This privacy notice (Privacy Notice) sets out the ways in which we, BookBlast Ltd (we, us, our), collect and use your personal data (your personal information) in connection with our business as a literary agency. It also explains what rights you have to access or change your personal data.
Our website is not intended for children. We do not knowingly collect or maintain the personal information of children under the age of 18. If you are under the age of 18, please do not access our website. We will take appropriate steps to delete the personal information of persons under the age of 18.
2. ABOUT US
1. We are a company registered in Cardiff under company number 3314906. Our registered address is: c/o M. N. Jenks & Co Ltd, 72 Commercial Road, Paddock Wood, Kent TN12 6DP.
2. You can contact us as follows:
FAO: G de Chamberet, Director
Address: P.O. Box 20184, London W10 5AU
3. INFORMATION WE MAY COLLECT ABOUT YOU
1. Information that you provide to us
i. We will collect any information that you provide to us when you:
i. are making an enquiry over the phone or via email;
ii. are an author or the beneficiary of a literary estate whose rights we represent either directly or via one of our client agencies or publishers;
iii. send unsolicited manuscripts to us by post, email or via our website;
iv. submit an application for a job vacancy;
ii. The information you provide to us might include your name, address, email address, phone number, and if you are submitting a manuscript or job application you may also provide additional information about your academic and work history, references and any other such similar information as may be required. For authors we represent we may need to collect some fiscal information (such as tax ID number, VAT number and/or other financial data) so that we can carry out the service we have been contracted to provide to our clients.
2. Information we collect about you
i. We will collect any information contained in any correspondence between us. For example, if you contact us by email or telephone, we may keep a record of that correspondence.
3. Information we receive from third parties
i. In certain circumstances, we will receive information about you from third parties. For example,
i. if you are an author or a literary estate, we may receive information about you from your publishers (or other licensees), agents or other representatives in order to consider representing you;
ii. if you are an author we represent, we may use third party providers (such as online bookseller websites) to verify or add to information provided by you or your agent in connection with your publication history so we can effectively represent your translation rights;
iii. if you are an author or literary estate we will receive information about you from your agent or publisher, if they are our client or as necessary to perform our contract with you, if you are our client, including fiscal data as required; and
iv. if you are a job applicant we may receive information about you from recruiters and your referees.
4. HOW WE USE INFORMATION ABOUT YOU AND RECIPIENTS OF YOUR INFORMATION
1. We will use your information for the purposes listed below either on the basis of:
i. performance of your contract with us and the provision of our services to you;
ii. your consent (where we request it); or
iii. our legitimate interests (including in accordance with your agent/publisher’s contract with us, if you are an author or literary estate) (see paragraph 4.3 below).
2. We may use your information for the following purposes:
i. for authors and estates: to enable receipt, review, promotion, licensing and management of your literary work(s) including sharing your information with our co-agents, foreign publishers and literary scouts (on the basis of performing our contract with you or our legitimate interests in managing our relationship and performing our contract with your agent/publisher);
ii. for authors and estates: to administer publishing contracts we have made on your behalf, including processing and payment of royalties, we may share some of your personal information with our external royalty administrator Rotherdale Accountancy Services TN31 6QT; our trademark agents Page White & Farrer WC1N 2BF; our co-agents and foreign publishers (on the basis of performing our contract with you);
iv. 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 contacts; on the basis of performing our contract with you);
v. for applicants: to process any job applications you submit to us including sharing this with our third party recruitment agency; and
vi. 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).
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:
i. personalising, enhancing, modifying or otherwise improving the services and/or communications that we provide to you;
ii. detecting and preventing fraud and operating a safe and lawful business;
iii. improving security and optimisation of our network, sites and services;
iv. providing representation according to our client agreements.
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
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:
i. third parties we work with to deliver our business which include our IT support provider Zen Internet Rochdale OL11 1RY; our database software manager Averba UK; our accountants M N Jenks & Co Ltd TN12 6DP; our bank HSBC; our book keeper Rotherdale Accountancy Services TN31 6QT; our digital contract execution and legal advisor;
ii. international publishers to whom we offer your rights and literary scouts to whom we send manuscripts; also our co-agents who handle rights for us in certain territories (listed on our website);
iii. any prospective buyer of our business or assets, only in the event that we decide to sell our business or assets; and
iv. any other third parties (including legal or financial 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.
2. We require third parties to maintain appropriate security to protect your information from unauthorised access or processing.
7. HOW WE LOOK AFTER YOUR INFORMATION AND HOW LONG WE KEEP IT FOR
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:
i. ensuring the physical security of our offices and equipment;
ii. ensuring the digital security of our equipment, devices and company data by using appropriate password protection and an appropriate enterprise level firewall; by using O365 so that all our email is stored securely in the cloud, rather than on site;
iii. maintaining an ILA network security policy which all employees are obliged to follow, and providing regular training for all staff to establish and maintain best practice, and to ensure continuous awareness of the importance of digital security;
iv. having our network assessed against the Cyber Essentials Scheme Test Specification;
v. maintaining a data protection policy for, and delivering data protection training to, our employees;
vi. limiting access to your personal information to those in our company who need to use it in the course of their work.
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. 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
1. Our company is located in the UK.
2. Your information will be processed outside of the European Economic Area (EEA) in the circumstances listed below and we will take all steps necessary to ensure that any of your information is adequately protected and processed in accordance with this Privacy Notice.
3. If you are our client, we supply information including your name (address, fiscal information such as tax ID number, VAT number etc) to publishers, scouts and agents around the world as necessary to perform our obligations in our contract with you.
9. YOUR RIGHTS TO THE INFORMATION WE HOLD ABOUT YOU
1. You have certain rights in respect of the information that we hold about you, including:
i. the right to be informed of the ways in which we use your information, as we seek to do in this Privacy Notice;
ii. the right to ask us not to process your personal data for marketing purposes;
iii. the right to request access to the information that we hold about you;
iv. 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
v. the right to request that we correct or rectify any information that we hold about you which is out of date or incorrect;
vi. 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;
vii. 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;
viii. in certain circumstances, the right to ask us to limit or stop processing information about you, or erase information we hold about you; and
ix. 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.
2. 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.
3. How to exercise your rights
You may contact us via the details at the top of this Privacy Notice if you wish to action any of these rights and we will comply with your requests unless we have a lawful reason not to do so.
4. What we need from you to process your requests
We may need to request specific information from you to help us confirm your identity and to enable you 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.
5. 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. We will 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.
10. CHANGES TO THIS PRIVACY NOTICE
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.
This Privacy Notice was updated on 24 May 2018.