PENGUIN RANDOM HOUSE PRIVACY NOTICE
1. INTRODUCTION
1.1 This privacy notice (Privacy Notice) sets out the ways in which we, The Random House Group Limited and Penguin Books Limited (we, us, our), collect and use your personal data (your personal information) in connection with our businesses. It also explains what rights you have to access or change your personal data.
1.2 We appreciate that you may be reading this Privacy Notice for a range of reasons. You may be a reader/purchaser, an author, agent or prospective writer, a freelancer or contractor, a prospective employee, an influencer or an Audience Insight participant (each a Group).
1.3 Paragraphs 1 to 13 of this Privacy Notice apply to you, no matter who you are. However, depending on which Group you fall into, specific information in relation to our use of your personal data is set out in the sections below.
1.4 Where we refer to the website in this policy, we are referring to any of our websites from which you have accessed this Privacy Notice.
2.1 We are companies registered in England under company numbers 00954009 (The Random House Group Limited) and 00861590 (Penguin Books Limited) and are the data controllers of your personal data.
2.2 You can contact us as follows:
FAO: Data Protection Compliance
Address: One Embassy Gardens, 8 Viaduct Gardens, London, SW11 7BW
Email: ukdataprotection@penguinrandomhouse.co.uk
3. HOW WE COLLECT YOUR PERSONAL DATA
3.1 Depending on which Group you fall into, further detail on the information we collect about you can be found here:
- Readers/purchasers
- Authors, Agents & Prospective Writers
- Prospective employees, Work Experience & Volunteering Programmes
- Independent Contractors including Freelancers
- Audience Insight participants (Market Research)
- Journalists, Influencers & Reviewers
3.2 The following applies to all Groups:
3.2.1 if you are a visitor of our websites we will collect certain information about how you use our websites and the device that you use to access our websites. 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 (Browsing Information). This information may be collected by a third-party website analytics service provider on our behalf and/or may be collected by third parties (such as Facebook) using cookies which are active on our websites. For more information on cookies and what you can do to disable certain cookies on our websites, please read our Cookie Policy. Please note that disabling certain cookies on our website may not remove cookies which have previously been placed on your device, (e.g. in a previous visit, or as part of a visit to a third party website elsewhere) and you may need to take further steps to change the settings on the device or web browser account you are using to prevent certain types of Browsing Information, from being stored or retained.
3.2.2 if you contact us (whether using a query button on our website or by email, telephone, or social media), we will collect any information contained in any correspondence between us; and
3.2.3 if you upload or post to any website or account, correspond or interact with other website account holders, we will collect that information.
3.3 If you follow us on Twitter or Facebook, we may also, in accordance with the privacy policies of those social media platforms, collect information about you, and/or other people that you follow, or interact with, on social media. That kind of processing takes place on the basis set out in the privacy policies made available on the social media platforms in question, if you wish to change the way that your data is processed as a result of your use of a particular social media platform then you will need to change your settings on that platform.
3.4 In certain circumstances, we will receive information about you from third parties. For example, if you have indicated to such third party that you would like to hear from us (e.g. where we run promotional campaigns on third party sites, and you tick a box there which indicates that you would like to hear from us in the future).
4. HOW WE USE YOUR PERSONAL DATA
4.1 We use your personal data on various legal grounds including the following:
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);
4.1.3 our legitimate interests (see paragraph 4.5 below); or
4.1.4 compliance with our legal obligations.
4.2 We may use your personal data differently, depending on which Group you fall into. To find out the specific uses we may make of your personal data, please click on the Group relevant to you:
- Readers/purchasers
- Authors, Agents & Prospective Writers
- Prospective employees, Work Experience & Volunteering Programmes
- Independent Contractors including Freelancers
- Audience Insight participants (Market Research)
- Journalists, Influencers & Reviewers
4.3 No matter which Group you fall into, we may use your information for the following:
4.3.1 Access and Optimisation - to provide you with access to our website in a manner convenient and optimal and with personalised content relevant to you, including sharing your Browsing 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);
4.3.2 Fraud - to protect, investigate, and deter against fraudulent, unauthorised, or illegal activity, including sharing your name, address, financial, correspondence and contact information (on the basis of our legitimate interests to operate a safe and lawful business or where we have a legal obligation to do so);
4.3.3 Policies, Procedures and Legal Rights - 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, including sharing your name, address, correspondence details and anything you have posted to our website (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/or
4.3.4 Archiving - for archiving purposes including internal and external research, filing and document management (on the basis of our legitimate interests to operate a safe and lawful business or where we have a legal obligation to do so).
4.4 We may also collect information about you (such as your IP address) from your use of our website and share this with social media platforms (such as Facebook), social media platforms (such as Facebook) so that relevant adverts may be selected and served to you, and others who are similar to you, via those platforms (on the basis of our legitimate interests to market our products to you and others who have similar preferences to you. More information can be found in our Cookie Policy. To disable the Facebook cookie so that we cannot collect information about you, please consult your Facebook settings.
4.5 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:
4.5.1 personalising, enhancing, modifying or otherwise improving the services and/or communications that we provide to you;
4.5.2 detecting and preventing fraud and operating a safe and lawful business; and/or
4.5.3 improving security and optimisation of our network, sites and services.
4.6 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 Relation To Your Personal Data” in paragraph 10 below.
5. WHO WE SHARE YOUR PERSONAL DATA WITH
5.1 In connection with the purposes and on the lawful grounds described above, we may share your personal information with third parties. These include:
5.1.1 third parties we work with to deliver our business (including for example third party providers of services including: hosting, operating or developing the website and our databases, site and app analytics, digital advertising and marketing, information storage, and technical assistance). Further detail about the specific parties we share your personal information with and why we share that information is included here:
- Readers/purchasers
- Authors, Agents & Prospective Writers
- Prospective employees, Work Experience & Volunteering Programmes
- Independent Contractors including Freelancers
- Audience Insight participants (Market Research)
- Journalists, Influencers & Reviewers
5.1.2 any selected third party that you consent to our sharing of your information with for marketing purposes, such as our competition co-promoters;
5.1.3 any member of our group, which means our subsidiaries, our ultimate group holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006;
5.1.4 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/or
5.1.5 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.
5.1.6 We reserve the right to change our third-party providers with whom we may share your personal data, from time to time at our discretion.
6. COOKIES
We use cookies to ensure that you get the most out of our website. Please find further details in our Cookie Policy.
7. SECURITY OF PERSONAL DATA
7.1 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; and
7.1.5 operating a policy of “security and privacy by design” including looking for opportunities to minimise the amount of personal information we hold about you.
8.1 We will only keep your personal data for as long as we need it to fulfil the purpose we collected it for, such as to provide you with our products and services.
8.2 The retention period for your data will depend upon the purpose for which it is being used, including any legal or regulatory obligations requiring us to retain it for a specified period as set out in our company policies. We may also retain your personal data for a longer period in the event of a legal complaint or proceedings.
8.3 If you want to know more about how long we hold your data, please feel free to contact us and we will endeavour to provide you with more detail on the retention period for the specific personal data you have provided to us.
9. INTERNATIONAL TRANSFERS OF YOUR DATA
9.1 In some cases we will share your personal data outside of the UK.
9.2 For example, we may share your personal data with our Group companies in the USA, Australia, New Zealand, Canada, Germany, Spain, South Africa, China and India where necessary to support the project or purposes for which the data was collected, such as providing administrative support, for analytics and insights, content production, or finance purposes.
9.3 Some of the external suppliers and third parties we work with are also based outside the UK, for example an e-commerce service provider in the US, so their processing of your personal data will involve a transfer of data outside the UK.
9.4 Whenever we transfer your personal data out of the UK, we ensure it is given a similar degree of protection and implement at least one of the following safeguards:
9.4.1 we transfer your data to countries that have been deemed to provide an adequate level of protection for personal data;
9.4.2 we use specific approved contracts, such as Standard Contractual Clauses, which give personal data the same level of protection it has in the UK.
9.5 Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
10. YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights include the following:
10.1 The right to access the information that we hold about you
10.1.1 You may, at any time, request access to the personal data that we hold which relates to you (you may have heard of this right being described as a "subject access request").
10.1.2 Please note that this right entitles you to receive a copy of the personal data that we hold about you in order to enable you to check that it is correct and to ensure that we are processing that personal data lawfully. It is not a right that allows you to request personal data about other people, or a right to request specific documents from us that do not relate to your personal data.
10.1.3 You can exercise this right at any time by writing to us by contacting us and telling us that you are making a subject access request. You do not have to fill in a specific form to make this kind of request.
10.2 The right to have inaccurate personal data about you rectified, or completed if it is incomplete
10.2.1 You may, at any time, request that we correct personal data that we hold about you which you believe is incorrect or inaccurate.
10.2.2 Please note that we may ask you to verify any new data that you provide to us and may take our own steps to check that the new data you have supplied us with is correct.
10.2.3 You can exercise this right at any time by contacting us and telling us that you are making a request to have your personal data rectified and on what basis you are making that request. If you want us to replace inaccurate data with new data, you should tell us what that new data is. You do not have to fill in a specific form to make this kind of request.
10.3 The right to ask us to erase your personal data
10.3.1 You may ask us to erase personal data if you do not believe that we need to continue processing it including storing it (you may have heard of this right described as the “right to be forgotten”).
10.3.2 Please note, we are not always obliged to erase personal data when asked to do so; if for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to erase we will tell you what that reason is at the time we respond to your request.
10.3.3 You can exercise this right at any time by contacting us and telling us that you are making a request to have your personal data erased and on what basis you are making that request.
10.4 The right to restrict or object to our processing of your personal data
10.4.1 Where we process your personal data on the basis of a legitimate interest (see the sections of this Privacy Notice which explain how and why we use your information) you are entitled to ask us to stop processing it in that way if you feel that our continuing to do so impacts on your fundamental rights and freedoms or if you feel that those legitimate interests are not valid.
10.4.2 You may also ask us to stop processing your personal data (a) if you dispute the accuracy of that personal data and want us verify that data's accuracy; (b) where it has been established that our use of the data is unlawful but you do not want us to erase it; (c) where we no longer need to process your personal data (and would otherwise dispose of it) but you wish for us to continue storing it in order to enable you to establish, exercise or defend legal claims.
10.4.3 In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms., We will tell you what that reason is, either at the time we first respond to your request or after we have had the opportunity to consider and investigate it.
10.4.4 You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a request to have us stop processing the relevant aspect of your personal data and describing which of the above conditions you believe is relevant to that request. You do not have to fill in a specific form to make this kind of request.
10.5 The right to request the transfer of your personal data to another service provider
10.5.1 Where you wish to transfer certain personal data that we hold about you, which is processed by automated means, to a third party you may write to us and ask us to provide it to you in a commonly used machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
10.6 The right to withdraw your consent for our use of your information in reliance of your consent
10.6.1 You have the right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
10.7 The right to stop receiving communications from us
10.7.1 Where we send you e-mail marketing communications (or other regulated electronic messages) you have the right to opt-out at any time. You can do this by using the ‘unsubscribe’ link that appears in the footer of each communication (or the equivalent mechanism in those communications).
10.8 Your right to object to automated decision making and profiling
10.8.1 You have the right to be informed about the existence of any automated decision making and profiling of your personal data, and where appropriate, be provided with meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing that affects you.
10.9 If you wish to exercise any of the rights set out above, please contact us at ukdataprotection@penguinrandomhouse.co.uk.
10.10 We may need to request specific information from you to help us confirm your identity and your right to access your personal data (or to exercise any of your other rights). We may also ask you for further information in relation to your request to speed up our response.
10.11 You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, if your request is unfounded or excessive, we may decide to charge a fee or in some cases refuse to comply with it.
10.12 You have 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.
11. YOUR CALIFORNIA PRIVACY RIGHTS
11.1 Under the California Consumer Privacy Act, residents of California have certain rights in relation to their personal data. These rights include:
11.1.1 Right to Know - You have the right to request access to any personal data we hold on you in the past 12 months.
11.1.2 Right to Opt-Out of Sale of Personal Data - You have the right to opt-out of the sale of your personal data to third parties.
11.1.3 Right to Deletion - You have the right to request that we delete any personal data we hold on you.
11.1.4 Right to Non-Discrimination - We will not discriminate against you for exercising any of the above rights.
11.2 If you wish to exercise any of the rights set out above, please contact us at ukdataprotection@penguinrandomhouse.co.uk.
12. AUTOMATED DECISION MAKING
12.1 We may analyse your personal information to create a profile of your interests and preferences so that we can contact you with information relevant to you. We may make use of additional information about you when it is available from external sources to help us do this effectively.
13. CHANGES TO THIS PRIVACY NOTICE
13.1 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 email.
This Privacy Notice was updated on 25.01.2022
Schedule 1 – Readers/purchasers
14. INFORMATION WE MAY COLLECT ABOUT YOU
14.1 Information that you provide to us
14.1.1 We will collect any information that you provide to us when you:
(a) make an enquiry, provide feedback or otherwise contact us via phone, email, post, our website, or any of our or social media accounts (such as our Twitter or Facebook pages) or apps;
(b) subscribe to our newsletters and mailing lists;
(c) enter one of our competitions and prize draws;
(d) purchase any books or other products from our online shop or website;
(e) create an account for one of our websites;
(f) purchase a ticket for, or attend, one of our events, whether physical or virtual (including live-reads, book signings or Facebook live parties);
(g) download one of our apps, or contact us with any queries relating to your use of our apps;
(h) download one of our podcasts;
(i) post on one of our websites or in our apps;
(j) complete one of our surveys including diversity and inclusion surveys.
14.1.2 The information you provide to us might include:
(a) your name, home and/or work address, email, telephone number;
(b) social media handle or profile;
(c) financial and/or payment details (if you are purchasing a product or service from us);
(d) password and log-in details (if you create an account on our website);
(e) details about your family e.g. the ages of any children you may have (only if you have expressly chosen to provide this);
(f) details of your sexual orientation, race, ethnicity, disability, adjustment requirements, religious or political views, socio-economic background and other demographic information (where you have completed one of our diversity and inclusion surveys).
14.2 Information we receive or collect from third parties
(a) In certain circumstances, we will receive or collect information about you from third parties. For example, we may use publicly available information held on websites e.g. customer reviews (on Amazon), and social media platforms. This may also include where we use social listening tools (e.g. Falcon).
15. HOW WE USE INFORMATION ABOUT YOU
15.1 We may use your information for the following purposes:
(a) to keep in contact with you about our news, events, new website features or services or new books or products 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);
(b) to administer orders made from our website or via other means, and sharing your information with our warehousing and delivery service providers (on the basis of performing our contract with you);
(c) to process your entry to any competitions or prize draws (either on the basis of your consent, or performing our contract with you);
(d) to carry out research about general engagement with our website, products, services and the publishing industry generally (either on the basis of your consent where we have requested it, or our legitimate interest in providing the right kinds of products and services to our website users);
(e) to provide customer service and support (on the basis of our contract with you), deal with enquiries or complaints about our products, website or apps and share your information with our 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 you);
(f) to carry out sales and other data analysis (on the basis of our legitimate interests to measure and improve our purchase, distribution and sales performance management);
(g) to further our company inclusivity and diversity goals (on the basis of your consent where required or where we have a legitimate interest in pursuing such goals and there are substantial public interest reasons for doing so);
15.1.1 to share your personal information with selected third parties such as:
(a) 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); and
(b) social media platforms (such as Facebook) so that relevant adverts may be selected and served to you, and others who are similar to you, via those platforms (on the basis of our legitimate interests to market our products to you and others who have similar preferences to you).
(c) Business partners and other third-party service providers to enhance, modify or otherwise improve their services (on the basis of our legitimate interests to ensure such third parties are providing the best possible service to us).
16. WHO WE MIGHT SHARE YOUR INFORMATION WITH
16.1 In addition to the parties listed in paragraphs 15 and 5.1 above, the third parties with whom we work to deliver our business and with whom we might share your personal information include:
(a) e-commerce providers (including Shopify),
(b) courier and transport providers (e.g. DHL);
(c) competition, newsletter and survey providers (including, Adestra);
(d) ticket sales providers (including, Eventbrite);
(e) invoice and payment service providers (including, Basware);
(f) editorial and advertisement production service providers;
(g) building security service providers (e.g. Evolution); and
(h) technical assistance and support service providers.
Schedule 2 – Authors, Agents & Prospective Writers
17. INFORMATION WE MAY COLLECT ABOUT YOU
17.1 Information that you provide to us
17.1.1 We will collect any information that you provide to us when you:
(a) submit manuscripts to us by post, email or via our website (on your own behalf or on behalf of your author);
(b) negotiate and/or enter into a contract with us for us to publish your book (on your own behalf or on behalf of your author);
(c) apply for one of our writing or design programmes (e.g. WriteNow);
(d) complete one of our surveys including diversity and inclusion surveys.
17.1.2 The information you provide to us might include:
(a) your name, home and/or work address, email, telephone number;
(b) financial and/or payment details (if we are paying you for your work);
(c) details of your sexual orientation, race, ethnicity, disability, adjustment requirements, religious or political views, socio-economic background and other demographic information (if you have agreed to have this information being processed for the purpose of our publishing, promoting your book, entering the relevant writing programme or completing our diversity and inclusion survey);
(d) passport or other identity document information (if we arrange foreign travel for you).
17.2 Information we receive from third parties
17.2.1 In certain circumstances, we will receive information about you from third parties. For example:
(a) we may use third party providers to verify information provided by you in connection with any manuscript you submit to us for publication. For example, we will use third-party databases or websites to confirm your publication history;
(b) we may also use third party providers to obtain sales and other publishing data relating to your books. For example we may use third party book data providers and publicly available information held on Amazon and social media platforms;
(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.
18. HOW WE USE INFORMATION ABOUT YOU
18.1 We may use your information for the following purposes:
(a) to enable receipt, review, editing, production and publication of your manuscript including sharing your information with our editorial and production service providers, other service providers and third-party manuscript readers (on the basis of performing our contract with you);
(b) to administer your publishing contract, including payment of royalties, and sharing your information with our payment service provider (on the basis of performing our contract with you);
(c) to arrange travel for you (on the basis of your consent or the performance of our contract with you);
(d) to carry out sales and other data analysis (on the basis of our legitimate interests to measure and improve our purchase, distribution and sales performance management); to further our company inclusivity and diversity goals (on the basis of your consent where required or where we have a legitimate interest in pursuing such goals there are substantial public interest reasons for doing so);
(e) to protect, investigate, and deter against fraudulent, unauthorised, or illegal activity (on the basis of our legitimate interests to operate a safe and lawful business or where we have a legal obligation to do so);
(f) 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).
19. WHO WE MIGHT SHARE YOUR INFORMATION WITH
19.1 In addition to the parties listed in paragraphs 18 and 5.1 above, the third parties with whom we work to deliver our business and with whom we might share your personal information include:
(a) courier and transport services (e.g. DHL, British Airways etc.);
(b) invoice and payment service providers (e.g. Basware);
(c) editorial and advertisement production service providers;
(d) building security services (e.g. Evolution); and
(e) technical assistance and support service providers;
Schedule 3 – Prospective employees, Work Experience, Internships and Volunteering Programmes
20. INFORMATION WE MAY COLLECT ABOUT YOU
20.1 Information that you provide to us
20.1.1 We will collect any information that you provide to us when you:
(a) submit an application to a job vacancy;
(b) apply for a work experience placement or internship;
(c) apply for a volunteering programme;
(d) complete one of our surveys including diversity and inclusion surveys.
20.1.2 The information you provide to us might include:
(a) your name, home and/or work address, email, telephone number;
(b) financial and/or payment details (if we are paying you for your time at the company);
(c) details of your academic and work history, references and any other such similar information (if you are submitting a job application or applying for a volunteering placement);
(d) details of your sexual orientation, race, ethnicity, disability, adjustment requirements, religious or political views, socio-economic background and other demographic information (if you have agreed to this information being processed for the purpose of your job or work experience application or completing our diversity and inclusion survey).
20.2 Information we receive from third parties
(a) In certain circumstances, we will receive information about you from third parties. For example, if you are a job applicant, we may receive your information from a third-party recruitment agency, conduct Google or LinkedIn searches, or contact your referees to provide information about you.
21. HOW WE USE INFORMATION ABOUT YOU
21.1 We may use your information for the following purposes:
(a) to process any job, work experience or volunteering applications you submit to us. This may include sharing your information with our business partners and other third parties such as our recruitment agency or volunteering organisations (on the basis of your consent or the performance of our contract with you);
(b) to protect, investigate, and deter against fraudulent, unauthorised, or illegal activity, (on the basis of our legitimate interests to operate a safe and lawful business or where we have a legal obligation to do so);
(c) to further our company inclusivity and diversity goals (on the basis of your consent where required or where we have a legitimate interest in pursuing such goals and there are substantial public interest reasons for doing so);
(d) 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).
22. WHO WE MIGHT SHARE YOUR INFORMATION WITH
22.1 In addition to the parties listed in paragraphs 21 and 5.1 above, the third parties with whom we work to deliver our business and with whom we might share your personal information include:
(a) recruitment agencies;
(b) technical assistance and support service providers;
(c) volunteering partners;
(d) survey and focus group providers; and
(e) building security service providers.
Schedule 4 – Independent Contractors including Freelancers
23. INFORMATION WE MAY COLLECT ABOUT YOU
23.1 Information that you provide to us
23.1.1 We will collect any information that you provide to us when you:
(a) negotiate and/or enter into a contract with us for you or your company/employer for you to provide products or services to us;
(b) are carrying out the work contracted;
(c) take part in any training required for the work contracted; and/or
(d) complete one of our surveys including diversity and inclusion surveys.
23.1.2 The information you provide to us might include:
(a) your name, home and/or work address, email, telephone number;
(b) financial and/or payment details (if we are paying you for a product or service); and/or
(c) details of your work history, references and any other such similar information.
(d) details of your sexual orientation, race, ethnicity, disability, adjustment requirements, religious or political views, socio-economic background and other demographic information (if you have agreed to this information being processed for the purpose of completing our diversity and inclusion survey).
23.2 Information we receive from third parties
(a) In certain circumstances, we will receive information about you from third parties. For example, we may use third party providers to verify your professional history and/or conduct Google and other public searches (such as LinkedIn) to verify information about you and/or your services.
24. HOW WE USE INFORMATION ABOUT YOU
24.1 We may use your information for the following purposes:
(a) to instruct you, negotiate, or conclude contracts with you for you to provide products or services to us (either on basis of performance of a contract or our legitimate interests pursued by us as a business);
(b) to further our company inclusivity and diversity goals (on the basis of your consent where required or where we have a legitimate interest in pursuing such goals and there are substantial public interest reasons for doing so);
(c) to protect, investigate, and deter against fraudulent, unauthorised, or illegal activity, (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
(d) 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).
25. WHO WE MIGHT SHARE YOUR INFORMATION WITH
25.1 In addition to the parties listed in paragraphs 24 and 5.1 above, the third parties with whom we work to deliver our business and with whom we might share your personal information include:
(a) courier and transport providers (e.g. DHL);
(b) survey and focus group providers;
(c) invoice and payment service providers (e.g. Basware);
(d) editorial and advertisement production service providers;
(e) building security service providers (e.g. Evolution);
(f) technical assistance and support service providers.
Schedule 5 – Audience Insight participants (Market Research)
26. INFORMATION WE MAY COLLECT ABOUT YOU
26.1 Information that you provide to us
(a) We will collect any information that you provide to us when you complete or participate in one of our surveys, focus groups, panels, promotional videos, ‘vox pops’, or consumer workshops.
26.1.1 The information you provide to us might include:
(a) your name, home and/or work address, email, telephone number;
(b) financial and/or payment details (if we are paying you for your assistance);
(c) details of your preferences e.g. your favourite books, genres and authors, (only if you have expressly chosen to provide this);
(d) details about your family e.g. the ages of any children you may have (only if you have expressly chosen to provide this); and/or
(e) details of your sexual orientation, race, ethnicity, disability, adjustment requirements, religious or political views, socio-economic background and other demographic information (if you have agreed to this information being processed for the purpose of completing our diversity and inclusion survey).
27. HOW WE USE INFORMATION ABOUT YOU
27.1 We may use your information for the following purposes:
(a) to keep in contact with you about our news, events, new website features or services or new books or products 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);
(b) to carry out research about general engagement with our website, products, services and the publishing industry generally (either on the basis of your consent where we have requested it, or our legitimate interest in providing the right kinds of products and services to our website users);
(c) to further our company inclusivity and diversity goals (on the basis of your consent where required or where we have a legitimate interest in pursuing such goals and there are substantial public interest reasons for doing so).
27.1.1 to share your personal information with selected third parties such as:
(a) 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);
(b) social media platforms (such as Facebook) so that relevant adverts may be selected and served to you, and others who are similar to you, via those platforms (on the basis of our legitimate interests to market our products to you and others who have similar preferences to you);
(c) survey and focus group providers to help us carry out the activities detailed above (either on the basis of your consent where we have requested it, or our legitimate interest in providing the right kinds of products and services to our website users).
28. WHO WE MIGHT SHARE YOUR INFORMATION WITH
28.1 In addition to the parties listed in paragraphs 27 and 5.1 above, the third parties with whom we work to deliver our business and with whom we might share your personal information include:
(a) courier and transport providers (e.g. DHL);
(b) invoice and payment service providers (e.g. Basware);
(c) building security service providers (e.g. Evolution);
(d) technical assistance and support service providers.
Schedule 6 - Journalists, Influencers & Reviewers
29. INFORMATION WE MAY COLLECT ABOUT YOU
29.1 Information that you provide to us
29.1.1 We will collect any information that you provide to us when you:
(a) post on or otherwise engage with our social media channels or our websites or otherwise contact us via phone, email or our apps.
(b) are directly contacted by us via social media (e.g. by direct message)
(c) negotiate and/or enter into an agreement with us for your services (on your own behalf or via your agent);
(d) create content for us, promote, review and/or comment on our books, products and services or otherwise in the course of working with us;
(e) complete one of our surveys including diversity and inclusion surveys.
29.1.2 The information you provide to us might include:
(a) your name, home and/or work address, email, telephone number;
(b) social media handle or profile;
(c) financial and/or payment details (if you are being paid for your services to us);
(d) details about your family e.g. the ages of any children you may have (only if you have expressly chosen to provide this).
(e) details of your sexual orientation, race, ethnicity, disability, adjustment requirements, religious or political views, socio-economic background and other demographic information (where you have completed one of our diversity and inclusion surveys).
29.2 Information we receive or collect from third parties
29.2.1 In certain circumstances, we will receive or collect information about you from third parties. For example:
(a) Any contact or other data made available on a media database (e.g. Gorkana);
(b) Any data provided by your agent;
(c) publicly available information held on websites e.g. customer reviews (on Amazon), and social media platforms. This may also include where we use social listening tools (e.g. Falcon).
30. HOW WE USE INFORMATION ABOUT YOU
30.1 We may use your information for the following purposes:
(a) to promote our books and other services through our social media channels (on the basis of your consent or the performance of our contract with you);
(b) to invite you to events (either with your consent or where we have a legitimate interest to send you such invitations);
(c) to administer your agreement with us, including payment for services, and sharing your information with our payment service provider (on the basis of performing our contract with you);
(d) to fulfil payments in kind for your services (e.g. books) including sharing your information with our warehousing and delivery service providers (on the basis of performing our contract with you);
(e) to arrange travel for you (on the basis of your consent or the performance of our contract with you);
(f) to keep in contact with you about our news, events, services or new books or products that we believe may interest you or you have requested (either with your consent or where we have a legitimate interest to provide you with such information);
(g) sharing your information with our marketing and other third party services providers, provided that we have a lawful basis to do so (either with your consent or where we have a legitimate interest to do so);
(h) to carry out research about general engagement with our books, products, services and the publishing industry generally (either on the basis of your consent where we have requested it, or our legitimate interest in providing the right kinds of products and services to our website users);
(i) to deal with feedback, enquiries or complaints about our books or other products, website or apps and share your information with our website developer, IT support provider, warehouse and delivery service provider, payment services provider as necessary to provide the required support (on the basis of our legitimate interest in providing the correct products and services to you);
(j) to carry out sales and other data analysis (on the basis of our legitimate interests to measure and improve our purchase, distribution and sales performance management);
(k) to further our company inclusivity and diversity goals (on the basis of your consent where required or where we have a legitimate interest in pursuing such goals and there are substantial public interest reasons for doing so);
(l) to share your personal information with selected third parties such as:
i. 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); and
ii. social media platforms (such as Facebook) so that relevant adverts may be selected and served to you, and others who are similar to you, via those platforms (on the basis of our legitimate interests to market our products to you and others who have similar preferences to you).
iii. Business partners and other third-party service providers to enhance, modify or otherwise improve their services (on the basis of our legitimate interests to ensure such third parties are providing the best possible service to us).
31. WHO WE MIGHT SHARE YOUR INFORMATION WITH
31.1 In addition to the parties listed in paragraphs 30 and 5.1 above, the third parties with whom we work to deliver our business and with whom we might share your personal information include:
(a) e-commerce providers (e.g. Shopify),
(b) courier and transport providers (e.g. DHL);
(c) competition, newsletter and survey providers e.g. Adestra);
(d) ticket sales providers (e.g. Eventbrite);
(e) invoice and payment service providers (e.g. Basware);
(f) editorial and advertisement production service providers;
(g) building security service providers (e.g. Evolution); and
(h) technical assistance and support service providers.