Welcome to Pen & Sword Books Limited privacy notice. We respect your privacy and are committed to protecting your personal data.
This notice gives you information on how we collect, process and look after your personal data through your interactions with us (whether through a use of a website, purchase of product or service or signing up to a newsletter) and tells you about your privacy rights and how the law protects you.
Please read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting your personal data so you are aware of how and why we are using your data.
This notice was last updated on 01/05/2018.
Who we are and contact details
Pen & Sword Books Limited is the controller and responsible for your personal data (collectively referred to as "COMPANY", "we", "us" or "our" in this privacy notice).
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.
Pen and Sword Books
47 Church Street, Barnsley, South Yorkshire, S70 2AS
Please inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. If you leave our website, we encourage you to read the privacy notice of every website you visit.
The data we collect about you
Personal data is information about an individual from which that person can be identified. It does not include data where the identity has been removed. We may collect, use, store and transfer different kinds of personal data about you as set out below:
Your identity including your name, username or similar identifier, marital status, title, date of birth and gender.
Your contact details including your billing address, delivery address, email address and telephone numbers.
Your financial details including your bank account and payment card details.
Transaction information about you including details about payments to and from you and other details of products and services you have purchased from us.
Technical information including internet protocol (IP) address, your login data (username and password), browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.
Profile information including your interests, preferences, feedback and survey responses and how you use our website.
Communications information including your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
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.
How do we collect your personal data?
We use different methods to collect data from and about you including:
Directly: You may give us your identity, contact and financial information by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you apply for our products or services; create an account; subscribe to our services or publications; request marketing; enter a competition or survey or give us feedback.
Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources examples of which are set out below:
How do we use your personal data?
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data:
- Where we need to perform a contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us at the address listed at the front of this policy.
For what purposes do we use your personal data?
We set out below a description of the ways we plan to use your personal data, and the legal bases we rely on to do so. We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
|Reason for use of personal data||Type of data involved||Lawful basis for processing the information|
|To register you as a new customer||Your identity and contact details||To perform a contract with you|
|To process and deliver your order including managing payments and collecting money owed to us||Your identity and contact details including financial and transactional information about you||To perform a contract with you and for our legitimate interests (i.e. recover debts due to us)|
|To manage our relationship with you including asking you to leave a review or to update you about changes to our policies||Your identity and contact details as well as profile information and communications preferences||To perform a contract with you, for our legitimate interests (updating records and to assess how customers use our products) and to comply with a legal obligation|
|To enable you to take part in a prize draw, competition or complete a survey||Your identity and contact details as well as profile information and communications preferences||To perform a contract with you, for our legitimate interests (to study how customers use our products, to develop them and grow our business)|
|To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||Your identity and contact details as well as profile and technical information about your use of our website and services||For our legitimate interests (for running our business including network and IT security and to prevent fraud) and to comply with our legal obligations|
|To deliver website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||Your identity and contact details as well as profile and technical information about your use of our website and services and communications preferences||For our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||Technical information about your use of our website and services.||For our legitimate interests (to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||Your identity and contact details as well as profile and technical information about your use of our website and services and communications preferences||For our legitimate interests (to develop our products/services and grow our business)|
|Our communications are designed to tell you about the benefits we can offer, so that you have exclusive access to our best deals. We use the information we have about you to tailor the content and try to ensure that the offers are as relevant to you as possible.||Your identity and contact details as well as profile and technical information about your use of our website and services and communications preferences||For our legitimate interests (to develop our products/services and grow our business)|
Legitimate Interest means our interest in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
How do we use your information for marketing purposes?
We want to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You can view and make certain decisions about your personal data use by calling 01226 734222 or by logging on to your account at www.pen-and-sword.co.uk.
Your information will be used for data profiling purposes using a third party company/service but it will not be sold to other businesses unless you have given us explicit permission for this to happen.
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company outside of our group of companies for marketing purposes.
How do I opt-out of marketing?
MARKETING OPT-IN AND OPT-OUT PROVISION
When you checkout with Pen and Sword, you will be given the option to opt-out of subscribing to our regular update service which will send you:
- Email alerts for new products, features, special offers, contests, events of interest, and one-off marketing promotions. Such alerts may include marketing information about our subsidiaries or selected business partners.
- Direct mail alerts for new products, special offers, upgrade opportunities, contests, events of interest, and one-off marketing promotions. Such alerts may include marketing information about Pen and Sword, our subsidiaries, or selected business partners.
We do occasionally make names and addresses available to trusted retail partners whose products we think may interest you.
By trusted retail partners, we mean companies operating in the clothing, collectables, food & wine, gardening, gadgets &entertainment, health & beauty ,household goods, and home interiors categories
During the check out process you will be asked whether you would like to opt in to third party communications or opt out of Pen & Sword direct communications, or you can email us at any time to change your preferences via firstname.lastname@example.org
In the event that your personal data becomes inaccurate or incomplete, or in any event you have the right to gain access to your personal data for the purposes of having it deleted or corrected; please e-mail us at email@example.com
At all times, we will offer you the opportunity to unsubscribe out of any service or update to which you have subscribed. Any e-mail we send will contain an easy automated unsubscribe link so that you can opt-out of that particular mail campaign.
Simply follow the indications in the relevant e-mail. Alternatively, if you do not wish to receive such offers or do not wish for us to share your details with any third parties please email us at firstname.lastname@example.org with your full name, address and postcode.
ACCESS AND CHANGE OF PERSONAL INFORMATION
If for any reason you are concerned that the personal information held by Pen and Sword is not correct, please visit the website and after logging into the site using the “Sign In” menu on the home page, your personal information will be made available for review and change in the “My Account” section.
If you prefer, you may contact us by email at email@example.com and we will amend your personal details. Cookies
Change of purpose
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. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
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. We may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
When might you disclose my personal data
We may have to share your personal data with other parties for our legitimate interests or as required by law as set out below.
- Other companies in the same group as the Company (which are all based in the United Kingdom) and provide IT and system administration services and undertake leadership reporting.
- Service providers based in the United Kingdom who provide IT and administrative services.
- Professional advisers including lawyers, bankers, auditors, Health and Safety advisers and insurers based the United Kingdom who provide consultancy, banking, legal, Health & Safety and insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities based in the United Kingdom.
- We work with Epsilon Abacus (registered as Epsilon International UK Ltd), a company that manages the Abacus Alliance on behalf of UK retailers. The participating retailers are active in the clothing, collectables, food & wine, gardening, gadgets & entertainment, health & beauty, household goods, and home interiors categories. They share information on what their customers buy. Epsilon Abacus analyses this pooled information to help the retailers understand consumers’ wider buying patterns. From this information, retailers can tailor their communications, sending people suitable offers that should be of interest to them, based on what they like to buy.
- To trusted partners and third parties; only when you have opted in to receive these communications.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Is any information transferred outside of the EEA?
Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented;
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
What data security is in place?
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including contact, identity, financial and transaction information) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data – see your legal rights below for further information.
We may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
- Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Although we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the of the data; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, 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.
- 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.
If you wish to exercise any of the rights set out above, please contact us at the address detailed at the start of this notice.
You have the right to make a complaint to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.