note that we may need to retain certain information for our own record-keeping and research purposes. We may also need to send you service-related communications relating to your website user account even when you have requested not to receive marketing communications.
9.4 From 25 May 2018, in accordance with new data protection laws which will be in force from that date, you will have certain additional rights in respect of the information that we hold about you, including:
9.4.1 the right to lodge a complaint about us to the UK Information Commissioner’s Office (https://ico.org.uk/) or the relevant authority in your country of work or residence;
9.4.2 the right to withdraw your consent for our use of your information in reliance of your consent (refer to paragraph 4 to see when we are relying on your consent), which you can do by contacting us using any of the details at the top of this Privacy Notice;
9.4.3 the right to object to our using your information on the basis of our legitimate interests (refer to paragraph 4 above to see when we are relying on our legitimate interests);
9.4.4 the right to receive a copy of any information we hold about you in connection with the performance of our contract with you or on the basis of your consent (or request that we transfer this to another service provider) in a structured, commonly-used, machine readable format; and
9.4.5 the right to ask us to limit or cease processing or erase information we hold about you in certain circumstances.
9.5 You can obtain a copy of your personal data in a structured, commonly used and machine readable format by contacting us using any of the contact details in paragraph 2 above. If you wish to make a request we may ask for such information as proof of identity or any other additional information we may reasonably require in order to confirm your identity and locate the information you have requested.
9.6 You may contact us with the details at the top of this Privacy Notice if you wish to action any of these additional rights and we will comply with your requests unless we have a lawful reason not to do so. We will respond to your requests within a maximum of four (4) weeks from receipt of your request or, within this deadline, advise you as to when we will be able to provide you with a response.
10. CHANGES TO THIS PRIVACY NOTICE
This Privacy Notice was updated on 23rd May 2018.