1 INTRODUCTION
1.1 Post Wave Publishing UK Limited is a UK-based book publisher registered in England under company number 14838766.
1.2 We are a “data controller” for the purposes of the EU General Data Protection Regulation, the UK General Data Protection Regulation and the UK Data Protection Act 2018 (as amended from time to time) (“Data Protection Law”). This means that we are responsible for and control the processing of your personal information (which means information that identifies you or could identify you).
1.3 We are committed to protecting your personal information and being transparent about the personal information we hold and how we use it.
1.4 This Privacy Notice, together with our Cookie Policy, sets out how Post Wave Publishing UK Ltd. (we, us, our),
- collects and uses your personal data (your personal information) in connection with our business;
- what rights you have to access or change your personal data.
1.5 You have rights and choices regarding your information and if you have any concerns about our processing, please refer to details of YOUR CONTROL OVER YOUR INFORMATION.
1.6 You can contact us as follows:
FAO: Data Protection Officer
Address:
Runway East Bloomsbury,
24-28 Bloomsbury Way,
London, WC1A 2SN
Email: uk.dataprotection@postwavepublishing.com
2 WHEN AND HOW WE COLLECT PERSONAL INFORMATION
2.1 We will collect information if you:
2.1.1 Interact or correspond with us (in letters, phone, SMS, email or via our website);
2.1.2 Subscribe to our mailing lists;
2.1.3 Submit manuscripts and materials to us (via post, email or our website);
2.1.4 Apply to a job vacancy;
2.1.5 Provide us with biographical information (e.g. by completing an author/illustrator questionnaire);
2.1.6 Order books or other products from our website;
2.1.7 Enter a competition or prize draw;
2.1.8 If you are a Post Wave author/illustrator.
In the case of authors/illustrators, we will:
2.2.1 use third-party databases or websites to confirm your publication history;
2.2.2 receive information about you from third parties if they are referring you to us for publication. For example, if you have a literary agent or co-author/illustrator making submissions on your behalf, your agent will provide us with information about you.
2.2.1 if you give permission for us to contact you to a bookseller or other third party running a competition or other event involving one of our books or authors/illustrators.
2.3 If you are a prospective employee, joining us for work experience or a volunteering programme we may:
2.3.1 contact your referees to provide information about you;
2.4 If you visit our website, we may:
2.4.1 collect site usage information like your location, device type, browsing history on our site, how long you stay, browser type, referral source, and search queries you make.
2.4.2 We use cookies to gather this information. Cookies are small pieces of data stored on your device. Cookies are placed by us on our website and may be provided by third parties (e.g. Google Analytics). Cookie-based information may be collected by third parties (e.g. Google and Facebook).
2.4.3 This information may be shared with our website hosts and developers, and it may be collected by third-party analytics service providers (e.g. Google Analytics) and other third parties (such as Facebook).
2.4.4 You can control cookies. You can learn more about cookies and how to turn them off in our Cookie Policy. However, turning off cookies on our site might not affect cookies from other websites you’ve visited. You may need to adjust settings on your device or browser to fully control your cookie preferences.
2.5 If you follow us on Twitter, Facebook or similar social media platforms or use social media to log in to our website the relevant platform will collect information about you in accordance with their privacy policies. If you wish to change the way that your data is processed because of your use of a particular social media platform then you will need to change your settings on that platform.
2.6 Social media platforms likely use your data for personalized ads and sharing activity with other users, but we don’t. We only see publicly shared content and may delete it or communicate with you through the platform for public relations purposes.
2.7 Information from Third Parties
2.7.1 In certain circumstances, we will receive information about you from third parties.
2.7.2 If you have indicated to a 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).
2.7.3 If you are an author/illustrator, we might check other sources (websites or databases) to see if you’ve published anything before.
2.7.4 If you are an author/illustrator and someone else submits your work to us (like your agent or co-author/illustrator), they’ll give us some information about you.
2.7.6 If you are a potential employee, joining us for work experience or a volunteering programme we may contact the people you listed as references to learn more about you.
2.7.7 If you let someone (like a bookseller or contest organizer) share your info with us, we might use it.
2.7.8 We might share your info with publishers and distributors we work with for distribution or rights acquisition.
3 CHILDREN
3.1 If we are processing information from children under 13, we will require parental consent procedures.
4 THE INFORMATION WE COLLECT
4.1 The information we collect depends on how you interact with us. We may collect information including:
4.1.1 Contact Information: Your name, address, email address, and phone number.
4.1.2 Browsing Information: Your IP address, browsing history on their website, and information about the device you use.
4.1.3 Account Information: Your username and password if you create an account.
4.1.4 Payment Information: Your credit card or debit card information if you purchase something.
4.1.5 Information You Provide: Information you submit such as your date of birth, reading preferences, or details about your submissions (author/illustrator)
4.1.6 Social Media Information: If you allow it, information from your social media profiles (e.g., Facebook) for targeted advertising.
4.2 Unless communicated to us by you as part of a submission, survey, or other deliberate communication with us by you, we do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
5 THE LEGAL BASIS FOR USING YOUR INFORMATION
We use your personal information on the following legal basis:
5.1.1 Performance of any contract there is between us to provide services;
5.1.2 your consent when it is requested;
5.1.3 our legitimate interest (see 6.1.3 below);
5.1.4 compliance with our legal obligations.
5.2 We will use your information on the above grounds to:
5.2.1 Provide you with access to our website in a manner that is optimal, convenient and personalised.
5.2.2 For marketing communications about our news, events, authors/illustrators or books, including sending you newsletters.
5.2.3 Tell you about new website features or services
5.2.4 To protect, investigate, and deter against fraudulent, unauthorised, or illegal activity
6 HOW WE USE YOUR INFORMATION
6.1 We might use your information for a variety of reasons, but they will always rely on a legal basis to do so and will be in accordance with at least one of the legal reasons allowed by Data Protection Law. Here’s a breakdown of the main reasons:
6.1.1 Fulfilling Contracts or Agreements to provide a service: This could include processing your orders, providing customer service, and administering author/illustrator or other contracts between us.
6.1.2 Marketing Communications: We may use your information for marketing communications (newsletters, emails about new books, new website features, etc), website personalisation, or sharing your information with partners (with your permission). You can always withdraw your consent to this.
6.1.3 Legitimate Interests: This means using your information for normal business reasons, as long as it doesn’t unfairly impact you.
6.1.4 “We will not use your information if we believe your interests are more important than ours, unless we have your consent or a legal requirement to do so.”
Examples of the use of information for legitimate interests include:
6.2.1 Website Optimization: Keeping our website secure and running smoothly, and tailoring content to your interests.
6.2.2 Fraud Prevention: Protecting against fraudulent, unauthorized or illegal activity and improving security of our sites and services.
6.2.3 Market Research: Analyzing website usage and reader engagement to improve our products and services.
6.2.4 Targeted Advertising: Delivering relevant ads to you on our website and social media platforms with your consent.
6.2.5 Automated technologies and interactions: As you interact with our website, we may analyse your personal information to create a profile of your interests and preferences so that we can contact you programmatically with information relevant to you. We may make use of additional information about you when it is available from third-party sources to help us do this effectively.
6.2.6 Processing job applications of potential employees and those joining us for work experience or a volunteering programme.
6.2.7 Processing author/illustrator submissions.
7 WHO WE SHARE OUR INFORMATION WITH
We share your information with a few different categories of parties to run their business and improve your experience. Please see Schedule 1 for more details as to what information we keep, and what we do with it for these different categories. We take steps to make sure all these parties keep your information secure (please see HOW WE PROTECT YOUR INFORMATION).
7.1.1 Staff working within Post Wave UK working on our manuscripts, illustrations, orders or other requests.
7.1.2 Third-Party Service Providers: companies that help us run our website, manage databases, handle marketing, or provide other services. This could include website developers, marketing agencies, warehousing companies, and in the case of online shopping, payment processors.
7.1.3 Selected publishing partners or authors/illustrators (for co-published books, etc.).
7.1.4 Marketing partners (with your consent for targeted advertising).
7.1.5 Legal or financial advisors, auditors, or regulatory bodies, courts and government agencies in some cases if we are required to enforce our legal rights, or to protect the rights, property or safety of our employees or where such disclosure is permitted or required by law and when we have a legal obligation to do so.
7.1.6 When you give your consent, we may share your information with specific marketing partners you approve of. In these cases, the third party will have its own privacy policy that governs how they use your information.
7.2 Third-Party Protection: we require all third parties to sign agreements to protect your information.
7.3 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. They may update the list of third parties they work with, and you can always check their privacy policy for the latest information.
8 HOW WE PROTECT YOUR INFORMATION
8.1 We take your privacy seriously. To keep your information safe, we use the following principles and systems:
8.1.1 Limited Information: We only collect the information we need to fulfil your requests and operate effectively.
8.1.2 Security by Design: We consider security from the very beginning when developing new systems and processes and always look for ways to minimize the amount of personal data we store by anonymizing it whenever possible.
8.1.3 Secure Systems: We use strong security measures to protect your information, including:
8.1.3.1 Physical security for our buildings and equipment.
8.1.3.2 Password protection and encryption for all our digital systems.
8.1.3.3 Limiting access to your information to only those who need it for their job duties.
8.1.3.4 Maintaining a data protection policy for our employees.
8.2 By following these practices, we aim to prevent unauthorized access, unlawful use, or accidental loss of your information.
9 HOW LONG WE KEEP YOUR INFORMATION
9.1 We will only keep your personal data for as long as we need it to fulfil the purpose.
9.2 How long we keep your information 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.
9.3 We may retain your personal data for a longer period in the event of a legal complaint or proceedings.
9.4 If you want to know more about how long we hold your information, please 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. The following offers a guideline for some specific circumstances:
9.4.1 To fulfil your requests: We keep information like order details and customer service inquiries for about 7 years.
9.4.2 Legal and regulatory reasons: Sometimes the law requires us to hold information for a certain period.
9.4.3 Marketing preferences: We keep track of your marketing preferences for up to 2 years after your last interaction with us.
9.4.4 Job applications: Unsuccessful job applications are deleted after the recruitment process unless otherwise requested.
9.4.5 Unwanted contact list: We maintain a suppression list of stored email addresses of people who don’t want to hear from us.
9.5 We regularly review the information we hold and delete anything we no longer need to protect your privacy and reduce the amount of data we store.
10 INTERNATIONAL TRANSFERS OF INFORMATION
10.1 Our company is located in the UK. In some cases, we may share your information with companies outside the UK.
10.2 We have staff in Germany, the USA and China and may share your information with them when necessary to support the purposes for which the data was collected, such as content production or administrative support.
10.3 We work with external suppliers and third parties to support our services (e.g., customer service, marketing). These companies may be located in places like the USA or the European Economic Area (EEA), or China.
10.4 Whenever we transfer your personal information internationally, we will take all steps necessary to ensure that it is adequately protected and processed in accordance with this Privacy Notice by using all appropriate cross-border transfer safeguards such as:
10.5 by entering into the European Commission’s Standard Contractual Clauses which gives personal data the same protection it has in the EEA; and where the provider is in the US, the EU-US Privacy Shield if the provider is part of the EU-US Privacy Shield Framework; and where the provider is in China, the Personal Information Protection Law (PIPL)
10.6 If you’d like to know more about how we protect your information in specific situations, please contact us.
11 YOUR CONTROL OVER YOUR INFORMATION
11.1 We want you to be in control of your information. Here’s what you can do:
11.1.1 Access Your Information: You can request a copy of the information we hold about you to verify its accuracy. Please note that this right entitles you to receive a copy of the personal data that we hold about you 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.
11.1.2 Correct Mistakes: If any information is wrong, you can ask us to rectify it, or, if incomplete, complete it.
11.1.3 Delete Your Information (the right to be forgotten): You can request that we delete your information. We are not always obliged to erase personal data if we believe there is a good legal reason to continue to process personal data.
11.1.4 Restrict Use of Your Information: You can limit how we use your information for marketing purposes.
11.1.5 Object to Processing: You can object to how we use your information based on our legitimate interests if you feel that doing so impacts your rights and freedoms or if you feel the legitimate interests involved are not valid.
11.1.6 Stop Marketing Messages: You can opt out of receiving marketing emails from us. You can do this by using the ‘unsubscribe’ link that appears in the footer of each communication.
11.1.7 Transfer Your Information: You can request your information in a format that allows you to transfer it to another service provider.
11.1.8 Withdraw Consent: If you previously consented to us using your information for a specific purpose, you can withdraw your consent at any time.
You can also prevent processing for marketing activities by checking certain boxes on forms, unsubscribing and similar actions that we use to collect your data to tell us that you don’t want to be involved in marketing.
11.3 If you wish to exercise any of the rights set out above, please contact us at: uk.dataprotection@postwavepublishing.com
12 YOUR CALIFORNIA PRIVACY RIGHTS
12.1 If you are a resident of California, USA under the California Consumer Privacy Act, residents of California have certain rights in relation to their personal data. These rights include:
12.1.1 Right to Know: You have the right to request access to any personal data we hold on you in the past 12 months.
12.1.2 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.
12.1.3 Right to Deletion: You have the right to request that we delete any personal data we hold on you.
12.1.4 Right to Non-Discrimination: We will not discriminate against you for exercising any of the above rights.
12.1.5 If you wish to exercise any of the rights set out above, please contact us at: us.dataprotection@postwavepublishing.com
13 YOUR RIGHT TO COMPLAIN
13.1 Please contact us if you have any questions or are unhappy about the way your information is used. We hope we will be able to resolve any problems or issues you may have. There may be limitations on these rights in certain situations. We’ll explain those limitations if they apply to your request.
You also have the right to complain to the UK Information Commissioner’s Office (https://ico.org.uk/) if you’re unhappy with how we handle your information or the relevant authority in your country of work or residence.
14 CHANGES OF PURPOSE
14.1 We will only use your personal data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
14.2 If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
15 CHANGES TO THIS PRIVACY NOTICE
15.1 We will update our site with any changes or notify you by email of any material changes.
15.2 This Privacy Notice was updated on 01.07.2024
SCHEDULE 1
15.3 This schedule provides further specific information about how we collect and use information about different groups of people.
15.4 Readers/Purchasers:
15.4.1 Information you provide: contact details, purchase history, social media handles, feedback, survey responses (including diversity and inclusion).
15.4.2 Information we might collect: publicly available information online.
15.4.3 How we might use it: order processing, marketing (with consent or based on legitimate interest), customer service, research, diversity and inclusion goals.
15.4.4 Sharing with third parties: payment processors, warehouses, delivery services, marketing service providers, social media platforms (for advertising).
15.5 Authors/illustrators, Agents & Prospective Writers:
15.5.1 Information you provide: contact details, payment details (if applicable), manuscript, diversity and inclusion information (optional).
15.5.2 Information we might collect: information from third parties (e.g., verification, sales data), information from co-authors/illustrators or agents.
15.5.3 How we might use it: manuscript review and processing, publishing contract administration, travel arrangements (with consent), research, diversity and inclusion goals, legal/security purposes.
15.5.4 Sharing with third parties: editorial and production service providers, payment processors, travel providers, technical support.
15.5.5 Prospective Employees, Work Experience, Internships and Volunteering Programmes:
15.5.6 Information you provide: contact details, work history, references, diversity and inclusion information (optional).
15.5.7 Information we might collect: information from third parties (e.g., recruitment agencies, public searches).
15.5.8 How we might use it: application processing (with consent), legal/security purposes, diversity and inclusion goals.
15.5.9 Sharing with third parties: recruitment agencies, volunteering partners, technical support.
15.6 Independent Contractors including Freelancers:
15.6.1 Information you provide: contact details, payment details, work history, references, diversity and inclusion information (optional)
15.6.2 Information we might collect: information from third parties (e.g., verification of professional history)
15.6.3 How we might use it: contracting, research, legal/security purposes, diversity and inclusion goals
15.6.4 Sharing with third parties: payment processors, technical support
15.7 Journalists, Influencers & Reviewers:
15.7.1 Information you provide: contact details, social media handles, payment details (if applicable), content creation, survey responses (including diversity and inclusion).
15.7.2 Information we might collect: information from third parties (e.g., media databases, agents), publicly available information online.
15.7.3 How we use it: social media promotion, event invitations, contract administration (payment), product fulfilment, travel arrangements (with consent), marketing (with consent or based on legitimate interest), research, customer service, data analysis, diversity, and inclusion goals.
15.7.4 Sharing with third parties: payment processors, warehouses, delivery services, marketing service providers, social media platforms (for advertising).