PENGUIN RANDOM HOUSE PRIVACY NOTICE

1. Introduction

1.1 This privacy notice (Privacy Notice) sets out the ways in which we, The Random House Group Limited and Penguin Books Limited (we, us, our), collect and use your personal data (your personal information) in connection with Bookmarks. It also explains what rights you have to access or change your personal data.
1.2 Where we refer to the website in this policy, we are referring to this website www.my-bookmarks.co.uk.

2. About us

2.1 We are companies registered in England under company numbers 00954009 (The Random House Group Limited) and 00861590 (Penguin Books Limited).  We are joint controllers of your personal data, meaning that we share responsibility for way in which it is held and processed. 
2.2 You can contact us 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 Information that you provide to us

3.1.1 We will collect any information that you provide to us when you:

(a) complete one of our profiling surveys and/or join the Bookmarks Community;

(b) participate in one of the polls, surveys or discussions on our website, or otherwise as a member of the Bookmarks Community;

(c) enter one of our competitions or prize draws; or

(d) when you make an enquiry or submit information to us via our website.

3.2 The information you provide to us might include your name, address, email address, working status, profession or industry, gender, ethnic background, details of your reading habits and preferences (e.g. your favourite books, genres, authors) and/or your purchasing habits and preferences (e.g. what newspapers you buy). We may also ask for information in relation to any children you may have (e.g. their ages and genders, as well as their reading habits and preferences).  However, we will not ask for information which directly identifies your children (e.g. their names).

3.3 All of the above information is provided by you, and processed by us, subject to your consent and you are under no obligation to provide any of this information to us. However, as Bookmarks is primarily a customer and market research initiative, without this information we may not be able to let you participate in the Bookmarks Community.

3.4 Information we collect about you

3.4.1 We will collect any information that you provide to us when you:We will collect any information contained in any correspondence between us. For example, if you contact us using a support button on our website or by email or telephone, we will keep a record of that correspondence.

3.4.2 We will collect information that you upload or post to your website account and/or any correspondence or interactions that you have with other website account holders.

3.4.3 We also 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, or using cookies. More information about the cookies that we use on our website, please see our Cookie Policy.

3.5 We will receive information about you from third parties. For example, we work closely with ResearchBods when running our surveys.

4. How we use information about you and recipients or your information

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

4.1.1 your consent (where we request it);
4.1.2 our legitimate interests (see paragraph 4.4 below)your consent (where we request it);
4.1.3 performance of your contract with us and the provision of our services to you; or
4.1.4 compliance with our legal obligations

4.2 We may use your information for the following purposes:

4.2.1 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);
4.2.2 to carry out research about general engagement with our products, website, services and the publishing industry generally (on the basis of your consent); 
4.2.3 to process your entry to any competitions or prize draws (either on the basis of your consent, or performing our contract with you);
4.2.4 to select and send you books we think may interest you based on your demographic information and preferences (on the basis of your consent); 

4.2.5 to keep in contact with you about our news, events, new website features or services or new books or products that we believe may interest you, provided that we have the consent to do so;
4.2.6 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 

4.2.7 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).

4.3 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:

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

4.4 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

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 third parties we work with to deliver our business including, for example:

5.1.1 market polling and research providers (e.g. ResearchBods);
5.1.2 competition providers (e.g. Adestra);
5.1.3 courier and transport providers (e.g. DHL);
5.1.4 building security service providers (e.g. Pearson);
5.1.5 website and app servicing, storage, analytics and hosting providers
; 
5.1.6 digital advertising and marketing providers; and
5.1.7 technical assistance providers;

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/or
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

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.

7.2 We use appropriate technological and operational security measures to protect your information against any unauthorised access or unlawful use, such as:

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

7.3 We will retain your information for as long as it is current (i.e. it is necessary to administer your participation in the Bookmarks Community). We will, however, retain the information for longer periods where it may reasonably be required for legal proceedings, 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. Internal 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, 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. 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. By way of example the steps we take in relation to some of these territories 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 In accordance with data protection laws, you have certain rights in respect of the information that we hold about you, including:

9.1.1 the right to withdraw your consent for our use of your information in reliance of your consent, which you can do by contacting us using any of the details at the top of this Privacy Notice. Please note that if you withdraw your consent to our use of your information, we may not be able to allow you to continue your participation in Bookmarks or the Bookmarks Community. Please also note that we may retain on an anonymised basis certain information that you have provided for marketing research purposes;
9.1.2 the right to object to our using your information on the basis of our legitimate interests (refer to paragraph 4 of this Privacy Notice to see when we are relying on our legitimate interests);
9.1.3 the right to ask us to rectify, limit, cease processing or erase information we hold about you in certain circumstances;
9.1.4 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

9.1.5 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.

9.2 You may contact us with the details at the top of this Privacy Notice if you wish to action any of these additional rights.
9.3 You may exercise your rights above by contacting us using the details in paragraph 2.2 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.
9.4 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.
9.5 Please note that you are entitled to request one detailed summary of any information we are holding about you in accordance with paragraph 9.1.4 at no cost, but for any further summaries, we reserve the right to charge a reasonable fee based on administration costs.

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 01.11.18.