Privacy Notice – Mobile Applications

Welbeck Publishing Group Ltd (‘Welbeck’) 

Last updated 6 November 2020

Introduction

Welbeck is committed to delivering talent-driven publishing with leading authors, Illustrators and brands worldwide, and that begins with protecting the privacy of everyone that engages with us. This means that we’ll protect the personal information of all visitors who download, open, register and interact with any of our mobile applications (the “Applications”). This privacy notice (“Privacy Notice”) explains how Welbeck, our subsidiaries and affiliates collect, share, and use your personal information. You’ll also find information about how you can exercise your privacy rights. By using our Applications you agree to Welbeck using your personal information as described in this Privacy Notice. The terms “we”, “us” or “our” are each intended as reference to Welbeck and any terms not defined in this Privacy Notice are defined in our Terms.

1. Information we collect from you and why

We may collect information about you in a variety of ways.  The information we may collect via the Application depends on the content and materials you use (This information may include your likely demographic group), and includes:  

A. Information that you provide voluntarily:

Certain parts of our Applications may ask you to provide personal information voluntarily.

For instance:

Registration information: When you create a Welbeck account, sign-up or fill in forms on the Applications (if applicable for such Applications), we may collect information about you including your name, address, telephone number, email address and the password you create.

Information regarding your marketing preferences: We collect information about your preferences to receive marketing information any time you subscribe or unsubscribe (if applicable for such Applications).

Sensitive Information: We may collect information that you provide when you contact us (such as through our online forms if applicable from such Applications). This information may include sensitive personal information to ensure we give the best possible resolution to any complaint or comments you may wish to make and in those circumstances,  we will only be collecting it with your consent.

B. Information that we collect automatically:

When you access our Applications, we may collect certain information automatically from your device. In some countries, including countries in Europe, this information may be considered personal information under applicable data protection laws.

For instance:

Activity information: We collect information about your usage of the Applications and information about you from the content you create and the notifications or messages you post or send as well as what you search for, look at and engage with (if applicable for such Applications).

Cookies and similar technologies: We use cookies and similar tracking technology to collect and use personal information about you (e.g. your Internet Protocol (IP) address, your device ID, your browser type and when, how often and how long you interact with the Applications), including to facilitate interest-based advertising if required for such Applications. 

For further information about the types of cookies and similar technologies we use, why, and how you can control such technologies, see our Cookies Policy on our website on www.welbeckpublishing.com 

C. Information that we obtain from third party sources.

From time to time, we may receive personal information from third party sources, including advertising networks but only where we have checked that these third parties either have your consent to process the information or are otherwise legally permitted or required to share your personal information with us. This information may include your likely demographic group.

For instance:

Analytics reports and market research surveys: We collect information from our third party affiliates and vetted supported developers about the way you respond to and engage with our Applications so that we can customise our Applications accordingly.

We may also receive aggregated information in the form of audience segments from third party sources in order to display targeted advertising on digital properties operated by organisations like Facebook and Google.

Our use of collected information

Examples of how we may use this information include:

A. Information that you provide voluntarily

Registration information: The registration information you provide when you create a Welbeck account (if applicable for such Applications) allows us to give you access to the Applications and to supply them to you under our Terms. We also use this information to authenticate your access to the Applications, to contact you for your views and to notify you of important changes or updates to our Applications.

Feedback and reviews:

If you give us feedback, we will use it to reply to your questions or queries, to provide customer support and resolve any problems with the Applications. We will publish reviews that you send to us about our Applications in general and we also analyse your feedback to improve and develop our Applications and in order to enhance your experience.

B. Information that we collect automatically

When you access our Applications, we may collect certain information automatically from your device such as your IP address, MAC address or device ID. In some countries, including in Europe, this information may be considered personal information under applicable data protection laws.

Activity Information

We analyse habits and how you interact with our Applications so that we resolve any technical and feature issues. If you choose to share your geo-location with us, we may use this information to show you content that is local to you. We may also provide you with customised content and advertisements based on your previous interactions with our Applications and our knowledge of your preferences which we understand from your usage and buying history relating to the Applications.

We may also collect information about your interaction with our emails and other forms of communication.

Cookies and similar technologies

We work with advertising affiliates and third-party developers that serve advertisements on our Applications (if applicable). Some of those networks and those third-party developers may use/require cookies which allow us to display advertisements that are personalised to your interests based upon your usage activity.

Like many other applications and websites, we use cookies and other technologies to maintain a record of your interaction with our Applications. Cookies also help us to manage a range of features and content as well as to store searches. For further information about the types of cookies and similar technologies we use, why, and how you can control such technologies, please see our Cookies Policy on our website www.welbeckpublishing.com 

C. Information that we obtain from third party sources

Analytics reports and market research surveys:

We may analyse information we collect from our third-party service providers to understand how you engage with our Applications. This helps us to understand your preferences and recommend you some of our other Applications which are tailored to your interests.

2. Who we share personal information with

In delivering the Applications to you, depending on the circumstances, we may share your personal information with the following entities:

Third-party developers who support our Applications and deliver it to the app stores and then you download. Companies within the Welbeck group of companies (which means our subsidiaries and affiliates, our ultimate holding company and its subsidiaries and affiliates either now or at any time in the future) - these companies act for us and process your personal information for the purposes set out in this Privacy Policy.

We will only share your information with these third parties where you have given your consent. If you don’t want us to use your personal information in this way or generally change your mind about receiving any form of marketing communications, you can unsubscribe at any time using the unsubscribe functionality in the communication you receive or by amending your profile accordingly. If you choose to unsubscribe from our marketing, we will keep a record of your preferences so that we don’t bother you with unwanted marketing in future.

If any part of our business enters into a joint venture, purchases another business or is sold to or merged with another business entity, your information may be disclosed or transferred to the target company, or new business partners or owners or their agents and advisors. In these circumstances we will always inform the relevant entities that they must only use your personal information for the purposes disclosed in this Privacy Notice.

Any law enforcement or regulatory body, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person.

Any other person provided that you have given your consent to the disclosure. We will not sell, distribute or lease your personal information unless we have your permission or are required by law to do so.

3. Legal basis for processing personal information

Our legal basis for collecting and using your personal information as described above will depend on the specific context in which we collect it.

Our main reason for collecting and using your personal information is to ensure the Application performs as its intended for (i.e. to make sure the Applications functions as we have intended and you expect). However, we will also use your personal information where it is in our legitimate business interests to do so (but only if our interests are not overridden by your data protection interests or your fundamental legal rights and freedoms). 

In some cases, we may have a legal obligation to collect personal information from you (e.g. in the event of legal proceedings) or we might need to process it or share it with others to “protect your vital interests” (this is legal speak for saving your life) or those of another person (e.g. in a case where another person’s life is in danger).

If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (and we’ll also explain the possible consequences of you not providing it).

Similarly, we may collect and use your personal information in reliance on our legitimate interests (or those of any third party). Relevant legitimate interests include a) to market to you or make you offers that we believe will interest you; b) to analyse and understand how our services are used and so to improve them; c) for fraud prevention or prevention of other criminal acts; or d) to keep our systems secure.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “How to contact us” below.

4. International data transfers

We may transfer your personal information to countries other than the country in which you are resident. Welbecks website servers are mainly located in the United Kingdom, Europe, USA. This means that when we collect your personal information we may process it in any of these countries.

Whilst these countries may have data protection laws that are different to the laws of your country, you can rest assured that Welbeck takes care to implement appropriate safeguards to protect your personal information in those countries in accordance with this Privacy Notice. Some of the safeguards we rely on include, where appropriate, using the European Commission’s approved standard contractual clauses with our suppliers, intra-group transfer agreements (so that we can safely transfer your data between the Welbeck group of companies all over the world) and contracting with Privacy Shield certified companies in the United States, where this is appropriate.

5. Security

We place great importance on keeping your personal information safe and secure. As such, we put in place appropriate technical and organisational measures / industry standard technology to protect it from unauthorised access and unlawful processing, accidental loss, destruction and damage.

The security measures we use are designed to provide a level of protection security appropriate to the risk of processing your personal information. Where you have chosen a password (if applicable for such Applications) which allows you to access certain parts of the Applications, you are responsible for keeping this password confidential. We advise you not to share your password with anyone and to use a unique password for our Applications. We will not be liable for any unauthorised transactions entered into using your name and password.

6. Data retention

Welbeck will retain your personal information where we have an ongoing legitimate business need to do so (for example, while you hold an account with us or to enable us to meet our legal, tax or accounting obligations).

If you object to us processing certain categories of your personal information (including in relation to receiving marketing communications from us), we will retain a record of your objection to the processing of your information so that we can continue to respect your wishes.

We will destroy or permanently anonymise your personal information at the point that we no longer need to process it for our ongoing legitimate business needs or for any legal reason. If this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store it and isolate it from any further processing until deletion is possible.

 

7. Your data protection rights

Welbeck respects your privacy and data protection rights. Below is a summary of your rights in respect of the personal information of yours which Welbeck may handle:

Welbeck will provide you with the tools to access, review or update your personal information at any time through your account (if applicable for such Applications). If you wish to request deletion of your personal information, you can do so by contacting us using the contact details provided under the “How to contact us” heading below.

You can object to processing of your personal information, ask us to restrict processing of your personal information or request that it be ported to a third party. Again, you can exercise these rights by contacting us using the contact details provided under the “How to contact us” heading below.

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  • You have the right to opt-out of receiving marketing communications we send you at any time. You can exercise this right by using the unsubscribe functionality in the communication you receive or by amending your profile accordingly.
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  • Similarly, if we collect and process your personal information on the basis of your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
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  • You have the right to complain to a data protection supervisory authority about our collection and use of your personal information.
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  • We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

 

8. Links to third-party sites

Our Applications may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates or to any number of websites that may offer useful information to our visitors. We provide these links to you only as a convenience and the inclusion of any link does not imply endorsement of the relevant website by Welbeck. If you follow a link to any of these websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for these policies or those linked websites. Please check these policies before you submit any personal information to such websites.

9. Updates to this Privacy Notice

We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Notice changes if and where this is required by applicable data protection laws.

We encourage you to periodically review this page for the latest information on our privacy practices.

10. How to contact us

If you have any questions or concerns about this Privacy Notice and Welbeck's privacy practices, please contact us:

By email at: gdpr@welbeckpublishing.com

By writing to us at:

Welbeck Publishing Group Limited – FAO: Data Protection Manager
20 Mortimer Street, London W1T 3JW
UK

 

Alternatively, you can contact our appointed Data Protection Officer directly by email at mozidur.rahman@welbeckpublishing.com