THE BOOK SERVICE LIMITED PRIVACY NOTICE

1. INTRODUCTION

1.1 This privacy notice (Privacy Notice) sets out the ways in which we, The Random House Group Limited, Penguin Books Limited and The Book Service Limited, also trading as Grantham Book Services (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 Customer, a Client, or an independent contractor (including freelancers) and prospective employee (each a Group).

1.3 Paragraphs 1 to 10 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 http://www.thebookservice.co.uk.

2. ABOUT US

2.1 We are companies registered in England under company numbers 00954009 (The Random House Group Limited), 00861590 (Penguin Books Limited) and 00453161 (The Book Service Limited).

2.2 You can contact as follows:

FAO: The Legal Department

Address: 20 Vauxhall Bridge Road, London SW1V 2SA

Email: legal@penguinrandomhouse.co.uk

3. INFORMATION WE COLLECT ABOUT YOU

3.1 Depending on which Group you fall into, further detail on the information we collect about you can be found here:

Customers
Clients
Independent contractors (including freelancers) and prospective employees

3.2 The following applies to all Groups:

3.2.1 if you are a visitor to this website we will 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 a third-party website analytics service provider on our behalf. For more information on cookies and what you can do to disable certain cookies on our websites, please read our Cookie Policy. ; or

3.2.2 if you contact us (whether using a query button on our website or by email, telephone), we will collect any information contained in any correspondence between us.

3.3 In certain circumstances, we may 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.

4. THE BASIS ON WHICH WE PROCESS YOUR INFORMATION

4.1 We will only ever use your personal data on the following grounds:

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 4.4 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:.

Customers
Clients
Independent contractors (including freelancers) and prospective employees

4.3 No matter which Group you fall into, we may use your information:

4.3.1 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);

4.3.2 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/or

4.3.3 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).

4.4 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:

4.4.1 personalising, enhancing, modifying or otherwise improving the services and/or communications that we provide to you;

4.4.2 detecting and preventing fraud and operating a safe and lawful business; and

4.4.3 improving security and optimisation of our network, sites and services.

4.5 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, 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 is included here;

Customers - who we might share information with
Clients - who we might share information with
Independent contractors (including freelancers) and prospective employees - who we might share information with

5.1.2 any selected third party that you consent to our sharing your information with for marketing purposes;

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

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.

6. COOKIES

6.1 We use cookies to ensure that you get the most out of our website. Please find further details in our Cookie Policy.

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; and

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 it is current (i.e. it is necessary to provide you with the services that you have requested from us). We may, however, retain the information for longer periods where it may reasonably be required for legal proceedings, to deal with tax issues, 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.

8. INTERNATIONAL TRANSFERS OF YOUR INFORMATION

8.1 Our businesses are located in the UK and Ireland, but we also have group companies in the USA, Australia, New Zealand, Canada, Spain, South Africa, China and India with whom we may share your personal information.

8.2 Your personal information will generally not be processed outside of the European Economic Area (EEA), except where we are sharing your information with one of our group companies or where we use a third party service provider with servers located outside the EEA. We take all steps necessary to ensure that any of your information which is passed to our group companies is adequately protected and processed in accordance with this Privacy Notice, including but not limited to using all appropriate cross-border transfer solutions such as the European Commission's Standard Contractual Clauses or the EU-US Privacy Shield Framework. The steps we take in relation to each territory are as follows:

8.2.1 USA, Australia, China and India group companies: personal information is transferred via the European Commission's Standard Contractual Clauses; and

8.2.2 New Zealand and Canada group companies: the European Commission has determined that personal data can safely be exported to these territories without any further safeguards in place.

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 not giving us consent where we ask for it, unsubscribing or otherwise updating your marketing preferences via your account with 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 any website user account even when you have requested not to receive marketing communications.

9.4 Please note that you are entitled to request one detailed summary of any information we are holding about you in accordance with paragraph 9.1.2 at no cost, but for any further summaries, we reserve the right to charge a reasonable fee based on administration costs.

9.5 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:

9.5.1 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;

9.5.2 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;

9.5.3 the right to object to our using your information on the basis of our legitimate interests (refer to paragraph 4 above to see when we are relying on our legitimate interests);

9.5.4 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

9.5.5 the right to ask us to rectify, limit, cease processing or erase information we hold about you in certain circumstances.

9.6 You may contact us with the details at the top of this Privacy Notice if you wish to action any of these additional rights.

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 updated on 17.05.18.

Schedule 1 – Customers

11. INFORMATION WE MAY COLLECT ABOUT YOU

11.1 Information that you provide to us

11.1.1 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;

(b) create a trade or other account with us; and/or

11.1.2 The information you provide to us might include:

(a) your name, home, work and/or business address, email, telephone number;

(b) 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).

11.2 Information we receive from third parties

11.2.1 In certain circumstances, we will receive information about you from third parties. For example,

(a) If you are purchasing books from a third party publisher for whom we distribute, we will receive details about you from that third party publisher;

(b) we may take information about you from your or your company’s website;

(c) we will receive credit information about you where have conducted a credit reference check on you (with your consent); and/or

(d) we may receive your signature from our delivery partners (i.e. anything you have signed to confirm receipt of the products we have delivered to you).

12. HOW WE USE INFORMATION ABOUT YOU AND RECIPIENTS OF YOUR INFORMATION

12.1 We may use your information for the following purposes:

12.1.1 to administer orders you make, and to share your information with our delivery service providers (on the basis of performing our contract with you);

12.1.2 to carry out research about general engagement with our website, products, services, and the publishing and distribution 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 Customers); and/or

12.1.3 to provide customer service and support (on the basis of our contract with you), deal with enquiries or complaints about our products and services and share your information with our website developer, IT support provider, 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).

13. WHO WE MIGHT SHARE YOUR INFORMATION WITH

13.1 In addition to the parties listed in paragraph 5.1.1 above, the third parties with whom we work to deliver our business and with whom we might share your personal information include:

(a) freight, courier and transport providers (e.g. DHL);

(b) our Clients (i.e. third party publishing clients);

(d) credit agencies and insurers (e.g. Experian, Euler Hermes and Atradius); and

(e) technical assistance and support service providers.

Schedule 2 – Clients

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;

(b) create a trade or other account with us; and/or

14.1.2 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 you are purchasing a product or service from us);

(d) password and log-in details (if you create an account).

14.2 Information we receive from third parties

In certain circumstances, we will receive information about you from third parties. For example, we may take information about you from your, or your company’s, website.

15. HOW WE USE INFORMATION ABOUT YOU AND RECIPIENTS OF YOUR INFORMATION

15.1 We may use your information for the following purposes:

15.1.1 to make deliveries on your behalf, and to share your information with our delivery service providers (on the basis of performing our contract with you);

15.1.2 to carry out research about general engagement with our website, products, services, and the publishing and distribution industry generally (either on the basis of your consent where we have requested it, or our legitimate interest in improving our services to Clients and Customers);

15.1.3 to provide Client service and support (on the basis of our contract with you), deal with enquiries or complaints about our products and services and share your information with our website developer, IT support provider, 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);

15.1.4 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 /or

15.1.5 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).

16. WHO WE MIGHT SHARE YOUR INFORMATION WITH

16.1 In addition to the parties listed in paragraph 5.1.1 above, the third parties with whom we work to deliver our business and with whom we might share your personal information include:

16.1.1 courier and transport services (e.g. DHL)

16.1.2 invoice and payment service providers; and

16.1.3 technical assistance and support service providers.

Schedule 3 – Independent contractors (including freelancers) and prospective employees

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) negotiate and/or enter into a contract with us for you or your company/employer to provide products or services to us; and/or

(b) submit an application to a job vacancy.

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 a product or service); and/or

(c) details of your academic and work history, references and any other such similar information (if you are submitting a job application to us).

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 your professional history. For example, we may conduct Google and other public searches (such as LinkedIn) to verify information about you and/or your services; and

(b) if you are a job applicant we may conduct Google or LinkedIn searches, or contact your referees to provide information about you.

18. HOW WE USE INFORMATION ABOUT YOU AND RECIPIENTS OF YOUR INFORMATION

18.1 We may use your information for the following purposes:

18.1.1 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);

18.1.2 to process any job applications you submit to us including sharing this with our third party recruitment agency;

18.1.3 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

18.1.4 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 paragraph 5.1.1 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; and