Privacy Policy

Introduction

We, Johanna Basford Ltd (“we”, “us”, “our”) are committed to protecting and respecting the privacy of everyone who visit our
website, www.johannabasford.com (the “website“). This privacy policy (“Policy“) will inform you as to how we look after your personal data when you visit our website and tell you about your privacy rights and how the law protects you. In this Policy, when we refer to “you“, we are referring to you, as the person or entity accessing, viewing and/or using the website. This Policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this Policy.

1. GLOSSARY
2. WHO WE ARE AND HOW TO CONTACT US
3. WHAT PERSONAL INFORMATION WE COLLECT ABOUT YOU
4. HOW WE USE YOUR PERSONAL INFORMATION
5. OUR LEGAL GROUNDS FOR PROCESSING YOUR PERSONAL INFORMATION
6. DO WE SHARE YOUR PERSONAL INFORMATION?
7. WHERE WE STORE YOUR PERSONAL INFORMATION
8. HOW WE PROTECT YOUR PERSONAL INFORMATION
9. THIRD PARTY LINKS
10. Your rights UNDER THE DATA PROTECTION LEGISLATION
11. ACCESS TO YOUR PERSONAL INFORMATION
12. RETENTION PERIODS
13. COOKIES
14. CHANGES TO OUR PRIVACY POLICY

 

1.Glossary

 

When we refer to Data Protection Legislation we mean the General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR“); the Data Protection Act 2018; and all applicable laws and regulations relating to the processing of personal information and privacy. Personal information is information that can be used to identify or contact a specific individual, such as a name, address, telephone number, email address, etc., and also online identifiers and location data such as IP addresses and mobile device IDs. Special category data means personal information revealing your racial or ethnic origin; political opinions; religious or philosophical beliefs; or trade union membership; genetic data; biometric data; data related to your health or data concerning your sex life or sexual orientation; and criminal convictions or involvement in criminal proceedings. A controller is someone who decides why personal data is to be collected and how it will be used and treated.

 

2. Who we are and how to contact us

 

Where we collect and process your personal information through the website we are the controller for the purposes of Data Protection Legislation. If you need to contact us for any reason regarding this Policy, including the collection and / or use of your personal data, or as otherwise indicated in any section of this Policy, our contact details are:

• Johanna Basford Ltd, Studio 1, Ellon Business Centre, Broomiesburn Road, Ellon, Aberdeenshire AB41 9RD; or
• [email protected]

If you are unhappy with how we handle your personal information you can:

• submit a complaint in writing for the attention of the Studio Manager, Johanna Basford Ltd, Studio 1, Ellon Business Centre, Broomiesburn Road, Ellon, Aberdeenshire AB41 9RD; and/or
• notify the Information Commissioner’s Office (ICO) by calling their helpline on: 0303 123 1113.

 

3. What PERSONAL Information WE collect about you

 

Personal information is information that can be used to identify or contact a specific individual, such as a name, address, telephone number or email address. We may collect and process the following information about you when you contact us by email or telephone:

Information which is given by you

We collect information you give us when you:

• register for an account on our Colouring Gallery. We collect the following information for this purpose: your full name, user name and email address. You may also choose to upload photographs of yourself to the Colouring Gallery;
• contact us by e-mail or otherwise with a query. The information you give us may include your name and email address and any other information you choose to provide; and
• apply for a job vacancy via email/post. The information you give to us may include: your name and contact details (e.g. telephone numbers, postal address, email address, etc.), education history and qualifications, employment history and any other information you choose to provide us; and use our website or access our posts or adverts on other sites (including social media sites).
• We ask that you do not provide any special category data to us or any personal information which is not relevant to your query.

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Information we collect about you

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• Technical Data: With each of your visits to the website (regardless of whether you register or log in during your visit), we will automatically collect the following information: [your Internet Protocol (IP) address, log in information, browser type and version, time zone and setting, browser plug in types and version, operating system and platform;
• Usage Data: information about your visit and how you use our website, including pages and products you viewed during your visit, any search terms entered on our website, length of time spent on each page, page response times, download errors and if you visited our website by clicking on one of our ads on another site, we or a third party acting on our behalf (such as Facebook) may collect information about your activity; and
• If you contact us, we may keep a record of that correspondence or telephone call

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Marketing and Communication Data

We are in the process of setting up a mailing list which we expect to go live later this year. When the function is made available, you can sign up to receive our newsletter and details of our products and services by email (keep an eye out for the link on our website). When you sign up we will collect your name and email address.

We also use online advertising and target our banners and ads to you on other websites and platforms, including social media platforms like Facebook. We use a number of advertising technologies to do this, including pixels and services from social networks like Facebook’s Custom Audience service. The information you see about us in these banners and ads will be informed by information we hold about you, your use of our site or banners and ads you have previously clicked on.

 

4. How we use your personal information

 

We will only use your personal information as the law allows us to. Most commonly we will use your personal data in the following circumstances:

• to administer your Colouring Gallery account (legal basis: performance of our contract with you or where our use is not for the purposes of our contract, our legitimate interests in running our business);
• to communicate with you in relation to your Colouring Gallery account and the service we are providing (legal basis: performance of our contract with you or where our use is not for the purposes of our contract, our legitimate interests in running our business);
• where you have submitted a CV and cover letter/email to us we will process your personal data to assess your skills and experience to determine your suitability for working with us and to communicate with you about the recruitment process (legal basis: performance of our contract with you or taking steps prior to entering into a contract with you as requested by you);
• to provide you with our newsletter and details of our products and services (legal basis: consent where we contact you by email and legitimate interests in communicating about and marketing our business where we contact you by post);
• to send promotional materials to you by post (legal basis: our legitimate interests in marketing our business);
• where we need to comply with a legal or regulatory obligation (legal basis: compliance with a legal obligation);
• to administer a promotion or other site feature (legal basis: consent, through your acceptance of non-essential cookies or our legitimate interests in operating our site and running our business);
• to use data analytics to improve our website, products/services, marketing, customer relationships and experiences (legal basis: consent, through your acceptance of non-essential cookies or our legitimate interests in operating our site and running and marketing our business);
• to personalise your experience on our site and other platforms we engage on (legal basis: consent, through your acceptance of non-essential cookies or our legitimate interests in operating our site and networks and running and marketing our business); and

to share photographs of you and your work on our website/social media accounts where you have agreed for us to do so (legal basis: consent).

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or to allow us to display your images on our website/social media accounts. You have the right to withdraw consent any time by contacting us at [email protected] or by disabling cookies (further details can be found in our Cookies Policy). Please note, if you consent to your personal information (i.e. your photograph and name) being shared on social media it may not be possible for us to completely delete this.

 

5. Our legal grounds for processing personal information

 

Our legal grounds for processing your personal information are:

• your consent, where you have agreed to us using your personal information (e.g. where you sign up to receive marketing materials and newsletters by email, or you agree to us displaying your photographs on our website/sharing on social media);
• the processing is necessary for compliance with a legal obligation to which we are subject; or
• the processing is necessary for the purpose of our legitimate interests or those of a third party, such as financial interests, operational and administrative interests, ensuring security, maintaining our relationship with you, marketing, optimising and understanding the use of our site, research and statistical analysis.

 

6. Do we share your personal information?

 

Except as provided below, we will not share personal information with any other third parties without informing you beforehand, unless required by, or in connection with, law and / or regulatory requirements. We may share your personal data with the following parties, for the purposes noted below:

• analytics and search engine providers that assist us in the improvement and optimisation of our site and marketing activities;
• our providers of web and hosting services, currently Braizen;
• our email service provider which is currently Microsoft Office 365;
• the company that provides email hosting services to us, currently MailChimp;
• our publisher, Penguin Random House, for the purpose of issuing promotional products and materials on our behalf; 
• social media sites which provide us with targeted advertising services such as Facebook;  and
• when we believe it is appropriate to comply with the law, we may disclose information about you to law enforcement officials in the investigation of any alleged unlawful activities by you. We may also be required to disclose information to a court or regulatory body when required to do so by law.

We will not sell, trade or lease your personal information to others.

 

7. Where we store your personal INFORMATION

 

The information which we collect about you will usually be stored inside the UK or the European Economic Area (EEA). However, we may transfer data outside the UK or EEA where our service providers host, process or store data outside the UK or EEA. Where we do this, we will ensure that the transfer is to a country covered by the decision of the European Commission or we will take steps to ensure is otherwise made in circumstances where we have put appropriate safeguards are in place to protect your data in accordance with Data Protection Legislation.

 

8. How We Protect Your Information

 

We implement a variety of security measures to maintain the safety of your personal information. Our security is reviewed and enhanced as necessary. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. Unfortunately, the transmission of information via the internet is not completely secure and although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Website; any transmission is at your own risk.

 

9. Third Party Links

 

The Website may, from time to time, contain links to and from other websites. Please note that this document applies solely to the personal information collected by us and does not apply to any third party websites.  We are not responsible for the privacy policies, content or use of these websites and we advise you to read the privacy policy and terms of use of any third party websites before you submit any personal data to them.

 

10. Your rights UNDER THE DATA PROTECTION LEGISLATION

 

You have the following rights in respect of the information we process about you:

• the right to access information held about you by making a subject access request in accordance with the Data Protection Legislation. We may charge a reasonable fee when a request is manifestly unfounded or excessive;
• the right to request us to rectify personal information concerning you which is inaccurate or incomplete;
• the right to request us to erase personal information concerning you (in certain conditions as set out in the Data Protection Legislation);
• the right to object to the processing of your information by us as well as the right to request us to restrict the extent to which we process your personal information (both in certain conditions as set out in the Data Protection Legislation);
• the right to data portability (in certain conditions out in the Data Protection Legislation);
• the right to ask us not to process your personal information for marketing purposes. You can exercise your right by contacting us at [email protected];
• the right to know about any automated decision-making or profiling;
• where you have provided your consent to us for us to process your personal information, you have the right to withdraw your consent by informing us (which will not affect the lawfulness of any processing carried out before you withdraw consent); and
• the right to lodge a complaint with the Information Commissioner’s Office in the UK.

The above rights may be exercised in accordance with data protection law.

 

11. Access to YOUR PERSONAL information

 

You have the right to request a copy of personal information that we hold about you under the Data Protection Legislation. To do this, simply contact us. Should we be prevented from disclosing your personal information, reasons will be given for the refusal. We may also request that you provide further information and identification to enable your request to be processed. If you believe that any information we hold about you is incorrect or incomplete, please contact us. We will thereafter correct any information found to be incorrect. You can find detailed information about your rights under the Data Protection legislation on the UK Information Commissioner’s website: http://www.ico.org.uk/.

 

12. Retention Periods

 

We will not store your personal data longer than necessary for the uses outlined above, unless it is required to do so to comply with the law and / or any regulatory requirements. Colouring Gallery: we will store your personal data for as long as it is necessary for us to provide the services or until you delete your Colouring Gallery account. Job applicants: we will retain your information for a period of 6 months after we have communicated to you our decision about your application. After this period, and if you are not successful in your application, we will securely destroy or anonymise your personal information. If you would like us to retain your personal information on file in case another opportunity may arise in the future so that we can consider you for that opportunity, please e-mail or write to us at [email protected].  We will continue to hold your personal information for this purpose for 12 months after receipt of your written confirmation.

 

13. Cookies

This website uses cookies. Cookies enable our system to recognise your computer and allow us to see how you use our site. Cookies enhance website performance in several ways, including provision of a secure way to measure website usage. This helps us to determine what is popular and can influence future content and development of our site. For further information on cookies on our site, please refer to our Cookies Policy.

 

14. Changes to our privacy policy

 

We keep this Policy under regular review and in the event we make any changes we will place an updated version on our Website and, where appropriate, notify you by e-mail, seek your consent or place a notification on the Website. Please review this page regularly to ensure that you are always aware of what personal information we collect, how we use it and under what circumstances we will share it with other parties. This policy was last amended on 30 August 2019.