1. Introduction The Vagrant Books website is owned and operated by Comment Services Ltd. We are committed to safeguarding the privacy of our website visitors and urge you to read this policy in its entirety. The policy contains important information about:
Who we are
How and why we collect, store, use and share personal information
Your rights in relation to your personal information
How to contact us and supervisory bodies in the event you have a complaint
This policy applies where we are acting as a data controller with respect to the personal data of our website visitors; in other words, where we determine the purposes and means of the processing of that personal data. Comment Services Ltd "we", "us" and "our" collect, use and are responsible for certain personal information about you. When we do so we are regulated under the General Data Protection Regulation which applies across the European Union (including the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws. 2. Personal information you provide to us We collect the following personal information that you provide to us:
Artwork or writing (for which you own the IP entirely, unless you enter into a contract with us as a paid Author, in which case IP terms will be identified and agreed upon separately)
Some examples of when we collect this information include when:
Signing up for our newsletter
Sending an enquiry about our business
Submitting your work for consideration to become a paid Author
You are purchasing a book or other from our online store
3. Personal information you provide about third parties If you give us information about another person, you confirm that the other person has appointed you to act on their behalf and agreed that you shall consent on their behalf to the processing of their personal data; shall receive any data protection notices on their behalf; and shall consent on their behalf to the transfer of their personal data where necessary.
4. Monitoring and recording communications We may monitor communications such as emails and telephone calls for quality assurance, training, fraud prevention and compliance purposes. 5. How we use your personal information We collect information about our users for the following purposes:
To provide you with business information through our newsletter (only if you opted in for this)
To respond to your enquiry
To evaluate your work and to determine if you may become a signed, paid Author
To see if you fit with our brand and can provide content for the kinds of books we aim to produce and sell
To provide an overview of royalties, sales figures, payments, and other for our paid Authors, and to complete relevant transactions associated with these
To carry out sales activities, including shipping of items or products
6. Who your information may be shared with We may share your information with law enforcement agencies in connection with any investigation to help prevent unlawful activity.
We will not share your personal information with any other third parties.
7. Marketing In some instances, we would like to send you information about products, services, offers, competitions and our business which may be of interest to you. Such information could be sent by email if you have opted in to receive these. 8. How long your personal information will be held for We will hold your personal information for up to six months in order to send correspondences, newsletters, or others. This will be until your enquiry has been sufficiently resolved, purchased items have been shipped and received, if you would like to continue receiving updates from us (you can unsubscribe at any time), and/or other miscellaneous needs.
This six-month rule may not apply if you are a paid Author, as we may need your details for as long as we are selling your work, which would be specified and agreed separately in your contract with us.
9. Reasons we can collect your personal data We will process your personal data where we have your consent, where collection and processing are necessary to comply with legal or regulatory obligations, or where collection or processing is necessary for our legitimate business interests. We have legitimate business interests in providing a good customer experience, understanding and responding to enquiries and client feedback, improving our services and offerings and providing publishing services. You may receive information about any of our services that may be relevant to you as a result of providing your personal information to us.
10. Keeping your information secure We have appropriate security measures in place to prevent personal information from being accidentally lost, used or accessed in any unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. In using our website, you acknowledge that use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data that are transferred from you or to you via the internet.
11. Your rights Under the General Data Protection Regulation (GDPR) you have a number of important rights. In summary, those rights include the following: (a) the right to access - you can ask for copies of your personal data; (b) the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data; (c) the right to erasure - you can ask us to erase your personal data; (d) the right to restrict processing - you can ask use to restrict the processing of your personal data; (e) the right to object to processing - you can object to the processing of your personal data; (f) the right to data portability - you can ask that we transfer your personal data to another organisation or to you; (g) the right to complain to a supervisory authority - you can complain about our processing of your personal data; and (h) the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent. These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects here. You may exercise any of your rights in relation to your personal data by written notice to us using the contact details set out below.
12. Amendments We may update this policy from time to time by publishing a new version on our website. You should check this page occasionally to ensure you are happy with any changes to this policy. We may notify you of significant changes to this policy by email. 13. Our details Contact Details including who data subject may write to with any complaints is email@example.com.