- Explaining the legal bases we rely on
- When do we collect your personal data?
- What sort of personal data do we collect?
- How and why do we use your personal data?
- How we protect your personal data
- How long will we keep your personal data?
- Who do we share your personal data with?
- Where your personal data may be processed
- What are your rights over your personal data?
- How can you stop the use of your personal data for direct marketing?
- Contacting the Regulator
- Any questions?
We know that there’s a lot of information here, but we want you to be fully informed about your rights, and how The Book People uses your data.
We hope the following sections will answer any questions you have but if not, please do get in touch with us.
2. Explaining the legal bases we rely on
The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:
In specific situations, we can collect and process your data with your consent.
For example, when you tick a box to receive email newsletters.
When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service.
In certain circumstances, we need your personal data to comply with our contractual obligations.
For example, if you order products from us, we’ll collect your address details to deliver your purchase.
If the law requires us to, we may need to collect and process your data.
For example, we can pass on details of people involved in fraud or other criminal activity affecting The Book People to law enforcement.
In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.
For example, we will use your purchase history to send you or make available personalised offers.
We also combine the purchase history of our customers to identify trends and ensure we can keep up with demand or develop new products/services.
We will also use your address details to send you direct marketing information by post, telling you about products and services that we think might interest you.
3. When do we collect your personal data?
- When you visit any of our websites, and use your account to buy products and services, or redeem vouchers on the phone or online.
- When you create an account with us.
- When you engage with us on social media.
- When you contact us by any means with queries, complaints etc.
- When you ask us to email you information about a product or service.
- When you enter prize draws or competitions.
- When you choose to complete any surveys we send you.
- When you comment on or review our products and services.
- When you've given a third party permission to share with us the information they hold about you.
4. What sort of personal data do we collect?
- If you have a web account with us: your name, gender, date of birth, billing/delivery address, orders and receipts, email and telephone number. [For your security, we’ll also keep an encrypted record of your login password.]
- Details of your interactions with us through contact centers, or online.
For example, we collect notes from our conversations with you, details of any complaints or comments you make, details of purchases you made, items viewed or added to your basket, vouchers, redemptions, web pages you visit and how and when you contact us.
- Copies of documents you provide to prove your age or identity where the law requires this, (including your passport and driver's licence). This will include details of your full name, address, date of birth and facial image. If you provide a passport, the data will also include your place of birth, gender and nationality.
- Details of your visits to our websites or apps, and which site you came from to ours.
- Personal details which help us to recommend items of interest.
For instance, you might tell us that you have an interest in travel, which we will use to guide our suggested products.
We’ll only ask for and use your personal data collected for recommending items of interest. Of course, it’s always your choice whether you share such details with us.
- Payment card information.
- Your comments and reviews.
- To deliver the best possible web experience, we collect technical information about your internet connection and browser, the web pages viewed during your visit, the advertisements you clicked on, and any search terms you entered. [Learn more about this – cookies policy hyperlink.]
- Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.
5. How and why do we use your personal data?
We want to give you the best possible customer experience. One way to achieve that is to get the richest picture we can of who you are by combining the data we have about you.
We then use this to offer you promotions, products and services that are most likely to interest you.
The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service.
Of course, if you wish to change how we use your data, you’ll find details in the ‘What are my rights?’ section below.
Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services you’ve asked for.
Here’s how we’ll use your personal data and why:
- To process any product orders that you make by using our websites. If we don’t collect your personal data, we won’t be able to process your order and comply with our legal obligations.
For example, your details may need to be passed to a third party to supply or deliver the product you ordered, and we may keep your details for a reasonable period afterwards in order to fulfil any contractual obligations such as refunds, guarantees and so on.
- To respond to your queries, refund requests and complaints. Handling the information you sent enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.
- To protect our business and your account from fraud and other illegal activities. This includes using your personal data to maintain, update and safeguard your account. We’ll also monitor your browsing activity with us to quickly identify and resolve any problems and protect the integrity of our websites. We’ll do all of this as part of our legitimate interest.
For example, by checking your password when you login and using automated monitoring of IP addresses to identify possible fraudulent log-ins from unexpected locations.
- To process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests. This also helps to protect our customers from fraud.
- If we discover any criminal activity or alleged criminal activity through our use of CCTV, fraud monitoring and suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting unlawful acts. We aim to protect the individuals we interact with from criminal activities.
- With your consent, we will use your personal data, preferences and details of your transactions to keep you informed by email, web, text, telephone and through our contact centres about relevant products and services including tailored special offers, discounts, promotions, events, competitions and so on.
Of course, you are free to opt out of hearing from us by any of these channels at any time.
- To send you relevant, personalised communications by post in relation to updates, offers, services and products. We’ll do this on the basis of our legitimate business interest.
You are free to opt out of hearing from us by post at any time.
- To display the most interesting content to you on our websites or apps we will use data about your favourite products and so on. We do so on the basis of your consent to receive app notifications and/or for our website to place cookies or similar technology on your device.
For example, we might display a list of products or services you’ve recently looked at, or offer you recommendations based on your purchase history and any other data you’ve shared with us.
- To administer any of our prize draws or competitions which you enter, based on your consent given at the time of entering.
For example, by combining this data, this will help us personalise your experience and decide which content to share with you.
- To develop, test and improve the systems, services and products we provide to you. We’ll do this on the basis of our legitimate business interests.
For example, we’ll record your browser’s Session ID to help us understand more when you leave us online feedback about any problems you’re having
- To comply with our contractual or legal obligations to share data with law enforcement.
For example, when a court order is submitted to share data with law enforcement agencies or a court of law
- To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our products or services more relevant to you.
Of course, you are free to opt out of receiving these requests from us at any time by updating your preferences in your online account.
- To build a rich picture of who you are and what you like, and to inform our business decisions, we'll combine data captured from across the group and third parties we'll do this on the basis of our legitimate interest.
6. How we protect your personal data
We know how much data security matters to all our customers. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it.
We secure access to all transactional areas of our websites and apps using ‘https’ technology.
Access to your personal data is password-protected, and sensitive data (such as payment card information) is secured by SSL encryption.
We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.
7. How long will we keep your personal data?
Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected, in accordance with our Corporate Retention Procedures.
At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.
8. Who do we share your personal data with?
We sometimes share your personal data with trusted third parties.
For example, for fraud management, carrier services or to handle complaints and so on.
Here’s the policy we apply to those organisations to keep your data safe and protect your privacy:
- We provide only the information they need to perform their specific services.
- They may only use your data for the exact purposes we specify in our contract with them.
- We work closely with them to ensure that your privacy is respected and protected at all times.
- If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.
Examples of the kind of third parties we work with are:
- IT companies who support our website and other business systems.
- Operational companies such as delivery couriers.
- Direct marketing companies who help us manage our electronic communications with you.
- Data insight companies to ensure your details are up to date and accurate.
Sharing your data with third parties for their own purposes:
We will only do this in very specific circumstances, for example:
- With your consent, given at the time you supply your personal data, we may pass that data to a third party for their direct marketing purposes.
- For fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies.
- We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration.
- For further information please contact our Data Supervisor.
- To help personalise your journey through our website we currently use the following companies, who will process your personal data as part of their contract with us:
- Rich Relevance
This includes, but is not limited to:
- Your IP address
- Your operating system
- Your browser type
- The name of your internet service provider
- The date, time and duration of your visit
- The name and URL of pages you access
The website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
10. Where your personal data may be processed
Sometimes we will need to share your personal data with third parties and suppliers outside the European Economic Area (EEA), such as U.S.A.
Protecting your data outside the EEA
The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway. We may transfer personal data that we collect from you to third-party data processors in countries that are outside the EEA.
For example, this might be required in order to fulfil your order, process your payment details or provide support services.
If we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed inside the EEA. For example, our contracts with third parties stipulate the standards they must follow at all times. If you wish for more information about these contracts please contact our Data Protection Manager.
11. What are your rights over your personal data?
An overview of your different rights
You have the right to request:
- Access to the personal data we hold about you, free of charge in most cases.
- The correction of your personal data when incorrect, out of date or incomplete.
- That we stop using your personal data for direct marketing (either through specific channels, or all channels).
- That we stop any consent-based processing of your personal data after you withdraw that consent.
- Review by us of any decision made based solely on automatic processing of your data (i.e. where no human has yet reviewed the outcome and criteria for the decision).
You have the right to request a copy of any information about you that we hold at any time, and also to have that information corrected if it is inaccurate. To ask for your information, please contact Data Supervisor, Book People, Bryn Derwen, Parc Menai, Bangor, LL57 4FB or email firstname.lastname@example.org.
To ask for your information to be amended, please update your online account, or contact our contact centre (see website contact us section for details).
If we choose not to action your request we will explain to you the reasons for our refusal.
Your right to withdraw consent
Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.
Where we rely on our legitimate interest
In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.
You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.
Checking your identity
12. How can you stop the use of your personal data for direct marketing?
There are several ways you can stop direct marketing communications from us:
- Click the ‘unsubscribe’ link in any email communication that we send you. We will then stop any further emails from that particular division.
- If you have an account, log in into your account, visit the ‘My Account’ area and change your preferences.
- Write to Data Supervisor, Book People, Bryn Derwen, Parc Menai, Bangor, LL57 4FB
Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.
13. Contacting the Regulator
If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
You can contact them by calling 0303 123 1113.
Or go online to www.ico.org.uk/concerns (opens in a new window; please note we can't be responsible for the content of external websites)
If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence. Details can be found in Section 16.
14. Any questions?
If you have any questions that haven’t been covered, please contact our Data Supervisor who will be pleased to help you:
Email us at email@example.com
Or write to us at: Data Supervisor, Book People, Bryn Derwen, Parc Menai, Bangor, LL57 4FB.
This policy was last updated: 25th May 2018