1. Important information andwho we are
Thiswebsite is not intended for children and we do not knowingly collect datarelating to children, under the age of 13.
Bloomsburyis the controller and responsible for your personal data.
Full nameof legal entity: Bloomsbury Publishing Plc, FAO: Maya Abu-Deeb (DataProtection Officer)
Postaladdress: 50 Bedford Square, London, England, WC1B 3DP
Telephonenumber: +44 (0)20 7631 5000
Company Number 01984336
ICO Registration NumberZ7552956
You havethe right to make a complaint at any time to the Information Commissioner'sOffice (ICO), the UK regulator for data protection issues (). We would, however, appreciate the chanceto deal with your concerns before you approach the ICO so please contact us inthe first instance.
2. The data we collect aboutyou
Personaldata, or personal information, means any information about an individual fromwhich that person can be identified. It does not include data where theidentity has been removed (anonymous data).
We maycollect, use, store and transfer different kinds of personal data about you asfollows:
· Typeof User (admin/author/student/teacher/manager)
· Accountcreation date
· Dateaccount last modified
· Lastlogin date
· Progressthrough questions/content, number of attempts of questions, the attempt itself,scores, date/time activities were attempted
We do not collect any Special Categories of Personal Data about you (thisincludes details about your race or ethnicity, religious or philosophicalbeliefs, sex life, sexual orientation, political opinions, trade unionmembership, information about your health, and genetic and biometric data). Nordo we collect any information about criminal convictions and offences.
If you failto provide personal data
Where we need to collect personaldata by law, or under the terms of a contract we have with you, and you fail toprovide that data when requested, we may not be able to perform the contract wehave or are trying to enter into with you (for example, to provide you withgoods or services). In this case, we may have to cancel a product or serviceyou have with us but we will notify you if this is the case at the time.
3. How is your personal datacollected?
We usedifferent methods to collect data from and about you including through:
· Direct interactions. You may give us your personal data by filling in forms or bycorresponding with us by post, phone, email or otherwise. This includespersonal data you provide when you
· when your academic institution signs anagreement with us;
· create an account on our website; or
· give us feedback or contact us.
· Automated technologies or interactions.As you interact with our website, we will automatically collect Technical Dataabout your equipment, browsing actions and patterns. We collect this personaldata by using cookies server logs and/ or other similar technologies. We mayalso receive Technical Data about you if you visit other websites employing ourcookies.
Third partiesor publicly available sources. We will receive personal data about you fromanalytics providers such as Google based outside the UK.
4. How we use your personaldata
We willonly use your personal data when the law allows us to. Most commonly, we willuse your personal data in the following circumstances:
· Where we need to perform the contract we areabout to enter into or have entered into with you or your academic institution.
· Where it is necessary for our legitimateinterests (or those of a third party) and your interests and fundamental rightsdo not override those interests.
· Where we need to comply with a legal obligation.
Generally,we do not rely on consent as a legal basis for processing your personal dataalthough we will get your consent before sending third party direct marketingcommunications to you via email or text message. You have the right to withdrawconsent to marketing at any time by contacting us.
Purposes forwhich we will use your personal data
We haveset out below, in a table format, a description of all the ways we plan to useyour personal data, and which of the legal bases we rely on to do so. We havealso identified what our legitimate interests are where appropriate.
Note thatwe may process your personal data for more than one lawful ground depending onthe specific purpose for which we are using your data. Please contact us if youneed details about the specific legal ground we are relying on to process yourpersonal data where more than one ground has been set out in the table below.
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new user
Performance of a contract with you or your academic institution
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(d) Marketing and Communications
(a) Performance of a contract with you or your academic institution
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
(e) Marketing and Communications
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
Change of purpose
We willonly use your personal data for the purposes for which we collected it, unlesswe reasonably consider that we need to use it for another reason and thatreason is compatible with the original purpose. If you wish to get anexplanation as to how the processing for the new purpose is compatible with theoriginal purpose, please contact us.
If we needto use your personal data for an unrelated purpose, we will notify you and wewill explain the legal basis which allows us to do so.
Pleasenote that we may process your personal data without your knowledge or consent,in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of yourpersonal data
We mayshare your personal data with the parties set out below for the purposes setout in the table above.
· Internal Third Parties as set out in the Glossary.
· External Third Parties as set out in the Glossary.
We requireall third parties to respect the security of your personal data and to treat itin accordance with the law. We do not allow our third-party service providersto use your personal data for their own purposes and only permit them toprocess your personal data for specified purposes and in accordance with ourinstructions.
6. International transfers
We share your personal data within the SOWISOBV Group. This will involve transferring your data outside the UK.
Wherepersonal data is transferred in relation to providing our services (includingwhere personal data is hosted on our behalf in countries which are notcertified as providing an adequate level of protection) we will take all stepsreasonably necessary to ensure that it is subject to appropriate safeguards,such as relying on a recognised legal adequacy mechanism which may include byentering into EC approved standard contractual clauses relevant to transfers ofpersonal information – see:
Please contact us if you want further information on the specificmechanism used by us when transferring your personal data out of the UK.
7. Data security
We haveput in place appropriate security measures to prevent your personal data frombeing accidentally lost, used or accessed in an unauthorised way, altered ordisclosed. In addition, we limit access to your personal data to thoseemployees, agents, contractors and other third parties who have a business needto know. They will only process your personal data on our instructions and theyare subject to a duty of confidentiality.
We haveput in place procedures to deal with any suspected personal data breach andwill notify you and any applicable regulator of a breach where we are legallyrequired to do so.
8. Data retention
How longwill you use my personal data for?
We willonly retain your personal data for as long as reasonably necessary to fulfilthe purposes we collected it for, including for the purposes of satisfying anylegal, regulatory, tax, accounting or reporting requirements. We may retainyour personal data for a longer period in the event of a complaint or if wereasonably believe there is a prospect of litigation in respect to ourrelationship with you.
Todetermine the appropriate retention period for personal data, we consider theamount, nature and sensitivity of the personal data, the potential risk of harmfrom unauthorised use or disclosure of your personal data, the purposes forwhich we process your personal data and whether we can achieve those purposesthrough other means, and the applicable legal, regulatory, tax, accounting orother requirements.
9. Your legal rights
Undercertain circumstances, you have rights under data protection laws in relationto your personal data. These rights are:
· Request access to your personal data.
· Request correction of your personal data.
· Request erasure of your personal data.
· Object to processing of your personal data.
· Request restriction of processing your personaldata.
· Request transfer of your personal data.
· Right to withdraw consent.
If youwish to exercise any of the rights set out above, please contact us.
No feeusually required
You willnot have to pay a fee to access your personal data (or to exercise any of theother rights). However, we may charge a reasonable fee if your request isclearly unfounded, repetitive or excessive. Alternatively, we could refuse tocomply with your request in these circumstances.
What we mayneed from you
We mayneed to request specific information from you to help us confirm your identityand ensure your right to access your personal data (or to exercise any of yourother rights). This is a security measure to ensure that personal data is notdisclosed to any person who has no right to receive it. We may also contact youto ask you for further information in relation to your request to speed up ourresponse.
Time limitto respond
We try torespond to all legitimate requests within one month. Occasionally it could takeus longer than a month if your request is particularly complex or you have madea number of requests. In this case, we will notify you and keep you updated.
Legitimate Interest means the interest of our business inconducting and managing our business to enable us to give you the bestservice/product and the best and most secure experience. We make sure weconsider and balance any potential impact on you (both positive and negative)and your rights before we process your personal data for our legitimateinterests. We do not use your personal data for activities where our interestsare overridden by the impact on you (unless we have your consent or areotherwise required or permitted to by law). You can obtain further informationabout how we assess our legitimate interests against any potential impact onyou in respect of specific activities by contacting us.
Comply with a legal obligation means processing yourpersonal data where it is necessary for compliance with a legal obligation thatwe are subject to.
Othercompanies in the Bloomsbury Group who may be acting as joint controllers orprocessors and who may be based outsideof the United Kingdom.
· Service providers acting as processors based inthe Netherlands who provide IT and system administration services.
· Professional advisers acting as processorsincluding lawyers, bankers, auditors and insurers based in or outside theUnited Kingdom who provide consultancy, banking, legal, insurance andaccounting services.
You havethe right to:
Request access to your personal data (commonlyknown as a "data subject access request"). This enables you toreceive a copy of the personal data we hold about you and to check that we arelawfully processing it.
Request correction of the personal data that wehold about you. This enables you to have any incomplete or inaccurate data wehold about you corrected, though we may need to verify the accuracy of the newdata you provide to us.
Request erasure of your personal data. This enablesyou to ask us to delete or remove personal data where there is no good reasonfor us continuing to process it. You also have the right to ask us to delete orremove your personal data where you have successfully exercised your right toobject to processing (see below), where we may have processed your informationunlawfully or where we are required to erase your personal data to comply withlocal law. Note, however, that we may not always be able to comply with yourrequest of erasure for specific legal reasons which will be notified to you, ifapplicable, at the time of your request.
Object to processing of your personal data where weare relying on a legitimate interest (or those of a third party) and there issomething about your particular situation which makes you want to object toprocessing on this ground as you feel it impacts on your fundamental rights andfreedoms. You also have the right to object where we are processing yourpersonal data for direct marketing purposes. In some cases, we may demonstratethat we have compelling legitimate grounds to process your information whichoverride your rights and freedoms.
Request restriction of processing of your personaldata. This enables you to ask us to suspend the processing of your personaldata in the following scenarios:
· If you want us to establish the data's accuracy.
· Where our use of the data is unlawful but you donot want us to erase it.
· Where you need us to hold the data even if we nolonger require it as you need it to establish, exercise or defend legal claims.
· You have objected to our use of your data but weneed to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to youor to a third party. We will provide to you, or a third party you have chosen,your personal data in a structured, commonly used, machine-readable format.Note that this right only applies to automated information which you initiallyprovided consent for us to use or where we used the information to perform acontract with you.
Withdraw consent at any time where we are relyingon consent to process your personal data. However, this will not affect thelawfulness of any processing carried out before you withdraw your consent. Ifyou withdraw your consent, we may not be able to provide certain products orservices to you. We will advise you if this is the case at the time youwithdraw your consent.
What are cookies and how do they work?
Cookies are pieces ofinformation that a website transfers to your hard drive to store and sometimestrack information about you. Most web browsers automatically accept cookies,but if you prefer, you can change your browser to prevent that and your helpscreen or manual will tell you how to do this. However, you may not be able totake full advantage of our site if you do so. Cookies are specific to theserver that created them and cannot be accessed by other servers, which meansthey cannot be used to track your movements around the web. Although they doidentify a user's computer, cookies do not personally identify users andpasswords and credit card information are not stored in cookies.
We use the following types of cookies:
• Strictly necessary cookies. These are cookiesthat are required for the operation of our website and under our terms withyou. They include, for example, cookies that enable you to log into secureareas of our website, use a shopping cart or make use of e-billing services.
• Analytical/performance cookies. They allow us torecognise and count the number of visitors and to see how visitors move aroundour website when they are using it. This helps us for our legitimate purposesto improve the way our website works, for example, by ensuring that users arefinding what they are looking for easily.
• Functionality cookies. These are used to recogniseyou when you return to our website. This enables us, subject to your choicesand preferences, to personalise our content for you, greet you by name andremember your preferences (for example, your choice of language or region).
We set our own cookies on the site and we also usethird party cookies, like Google Analytics.
Where can you find more information about the cookies that we use?
This is a session cookie which is used to keep you logged in and maintain your session.
This cookie is used to redirect you to a specific page after you log out (for instance, when you've used an LMS)
This cookie is used to prevent cross-site request forgery.
Used to distinguish users.
Used to distinguish users.
Used to persist session state.
Contains campaign related information. If you have linked your Google Analytics and Google Ads accounts, Google Ads website conversion tags will read this cookie unless you opt-out.
reCaptchacookies (only on “Forgot password” page)
Google cookie consent tracker (info source: https://github.com/jkwakman/Open-Cookie-Database/blob/master/open-cookie-database.csv)
Up to 20 years
This cookie contains a unique ID used to remember your preferences and other information, such as your preferred language, how many search results you prefer to have shown on a results page (for example, 10 or 20), and whether you want to have Google’s SafeSearch filter turned on. (source: https://policies.google.com/technologies/cookies?hl=en-US)
How do you disable cookies?
The effect of disabling cookiesdepends on which cookies you disable, but in general the website may notoperate properly if cookies are switched off. If you only disable third partycookies, you will not be prevented from making purchases on our site. If youdisable all cookies, you will be unable to complete a purchase on our site. Seebelow for details of how to use common types of browser to disable cookies.
Disabling cookies in Internet Explorer
1. Choose the menu “tools” then “Internet Options”
2. Click on the “privacy” tab
3. Select the setting the appropriate setting
Disabling cookies in Google Chrome
1. Choose Settings> Advanced
2. Under "Privacy and security," click“Content settings”.
3. Click “Cookies”
Disabling cookies in Safari
1. Choose Preferences > Privacy
2. Click on “Remove all Website Data”
Disabling cookies in Firefox
1. Choose the menu “tools” then “Options”
2. Click on the icon “privacy”
3. Find the menu “cookie” and select the relevantoptions
Disabling cookies in Opera
Opera 6.0 and subsequent:
1. Choose the menu Files”> “Preferences”
Social medial platforms
If you 'share' our websites content on socialnetworks, such as Instagram and Twitter, you may be sent cookies from thesocial network. We do not control the setting of these cookies, so please checkthe social network platforms for information on how to manage them.
For third party cookies that track activity inconnection with targeting advertising, you can currently opt-out of thesecookies on the Digital Advertising Alliance’s consumer choice page(http://optout.aboutads.info) or the Network Advertising Initiative’s consumerchoice page (http://optout.networkadvertising.org).
Other tools offered bythird parties can help you see and manage cookies. More information aboutcookies and cookie management can be found on www.allaboutcookies.org andwww.aboutcookies.org