HOLROYDE CARTEY PRIVACY NOTICE
1.1 This privacy notice sets out the way in which Holroyde Cartey Limited (we, us, our) collect and use your personal data in connection with our business. It also explains what rights you have to access or change your personal data.
1.2 Our website is not intended for children. We do not knowingly collect or maintain the personal information of children under the age of 13.
2. ABOUT US
2.1 We are a company registered in England under company number 9495767 with a registered address of 9 Bickells Yard, 151-153 Bermondsey Street, London SE13HA
3. INFORMATION WE MAY COLLECT ABOUT YOU
3.1 We will collect any information you provide to us when you:
a) make an enquiry by email
b) submit manuscripts via email
c) enter into a contract with us to represent you
d) interact with our social media accounts
3.2 The information you provide to us will include (depending on the circumstances)
a) identity and contact data: title, names, addresses, email addresses and phone numbers
b) financial and contract data: if we represent you, you may also provide us with your bank details, VAT and tax information, immigration and residency information, your existing contracts (and related correspondence) with publishers or other licensees of you work
c) employment and background data: if you are submitting a manuscript for review, you may also provide additional information about your academic and work history, qualifications, skills, projects and research
3.3 Information we collect about you
a) information contained in correspondence, for example, if you contact us by email, we may keep a record of that correspondence
b) website usage data: we may collect information about your interactions with our website, including information such as login data, IP address, page views, searches, requests, orders, pre-approvals, confirmations, agreements between you and other website users and other actions on the website
3.4 Information we receive from third parties. In certain circumstances we may received information about you from third parties, for example:
a) publishers and other licensees of your work. If we represent you, you will normally authorise us to receive information about you from your publishers and other licensees.
b) third parties who can verify information: if you submit a manuscript to us for our review, we may use third party providers to verify the information that you provide to us in connection with that submission, for example, websites to confirm your publication history
4. HOW WE USE INFORMATION ABOUT YOU AND RECIPIENTS OF YOUR INFORMATION
4.1 We will use your information for the purposes listed below either on the basis of:
a) performance of your contract with us and the provision of our service to you
b) your consent (where we request it)
c) our legitimate interests
d) where we need to comply with a legal or regulatory requirement
4.2 We use your information for the following purposes
a) to provide access to our website: 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)
c) to conduct business with you: to contact you and manage and facilitate our business relationship with you, including (if we represent you) the administration of your contract with us (including administration of any contracts with third parties when we represent you on such contracts) (on the basis of our legitimate interests in maintaining our business contracts; on the basis of performing our contract with you)
d) user and client support: to deal with enquiries or complaints about the website and share your information with our [website developer, IT support provider ] as necessary to provide support (on the basis of our legitimate interest in providing the correct services to our website users and to comply with our legal obligations)
e) social media interactions: to interact with users on social media platforms including (Facebook, LinkedIn, Twitter, Pinterest, Instagram and Google+), for example, responding to comments and messages, posting, ‘retweeting’ and ‘liking’ posts (on the basis of our legitimate interest in promoting our brand and communicating with interested individuals)
f) compliance with policies, procedures and laws: 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:
a) personalising, enhancing, modifying or otherwise improving the services and/or communications that we provide to you
b) detecting and preventing fraud and operating a safe and lawful business
c) improving security and optimisation of our network, sites and services
d) providing representation according to our client agreements
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
5.1. In connection with the purposes and on the lawful grounds described above and in addition to the recipients of your information as described above, we will share your personal information when relevant with third parties such as:
a) our service providers: third parties we work with to deliver our business (including, for example, hosting or operating the website, our databases our bank and our accountants
b) publishers, licensees, sub-agents, advisors and service companies: if we represent you, any publishers or other licensees of your work (or prospective publishers and licensees) as well as sub- or co-agents, advisors (such as your solicitor or accountant) and editorial service providers, where applicable
c) prospective sellers and buyers of our business: 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
d) other third parties (including professional advisers): any other third parties (including legal or other advisors, regulatory authorities, HMRC, courts, law enforcement agencies 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
5.2 We require third parties to maintain appropriate security to protect your information from unauthorised access or processing.
6.2. If you do not wish for cookies to be installed on your device, you can change the settings on your browser or device to reject cookies. For more information about how to reject cookies using your internet browser settings please consult the “Help” section of your internet browser (or alternatively visit http://www.aboutcookies.org). Please note that, if you do set your Internet browser to reject cookies, you may not be able to access all of the functions of the website.
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. We use appropriate technological and operational security measures to protect your information against any unauthorised access or unlawful use, such as:
a) ensuring the physical security of our offices and equipment
b) ensuring the physical and digital security of our equipment and devices by using appropriate password protection, firewall protection and O365 so that our email is stored securely in the cloud
c) maintaining a data protection policy which all employeed are obliged to follow and to ensure the continuous awareness of the importance of digital security
d) limiting access to your personal information to those in our company who need to use it in the course of their work.
7.2 We will retain your information for as long as is necessary to provide you with the services that you have requested from us or for as long as we reasonably require to retain the information for our lawful business purposes, such as for the purposes of exercising our legal rights or where we are permitted to do. 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. INTERNATIONL TRANSFERS OF YOUR INFORMATION
8.1 our company is located in the UK
8.2 if you are represented by us, some 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 as necessary to perform our contractual obligations to you.
9. YOUR RIGHTS TO THE INFORMATION WE HOLD ABOUT YOU
9.1. You have certain rights in respect of the information that we hold about you, including:
a) the right to ask us not to process your personal data for marketing purposes
b) the right to request access to the information that we hold about you
c) in certain circumstances, the right to ask us to limit or stop processing information about you, or erase information we hold about you
d) in certain circumstances, the right to receive a copy of any information we hold about you (or request that we transfer this to another service provider) in a structured, commonly-used, machine readable format
e) the right to request that we correct or rectify any information that we hold about you which is out of date or incorrect
f) the right to withdraw your consent for our use of your information in reliance of your consent (refer to paragraph 4 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;
g) the right to object to our using your information on the basis of our legitimate interests (refer to paragraph 4 above to see when we are relying on our legitimate interests) (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
h) the right to lodge a complaint about us to the UK Information Commissioner’s Office https://ico.org.uk as well as with the relevant authority in your country of work or residence.
9.2. Please note that we may need to retain certain information for our own record-keeping and research purposes.
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 website, or notify you of any material changes by e-mail.
Updated 24th May 2018