1.1 We are committed to safeguarding the privacy of our Website visitors, subscribers and customers; in this policy we explain how we will handle your personal data.
2. How we use your personal data
2.1 In this Section 2 we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
2.2 We process data about your use of our Website(s) and services ("usage data"). The usage data includes your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and Website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the Website(s) and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our Website(s) and services.
2.3 We process your account data ("account data"). The account data includes your name, postal address, telephone numbers, billing address, email address, user name and password, purchase history, and relevant publication or publishing service interests. The source of the account data is you or your employer. The account data may be processed for the purposes of operating our Website(s), providing our services, ensuring the security of our Website(s) and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.4 We may process information contained in any enquiry you submit to us regarding goods and/or services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.
2.5 We process information relating to transactions, including purchases or subscriptions of goods and services, that you enter into with us and/or through our Website ("transaction data"). The transaction data includes your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our Website and business.
2.6 We process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent. We also email marketing material which are relevant to the context of your employment to email addresses which are publicly available. The basis for this processing is our legitimate business interests. You may choose to unsubscribe from such emails at any time by following the link in the email footer.
2.7 We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our Website(s) will generate the metadata associated with communications made using the Website(s) contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our Website(s) and business and communications with users.
2.8 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
2.9 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
2.10 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
3. Providing your personal data to others
3.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
3.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
3.3 We disclose account data and transaction data to our warehouse and distribution providers and postal suppliers insofar as reasonably necessary for posting your purchases or distributing catalogues. We may disclose account data, usage data and transaction data to our IT services suppliers to enable us to run an efficient business. If you have consented to receiving marketing emails from us, we disclose your email address to a third party who sends the emails on our behalf and manages our email database.
3.4 Financial transactions relating to our Website and services are handled by our payment services providers, namely Sage Pay, PayPal and Elavon Financial Services Limited. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers' privacy policies and practices at https://www.sagepay.co.uk/policies/privacy-policy, https://www.paypal.com/en/webapps/mpp/ua/privacy-full and https://www.elavon.co.uk/cookie-policy-and-privacy-pledge.htmlrespectively.
3.5 In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4. International transfers of your personal data
4.1 In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
4.2 We have offices and facilities in the United States of America. Transfers to the USA will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en
4.3 The hosting facilities for our Website(s) are situated in Ireland and the United Kingdom. These countries are both (currently) in the European Union so are subject to the provisions of European data protection laws.
4.4 The technology platform provider of our Website at www.elgaronline.com and www.advancedintros.com is situated in the United States of America. Transfers to the United States will be protected by the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en
4.5 You acknowledge that personal data that you submit for publication through our Website(s) or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
5. Retaining and deleting personal data
5.1 This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. The purposes include satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
5.3 It is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the factors outlined in section 5.2 above.
5.4 Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
6.1 We may update this policy from time to time by publishing a new version on our Website.
6.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
6.3 We may notify you of changes to this policy by email or via a banner notification on the Website(s).
7. Your rights
7.1 In this Section 7, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
7.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
7.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
7.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
7.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
7.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
7.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
7.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
7.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
7.10 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
7.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
7.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
7.13 You may exercise any of your rights in relation to your personal data by written notice to us, in addition to the other methods specified in this Section 7.
8. Personal data of children
8.1 Our Website and services are targeted at persons over the age of 18.
8.2 If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
9. Updating information
9.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.
10. About cookies
10.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
10.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
10.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
11. Cookies that we use
ServerID - used for affinity to back end servers to optimize browsing experience
atuvc & _atuvs – Are used for ‘add-this’ to show page shares
ga - Used to optimize site behavior
gat_UA- used to optimize site behavior
gid - Used to anonymously link browser activity for site optimization
Name of cookie:"webform-NodeId"
Checks the submission history from the users' machine using cookies.
Name of cookie: "has_js"
Used for checking if a user has enabled JS on the browser.
Name of cookie: "Drupal.toolbar.collapsed"
Toggles the visibility of the toolbar drawer.
Name of cookie: "Drupal.visitor"
Saves visitor information as a cookie so it can be reused.
Name of cookie: frontend
Name of cookie: "DRUPAL_UID"
Sets a special cookie preventing authenticated users getting served pages from the static page cache.
Name of cookie: ___website
Used for store switcher between UK and US in a header.
Name of cookie: guest-view
Allows guests to edit their orders.
Name of cookie: incap_ses_*
Improves the performance and security on the site.
Name of cookie: visid_incap_*
Improves the performance and security on the site.
Name of cookie: persistent_shopping_cart
The session key.
Name of cookie: Stf
If product links were sent to friends, stores the timestamps in the format: $timeStamp1, $timestamp2, ..., $timestampN.
Name of cookie: _utma
Distinguishes users and sessions.
Name of cookie: _utmb
Determines new sessions/visits.
Name of cookie: _utmc
Determines if the user was in a new session/visit.
Name of cookie: _utmz
Stores the traffic source or campaign that explains how the user reached your site.
Name of cookie: pollN
A poll ID that indicates if a vote has occurred, may appear on the site in the future but is not current functionality
Storing cookie preferences: we use cookie/ caching acceptance, cookies include:
Name of cookie: "ccShowCookieIcon"
Hides the Cookie Control icon after acceptance
Name of cookie: USER_ALLOWED_SAVE_COOKIE
Name of cookie: external_no_cache
A flag that indicates if caching is disabled.
12. Cookies used by our service providers
13. Managing cookies
13.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
13.2 Blocking all cookies will have a negative impact upon the usability of many Websites.
13.3 If you block cookies, you will not be able to use all the features on our Website.
14. Our details
14.1 This Website is owned and operated by Edward Elgar Publishing Limited.
14.2 We are registered in England and Wales under registration number 02041703, and our registered office is at Lypiatts 15 Lansdown Road, Cheltenham, Gloucestershire, GL50 2JA.
14.3 You can contact us:
(a) by post, to the postal address given above;
(b) by email, to firstname.lastname@example.org.
LAST UPDATED 26 April 2018