It covers all the site-related data processing activities of the following two entities (together, “we”, “us” or “our”):
- Robert Galbraith Limited (“RGL”), the company that operates the site; and
- The Blair Partnership (“TBP”), the partnership that acts as the agent of the author professionally known as Robert Galbraith (“RG”) and also assists RGL in administering the site.
This policy sets out the basis on which any of your personal information will be processed by us in connection with the site. We are the joint data controllers in relation to such processing. For certain offerings on or via the site, there may be additional notices about our privacy practices, each of which will be considered to form part of this policy.
Please read the following carefully to understand our practices regarding your personal information and how it will be treated. This policy is provided in a layered format so that you can click through to the specific areas set out below.
TABLE OF CONTENTS
- HOW AND WHEN WE COLLECT PERSONAL INFORMATION ABOUT YOU
- WHAT PERSONAL INFORMATION WE COLLECT ABOUT YOU
- HOW AND WHY WE USE YOUR PERSONAL INFORMATION
- WHERE WE STORE YOUR PERSONAL INFORMATION
- HOW WE RETAIN AND SECURE YOUR PERSONAL INFORMATION
- DISCLOSING YOUR PERSONAL INFORMATION
- COOKIES AND SIMILAR TECHNOLOGIES
- DO NOT TRACK
- YOUR LEGAL RIGHTS
- CALIFORNIA RESIDENTS
- CHANGES TO THIS POLICY
- CONTACT US
1. HOW AND WHEN WE COLLECT PERSONAL INFORMATION ABOUT YOU
We may collect and combine different types of personal information from you when you:
- visit the site;
- contact us or request information from us;
- subscribe to our newsletter or other offerings on or via the site; and/or
- communicate with us via social networking sites, third-party apps or similar technologies.
We will indicate where any personal information we have requested is mandatory or optional. We will also explain the consequences should you decide not to provide information that we have indicated is mandatory. In some circumstances that might mean we cannot provide you with a certain service.
We may also collect information about you from third-party sources, such as from your use of other sites that we operate, or from related third parties such as our suppliers, agents or sub-contractors.
2. WHAT PERSONAL INFORMATION WE COLLECT ABOUT YOU
We will collect:
- information about you in the course of your use of the site;
- any information about you that you disclose when contacting us with a complaint or query, including related correspondence;
- any other information about you that you provide to us, such as your contact details (e.g. your name and/or email address);
- any information about you that we receive from any relevant third-party sources, which we may combine with information that we have collected from you direct; and
- certain technical and usage information, such as the type of device, browser and operating system you are using, your internet service provider or mobile carrier, device/app/network identifiers, IP address, device and browser settings, the webpages and apps you use, and certain site usage information across the site and other sites and apps.
In addition, we may collect certain information that is not personal information, such as anonymous analytics data.
If we need to collect personal information by law, or under the terms of a contract that we have with you, and you fail to provide that information when requested, we may not be able to perform the contract that we have or are trying to enter into with you (e.g. to provide you with services).
The site is not intended for children, and we do not knowingly collect data relating to children.
The site may, from time to time, contain links to and from third-party websites and services (including third-party social media platforms). If you follow a link to any of these websites and/or services, please note that they have their own privacy policies and we do not accept any responsibility or liability for them. Please check any such third-party privacy policies before you submit any personal information to those websites or services.
3. HOW AND WHY WE USE YOUR PERSONAL INFORMATION
We will only process your personal information where we have a lawful basis to do so. The lawful basis will depend on the purposes for which we have collected and use your personal information.
We may use your personal information for the following purposes and related lawful bases described below (or disclosed at the time of collection):
(1) Basis: where necessary to perform a contract with you (or to take steps at your request before entering into a contract)
Purposes of processing:
- To provide you with access to content, services and other features on or via the site.
- To process your registration for a competition or other promotion, and to administer your account or entry in accordance with any related contractual terms.
- To send you information about any changes to our services, terms or policies.
(2) Basis: where necessary for purposes of our or third parties’ legitimate interests
Purposes of processing (and related legitimate interests):
- To respond to your enquiries, e.g. to send you information you have requested and to provide user support services (fulfilling your request and providing you with such assistance).
- To analyse and understand how the site is used, including by aggregating data about categories of users and by informing surveys, so that we can develop, maintain, personalise, protect and improve the site (researching site usage and compiling usage statistics with a view to operating the site more effectively and enhancing it to improve your experience).
- To assist with the security and safety of the site and its users, e.g. by trying to prevent unauthorised or malicious activities, and to detect and prevent any fraud (making the site safe for users and tackling any fraudulent activity).
- To send direct marketing to you and to tailor content and offers for you, where we do not need consent to do so (promoting content and/or services from us that we believe may be of interest to you).
(3) Basis: where you give us consent
Purposes of processing:
- To email you with news and features about the Robert Galbraith books and related promotions, such as quizzes, puzzles and competitions (if you have opted in to receive such emails).
- To place cookies and to use similar technologies with your consent (where we need your consent to do so).
- On other occasions where we ask you for consent, for a purpose that we explain at that time.
(4) Basis: where necessary for complying with our legal obligations
Purposes of processing:
- In response to requests by government or law enforcement authorities conducting an investigation.
- To comply with any other legal requirements.
The personal information that we collect will be stored in the UK and may also be transferred to, and stored at, a destination outside the UK and/or European Economic Area (the “EEA”), including countries that have less strict or no data protection laws, when compared with those in the UK and/or the EEA.
Whenever we transfer your information as described in the paragraph above, we will take steps that are reasonably necessary to ensure that adequate safeguards are in place to protect your personal information and to make sure it is treated securely and in accordance with this policy. In these cases, we rely on approved data transfer mechanisms (such as the “standard contractual clauses” approved by the European Commission) to ensure that your information is subject to adequate safeguards in the recipient country. If you are located in the EEA or the UK, you may contact us using the details in section 12 below for a copy of the safeguards that we have put in place to protect your personal information and privacy rights in these circumstances.
- HOW WE RETAIN AND SECURE YOUR PERSONAL INFORMATION
We take steps to ensure that the personal information that you provide is retained for only as long as it is necessary for the purpose for which it was collected. After this period it will be deleted or in some cases anonymised. For example, we may keep a record of any correspondence with you (e.g. if you have made a complaint) for as long as is necessary to protect us from a legal claim.
We maintain reasonable technical and organisational measures to protect personal information from loss, misuse, alteration or unintentional destruction. No security measures are perfect, however, and so we cannot assure you that personal information that we collect will never be accessed or used in an unauthorised way, which may happen due to circumstances beyond our reasonable control. We have put in place procedures to deal with a suspected personal data breach, and we shall notify you and any applicable regulator of a breach where we are legally required to do so.
We share and disclose your information in the ways described below or for other purposes that we explain when we collect your personal information. We may share your information with the organisations below, their personnel, or people providing services to them (e.g. professional advisers who are connected with the activity described). When we share personal information with service providers, they usually only process personal data in accordance with our instructions, as data processors. The other third parties listed below are independent controllers of the information, unless otherwise specified.
We may disclose your personal information as follows:
- between ourselves, where either RGL or TBP has separately collected the information in the first instance;
- within our respective groups of companies (i.e. with our respective subsidiaries from time to time, as defined in section 1159 of the UK Companies Act 2006);
- with our suppliers, business partners and service providers, where they are helping us to promote the site and its content and/or to provide our services to you;
- with Little, Brown Book Group Limited, the publisher of the Robert Galbraith books, so that they may email you with news and features about the Robert Galbraith books and related promotions, such as quizzes, puzzles and competitions (if you have opted in to receive such emails);
- with business reorganisation parties, in the event that RGL or TBP sells any business or assets, in which case RGL/TBP may disclose your personal information to the prospective buyer of such business or assets;
- if RGL or TBP or substantially all of its assets are acquired by a third party, in which case personal information held by RGL/TBP about its customers and visitors to the site may be one of the transferred assets;
- with authorities or similar third parties (e.g. auditors) requesting mandatory disclosure in compliance with applicable law, if we are under a duty to disclose or share your personal information in order to comply with any legal or regulatory obligation or request;
- with other companies and organisations for the purposes of fraud protection to protect the rights, property or safety of us or our users, or others, and in order to enforce or apply our terms and conditions (which includes exchanging information); and/or
- with other third parties where you give us permission to do so.
Cookies are small text files placed in your browser. Web beacons are small strings of code that provide a method for delivering a graphic image on a webpage for the purpose of transferring data, such as the IP address of the device that downloaded the page on which the web beacon appears, the URL of the page on which the web beacon appears, the time the page containing the web beacon was viewed, the type of browser that fetched the web beacon, and the identification number of any cookie on the device previously placed by that server.
Various different types of cookies are used via the site:
- “Session cookies” are used (which will usually be deleted when you log out) to keep track of your internet session, which, for instance, allows us to remember the site language. Without these cookies the online services that you have asked for cannot be provided. Session cookies are necessary and/or useful for the functioning of the site.
- “Persistent cookies” are used (which are longer-term) to help you move around and enjoy the features on the site more easily and to remember preferences, actions and settings to improve your visit (at your request).
You can object to such cookies through your browser settings, but please note that, without essential cookies, some features or activities may be limited or not available to you. For more information on how to control cookies on your browser, or about cookies generally, please see https://www.aboutcookies.org/.
We also use a local storage mechanism (LSM), in place of cookies, to improve and customise your experience on our website. The LSM acts like a functional cookie, but adds an additional layer of privacy in that the LSM cannot be read by our servers, only you. This means that the LSM cannot be used for tracking you online. Browser settings will not allow you to manage LSMs, but you may be able to manage them by alternative means. To learn more, see https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html.
- Strictly necessary: enabling core site functionality.
Strictly necessary cookies and similar technologies are essential in order to enable you to move around the site and to use its features. Without them, services like enabling appropriate content based on your type of device cannot be provided.
- Analytics: allowing us to analyse site usage.
Analytics cookies and similar technologies collect information about how you use the site, so that we can analyse traffic and understand users’ interactions to perform analytics, including to analyse, measure and report on usage and performance of the site.
For this purpose, we may use third-party service providers such as Google Analytics, who may use their own cookies and similar technologies. The information is used to improve our sites or products. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage.
To opt out of Google Analytics relating to your use of our sites, you can download and install the Google Analytics Opt-out Browser Add-on available via this link:
- Functional: allowing us to personalise your experience of our sites.
Functional cookies and similar technologies allow the site to remember choices you make (such as the region you are in) and to provide enhanced, more personal features. They can also be used to remember changes you have made to text size, fonts and other parts of webpages that you can customise.
Managing cookies and similar technologies.
If you are in the UK or EEA, we will ask for your consent before using any cookies (apart from strictly necessary cookies) and you can withdraw your consent at any time.
You can also manage your consents for cookies on the site through your browser settings. You can adjust your browser to reject cookies from us or from any other site operator. Controlling cookies via browser controls may not limit our use of other technologies. Please consult your browser’s settings for more information. You can also check your browser settings to learn how to delete cookies.
Blocking cookies and similar technologies might, however, prevent you from accessing some of our content or site features.
Adobe’s Flash player and similar applications use Local Shared Object (“LSO”) technology to remember settings, preferences and usage similar to browser cookies. Flash cookies are not managed through your web browser, but you can access your Flash management tools from Adobe’s website. Your browser may also offer other tools to delete or reject other LSOs; please check your browser’s settings or help menu for more information.
8. DO NOT TRACK
Given the divergent practices of organisations that offer browsers and the lack of a standard in the marketplace, we do not respond to DNT signals at this time.
9. YOUR LEGAL RIGHTS
Your legal rights. Under certain circumstances, you may have the following rights under data protection laws in relation to your personal information (which may be limited to personal data):
- right of access to your personal information;
- right to rectification of your personal information;
- right to erasure of your personal information;
- right to restriction of processing of your personal information;
- right to portability of your personal information;
- right to object to processing of your personal information;
- right not to be subject to significant automated decision-making (including when based on profiling); and/or
- right to withdraw consent to processing of your personal information.
Some of those rights may only apply to you if you are resident in the UK or the EEA or a country with similar data protection laws. To find out more about those specific rights, please see the last paragraph of this section and your local data protection authority’s website, such as the ICO’s website (www.ico.org.uk), if you are located in the UK, or the Irish Data Protection Commission’s website (www.dataprotection.ie), if you are located in Ireland.
Additionally, California law grants California residents the right, among other things, to access, delete, and opt out of the sale of certain personal information. For a description of these rights, please see section 10 below.
Exercising your rights. We will handle any request to exercise your rights in accordance with applicable law and any relevant legal exemptions. If you wish to exercise any of those rights, please send an email to [email protected].
Your legal rights in more detail (for UK and EEA residents). In certain circumstances, you have the following legal rights in relation to your personal information (to the extent consisting of “personal data” in the UK and the EEA and countries with similar data protection laws, and so we use that term in the rest of this section). We may ask you for additional information, so that we take reasonable steps to check that – for example – we only provide personal data to the person to whom the data relate.
- Right of access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data that we hold about you and to check that we are lawfully processing such data.
- Right of rectification of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, although we may need to verify the accuracy of the new data that you provide to us.
- Right to erasure of your personal data. This enables you to ask us to delete or remove personal data in certain circumstances. Please note, however, that we may retain your data in certain circumstances in accordance with law, which will be notified to you, if applicable, at the time of your request.
- Right to 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 would like us to establish the accuracy of such 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.
- Right to portability of your personal data to you or to a third party. If you so request, we shall provide you, or a third party that you have chosen, with a copy of your personal data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information that you initially provided consent for us to use or where we used the information to perform our contract with you.
- Right to 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 that makes you want to object to processing on this ground, in which case we will consider whether we have compelling reasons to continue to process your data.
- Right to object to direct marketing. You also have the right to object where we are processing your personal data for purposes of direct marketing. Please see the section above Your marketing and advertising choices for how to exercise the right.
- Right to withdraw consent at any time where we are relying on consent to process your personal data. If you withdraw your consent, we may not be able to provide certain products, content or services to you.
- Right to complain in the UK or in the EEA. If you would like to complain, please contact us using the details in section 12 below. This does not override your right to complain to the relevant supervisory authority at any time.
- California residents
California law requires that we describe the personal information that we have collected about California consumers in the past 12 months, by identifying specific categories of personal information. We may have collected the following categories of such information:
- identifiers, such as name and email address, and online identifiers relating to your IP address, device and operating system;
- internet or other electronic network activity information, such as information regarding your interaction with the site; and
- characteristics of protected classifications under California or US Federal law, such as age or national origin.
For more details on what is collected, or for information regarding the sources of such personal information, please see sections 2 and 3 above. For information regarding how and why we may use or disclose such personal information, please see sections 3, 4 and 6 above.
California law also mandates that we specify certain disclosures, as some disclosures constitute a “sale” of data under California law, even if no money is exchanged. We do not sell personal information. We may, however, have disclosed the following personal information as permitted by law to the following categories of third parties for our operational “business purposes” as defined by California law, in the last 12 months:
|Identifiers||· Little, Brown Book Group Limited, the publisher of the Robert Galbraith books · Our other suppliers, business partners and service providers|
|Internet or other electronic network activity information||· Little, Brown Book Group Limited· Our other suppliers, business partners and service providers|
In addition to the right to access the personal information that we collect, use, disclose and sell, and the right to deletion, as described above, California residents also have the right to access specific pieces of information we hold about them, and the right to opt out of the sale of their personal information. We do not, however, sell personal information, nor do we have any actual knowledge of any sale of personal information of minors under 16 years of age.
You have the right not to be denied goods or services for exercising your rights.
If you wish to exercise any of these rights or have any questions or concerns regarding the processing of your personal information, please contact us at [email protected]. We will respond to your request consistent with applicable law. You have the right not to receive discriminatory treatment if you exercise any of the rights explained in this section 10, and we will not disadvantage you if you choose to exercise your rights.
Please note, however, before we will be able to process your request for access or deletion of personal information, we will need to verify your identity properly for security purposes. Where we possess appropriate information about you on file (e.g. name and email address), we will attempt to verify your identity using that information. We will be able to confirm the precise information we require to verify your identity in your specific circumstances if and when you make such a request.
To use an authorised agent to make a request on your behalf, you will need (a) to confirm directly with us that you have provided the authorised agent permission to submit the request, (b) to provide us with signed permission for the authorised agent to act on your behalf and (c) to verify your identity, directly with us.
- CHANGES TO THIS POLICY
We may make changes to this policy from time to time. We will notify you about material changes by placing a notice on the site and/or sending an email to you. We encourage you to check back and review this policy periodically so that you always know our current privacy practices. The date when this policy was last updated appears at the bottom.
- CONTACT US
Robert Galbraith Limited, a private company limited by shares registered in England and Wales and the operator of the site, and The Blair Partnership, a partnership doing business in England and Wales and the administrator of the site, jointly control how your personal information is used. We work together to make decisions about use of information and to respond to queries, or to respond to requests to exercise personal data rights.
If you have any questions about this policy or any concerns about our privacy practices, you can contact The Blair Partnership:
- by post at P.O. Box 7828, London W1A 4GE; or
- by email at [email protected].
Please mark your correspondence for the attention of the Robert Galbraith data privacy team. Neither address should be used for fan mail, please.
Last updated: 24 August 2020