Privacy Policy

This privacy policy sets out the terms of how GWL Publishing, a wholly-owned Great War Literature Publishing LLP imprint, (“we”, “us” and “our”) and our related companies will use any information or personal information that you (“you”, “yours”) give to us or we collect from you. Personal information means any information about you from which you could be identified such as your name, address, telephone number or email address. Whenever you provide us with personal information we will use it as per these terms. Whilst this privacy policy will apply to most of our websites, some of our websites may have additional terms not covered by this privacy policy and you should always check a site’s Terms of Use carefully.

Who are we?

This website is run by GWL Publishing, whose offices are located at Forum House, Stirling Road, Chichester, West Sussex, PO19 7DN, United Kingdom.

You may contact us via email at contact.us@gwlpublishing.co.uk.

How we collect and use your personal information

Any information we collect or hold about you will be treated in strictest confidence and held securely on our office server or on our agents’ servers in compliance with the Data Protection Act 1998 and the Regulation (EU) 2016/679 (General Data Protection Regulation).

As you use our website you may come across certain activities and services for which we request personal information. These activities and services are outlined and explained below. We will not use your name or email address for any purpose other than as stated in this Privacy Policy document:

  • Manuscript submissions
    If you are sending us a manuscript submission, you will be asked to supply contact details, such as your name, e-mail address and telephone number. We will use these details to contact you regarding your submission, and for no other purpose. If you are unsuccessful, we will delete your submission from our records within 24 hours of informing you. If you are successful, a contract will be issued to you. (See our legal basis for using your personal information and data).
  • Administrative matters
    If you have contact us to ask a question about a product or service, we will send you an email in response.
  • Focus groups and questionnaires
    It is sometimes extremely helpful to know what readers and potential readers think about a new cover design, a new book idea or a plan to revise an existing book. If you have consented, we would like to be able to ask you questions about subjects we believe to be of interest to you.
  • Feedback, suggestions, opinions
    If you have consented, we may ask you for your suggestions and opinions and provide you with a link for emailing us your response. We will only use the email address we receive from you for the purpose of responding to your questions or suggestions.

Age restrictions

You can only register to use our site or submit a manuscript if you are over the age of majority in the country in which you reside. That means that we do not knowingly collect any information about (or market to) children, minors or anyone under the age of majority unless their parent or legal guardian has consented.
If we become aware that a child, minor or anyone under the age of majority has registered with us and provided us with personal information without parental or guardian consent, we will take steps to terminate that person’s account and delete their profile information from our site. If we do delete an account because they violated our age restriction rules, we may retain their email and IP address to ensure that they do not try to get around our rules by creating a new account.

Our legal basis for using your personal information and data

The legal bases on which we rely to use your information are:

  • To allow us to exercise our legitimate interests as a data controller: we rely on our legitimate interests as a data controller to process the personal information that you provide to us on contact or submission forms on our website. It is in our legitimate interests as a business to process the above information in order to administer our business, and to ensure that content from our website is presented to you effectively and securely.
  • Where we have obtained your consent: we may provide you with certain marketing information about services or products where you have provided your explicit consent for us to do so.
  • Where a contract has been issued to you as an author, certain terms of this Privacy Policy shall be superseded by the terms of the aforementioned contract.

Disclosure of personal information and your rights

We will only disclose your personal information to:

  • our business partners and our suppliers and sub-contractors for the performance of any contract we enter into with them or you. Any information GWL Publishing holds about you will be treated in strictest confidence and held securely on our server or our agents’ servers in compliance with the Data Protection Act 1998. We will not divulge any of your details to any third party without your permission, except when it is necessary for us to satisfy a request made by you;
  • our third-party service providers in order to identify or resolve technical problems arising from the use of the website; and
  • our regulators, law enforcement or fraud prevention agencies, as well as our legal advisers, courts and any other authorised bodies, for the purposes of investigating any actual or suspected criminal activity, enforcing our rights or other regulatory or legal matters.

Marketing

  • We may provide you with certain marketing information about services or products where you have provided your explicit consent for us to do so. Please note that we will use your personal information in order to provide certain marketing information for the same or similar services you have previously used.
  • If you register to be sent information about our authors, books or events we will ask you for some personal information (name and email address) in order to provide you with the service you are requesting. As noted above, you may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.
  • If you wish to opt out of receiving marketing communications from GWL Publishing you can do so by emailing us at contact.us@gwlpublishing.co.uk or clicking the ‘unsubscribe’ button and following the instructions. Please note that if you have signed up for several different lists you will have to remove yourself from each one individually.

Analysis of site visits

We may want to use information collected anonymously about the number of visitors entering our website and where they go within it. We will do this in order to find out whether the structure or content of the site needs amendment, whether we should develop additional titles on certain subjects or reprint certain titles sooner than others. To the best of our knowledge none of this information will be personally identifiable, but if we inadvertently acquired personal information, we would never divulge it to a third party.

Cookies

We use traffic-log cookies to identify which pages are being used. This helps us analyse data about web-page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis.

Overall, cookies help us provide a better website by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

Please visit our Cookie Policy page for more information.

Links to other websites

Our website contains links to other sites that are not under our control, even though they may use the GWL Publishing name or logo on their website, through an agreement with us. Such other websites do not necessarily follow our privacy policies, and may place their own cookies on your computer.

This practice is standard on the Internet. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for those policies.

Security of private information

It is impossible for GWL Publishing completely to guarantee the security of any transmission of information via the Internet. Although we will do our very best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to prevent unauthorised access.

Please note that where we provide you (or where you have chosen) a password which enables you to gain access to certain parts of the website, you are responsible for keeping this password confidential. Please do not share a password with anyone.

We make no undertaking or warranty about how or where your data may be stored by third parties with whom you may choose to engage via our website, and to whom you may supply personal data, or request that we supply personal data.

Storage and retention

Where GWL Publishing collect and store personal data it will be held on servers located within the European Economic Area (EEA). We do not transfer your personal data outside the EEA. Any personal data stored on hard copy will be securely held at the office and will not be taken out of the building.

We will retain information about you for the period necessary to fulfil the purposes for which the information was collected. After that, we will delete it.

The retention period may vary depending on the purposes for which the information was collected. Where a specific legal or regulatory requirement applies to your information we will retain it for the period of time specified in such legal or regulatory requirement. In the absence of a specific legal or regulatory requirement we will retain your information for six years following the event to which it relates (e.g. the specific sale, the specific competition, etc.). We may be required to extend the retention period if the information is required due a complaint or because it is required for litigation. Please also note that we are sometimes legally obliged to retain the information, for example for tax and accounting purposes.

Your rights regarding your personal information

You have certain rights in relation to your personal information that is processed by us. We set out an overview of these rights below. These rights are not absolute and apply subject to certain conditions, as set out in applicable data protection laws. Your rights may include:

  • the right to obtain access to personal data held by us about you;
  • the right to require us to rectify any inaccurate personal data held by us about you;
  • in certain circumstances, the right to require us to erase personal data held by us about you;
  • in certain circumstances, the right to restrict our processing of personal data held by us about you;
  • in certain circumstances, a right to receive personal data which you have provided to us in a structured, commonly used and machine-readable format. You may also have the right to require us to transfer this personal data to another organisation, at your request;
  • the right to object to our processing of personal data held by us about you (including for the purposes of sending marketing materials to you); and
  • the right to withdraw your consent, where we are relying on it to use your personal data (for example, to provide you with marketing information about our services and products).

You can exercise these rights by emailing us at contact.us@gwlpublishing.co.uk

Contacting the Information Commissioner’s Office (ICO)

Should you wish to make a complaint, you may also contact the Information Commissioner’s Office here.

Changes in policy

If we change our policy, we will indicate the changes on this page so you are always aware of the rules we follow in safeguarding personal information.

Queries and concerns

If you have any questions about our privacy policy, please feel free to contact us by email at contact.us@gwlpublishing.co.uk

ADDENDUM

1. Definitions

“Controller-to-Controller SCCs” means the Standard Contractual Clauses (Controller to Controller Transfers – Set II) in the Annex to the European Commission Decision of December 27, 2004, as may be amended or replaced from time to time by the European Commission.

“Controller-to-Processor SCCs” means the Standard Contractual Clauses (Processors) in the Annex to the European Commission Decision of February 5, 2010, as may be amended or replaced from time to time by the European Commission.

“Customer or Author Personal Data” means Personal Data that processes as a data processor for Customer or Author Data. Customer or Author Personal Data includes Personal Data that Customer or Author uploads or otherwise provides GWL Publishing in connection with its use of our services or for which the Customer or Author is otherwise a data controller.

“Data Protection Requirements” means the General Data Protection Regulation, Local Data Protection Laws, and any applicable laws, regulations, and other legal requirements relating to (a) privacy, data security, consumer protection, marketing, promotion, and text messaging, email, and other communications; and (b) the use, collection, retention, storage, security, disclosure, transfer, disposal, and other processing of any Personal Data.

“European Personal Data” means Personal Data the sharing of which pursuant to this Agreement is regulated by the General Data Protection Regulation or Local Data Protection Laws.

“General Data Protection Regulation” means Regulation (EU) 2016/679 of the European Parliament and of the Council.

“Local Data Protection Laws” means any subordinate legislation and regulation implementing the General Data Protection Regulation.

“Personal Data” means information about an individual that (a) can be used to identify, contact or locate a specific individual, including data that Customer chooses to provide to GWL Publishing from services such as applicant tracking systems (ATSs) or customer-relationships management (CRM) services; (b) can be combined with other information that can be used to identify, contact or locate a specific individual; or (c) is defined as “personal data” or “personal information” by applicable laws or regulations relating to the collection, use, storage or disclosure of information about an identifiable individual.

“Personal Data Breach” means any accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to Customer Personal Data.

“Process” and its cognates mean any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

“SCCs” means all Controller-to-Processor SCCs and Controller-to-Controller SCCs entered into between the parties under the Agreement.

“Subprocessor” means any entity which provides processing services to GWL Publishing in furtherance of GWL Publishing’s processing on behalf of the Customer or Author.

“Supervisory Authority” means an independent public authority which is (i) established by a European Union member state pursuant to Article 51 of the General Data Protection Regulation; or (ii) the public authority governing data protection, which has supervisory authority and jurisdiction.

2. NATURE OF DATA PROCESSING

Each party agrees to process Personal Data received under the Agreement only for the purposes set forth in the Agreement. For the avoidance of doubt, the categories of Personal Data processed and the categories of data subjects subject to this DPA are described in Schedule A (Annex B) to this DPA.

3. COMPLIANCE WITH LAWS

The parties shall each comply with their respective obligations under all applicable Data Protection Requirements.

4. CUSTOMER OBLIGATIONS

4.1 Customer agrees to:

  • (i) determine the purposes and general means of GWL Publishing’s processing of Customer or Author Personal Data in accordance with the Agreement; and
  • (ii) comply with its protection, security and other obligations with respect to Customer or Author Personal Data prescribed by Data Protection Requirements for data controllers.

4.2 The Customer or Author agrees to, at GWL Publishing’s request, designate to GWL Publishing a single point of contact (the “Master Admin”) responsible for

  • (i) receiving and responding to data subject requests GWL Publishing receives from Customer or Author data subjects relating to Customer or Author Personal Data; and (ii) notifying GWL Publishing of the Customer’s or Author’s intended response to a data subject request relating to the access to or the rectification, erasure, restriction, portability, blocking or deletion of Customer or Author’s Personal Data that GWL Publishing processes for the Customer or Author, and authorising GWL Publishing to fullfill such responses on behalf of the Customer or Author.

5. GWL Publishing OBLIGATIONS

5.1 Processing Requirements. GWL Publishing will:

  • a. Process Customer or Author Personal Data (i) only for the purpose of providing, supporting and improving GWL Publishing’s services (including to provide insights and other reporting), using appropriate technical and organisational security measures; and (ii) in compliance with the instructions received from the Customer or Author. GWL Publishing will not use or process the Customer or Author Personal Data for any other purpose. GWL Publishing will promptly inform the Customer or Author in writing if it cannot comply with the requirements under Sections 5-8 of this DPA, in which case the Customer or Author may terminate the Agreement or take any other reasonable action, including suspending data processing operations;
  • b. Inform the Customer or Author promptly if, in GWL Publishing’s opinion, an instruction from the Customer or Author violates applicable Data Protection Requirements;
  • c. If GWL Publishing is collecting Customer or Author Personal Data from individuals on behalf of the Customer or Author, follow the Customer or Author’s instructions regarding such Customer or Author Personal Data collection (including with regard to the provision of notice and exercise of choice);
  • d. Take commercially reasonable steps to ensure that (i) persons employed by it and (ii) other persons engaged to perform on GWL Publishing’s behalf comply with the terms of the Agreement;
  • e. Ensure that its employees, authorised agents and any Sub-processors are required to comply with and acknowledge and respect the confidentiality of the Customer or Author Personal Data, including after the end of their respective employment, contract or assignment;
  • f. If it intends to engage Sub-processors to help it satisfy its obligations in accordance with this DPA or to delegate all or part of the processing activities to such Sub-processors, (i) exclusive of the list of Sub-processors GWL Publishing maintains online, obtain the prior written consent of the Customer or Author to such sub-contracting, such consent to not be unreasonably withheld; (ii) remain liable to the Customer or Author for the Sub-processors’ acts and omissions with regard to data protection where such Sub-processors act on GWL Publishing’s instructions; and (iii) enter into contractual arrangements with such Sub-processors binding them to provide the same level of data protection and information security to that provided for herein; and
  • g. Upon request, provide the Customer or Author with a summary of GWL Publishing’s privacy and security policies.

5.2 Notice to Customer or Author. GWL Publishing will inform the Customer or Author if GWL Publishing becomes aware of:

  • a. Any non-compliance by GWL Publishing or its employees or representatives with Sections 5-8 of this DPA or the Data Protection Requirements relating to the protection of Customer or Author Personal Data processed under this DPA;
  • b. Any legally binding request for disclosure of Customer or Author Personal Data by a law enforcement authority, unless GWL Publishing is otherwise forbidden by law to inform the Customer or Author, for example to preserve the confidentiality of an investigation by law enforcement authorities;
  • c. Any notice, enquiry or investigation by a Supervisory Authority with respect to Customer or Author Personal Data; or
  • d. Any complaint or request (in particular, requests for access to rectification, erasure, restriction, portability, blocking or deletion of Customer or Author Personal Data) received directly from data subjects of the Customer or Author. GWL Publishing will not respond to any such request without the Customer or Author’s prior written authorisation.

5.3 Assistance to Customer. GWL Publishing will provide reasonable assistance to the Customer or Author regarding:

  • a. Any requests from the Customer or Author data subjects in respect of access to or the rectification, erasure, restriction, portability, blocking or deletion of Customer or Author Personal Data that GWL Publishing processes for the Customer or Author. In the event that a data subject sends such a request directly to GWL Publishing, GWL Publishing will promptly send such request to the Customer or Author;
  • b. The investigation of Personal Data Breaches and the notification to the Supervisory Authority and Customer or Author’s data subjects regarding such Personal Data Breaches; and
  • c. Where appropriate, the preparation of data protection impact assessments and, where necessary, carrying out consultations with any Supervisory Authority.

5.4 Required Processing. If GWL Publishing is required by Data Protection Requirements to process any Customer or Author Personal Data for a reason other than providing the services described in the Agreement, GWL Publishing will inform the Customer or Author of this requirement in advance of any processing, unless GWL Publishing is legally prohibited from informing the Customer or Author of such processing (e.g., as a result of secrecy requirements that may exist under applicable EU member state laws).

5.5 Security. GWL Publishing will:

  • a. Maintain appropriate organisational and technical security measures (which may include, with respect to personnel, facilities, hardware and software, storage and networks, access controls, monitoring and logging, vulnerability and breach detection, incident response, encryption of Customer Personal Data while in transit and at rest) designed to protect against unauthorised or accidental access, loss, alteration, disclosure or destruction of Customer or Author Personal Data;
  • b. Be responsible for the sufficiency of the security, privacy, and confidentiality safeguards of all GWL Publishing personnel with respect to Customer or Author Personal Data and liable for any failure by such GWL Publishing personnel to meet the terms of this DPA;
  • c. Take reasonable steps to confirm that all GWL Publishing personnel or representatives are protecting the security, privacy and confidentiality of Customer or Author Personal Data consistent with the requirements of this DPA; and
  • d. Notify the Customer or Author of any Personal Data Breach by GWL Publishing, its Sub-processors, or any other third-parties acting on GWL Publishing’s behalf without undue delay and in any event within 48 hours of becoming aware of a Personal Data Breach.

6. AUDIT, CERTIFICATION

6.1 Supervisory Authority Audit. If a Supervisory Authority requires an audit of the data processing facilities from which GWL Publishing processes Customer or Author Personal Data in order to ascertain or monitor Customer’s compliance with Data Protection Requirements, GWL Publishing will cooperate with such audit. The Customer or Author is responsible for all costs and fees related to such audit, including all reasonable costs and fees for any and all time GWL Publishing expends for any such audit, in addition to the rates for services performed by GWL Publishing.

6.2 Audits. Customer may not audit GWL Publishing more than once annually.

7. DATA TRANSFERS

For transfers of European Personal Data to GWL Publishing for processing by GWL Publishing in a jurisdiction other than a jurisdiction in the EU, the EEA, or the European Commission-approved countries providing ‘adequate’ data protection, GWL Publishing agrees it will (a) provide at least the same level of privacy protection for European Personal Data as required under the U.S.-EU and U.S.-Swiss Privacy Shield frameworks; or (b) use the form of the Controller-to-Processor SCCs. If data transfers under Section 7 of this DPA rely on Controller-to-Processor SCCs to enable the lawful transfer of European Personal Data, as set forth in the preceding sentence, the parties agree that data subjects for whom a GWL Publishing entity processes European Personal Data are third-party beneficiaries under the Controller-to-Processor SCCs. If GWL Publishing is unable or becomes unable to comply with these requirements, then European Personal Data will be processed and used exclusively within the territory of a member state of the European Union and any movement of European Personal Data to a non-EU country requires the prior written consent of Customer. GWL Publishing shall promptly notify the Customer or Author of any inability by GWL Publishing to comply with the provisions of this Section 7.

8. DATA RETURN AND DELETION

The parties agree that on the termination of the data processing services or upon the Customer or Author’s reasonable request, GWL Publishing shall, and shall cause any Sub-processors to, at the choice of the Customer or Author, return all the Customer or Author Personal Data and copies of such data to the Customer or Author or securely destroy them and demonstrate to the satisfaction of the Customer or Author that it has taken such measures, unless Data Protection Requirements prevent GWL Publishing from returning or destroying all or part of the Customer or Author Personal Data disclosed. In such case, GWL Publishing agrees to preserve the confidentiality of the Customer or Author Personal Data retained by it and that it will only actively process such Customer or Author Personal Data after such date in order to comply with applicable laws. For clarity, GWL Publishing may continue to process Customer or Author Personal Data that has been aggregated in a manner that does not identify individuals or customers to improve GWL Publishing’s systems and services.

9. CONTROLLER-TO-CONTROLLER SCENARIOS

Each party will, to the extent that it, along with the other party, acts as data controller, as the term is defined in applicable Data Protection Requirements, with respect to Personal Data, reasonably cooperate with the other party to enable the exercise of data protection rights as set forth in the General Data Protection Regulation and in other Data Protection Requirements. Where both parties each act as data controller with respect to Personal Data, and the transfer of data between the parties results in a transfer of European Personal Data to a jurisdiction other than a jurisdiction in the EU, the EEA, or the European Commission-approved countries providing ‘adequate’ data protection, each party agrees it will (a) provide at least the same level of privacy protection for European Personal Data as required under the U.S.-EU and U.S.-Swiss Privacy Shield frameworks; or (b) use the Controller-to-Controller SCCs, which are incorporated herein by reference. If data transfers under this DPA rely on Controller-to-Controller SCCs to enable the lawful transfer of Personal Data, as set forth in the preceding sentence, the parties agree that the following terms apply: (i) Data subjects for whom a Customer or Author processes European Personal Data are third-party beneficiaries under the Controller-to-Controller SCCs; (ii) Schedule A to this DPA shall apply as Annex B of the Controller-to-Controller SCCs; and (iii) for purpose of Section II(h), the data importer will process the European Personal Data, at its option, in accordance with “the relevant provisions of any Commission decision pursuant to Article 25(6) of Directive 95/46/EC, where the data importer complies with the relevant provisions of such an authorisation or decision and is based in a country to which such an authorisation or decision pertains, but is not covered by such authorisation or decision for the purposes of the transfer(s) of the personal data.” The parties acknowledge and agree that each is acting independently as Data Controller with respect of Personal Information and the parties are not joint controllers as defined in the General Data Protection Regulation.

10. THIRD PARTY DATA PROCESSORS

The Customer or Author acknowledges that in the provision of some services (such as ATSs and CRMs), GWL Publishing, on receipt of instructions from the Customer or Author, may transfer Customer or Author Personal Data to and otherwise interact with third party data processors. The Customer or Author agrees that if and to the extent such transfers occur, the Customer or Author is responsible for entering into separate contractual arrangements with such third party data processors binding them to comply with obligations in accordance with Data Protection Requirements. For avoidance of doubt, such third party data processors are not Sub-processors.

11. TERM

This DPA shall remain in effect as long as GWL Publishing carries out Personal Data processing operations on behalf of the Customer or Author or until the termination of the GWL Publishing Contract (and all Personal Data has been returned or deleted in accordance with Section 8 above).

12. GOVERNING LAW, JURISDICTION, AND VENUE

Notwithstanding anything in the Agreement to the contrary, this DPA shall be governed by the laws of England and Wales, and any action or proceeding related to this DPA (including those arising from non contractual disputes or claims) will be brought in London, United Kingdom.

SCHEDULE A

ANNEX B – DESCRIPTION OF THE TRANSFER

1. Data Subjects. The personal data transferred concern the following categories of data subjects:

Depending on the services used by the data exporter:

  • Potential and actual candidates, employees and representatives of the data exporter;
  • Sales and marketing leads of the data exporter; and
  • Third parties that have, or may have, a commercial relationship with the data exporter (e.g. advertisers, customers, corporate subscribers and contractors).

2. Purposes of the Transfer. The transfer is made for the following purposes:

The transfer is intended to enable the data exporter to determine the purposes and means of the processing of personal data obtained through data importer’s products to support the sales, recruiting, marketing, educational, or other business practices of the data exporter.

3. Categories of Data. The personal data transferred concern the following categories of data:

The data transferred is the personal data provided by the data exporter to the data importer in connection with its use of GWL Publishing’s online author recruiting, sales, marketing and/or educational services, referred to as Customer or Author Personal Data in GWL Publishing Agreements and Contracts. Such personal data may include first name, last name, email address, contact information, education and work history provided in resumes, CRM data concerning sales leads and customer and/or Author lists, and any notes provided by the data exporter regarding the foregoing.

4. Recipients. The personal data transferred may be disclosed only to the following recipients or categories of recipients:

Employees and other representatives of the data importer who have a legitimate business purpose for the processing of such personal data.

5. Sensitive Data (if appropriate). The personal data transferred concern the following categories of sensitive data:

None.

6. Data Protection Registration Information of Data Exporter (where applicable).

None.

7. Additional Useful Information (storage limits and other relevant information).

The personal data transferred between the parties may only be retained for the period of time permitted under the Agreement. The parties agree that each party will, to the extent that it, along with the other party, acts as a data controller with respect to Personal Data, reasonably cooperate with the other party to enable the exercise of data protection rights as set forth in the Data Protection Requirements.

8. Contact Information. Contact points for data protection enquiries:

  • Data importer: Signatory to the Agreement between the parties
  • Data exporter: Signatory to the Agreement between the parties

This policy was last updated on 01 May, 2019.

©2019 GWL Publishing

Connect with us

Keep up with news about books, authors, and more from GWL Publishing.

Facebook
Instagram
Linkedin
Tumblr
Twitter
YouTube