WHO WE ARE
We are Osprey Publishing Ltd. Our contact and other details are set out at the end of this policy. We are the data controller in relation to the personal data processed in accordance with this policy (except where this policy explains otherwise).
We are a publisher specialising in military history. We publish books (including e-books) and also produce board, card and other book-based games under our brand Osprey Games. We run forums for people interested in military history and other subjects via our website, and individuals can become Osprey members (which entitles them to discounts on our products and access to other material such as maps and illustrations). We sell our books, games and other products both directly to individual customers and via retailers.
THE PURPOSES FOR WHICH WE COLLECT PERSONAL DATA
We collect and process personal data as follows:
If you are an individual customer of ours or if you have registered individually to set up an account, download an e-book, become an Osprey member or join any of our online communities, or to receive any of our newsletters
We may collect your individual contact and other information that you give to us to enable us to fulfil any orders you make or otherwise to communicate with you in relation to the provision of books, games, other products or services by us (for example, in order to supply books that you have ordered, or to send you a newsletter that you have signed up to). Information that you give us may include (apart from your contact information such as your email address, postal address or phone number and IP address) credit card, bank account or other financial details relevant to payments made by you and other information relating to you that is included in any communications between us and you in the course of provision by us of books, game, other products or services.
If you are (or you work for) a business customer of ours, such as a bookshop or other retailer or a wholesaler or if you work for a relevant business and want to register to receive our newsletter
We may collect your individual contact and other information that you give to us to enable us to fulfil any orders that you (or the person that you work for) makes or otherwise to communicate with you in relation to the provision of books, games, other products or services by us (for example, in order to supply books that you or the person that you work for has ordered or to send you a newsletter that you have signed up to). Information that you give us may include (apart from your contact information such as your email address, postal address or phone number) credit card, bank account or other financial details relevant to payments made by you and other information relating to you that is included in any communications between us and you in the course of provision by us of books, game, other products or services.
If you use or browse any of our websites, including posting on the website, voting for books to be published or otherwise participate in any activities via our website
If you enter or wish to attend any of our competitions or events
We may collect information relevant to your participation or attendance in or at the competition or event, including your contact details and any other information we specifically ask you for at the time that is relevant to the competition or event concerned. We will use this information for the purposes of managing and administrating the competition or event concerned but not for any other purpose (such as marketing), except to the extent this is separately agreed with you at the time.
If we wish to send you advertising, marketing or promotional material
We may collect your individual contact details in order to send you direct marketing material in order to advertise, market or promote our goods and services (this will be subject to your prior consent where appropriate). For example, you may sign up to receive one of our regular newsletters. We may combine this with other information we obtain about the things you are interested in and that are relevant to the services provided by us (for example, when you buy something from us or browse our website and view particular content) in order to help us ensure that marketing material that we send you is relevant to what you are interested in.
If you are an author, illustrator, designer or other contributor to any books or games that we publish or if we are evaluating you or any of your work to assess whether or not to ask you to contribute or to publish or produce any of your work
We may collect your individual contact details, details of your past work and details of the work proposed for contribution or publication by you, together with other information relating to you that is relevant to the decision to commission or accept your work for publication or to publishing the work concerned, and we may use this information for the purposes of evaluating your work (or proposed work) and for dealing and communicating with you in relation to publication and sale of your work. Other information relating to you may include, for example, bank account or other financial details, and other information relating to you that is included in any communications between us and you or anyone you work with in the course of working with you in relation to the publication or exploitation of your work.
If you provide goods or services (or you work for someone who supplies goods or services) to us.
We may collect your individual contact information to enable us or other suppliers of ours to communicate with you in relation to the provision of goods or services by you or the person that you work for (for example, in relation to the management and administration of the provision of the relevant goods or services) and other personal information relating to you to in the course of provision of the goods or services concerned. This may include, for example, bank account or other financial details, and other information relating to you that is included in any communications between us and you or anyone you work with in the course of provision of the goods or services.
If we are assessing your suitability or ability to provide goods or services to us or to any of our group companies
We may collect relevant personal information relating to you to the extent necessary to enable that assessment to take place – for example, if we need to assess or confirm your age, your right to work in the UK, your skills and previous experience, your qualifications or whether there is anything that would adversely affect your suitability or ability to provide the goods or services concerned. This will be explained to you in more detail at the time we collect the personal data and, where appropriate, will be subject to your prior consent.
If you apply for a position with us
We may collect personal information in relation to you in connection with any application by you for a position with us. In that case, we will explain in more detail at the time how and for what purposes we intend to process the relevant personal information.
WHERE WE PROCESS YOUR PERSONAL DATA
We normally process personal data only in the UK or elsewhere in the EU or in non-EU countries (like Canada) that are certified as providing an adequate level of protection for personal data. If any relevant data is hosted on our behalf in countries that do not provide an adequate level of protection, then we will ensure an adequate level of protection by other means, such as use of appropriate contracts incorporating approved model clauses (see below).
Where necessary in order to manage our business, we may share relevant personal data with our group companies outside the EU, but only to the extent necessary in order to provide the services concerned.
Where you order products from us that are distributed from any of our warehouses outside the EU, we may share information relating to you (your name and address together with the products you have ordered) to the extent necessary to enable our service partner who operates the relevant warehouses to deliver the relevant products to you.
Where personal data is transferred in relation to providing our services we will take all steps reasonably necessary to ensure that it is subject to appropriate safeguards, such as relying on a recognised legal adequacy mechanism which may include by entering into EC approved standard contractual clauses relevant to transfers of personal information – see:
SECURITY OF YOUR PERSONAL DATA
All personal data processed by us is stored securely (the level of security being appropriate to the nature of the data concerned and the other relevant circumstances).
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website and any transmission is at your own risk. Once we have received your information, we will use appropriate procedures and security features to try to prevent unauthorised access
WHO WE SHARE YOUR PERSONAL DATA WITH
We may where appropriate share your personal data with:
- Appropriate third parties including:
- payment service providers (such as Firsty and Paypal);
- our business partners, customers, suppliers and sub-contractors (for example distributors and software providers) for the performance of any contract we enter into or other dealings we have in the normal course of business with you or the person that you work for;
- our auditors, legal advisors and other professional advisors or service providers;
- credit or other similar reference agencies for the purpose of assessing your suitability or ability where this is in the context of us entering (or proposing to enter) into a contract with you or the person that you work for.
- In relation to information obtained via our website, analytics and search engine providers that assist us in the improvement and optimisation of our site and subject to the cookies policy, and
- any of our group companies where necessary in order to address a specific order query or deal with a complaint that require escalation to another part of the business.
OTHER DISCLOSURES WE MAY MAKE
We may disclose your personal data to third parties:
- If we or substantially all of our assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of supply and other agreements with you or the person that you work for; or to protect the rights, property, or safety of our business or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection, or credit risk reduction.
THE LEGAL BASIS FOR OUR PROCESSING OF PERSONAL DATA
The legal basis on which we process your personal data is as follows:
- Where it is necessary to obtain your prior consent to processing in order for us to be allowed to do it, we will obtain and rely on your consent in relation to the processing concerned (in relation to any processing we are carrying out with your consent, see below for how to withdraw your consent).
- Otherwise, we will process your personal data where the processing is necessary:
- for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into such a contract;
- for compliance with a legal obligation to which we are a subject; or
- for the purposes of the legitimate interests pursued by us or another person, provided that this will only be in circumstances in which those legitimate interests are not overridden by your interests or fundamental rights and freedoms which require protection of personal data.
HOW LONG WE KEEP YOUR PERSONAL DATA
We process personal data only for so long as is necessary for the purpose(s) for which it was originally collected, after which it will be deleted or archived except to the extent that it is necessary for us to continue to process it for the purpose of compliance with legal obligations to which we are subject or for another legitimate and lawful purpose.
You have the following rights in relation to personal data relating to you that we process:
- You may request access to the personal data concerned.
- You may request that incorrect personal data that we are processing be rectified.
- In certain circumstances (normally where it is no longer necessary for us to continue to process it), you may be entitled to request that we erase the personal data concerned.
- Where we are processing your personal data for marketing purposes or otherwise based on our legitimate interests, you may in certain circumstances have a right to object to that processing.
- Where we are processing personal data relating to you on the basis of your prior consent to that processing (such as in relation to marketing by email), you may withdraw your consent, after which we shall stop the processing concerned.
- To exercise any of your rights (including withdrawing relevant consents or obtaining access to your personal data), you should contact us as set out below. To stop receiving any marketing emails, you can click on the unsubscribe link in the relevant marketing correspondence.
CONTACTING THE REGULATOR
The Information Commissioner is the supervisory authority in the UK and can provide further information about your rights and our obligations in relation to your personal data, as well as deal with any complaints that you have about our processing of your personal data.
Our contact details are:
The Data Protection Officer
Osprey Publishing c/o Bloomsbury Publishing Plc
50 Bedford Square
Contact: Michael Daykin, Data Protection Officer
Phone: 0207 631 5600
UPDATES TO THIS POLICY
DATE OF THIS POLICY
This policy was last updated on 22 May 2018.