Privacy Policy
PRIVACY NOTICE
- INTRODUCTION
1.1 This privacy notice (Privacy Notice) sets out the ways in which we, NetGalley UK Ltd (we, us, our), collect and use your personal data (your personal information) in connection with www.readersfirst.co.uk (“our site”). It also explains what rights you have to access or change your personal data.
2. ABOUT US
2.1 We are a UK company with our registered address as set out below.
2.2 You can contact us as follows:
NetGalley UK Ltd.
℅ Fiander/Tovell & Co
Stage Gates House
63/64 The Avenue
Southampton SO17 1XS
Email: GDPRCompliance@netgalley.com
3. INFORMATION WE MAY 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) are corresponding with us over the phone, by email, on our website or at Readers First events or otherwise;
(b) fill in details on our site or otherwise use our site’s functions, such as when you register to use our site and receive our newsletter, subscribe to our service, search for a book, claim a book, participate in discussion boards or forums, provide a book impression or review, use the social media functions associated with our site, enter a competition, promotion or survey, or use other activities or services we may add to our site, and when you report a problem with our site.
(c) subscribe to our mailing lists.
3.1.2 The information you provide to us might include your name, address, email address, phone number, and if you’re creating an account you may also provide a password, personal description and photograph, gender, date of birth, family details, employment and education details, reading habits and preferences and other similar information that at times may be requested or volunteered.
3.1.3 From time to time we might ask if you would be willing to participate in our surveys; if you agree, we will also collect any information that you provide as part of that survey.
3.2 Information we collect about you
3.2.1 We will collect any information contained in any correspondence between us. For example, if you contact us using a query button on our site or by email or telephone, we will keep a record of that correspondence.
3.2.2 We will collect information that you upload or post to your website account and/or any correspondence or interactions that you may have with other website account holders.
3.2.3 We will also collect certain information about how you use our site and the device that you use to access our site. 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 Google Analytics or another third-party website analytics service provider on our behalf and/or may be collected using cookies. For more information on cookies please read paragraph 6 below.
3.3 Information we receive from third parties
3.3.1 In certain circumstances, we might receive information about you from third parties if you have indicated to such third party that you would like to hear from us.
3.4 Information you share publicly
All information or contributions that you make in public areas of our site, including uploading reviews, reader comments, forum entries, etc., may be accessible without restriction by other visitors to our site. This Privacy Notice does not cover any of this publicly shared information. Therefore, be careful not to share personal information that you do not want to be publicly known.
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:
4.1.1 performance of your contract with us and the provision of our services to you;
4.1.2 your consent (where we request it); or
4.1.3 our legitimate interests (see paragraph 4.3 below).
4.2 We may use your information for the following purposes:
4.2.1 to provide you with access to our site in a manner convenient and optimal and with personalised content relevant to you including sharing your information with our site hosts and developers (on the basis of our legitimate interest to ensure our site is presented in an effective and optimal manner);
4.2.2 to keep in contact with you about our news, events, new website features or services or new books that we believe may interest you, provided that we have the requisite permission to do so, (either on the basis of your consent where we have requested it, or our legitimate interests to provide you with marketing communications where we may lawfully do so);
4.2.3 to send you our newsletters provided that we have your consent to do so (currently we use “MailChimp” to manage the delivery of our newsletter as well as for analysis of newsletter data such as the open rate of this newsletter. MailChimp is part of The Rocket Science Group, LLC, 512 Means Street, Ste 404 Atlanta, GA 30318, USA. This Privacy Notice does not apply to Mailchimp but the company is a member of the Safe Harbor Agreement, a special data protection agreement between the European Union and the United States. For more information about the privacy policies of MailChimp, go to http://mailchimp.com/legal/privacy/)
4.2.4 ;to send you the books you win or claim from our site by providing your name and address details, and if necessary email address, to publishers or publishers’ warehouses and/or delivery service providers, and as necessary to provide customer support to ensure you receive said books;
4.2.5 to share your information with selected third parties such as publishing partners and authors, to enable them to contact you with information about things that may interest you (where we have your consent to do so);
4.2.6 to provide customer service and support (on the basis of our contract with you), deal with enquiries or complaints about our site and share your information with our website developer and IT support provider, as necessary to provide customer support (on the basis of our legitimate interest in providing the correct services to our site users);
4.2.7 to carry out aggregated and anonymised research about general engagement with our site (on the basis of our legitimate interest in providing the right kinds of products and services to our site users);
4.2.8 to protect, investigate, and deter against fraudulent, unauthorised, or illegal activity, including without limitation plagiarism and identity fraud (on the basis of our legitimate interests to operate a safe and lawful business or where we have a legal obligation to do so);
4.2.9 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); and
4.2.10 to enable us to build profiles of ‘lookalike’ customers for advertising and marketing purposes on social media (on the basis of our legitimate business interest).
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;
4.3.3 improving security and optimisation of our network, sites and services;
4.3.4 conducting business with suppliers and purchasers.
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 may share your personal information with third parties that we work with such as:
5.1.1 third parties we work with to deliver our business (including for example, hosting or operating our site and our databases, site analytics, providing technical assistance and support, providing newsletter services), including Readers First GmbH (the Data Processor), a division of Ullstein Buchverlage GmbH, who provide our site with development, hosting and data processing and storage services.
5.1.2 ;any selected third party that you consent to our sharing your information with for marketing purposes;
5.1.3 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;
5.1.4 any joint-venture partner or other partner in a commercial partnership related to Readers First to whom we transfer the running (in whole or part) of our site; and
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.
5.2 We require third parties to maintain appropriate security to protect your information from unauthorised access or processing.
6. COOKIE POLICY
6.1 Cookies are small text files that are placed on your computer when you use your browser to visit a website that uses cookies. They are widely used in order to make websites work, work more efficiently and to provide information to the owners of the site.
6.2 Cookies enables us to estimate our audience size and usage patterns, store information about your preferences, allowing us to customize our site according to your individual interests; and recognize you when you return to our site.
6.3 Please note that third parties (including, for example, providers of external services like web traffic analysis services and web analytics tools such as Google analytics) may also use cookies, over which we have no control and this Privacy Notice does not apply to them. These cookies are likely to be analytical/performance cookies or targeting cookies. The names of the main cookies that may be used on our site and the purposes for which these cookies are used are set out below:
"DSID" Doubleclick ID, see https://policies.google.com/technologies/types (duration 14 days*)
"IDE" Doubleclick ID, see https://policies.google.com/technologies/types (duration 434 days*)
"*(Facebook.com)" See detailed cookie information at https://www.facebook.com/policy/cookies/ (click link Cookies in first paragraph of "Why do we use Cookies?") (duration variable)
"_gid" Google Analytics (GA) Tracking ID, see https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage (duration 24 hours*)
"-gat-UA-48223844-3" GA Performance Throttling (duration 1 minute*)
"-ga" Used to distinguish users (duration 2 years*)
"optimizelyBuckets" Optimizely Test-Variant shown to user, see https://help.optimizely.com/Set_Up_Optimizely/Cookies_and_localStorage_in_the_Optimizely_snippet (duration 10 years*)
"optimizelySegments" Optimizely Segments for test (duration 10 years*)
"optimizelyEndUserId" Optimizely User Id (duration 10 years*)
"-vorablesen-session" Session ID for App, managing user login status. encrypted information (duration unlimited)
"cookieconsent_dismissed" When cookie consent banner clicked. (duration 365 days)
"remember-user-token" Encrypted user identifier for automatic login. (duration 14 days)
"AMP TOKEN" Contains a token that can be used to retrieve a client ID from AMP client ID service. (duration 30 seconds to 1 year)
"gac" Contains campaign related information for the user (duration 90 days)
NB times marked * are approx. and can be changed by cookie issuer any time.
6.4 Our site may contain content and links to other sites that are operated by third parties that may also operate cookies. We don’t control these third party sites or cookies and this Privacy Notice does not apply to them. Please consult the terms and conditions and Privacy Notice of the relevant third party site to find out how that site collects and uses your information and to establish whether and for what purpose they use cookies.
6.5 If you do not wish us to collect cookies, you may set your browser to refuse cookies, or to alert you when cookies are being sent. However, if you select this setting you may be unable to access certain parts of our site. Unless you have adjusted your browser setting so that it will refuse cookies, your system will continue to accept cookies when you direct your browser to our site.
6.6 To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org. To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.
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:
7.1.1 ensuring the physical security of our offices, warehouses or other sites;
7.1.2 ensuring the physical and digital security of our equipment and devices by using appropriate password protection [and encryption];
7.1.3 maintaining a data protection policy for, and delivering data protection training to, our employees;
7.1.4 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 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. INTERNATIONAL TRANSFERS OF YOUR INFORMATION
8.1 Our company is located in the UK. Our Data Processor, Readers First GmbH, a division of Ullstein Buchverlage GmbH, is based in Berlin, Germany.
8.2 We take all steps necessary to ensure that any of your information is adequately protected and processed in accordance with this Privacy Notice, including aiming to ensure that all data is stored and processed within the European Union or otherwise in the USA, and by using all appropriate cross-border transfer solutions such as the European Commission's Standard Contractual Clauses or the EU-US Privacy Shield Framework;
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:
9.1.1 the right to ask us not to process your personal data for marketing purposes;
9.1.2 the right to request access to the information that we hold about you; and
9.1.3 in certain circumstances, the right to ask us to stop processing information about you.
9.2 You may exercise your rights above by contacting us using the details in paragraph 2 of this Privacy Notice, or in the case of preventing processing for newsletter activities also by unchecking certain boxes on our site, or by clicking Unsubscribe on any email marketing correspondence that you receive from us.
9.3 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 your website user account even when you have requested not to receive marketing communications.
9.4 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:
9.4.1 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;
9.4.2 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;
9.4.3 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);
9.4.4 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
9.4.5 the right to ask us to limit or cease processing or erase information we hold about you in certain circumstances.
9.5 You may contact us with the details at the top of this Privacy Notice if you wish to action any of these additional rights and we will comply with your requests unless we have a lawful reason not to do so.
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 last updated on 29th October 2021.
We may revise this acceptable use policy at any time by amending this page. You are expected to check this page from time to time to take notice of any changes we make, as they are legally binding on you. Some of the provisions contained in this acceptable use policy may also be superseded by provisions or notices published elsewhere on our site.
ACCEPTABLE USE POLICY
This acceptable use policy sets out the terms between you and us under which you may access our website www.readersfirst.co.uk (our site). This acceptable use policy applies to all users of, and visitors to, our site.
Your use of our site means that you accept, and agree to abide by, all the policies in this acceptable use policy, which supplement our Terms of Use (see above).
www.readersfirst.co.uk is a site operated by NetGalley UK Ltd (we, us, our), a UK company whose registered office is: ℅ Fiander/Tovell & Co, Stage Gates House, 63/64 The Avenue, Southampton SO17 1XS.
PROHIBITED USES
You may use our site only for lawful purposes. You may not use our site:
in any way that breaches any applicable local, national or international law or regulation;
in any way that is unlawful or fraudulent, or has any unlawful or fraudulent purpose or effect;
for the purpose of harming or attempting to harm minors in any way;
to send, knowingly receive, upload, download, use or re-use any material which does not comply with our content standards below;
to transmit, or procure the sending of, any unsolicited or unauthorised advertising or promotional material or any other form of similar solicitation (spam); or
to knowingly transmit any data, send or upload any material that contains viruses, Trojan horses, worms, time-bombs, keystroke loggers, spyware, adware or any other harmful programs or similar computer code designed to adversely affect the operation of any computer software or hardware.
You also agree:
not to reproduce, duplicate, copy or re-sell any part of our site in contravention of the provisions of our Terms of Use (see above);
not to access without authority, interfere with, damage or disrupt:
any part of our site;
any equipment or network on which our site is stored;
any software used in the provision of our site; or
any equipment or network or software owned or used by any third party.
INTERACTIVE SERVICES
We may from time to time provide interactive services on our site, including, without limitation:
chat rooms;
bulletin boards;
book review or other forums; or
other communicative or interactive services
Where we do provide any interactive service, we will provide clear information to you about the kind of service offered, if it is moderated and what form of moderation is used (including whether it is human or technical).
We will do our best to assess any possible risks for users (and in particular, for children) from third parties when they use any interactive service provided on our site, and we will decide in each case whether it is appropriate to use moderation of the relevant service (including what kind of moderation to use) in the light of those risks. However, we are under no obligation to oversee, monitor or moderate any interactive service we provide on our site, and we expressly exclude our liability for any loss or damage arising from the use of any interactive service by a user in contravention of our content standards, whether the service is moderated or not.
The use of any of our interactive services by a minor is subject to the consent of their parent or guardian. We advise parents who permit their children to use an interactive service that it is important that they communicate with their children about their safety online, as moderation is not foolproof. Minors who are using any interactive service should be made aware of the potential risks to them.
Where we do moderate an interactive service, we will normally provide you with a means of contacting the moderator, should a concern or difficulty arise.
CONTENT STANDARDS
These content standards apply to any and all material which you contribute to our site ("contributions"), and to any interactive services associated with it.
You must comply with the spirit and the letter of the following standards. The standards apply to each part of any contribution as well as to its whole.
Contributions must:
be accurate (where they state facts);
be genuinely held (where they state opinions), and in the case of blurbs and book reviews be your own original non-plagiarized opinions, written to genuinely represent opinions on and facets of the book, and not in any other way faked or falsified for the purpose of gaining points, rewards or otherwise; and
comply with applicable law in the UK and Republic of Ireland and in any country from which they are posted.
Contributions must not:
contain any material which is defamatory of any person;
contain any material which is obscene, offensive, hateful or inflammatory;
promote sexually explicit material;
promote violence;
promote discrimination based on race, sex, religion, nationality, disability, sexual orientation or age;
infringe any copyright, database right or trade mark of any other person;
be likely to deceive any person;
be made in breach of any legal duty owed to a third party, such as a contractual duty or a duty of confidence;
promote any illegal activity;
be threatening, abuse or invade another’s privacy, or cause annoyance, inconvenience or needless anxiety;
be likely to harass, upset, embarrass, alarm or annoy any other person;
be used to impersonate any person, or to misrepresent your identity or affiliation with any person;
give the impression that they emanate from us, if this is not the case; and
advocate, promote or assist any unlawful act such as (by way of example only) copyright infringement or computer misuse.
SUSPENSION AND TERMINATION
We will determine, in our discretion, whether there has been a breach of this acceptable use policy through your use of our site. When a breach of this policy has occurred, we may take such action as we deem appropriate.
Failure to comply with this acceptable use policy constitutes a material breach of the Terms of Use (see above) upon which you are permitted to use our site, and may result in our taking all or any of the following actions:
immediate, temporary or permanent withdrawal of your right to use our site;
immediate, temporary or permanent removal of any posting or material uploaded by you to our site;
issue of a warning to you;
legal proceedings against you for reimbursement of all costs on an indemnity basis (including, but not limited to, reasonable administrative and legal costs) resulting from the breach;
further legal action against you; and/or
disclosure of such information to law enforcement authorities as we reasonably feel is necessary.
We exclude liability for actions taken in response to breaches of this acceptable use policy. The responses described in this policy are not limited, and we may take any other action we reasonably deem appropriate.
CHANGES TO THE ACCEPTABLE USE POLICY
We may revise this acceptable use policy at any time by amending this page. You are expected to check this page from time to time to take notice of any changes we make, as they are legally binding on you. Some of the provisions contained in this acceptable use policy may also be superseded by provisions or notices published elsewhere on our site.
COOKIE POLICY
INFORMATION ABOUT OUR USE OF COOKIES
Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.
We use the following cookies:
Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
Analytical/performance cookies. They allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies. These are used to recognize you when you return to our website. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and any advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services and web analytics tools such as Google analytics, Keen.io, segment and others) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site. Cookies can also be managed in the Usercentrics consent management platform that we use.