1.1 This privacy notice (Privacy Notice) sets out the ways in which we, Bonnier Zaffre Ltd (we, us, our), collect and use your personal data (your personal information) in connection with wilbursmithbooks.com (“our site”, “our website”) and our publishing business. It also explains what rights you have to access or change your personal data
2. ABOUT US
2.1 We are a company [registered in England under company number 07735953], with our registered address as set out below.
2.2 You can contact us as follows:
Thomas Ogilvie, Privacy Officer
℅ Bonnier Zaffre Ltd, 80-81 Wimpole Street, London W1G 9RE, UK
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 over the phone or our website;
(b) subscribe to our mailing lists;
(c) submit content to us by post, email or via our website;
(d) enter your score and details to our quiz result tables;
(e) or otherwise fill in details on our site or use our site’s functions including but not limited to when you register to use our site or receive our newsletter, subscribe to our services, search for a book, participate in discussion boards or forums, use the social media functions associated with our site, enter a competition or promotion, claim a book or prize, or use other activities or services we may add to our site in future, and when you report a problem with our site.
3.1.2 The information you provide to us might include your name, address, email address, phone number, and if you’re creating an account you may also provide a password, and other similar information that at times may be requested or volunteered.
3.1.3 From time to time we might ask if you would be willing to participate in our surveys; if you agree, we will also collect any information that you provide as part of that survey.
3.2 Information we collect about you
3.2.1 We will collect any information contained in any correspondence between us. For example, if you contact us using a query button on our website or by email or telephone, we will keep a record of that correspondence.
3.2.2 We will collect information that you upload or post to your website account and/or any correspondence or interactions that you may have with other website account holders.
3.2.3 We will also collect certain information about how you use our website and the device that you use to access our website. This might include your IP address, geographical location, device information (such as your hardware model, mobile network information, unique device identifiers), browser type, referral source, length of visit to the website, number of page views, the search queries you make on the website and similar information. This information may be collected by Google Analytics or another third-party website analytics service provider on our behalf and/or may be collected using cookies. For more information on cookies please read paragraph 6 below.
3.3 Information we receive from third parties
3.3.1 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 content you submit to us for publication. For example, we may 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 a literary agent making submissions on your behalf, your agent will provide us with information about you.
3.3.2 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 your contract with us 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 content including sharing your information with our editorial and production service providers, peer-reviewers, third-party manuscript readers (on the basis of performing our contract with you);
4.2.3 to administer your content contract, including payment of royalties or fees and sharing your information with our royalty system software provider and/or payment service provider (on the basis of performing our contract with you);
4.2.4 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, (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);
4.2.5 to send you our newsletters provided that we have your consent to do so (currently we use “MailChimp” to manage the delivery of our newsletter as well as for analysis of newsletter data such as the open rate of this newsletter. MailChimp is part of The Rocket Science Group, LLC, 512 Means Street, Ste 404 Atlanta, GA 30318, USA. This Privacy Notice does not apply to Mailchimp but the company is a member of the Safe Harbor Agreement, a special data protection agreement between the European Union and the United States. For more information about the privacy policies of MailChimp, go to http://mailchimp.com/legal/privacy/)
4.2.6 to share your information with selected third parties such as publishing partners and authors, to enable them to contact you with information about things that may interest you (where we have your consent to do so);
4.2.7 to provide support, deal with enquiries or complaints about the website and share your information with our website developer and IT support provider;
4.2.8 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);
4.2.9 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
4.2.10 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).
4.2.11 to enable us to build profiles of ‘lookalike’ customers for advertising and marketing purposes on social media (on the basis of our legitimate business interest).
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;
4.3.4 conducting business with suppliers and purchasers.
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 don’t 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 technical assistance and support, financial services institutions);
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.
6.2 Cookies enables us to estimate our audience size and usage patterns, store information about your preferences, allowing us to customize our website according to your individual interests; and recognize you when you return to our website.
6.3 The names of the cookies used on our website and the purposes for which these cookies are used are set out in the below:
Cookie Name: [wilbur.sid ]
Purpose: [Session Identification]
Duration: [24 hours]
Cookie Name: [wilbur.csrf ]
Purpose: [Cross Site Request Forgery protection]
Duration: [Sesssion Duration]
Cookie Name: _ga
Purpose: [Used to distinguish users]
Duration: [2 years]
Cookie Name: _gid
Purpose: [Used to distinguish users]
Duration: [24 hours]
Cookie Name: _gat
Purpose: [Used to throttle request rate. If Google Analytics is deployed via Google Tag Manager, this cookie will be named _dc_gtm_<property-id>.]
Duration: [1 minute]
Cookie Name: AMP_TOKEN
Purpose: [Contains a token that can be used to retrieve a Client ID from AMP Client ID service. Other possible values indicate opt-out, inflight request or an error retrieving a Client ID from AMP Client ID service.]
Duration: [30 seconds to 1 year]
Cookie Name: _gac_<property-id>
Purpose: [Contains campaign related information for the user. If you have linked your Google Analytics and AdWords accounts, AdWords website conversion tags will read this cookie unless you opt-out. Learn more.]
Duration: [90 days]
6.6 To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org. To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.
7. HOW WE LOOK AFTER YOUR INFORMATION AND HOW LONG WE KEEP IT FOR
7.1 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:
7.1.1 ensuring the physical security of our offices, warehouses or other sites;
7.1.2 ensuring the physical and digital security of our equipment and devices by using appropriate password protection [and encryption];
7.1.3 maintaining a data protection policy for, and delivering data protection training to, our employees;
7.1.4 limiting access to your personal information to those in our company who need to use it in the course of their work.
7.2 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. In addition, 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;
8. INTERNATIONAL TRANSFERS OF YOUR INFORMATION
8.1 Our company is located in the UK.
8.2 We take all steps necessary to ensure that any of your information is adequately protected and processed in accordance with this Privacy Notice, including aiming to ensure that all data is stored and processed within the European Union and by using all appropriate cross-border transfer solutions such as the European Commission's Standard Contractual Clauses or the EU-US Privacy Shield Framework;
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, by updating your marketing preferences via your account with us, or by clicking Unsubscribe on any email marketing correspondence that you receive from us.
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); and
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 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.
10. CHANGES TO THIS PRIVACY NOTICE
10.1 We may make changes to this Privacy Notice from time to time. We will post any changes to our site, or notify you of any material changes by e-mail.
This Privacy Notice was last updated on 17th August 2018.