Privacy Policy

HACHETTE AUSTRALIA PRIVACY POLICY

(as at 8 August 2018)

Hachette Australia Pty Ltd (ABN 3200 088 4855) (Hachette) is committed to protecting and respecting your privacy and takes seriously its obligations under the Privacy Act 1988 (Cth), the Privacy Act 1993 (NZ),  and similar legislation in other countries (including the General Data Protection Regulation (GDPR) that applies in European Union countries (including the United Kingdom) and the UK Data Protection Act 2018. As a result, Hachette has implemented practices, procedures and systems to comply with its legal obligations and, in particular, to:

maintain the confidentiality and security of personal information it collects and holds; and

manage its systems, practices and procedures in an open and transparent way.

By “personal information we mean information, data or an opinion about an identified individual, or about an individual who is reasonably identifiable  directly or indirectly from the information (including by reference to identifiers such as a name, an ID number, location data, an online identifier or to one or more factors specific to the physical, economic, cultural or social identity of that person). Those individuals include but are not limited to customers, potential customers, agents, suppliers, distributors, contractors and other business associates. This policy sets out how we handle the personal information we collect and hold. By continuing to use our sites, you agree that to the maximum extent permitted by law we may collect and handle your personal information in accordance with this policy (as amended from time to time).

What personal information does Hachette collect and hold?

The kinds of personal information we may collect and hold are:

• contact details (including email addresses);
• names;
• dates of birth;
• answers to log-in questions that may consist of personal information (such as the name of your first pet);
• details of transactions you carry out through our site;
• details concerning your orders;
• details of your visits to our sites (including traffic and location information, which pages you visit, weblogs and other communication information); and
• information about your reading preferences (in order to be able to suggest other titles you might be interested in reading).
• Also, when you visit our site, we may collect information about your computer, including (where available) your IP address, operating system and browser type.

If you provide us with more sensitive information this is known as Special Category (“Sensitive”) information and may include details about a person’s racial or ethnic origin, political opinions, religious, philosophical or similar beliefs, trade union membership, genetics, biometrics, health, sexual life, sexual orientation or about criminal offences or proceedings. This type of information will be treated differently and we will explain why we are collecting it and it will only be used with your explicit consent.

We do not keep files containing all of the above information on all people who contact us, or with whom we deal. In many cases, we may have only one or two pieces of data relating to any particular person.

If you purchase products from our sites by credit card, your credit card details will not be handled by us but by Shopify Inc, a USA based company that is subject to privacy obligations under US law and who are certified Level 1 PCI DSS compliant by both Vista and MasterCard: see https://www.shopify.com.au/pci-compliant. If you purchase from Shopify using PayPal, your details will be subject to PayPal's privacy policy (available at https://www.paypal.com/us/webapps/mpp/ua/privacy-full).

Why does Hachette collect and hold personal information?

We collect and hold personal information for a variety of purposes – and different kinds of personal information are used for different purposes.

In each case, however, the personal information we collect and hold is reasonably necessary for our functions and activities and for our legitimate interests, including in order to provide you with services you would expect from us. These purposes are:

• to provide you with news and information, products or services that you request from us or which we reasonably believe may interest you;
• for purposes necessary to providing you with goods and services that you have ordered or requested from us (including through our sites);
• to personalise and customise your experience when using our sites (including so that our sites is presented in the most effective manner for you and for your computer);
• to communicate with you (including by email, mail or telephone, and including in relation to changes to our products and services);
• to manage and enhance our products and services;
• to conduct competitions and promotions (both on our own behalf and in conjunction with Hachette’s affiliates and selected third parties);
• for system administration and for network analysis and security (by ourselves and our IT contractors);
• to process any job application you may submit to us;
• to report aggregate information to our affiliates and advertisers;
• to allow you to participate in interactive features of our sites that may be available;
• to investigate any complaints about or made by you, or if we have reason to suspect that you are in breach of any of our terms and conditions or that you are or have been otherwise engaged in any unlawful activity; and
• as required or permitted by any law (including privacy legislation).

From time to time, when collecting information from you, we may also ask you to “opt-in” to consent to us using or disclosing your personal information other than in accordance with this policy or any applicable law., However, you will also be given the opportunity to “opt out” from receiving communications from us or from third parties that send communications to you in accordance with this policy or in accordance with any additional consent you give, and we will comply with your decision. (You will be able to “opt out”, for example, by clicking on an “unsubscribe” link at the end of an email, or by contacting our Privacy Officer.)

How does Hachette get the personal information it collects and holds?

Hachette only collects personal information by fair , lawful  and transparent means, including when people:

• order books and other products from us through our sites;
• enter any of our competitions or promotions;
• fill in any contact forms on our sites (including when signing up for newsletters or events);
• browse our sites (we use cookies to ensure you have the best experience when browsing);
• post material to our sites or to social media that we use (such as Facebook, Twitter, Pinterest and Instagram);
• submit manuscripts to us;
• submit job applications;
• use any app we might provide;
• link their social media accounts to a Hachette account;
• contact us for assistance or with questions, or report problems with our sites or with a product; and
• contact us other than through our sites or social media (for example, if you email us directly, or send us a fax or letter)

If you wish to find out more about what personal information we may hold about you, please see below for information on how you can access and (if necessary) correct that information and data, and how you can have that information or data deleted.

Cookies

When you visit our website or use our apps we may send your browser a cookie. A cookie is a small file placed on your computer or mobile phone's browser that helps us recognise you when you return to our website or to the app and can tell us whether or not you've visited the site before. Your browser will tell us if you have these cookies, and if you don't, we may generate new ones.

You can disable cookies from our site at any time by changing your browser settings (typically found in the “options” or “preferences” menu of your browser). Please note, however, that changing these settings may prevent areas of our website from working as intended.

We also use third-party cookies, including Google Analytics features (such as Remarketing, e-Commerce Tracking, Demographics and Interest Reporting), Facebook Remarketing tags and tracking pixels and DoubleClick remarketing pixels. Based on your past visits to our website, these enable third-party vendors such as Google and Facebook to provide you with information about products and services that may be of interest to you as you browse the internet more generally (including information about products and services from third-parties).

You can choose to opt out of the above by visiting the Network Advertising Initiative opt out page (available at http://www.aboutads.info/choices) or, for Google Analytics, by visiting Google's Ads Settings and, for DoubleClick, the DoubleClick opt-out page.

For more information about cookies, including to see what cookies have been placed, how to manage and delete them, and how to opt-out of being tracked by social networks and third-party advertisers, visit these services:

www.aboutads.info/choices; 

www.youronlinechoices.eu;

www.aboutcookies.org; and

www.allaboutcookies.org. 
 

Children

Our services are only available to people aged 13 years or over. If you are aged under 13, you will need to have a parent or guardian sign up for our services or to place orders on your behalf

Can I interact with Hachette anonymously or under a pseudonym?

In many cases, you will need to provide your real name when interacting with us. This will particularly be the case when you are (for example) purchasing an item or claiming a prize in a competition.

You may however – wherever lawful and practicable – use a pseudonym (or simply not identify yourself) when dealing with us. For example, if you have a complaint or concern about our site, or a general question about any of our products or services, you are welcome to contact us without identifying yourself. In some cases, however, if you do not provide us with information, we may not be able to provide you with our products or services, or we may not otherwise be able to respond adequately to you.

For clarification on when you must identify yourself, please contact our Privacy Officer. (You may use a pseudonym – or simply not identify yourself – when making such an enquiry.)

Who has access to my personal information?

Generally, only our staff will access your personal information, and then only on a “need to know” basis.

We may, however, also disclose your personal information:

• to people who work for us or for one of our suppliers, or on our behalf, and who may be engaged in, among other things, filling and delivering orders, processing payments and mail-outs, marketing, administration, research and providing other technical and non-technical support (including IT services); ( see section on third party data processors below)
• to enforce or apply our terms of use or where you have otherwise been engaged in any unlawful activity, and we reasonably believe that disclosure is necessary to the police, any relevant authority or enforcement body, or your internet service provider or network administrator;
• to protect the rights, property, health or safety of Hachette or its staff, customers or others (including exchanging information with other companies and organisations to protect against fraud and to reduce credit risk);
• to our agents, legal advisers, business partners, joint venture entities and other partners, including any holding company or subsidiary, our ultimate holding company, and its holding companies and subsidiaries, as defined in section 50 of the Corporations Act 2001 (Cth);
• to sponsors and promoters of any competition that we conduct or promote; 
• as part of a sale (or proposed sale) of all or part of our business;
• to anyone else that you specifically authorise us to receive information held by us; and/or
• as otherwise required or permitted by law (including under privacy legislation).

Also, while we try to link only to websites that share our high standards and respect for privacy, we are not responsible for the privacy policy of any other web sites to which you provide personal information. We recommend that you read the privacy policies of such other web sites.

Third party data processors

Your information may be processed by our staff or by the staff of third parties we work with to deliver our business. We take measures to ensure that third parties processing your information on our behalf are acting lawfully in accordance with our instructions and are subject to appropriate confidentiality requirements. We also have adequate technical and organisational safeguards in place in our company and with third party processors to protect your information. Third Party processors of your information include our website hosts and operators, IT support providers, database operators, site analytics providers and software developers; 

• our marketing or publicity services providers;
• our editorial and production service providers, peer-reviewers, third-party manuscript readers
• our royalty system software provider; 
• our financial services and payment service provider;
• our warehousing and delivery service providers;
• our auditors, technical consultants and legal advisors;  
• our fraud detection services;
• How long we keep your personal information and data

We only keep your personal information and data for as long as is necessary to provide you with the goods or services you have requested from us or for as law as we reasonably need to retain the information for our legitimate interests.

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 we need to keep it.

Your rights and choices

As set out in more detail below, you may:

• object to our using your information for direct marketing and on the basis of our legitimate interests;
• withdraw any consent you have given to us in relation to our use of your personal information and data (including by contacting us as set out below or by “unsubscribing” to emails sent to you;
• request access to the information or data we hold about you;
• receive a copy of information or data we hold about you;
• ask us to transfer the information or data we hold about you to another service provider;
• ask us to correct information or data we hold about you;
• in certain circumstances, restrict the processing of information or data we hold about you;
• in certain circumstances, delete information and data we hold about you; and
• make a complaint (as further discussed below) in relation to how we have collected or used your personal information and data.

How can I access (and, if necessary, correct or delete) personal information that Hachette has collected and holds about me?

If you want to review (and, if necessary, correct or delete) personal information that Hachette may have collected and holds on you, please contact our Privacy Officer.

We will respond to your requests to access and to correct or delete your personal information as soon as possible (but in any case, within a reasonable period).

How can I complain about Hachette if it breaches any of applicable privacy principles or any registered code that binds it?

Contact our Privacy Officer (details below) if you have any complaints about breaches by Hachette of any applicable privacy principles or of any registered code that binds it. Alternatively, if you qualify as a “European Union data subject” (for example, because you live or work in Europe, including in the UK), you may contact our EU Data Representative (currently Hachette UK Ltd – [The Legal Department Hachette UK Limited, Carmelite House 50, Victoria Embankment London EC4Y 0DZ ]).

If you qualify as a “European Union data subject”, you may also lodge a complaint about us and our use of your personal information or data to the relevant supervisory authority. Information on how to file such a complaint is available at http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.

How will Hachette deal with complaints I might have about breaches of applicable privacy legislation or any relevant registered code?

We will treat any complaint about a breach of privacy legislation or any relevant registered code seriously and will investigate any breach of which we become aware – including how it occurred and how best to prevent such a breach occurring again. 

We take reasonable steps to ensure that your personal information is treated securely and in accordance with this policy and is not subject to misuse, interference or loss, or unauthorised access, modification or disclosure. We use appropriate technological and operational security measures to protect your information against any unauthorised access or unlawful use, such as using secure servers, we implement firewalls, password access and challenge phrases and, where relevant, we impose limits on who can access personal information. We also encrypt payment transactions using Secure Socket Layer (SSL) certificates. 

You understand, however, that the transmission and storage of personal information is not necessarily wholly secure, and that the steps we take to protect your information, though reasonable, may not always be effective. In those circumstances, except insofar as the GDPR requires, we do not accept responsibility for any misuse or loss of, or unauthorised access to, your personal information. If you suspect any misuse or loss of, or unauthorised access to, your personal information, please let us know immediately.

If we have given you (or where you have chosen) a password which enables you to access our services or parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Does Hachette disclose personal information to people or organisations outside Australia?

Hachette holds personal information securely both in its offices and on secure servers, some of which are located in Australia, and some of which are located in the United Kingdom, under the control of our affiliate company, Hachette UK. Personal information may also be processed by staff operating outside Australia or the European Economic Area. Such staff may be engaged in, among other things, filling your orders, processing payment details and providing support services.

By submitting your personal information to us, you agree to such transfers, storing and processing. In return, we will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this privacy policy and at least to the same standard as under Australian law and the GDPR.

We will not, however, transfer your personal information overseas to a country that is not subject to a comparable privacy scheme unless the organisation to which we disclose that information implements privacy policies at least comparable to the obligations that apply under the GDPR.

Does Hachette ever change its privacy policy?

We will review our privacy policy from time to time, to ensure it is in line with best practice and up-to-date with any legislative changes. Any changes to our privacy policy will be incorporated into a new version of this Policy and posted on this page, stating the date from which it operates. Our use of your personal information will be governed by our most recent policy.

Contact our Privacy Officer if you have any questions, comments or requests in relation to this privacy policy.

Who do I contact about privacy issues?

Contact our Privacy Officer on privacyofficer@hachette.com.au or on 61 2 8248 0800 if you have any concerns or questions about privacy issues, including how Hachette is dealing with or holding your personal information and data. Alternatively, if you qualify as a “European Union data subject” (for example, because you live or work in Europe, including in the UK), you may contact our EU Data Representative (currently Hachette UK Ltd – The Legal Department, Hachette UK Limited, Carmelite House 50 Victoria Embankment, London EC4Y 0DZ) ,

Please also contact our Privacy Officer if, for example:

• you want to review and/or correct any personal information or data we hold about you;
• you would like to withdraw any consent you have given to us in relation to how we use your personal information or data; 
• you would like us to delete your personal information and data; or
• you receive communications purporting to be connected with Hachette or our services that you believe have been sent other than in accordance with this policy or in breach of any law.