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 9 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 https://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: Data Protection
Address: One Embassy Gardens, 8 Viaduct Gardens, London SW11 7BW
Email: ukdataprotection@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 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); 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;
4.4.4 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).
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 8 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: freight and transport services, 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
Clients
Independent contractors (including freelancers) and prospective employees
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. 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:
7.2 ensuring the physical security of our offices, warehouses or other sites;
7.3 ensuring the physical and digital security of our equipment and devices by using appropriate password protection and encryption;
7.4 maintaining a data protection policy for, and delivering data protection training to, our employees;
7.5 limiting access to your personal information to those in our company who need to use it in the course of their work; and
7.6 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. HOW LONG WE KEEP YOUR DATA
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 INFORMATION
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. CHANGES TO THIS PRIVACY NOTICE
11.1 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 20.10.2023
12. INFORMATION WE MAY COLLECT ABOUT YOU
12.1 Information that you provide to us
12.1.1 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
(c) make an order with us.
12.1.2 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);
(c) a recording of any telephone calls we have with you; or
(d) password and log-in details (if you create an account).
12.2 Information we receive from third parties
12.2.1 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); 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).
13. HOW WE USE INFORMATION ABOUT YOU AND RECIPIENTS OF YOUR INFORMATION
13.1 We may use your information for the following purposes:
13.1.1 to administer orders you make, and to share your information with our delivery service providers (on the basis of performing our contract with you);
13.1.2 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
13.1.3 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).
13.1.4 to carry out credit checks by exchanging information about you with credit reference agencies on an ongoing basis, including about your settled accounts and any debts not fully repaid on time (on the basis of our legitimate interest to ensure our customers are able to meet their payment obligations). Credits reference agencies will share your information with other organisations. For more detail please see: http://www.experian.co.uk/crain/
14. WHO WE MIGHT SHARE YOUR INFORMATION WITH
14.1 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);
(c) payment services providers (e.g. Batch);
(d) credit agencies and insurers (e.g. Experian, Euler Hermes and Atradius); and
(e) technical assistance and support service providers.
15. INFORMATION WE MAY COLLECT ABOUT YOU
15.1 Information that you provide to us
15.1.1 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
(c) make an order with us.
15.1.2 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);
(c) a recording of any telephone calls we have with you;
(d) password and log-in details (if you create an account).
15.2 Information we receive from third parties
15.2.1 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.
16. HOW WE USE INFORMATION ABOUT YOU AND RECIPIENTS OF YOUR INFORMATION
16.1 We may use your information for the following purposes:
16.1.1 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);
16.1.2 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);
16.1.3 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);
16.1.4 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
16.1.5 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).
17. WHO WE MIGHT SHARE YOUR INFORMATION WITH
17.1 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:
17.1.1 courier and transport services (e.g. DHL)
17.1.2 invoice and payment service providers; and
17.1.3 technical assistance and support service providers.
18. INFORMATION WE MAY COLLECT ABOUT YOU
18.1 Information that you provide to us
18.1.1 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.
18.1.2 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).
18.2 Information we receive from third parties
18.2.1 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.
19. HOW WE USE INFORMATION ABOUT YOU AND RECIPIENTS OF YOUR INFORMATION
19.1 We may use your information for the following purposes:
19.1.1 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);
19.1.2 to process any job applications you submit to us including sharing this with our third party recruitment agency;
19.1.3 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
19.1.4 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).
20. WHO WE MIGHT SHARE YOUR INFORMATION WITH
20.1 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:
20.1.1 courier and transport providers (e.g. DHL);
20.1.2 invoice and payment service providers; and
20.1.3 technical assistance and support service providers.