Privacy Policy

Fairlight Books Privacy Policy

We want to make sure that when we collect information from you, we do so in a way that does not infringe your right to privacy.

This Privacy Policy sets out the way we (Fairlight Books) collect and use your personal data (your personal information) and how we use cookies.  It also explains what rights you have to access or change your personal data.

Please read the following carefully because by visiting http://www.fairlightbooks.com or by subscribing to one of our newsetters you are accepting and consenting to the practices described in this policy.

For the purpose of the Data Protection Act 1998 (the Act), the data controller is Fairlight Books Limited of Summertown Pavilion, 18-24 Middle Way, Oxford, OX2 7LG (referred to in this policy as “we”). You can contact us at this address or by email to: contact@fairlightbooks.com.

You may provide us with information about you by filling in forms on our site, by email, phone, or otherwise. We will only use that information as we specifically state when you provide that information or as set out in this policy.

Emails and letters – You may wish to contact us by sending us letters or emails or by filling in contact forms on one of our websites. We will only use this information to respond to your query or suggestion.

Newsletters – Where you subscribe to one of our newsletters, we will require you to send us your email address so that we can send the newsletter to you. We may also ask you to provide other demographic information about yourself so that we can personalise your newsletters.

Prize Promotions – We sometimes run competitions and prize draws and, in addition to your answer or entry, we might require you to send us certain information, such as your name and email address. We will only use this information to administer the promotion and for any other purpose to which you consented when you entered.

When you visit our website we may automatically collect the following information:

• technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
• 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 and/or may be collected by third parties (such as Facebook) using cookies which are active on our website. For more information on cookies and what you can do to disable certain cookies on our websites, please see the section about our Cookie Policy below.
• information about your visit, including the full Uniform Resource Locators from which you have visited our site or that you visit after our site; products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
• If you follow us on Twitter or Facebook, we may also, in accordance with the privacy policies of those social media platforms, collect information about other people that you follow, or interact with, on social media.
• In certain circumstances, we will 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.

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

• performance of your contract with us and the provision of our services to you;
• your consent (where we request it);
• our legitimate interests (outlined below); or
• compliance with our legal obligations.

We use this information:

• to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
• to allow you to participate in interactive features of our service, when you choose to do so;
  as part of our efforts to keep our site safe and secure;
• to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
• to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
• 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);
• 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
• 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).

We may also collect information about you (such as your IP address) from your use of our website and share this with social media platforms (such as Facebook), so that, if you use such platform, they may select and serve relevant adverts to you and others who are similar to you. More information can be found in our Cookie Policy. To disable the Facebook cookie so that we cannot collect information about you, please consult your Facebook settings.

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:
personalising, enhancing, modifying or otherwise improving the services and/or communications that we provide to you;
detecting and preventing fraud and operating a safe and lawful business; and/or
improving security and optimisation of our network, sites and services.

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).

We may receive information about you if you use any of the other websites we operate or the other services we provide. We may also receive information about you from any of business partners to whom you may have given your details with permission for them to send it to us.

Cookies

Our website uses cookies to distinguish you from other users of our site. For detailed information on the cookies we use and the purposes for which we use them see our Cookie Policy.

In connection with the purposes and on the lawful grounds described above, we may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.

• We may share your information with selected third parties including:
  Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them.
• Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users. We may also use such aggregate information to help advertisers reach the kind of audience they want to target.
• Analytics and search engine providers that assist us in the improvement and optimisation of our site.

We may disclose your personal information to third parties:

• In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
• If we or substantially all of our assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements or to protect our rights, property, or safety or that of our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Data Retention

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:

• ensuring the physical security of our offices, warehouses or other sites;
• ensuring the physical and digital security of our equipment and devices by using appropriate password protection and encryption;
• maintaining a data protection policy for, and delivering data protection training to, our employees; and
• limiting access to your personal information to those in our company who need to use it in the course of their work.
  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.

International Transfer of Personal Data

Our company is located in the UK.

Your personal information will generally not be processed outside of the European Economic Area (EEA), except where we are sharing your information 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 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.  By way of example the steps we take in relation to some of these territories are as follows:

USA, Australia, China and India group companies: personal information is transferred via the European Commission’s Standard Contractual Clauses; and
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.
In addition, if you are a reader or purchaser who has purchased, or wishes to purchase a product from us, we may supply your personal information to:

(a)             an e-commerce service provider in the USA via the EU-US Privacy Shield Framework;

(b)             an e-commerce service provider in Australia via the Standard Contractual Clauses.

YOUR RIGHTS TO THE INFORMATION WE HOLD ABOUT YOU

You have certain rights in respect of the information that we hold about you, including:

the right to ask us not to process your personal data for marketing purposes;
the right to request access to the information that we hold about you; and
in certain circumstances, the right to ask us to stop processing information about you.
You may exercise your rights above by contacting us using the details provided at the start 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.

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.

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

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:

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;
the right to withdraw your consent for our use of your information in reliance of your consent (refer to paragraph 4 and the relevant Group sections of this Privacy Notice 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;
the right to object to our using your information on the basis of our legitimate interests;
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
the right to ask us to rectify, limit, cease processing or erase information we hold about you in certain circumstances.
You may contact us with the details at the top of this Privacy Notice if you wish to action any of these additional rights.

AUTOMATED DECISION MAKING

We may analyse your personal information to create a profile of your interests and preferences so that we can contact you with information relevant to you. We may make use of additional information about you when it is available from external sources to help us do this effectively.

Any changes we may make to our privacy policy in the future will be posted on this page or notify you of any material changes by e-mail.  This Privacy Notice was updated on 24 May 2018.