References to “an individual” or “individuals” are to individuals using our websites or otherwise with whom we have contact or other dealings (whether on behalf of themselves, or their business or another individual or organisation).
1 IMPORTANT INFORMATION
This version was last updated on 21 June 2018.
It is important that the personal data we hold about individuals is accurate and current. Individuals should keep us informed if their personal data changes during their relationship with us.
Our website is not intended for children and we do not knowingly collect data relating to children.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
2 WHO WE ARE
The Online Book Company provides bespoke digital books, customised for each client, which are operated on our viewer platform. Our customers may display the book on their websites and we will host the software to enable them to do this. We also provide App services, allowing words, images and donations to be added directly to a customer’s online book. We most commonly provide our products / services to business customers and occasionally to consumer customers.
We are bound by applicable data protection laws in respect of the handling and collection of your personal data. The Online Book Company is registered as a data controller in England and Wales, with the Information Commissioner’s Office (ICO) under the ICO number Z3137672.
3 BASIS FOR PROCESSING PERSONAL DATA
This policy only applies to the processing that we carry out as a Data Controller.
When our business customers (such as charities) order our products or use our services, for example by sending us information for inclusion within a digital book, such data may include the personal data of members of the public or of the customers of our business customers.
We provide our services in this way as a Data Processor on behalf of such customers, our customers are the Data Controller of the information. They are responsible for how personal data is used when purchasing and using our products and services. If you have any specific queries or concerns about how other services have been used by our customer, you should contact the relevant organisation (our customer) in their capacity as a controller.
The legal basis on which we process an individual’s personal data in these circumstances is our legitimate interest to assist individuals with queries, grow our business and to provide good customer service.
We will also process personal data for the purposes of making our website more secure, and to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
The legal basis on which we process personal data in these circumstances is our legitimate interest to provide an individual with the best experience we can, keep our website updated and relevant, study how individuals use our services, to inform our marketing strategy and to ensure that our website is kept secure.
Business customers: We may send marketing to business customers relating to the products and services they can purchase from us. The legal basis we rely on to engage with our customers in this way is our shared legitimate interests in doing business together. Any individual that receives any such marketing is entitled to exercise their right to object to receiving such marketing communications by contacting us (please see sections 9 and 10).
Consumers: We will only send direct marketing communications to consumers if the individual has provided their express, opt-in consent. Individuals can withdraw their consent at any time by contacting us (please see section 10) or, by following the unsubscribe link in every marketing communication received from us.
If an individual does choose to object to the communications, unsubscribe or withdraw their consent, this will not mean that our processing of such individual’s personal data before they withdrew their consent was unlawful.
The legal basis on which we process personal data in these circumstances is our legitimate interest to remain transparent in our use of individuals’ personal data and to ensure individuals are kept updated on how and why we process their personal data.
Please note that we may process an individual’s personal data without knowledge or consent, where this is required or permitted by law.
4 CATEGORIES OF INFORMATION WE COLLECT FROM INDIVIDUALS
Information individuals give us: Individuals (such as individuals working for and on behalf of a customer) may provide their personal data when corresponding with us by post, phone, email or otherwise. This includes personal data provided when an individual:
- purchases our products or services;
- registers with us or opens a user account;
- contacts us using the details provided on our website;
- comments, writes dedications or posts other material on our website;
- applies for a job with us;
- requests marketing to be sent to them;
- completes a survey; or
- gives us some feedback.
However, our business customers may process this type of data in their capacity as a controller.
5 DISCLOSURES OF INDIVIDUALS’ PERSONAL DATA
For the purposes set out in section 3, we may have to share individuals’ personal data with the following parties:
External Third Parties such as:
- Service providers acting as processors based in the UK who provide IT and system administration services.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, insurers and employment and recruitment agencies based in the UK (or other relevant jurisdictions) who provide consultancy, banking, legal, insurance, accounting and recruitment services.
- Credit reference agencies.
- Debt collection agencies.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the UK (or other relevant jurisdictions) who require reporting of processing activities in certain circumstances.
- Other third party companies where we have an agreement in place and only where an individual has agreed that we may share their Identity and Contact Data with them.
Specific Third Parties such as:
- Sendgrid based in the USA who provide us with email services
- Microsoft based in the USA who provide us with email services
- UKFast based in UK who provide web hosting services.
- WP-Engine based in Ireland who host our online donations sites.
- Stripe based in USA who provide payment processing services.
- PayPal based in Luxemburg who provide payment processing services.
- CloudSwipe based in USA who provide payment processing services.
- Salesforce based in USA who provide CRM services
We require all third parties to respect the security of individuals’ personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use individuals’ personal data for their own purposes and only permit them to process individuals’ personal data for specified purposes and in accordance with our instructions.
6 INTERNATIONAL TRANSFERS
Individuals or customers who access our website may be based outside the European Union (EU) so the processing of their personal data will involve the transfer and storage of data outside the EU. Some of our suppliers are based outside the EU.
Whenever we transfer an individual’s personal data out of the EU, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer the personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.
Please contact us if you want further information on the specific mechanism used by us when transferring personal data out of the EU.
7 DATA SECURITY
We have put in place appropriate security measures to prevent personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to individuals’ personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify the individuals involved and any applicable regulator of a breach where we are legally required to do so.
8 DATA RETENTION
How long will you use an individual’s personal data for?
In some circumstances we may anonymise personal data (so that it can no longer be associated with an individual) for research or statistical purposes in which case we may use this information indefinitely without further notice to that individual.
9 INDIVIDUALS’ LEGAL RIGHTS
Under certain circumstances, individuals have rights under data protection laws in relation to their personal data. Individuals may have the right to: 9.1.1
Individuals wishing to exercise any of the rights set out above should contact us directly.
Individuals have the right to make a complaint at any time to the ICO, the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with concerns before you approach the ICO so please contact us in the first instance.
Individuals will not have to pay a fee to access their personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if their request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with their request in these circumstances.
We may need to request specific information from individuals to help us confirm their identity and ensure their right to access personal data (or to exercise any of their other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact individuals to ask for further information in relation to their request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if an individual’s request is particularly complex or they have made a number of requests. In this case, we will notify the individual and keep them updated.
10 CONTACT DETAILS
|Our full details are:|
|Full name of legal entity:||The Online Book Company Limited|
|Postal address:||The Online Book Company Limited|
|5 Stratton Terrace|
|Telephone number:||+44 (0) 1872 226800|