Your privacy is important to us.
This privacy notice (Privacy Notice) sets out the ways in which we, Shulph Limited (we, us, our), collect and use your personal data (your personal information) in connection with our business. It also explains what rights you have to access or change your personal data.
The Shulph service is not intended for children. We do not knowingly collect or maintain the personal information of children under the age of 18. If you are under the age of 18, please do not access the Shulph service at any time or in any manner. We will take appropriate steps to delete the personal information of persons under the age of 18.
We are a company registered in England under company number 09583505, with our registered address as set out below.
You can contact us as follows:
FAO: The Managing Director,
40 Bloomsbury Way,
Lower Ground Floor,
London WC1A 2SE
Information we may collect about you
We will collect any information that you provide to us when you:
- make an enquiry, provide feedback or make a complaint over the phone, by email or on our website or app;
- submit correspondence to us by post, email or via our website or app;
- order products from our website or app;
- create an account to use the Shulph service;
- update your profile and other account details;
- subscribe to our newsletter and mailing lists;
- fill in a form, conduct a search, post content on the website or app, respond to surveys, participate in promotions or use any other features of the Shulph service;
- submit reviews and comments on the website or app;
- register to and/or attend our events;
- submit a CV;
- submit an application to a job vacancy;
- attend an interview or assessment;
- Post to our, interact with our, ‘follow’, ‘like’, social media accounts, including Facebook, LinkedIn, Twitter, Pinterest, Instagram and Google+; and
- And of your purchasing and reading history done through the Shulph service.
The information you provide to us will include (depending on the circumstances):
- Identity and contact data: title, names, addresses, email addresses and phone numbers;
- Account profile data: if you’re registering for an account you may also provide a, username, password, job title/position, and language preferences;
- Financial Data: If you are using the Shulph service to purchase products or services, you will also provide payment details, which may include billing addresses, credit/debit card details and bank account details. In circumstances where you provide credit/debit card details, bank account details or billing and shipping addresses, we will only store these details if you expressly ask us to. Saving those details will make it easier for you to make future purchases;
- Employment and background data: If you are submitting a job application, you may also provide additional information about your academic and work history, qualifications, skills, projects and research that you are involved in, references, proof of your entitlement to work in the UK, your national security number, your passport or other identity document details, and any other such similar information that you may provide to us;
- Survey data: from time to time we might ask if you would be willing to participate in our surveys; if you agree, we will also collect any information that you provide as part of that survey; and
- Sensitive information: If you are submitting a job application, you may provide information about your race or ethnicity, religious beliefs, sexual orientation, health and whether or not you have any disability.
Information we collect about you:
- Information contained in correspondence: We will collect any information contained in any correspondence between us. For example, if you contact us using a query button on our website or app or by email or telephone, we may keep a record of that correspondence;
- Information transmitted on the Shulph Service: We will collect information that you upload or post to your Shulph account and/or any correspondence or interactions that you may have with other Shulph users;
- Transactional data: We will collect information related to your transactions on the Shulph service, including the date and time, the amounts charged and other related transaction details;
- Website usage data: We will collect information about your interactions with the website, including information such as login data, IP address, page views, searches, requests, orders, pre-approvals, confirmations, agreements between you and other website users and other actions on the website; and
- Technical data: We will also collect certain information about how you use our website and the device that you use to access our website, even where you have not created an account or logged in. [This might include your geographical location, device information (such as your hardware model, mobile network information, unique device identifiers), the data transmitted by your browser (such as your IP address, date and type of the request, content of the request regarding the specific site, time zone settings, access status/HTTP status code, volume of data transmitted, browser type and version, language settings, time zone settings referral source, length of visit to the website, date and time of the request, operating system and interface) number of page views, the search queries you make on the website and similar information.] This information may be collected by a third-party website analytics service provider on our behalf and/or may be collected using cookies or similar technologies.
“Special categories” of particularly sensitive personal information require higher levels of protection. Special categories of data include details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. Depending on the circumstances we will also collect information about criminal convictions and offences as described in more detail below.
We need to have further justification for collecting, storing and using this type of personal information. We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data. We process special categories of personal information in the following circumstances:
- in limited circumstances, with your explicit written consent;
- where we need to carry out our legal obligations or exercise rights in connection with employment;
- where it is needed in the public interest, such as for equal opportunities monitoring;
- where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else's interests) and you are not capable of giving your consent; or
- where you have already made the information public.
If you are an applicant or an employee, we will collect special categories of information about:
- your race, ethnicity, religious or philosophical beliefs and sexual orientation for the purpose of our diversity and equal opportunities records (on the basis that it is needed in the public interest, for equal opportunities monitoring);
- your health as necessary for the purpose of arranging your interview if you are an applicant, or supporting your needs and access to our workplace if you are an employee (on the basis of your explicit consent if you are an applicant and for compliance with our legal obligations or exercise of employment rights if you are an employee); and
- your criminal record for the purposes of completing background checks necessary for you to be able to work with us (on the basis such processing is necessary for reasons of substantial public interest under applicable laws).
Information we receive from third parties
In certain circumstances, we will receive information about you from third parties. For example:
- Website users: we may receive personal information from other Shulph users, who may be based inside or outside the EU, for example information that is posted or uploaded by other users (e.g. reviews) and information relating to transactions;
- Publishing partners and collaborators: we may receive personal information from our publishing partners and collaborators who may be based inside or outside the EU, for example, if you are an author, details about you and any books you have written, or if you are a Shulph user, any complaints or issues you have raised about the Shulph service with them;
- Employers, recruitment agencies and referees: if you are a job applicant we may contact your recruiter, current and former employers and/or referees, who may be based inside or outside the EU, to provide information about you and your application;
- Service providers: we may collect personal information from our technology provider (Amazon Web Services) and payment services provider (Stripe Inc.) who may be based inside OR outside the EU;
- Website and app security: we will collect information from our website and app security service partners who are based inside and outside the EU, about any misuse to the website and apps, for instance, the introduction of viruses, Trojans, worms, logic bombs, website attacks or any other material or action that is malicious or harmful; and
- Publicly available sources: we currently use publicly available sources such as Companies House, for instance to carry out identity and compliance checks.
We might also receive information about you from third parties if you have indicated to such third party that you would like to hear from us.
How we use information about you and recipients of your information
We will use your information for the purposes listed below either on the basis of:
- performance of your contract with us and the provision of our services to you;
- your consent (where we request it);
- where we need to comply with a legal or regulatory obligation; or
- our legitimate interests or those of a third party.
We use your information for the following purposes:
- To provide access to the Shulph service: to provide you with access to the Shulph service in a manner convenient and optimal and with personalised content relevant to you including sharing your information with our website and app hosts and developers (on the basis of our legitimate interest to ensure the Shulph service is presented in an effective and optimal manner);
- To register your account: when you sign up to use the Shulph service, we will use the details provided on your account registration form (on the basis of performing our contract with you);
- To process and facilitate transactions with us: and to collect and recover money owed to us (on the basis of performing our contract with you and on the basis of our legitimate interest to recover debts due);
- To market and promote books: if you are an author, illustrator or publisher, we may use your personal information to market and promote your products on the Shulph service (on the basis of our contract with you and on the basis of our legitimate interest in promoting the products we sell).
- User and customer support: to provide customer service and support (on the basis of our contract with you or on the basis of our legitimate interests to provide you with customer service), deal with enquiries or complaints about the Shulph service and share your information with our website and app developer, IT support provider, payment services provider (Stripe Inc.) as necessary to provide customer support (on the basis of our legitimate interest in providing the correct products and services to our users and to comply with our legal obligations);
- Prize draws, competitions and surveys: to enable you to take part in prize draws, competitions and surveys (on the basis of performing our contract with you and our legitimate interest in studying how our the Shulph service is used, to develop it and grow our business);
- Recruitment: to process any job applications you submit to us, whether directly or via an agent or recruiter including sharing this with our third party recruitment agency (on the basis of our legitimate interest to recruit new employees or contractors);
- Marketing: to keep in contact with you about our news, events, new features products or services that we believe may interest you, provided that we have the requisite permission to do so, [and sharing your information with our marketing services provider, Mailchimp] (either on the basis of your consent where we have requested it, or our legitimate interests to provide you with marketing communications where we may lawfully do so);
- Social media interactions: to interact with users on social media platforms including [Facebook, LinkedIn, Twitter, Pinterest, Instagram and Google+], for example, responding to comments and messages, posting, ‘retweeting’ and ‘liking’ posts (on the basis of our legitimate interest in promoting our brand and communicating with interested individuals);
- Analytics: to use data analytics to improve the Shulph service and products we offer, marketing, customer relationships and experiences (on the basis of our legitimate interests in defining types of customers for our services, to keep our website and app updated and relevant, to develop our business and to inform our marketing strategy);
- Suggestions and recommendations: to share your information with selected third parties such as suppliers and partners, to enable them to contact you with information about things that may interest you (where we have your consent to do so);
- Research: to carry out aggregated and anonymised research about general engagement with the Shulph service (on the basis of our legitimate interest in providing the right kinds of products and services to our users);
- Fraud and unlawful activity detection: to protect, investigate, and deter against fraudulent, unauthorised, or illegal activity, including identity fraud (on the basis of our legitimate interests to operate a safe and lawful business or where we have a legal obligation to do so); and
- Compliance with policies, procedures and laws: to enable us to comply with our policies and procedures and enforce our legal rights, or to protect the rights, property or safety of our employees and share your information with our technical and legal advisors (on the basis of our legitimate interests to operate a safe and lawful business or where we have a legal obligation to do so).
As outlined above, in certain circumstances we may use your personal information to pursue legitimate interests of our own or those of third parties. Where we refer to using your information on the basis of our “legitimate interests”, we mean our legitimate business interests in conducting and managing our business and our relationship with you, including the legitimate interest we have expressly stated above.
Where we use your information for our legitimate interests, we make sure that we take into account any potential impact that such use may have on you. Our legitimate interests don’t automatically override yours and we won’t use your information if we believe your interests should override ours unless we have other grounds to do so (such as your consent or a legal obligation). If you have any concerns about our processing please refer to details of “Your Rights” below.
Who we might share your information with
In connection with the purposes and on the lawful grounds described above and in addition to the recipients of your information as described above, we will share your personal information when relevant with third parties such as:
Publishers, partners and collaborators: the publishers, partners and collaborators of any title that you purchase, in order to fulfil and deliver that purchase. Details of relevant publishers, partners and collaborators are available in the description of each title on the Shulph website and app;
Our service providers: service providers we work with to deliver our business, who are acting as processors and provide us with:
- website and app development and hosting services based in the United Kingdom, India and the United States of America;
- marketing and advertising services (including the Google AdWords service), analytics providers (including Google Analytics), and CRM provider MailChimp Inc based in the United States of America and/or the United Kingdom;
- social media plugin services including Facebook, Google+, Twitter, LinkedIn, Instagram based in the United States of America;
- payment services by Stripe Inc. based in the United States of America;
- identity verification, fraud prevention and detection services based in the United States of America and the United Kingdom;
- banking services based in the United Kingdom;
- legal, accountancy, auditing and insurance services and other professional advisers based in the United Kingdom; and
- recruitment service providers based in the United Kingdom;
Regulators and governmental bodies: HM Revenue & Customs, regulators, governmental bodies and other authorities acting as processors or joint controllers based in the United Kingdom, who require reporting of processing activities in certain circumstances;
Marketing parties: any selected third party that you consent to our sharing your information with for marketing purposes;
Prospective sellers and buyers of our business: any prospective seller or buyer of such business or assets, only in the event that we decide to sell or buy any business or assets; and
Other third parties (including professional advisers): any other third parties (including legal or other advisors, regulatory authorities, courts, law enforcement agencies, and government agencies) based in the United Kingdom where necessary to enable us to enforce our legal rights, or to protect the rights, property or safety of our employees or where such disclosure may be permitted or required by law.
We require third parties to maintain appropriate security to protect your information from unauthorised access or processing.
If you do not wish for cookies to be installed on your device, you can change the settings on your browser or device to reject cookies. For more information about how to reject cookies using your internet browser settings please consult the “Help” section of your internet browser (or alternatively visit http://www.aboutcookies.org). Please note that, if you do set your Internet browser to reject cookies, you may not be able to access all of the functions of the website.
How we look after your information and how long we keep it for
We operate a policy of “privacy by design” by looking for opportunities to minimise the amount of personal information we hold about you. We use appropriate technological and operational security measures to protect your information against any unauthorised access or unlawful use, such as:
- ensuring the physical security of our offices, warehouses or other sites;
- ensuring the physical and digital security of our equipment and devices by using appropriate password protection and encryption;
- maintaining a data protection policy for, and delivering data protection training to, our employees; and
- limiting access to your personal information to those in our company who need to use it in the course of their work.
We will retain your information for as long as is necessary to provide you with the services that you have requested from us or for as long as we reasonably require to retain the information for our lawful business purposes, such as for the purposes of exercising our legal rights or where we are permitted to do. 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 that we need to keep it. For example:
- we archive our email and paper correspondence regularly and destroy information older than 5 years;
- we retain information relating to orders, refunds and user queries for approximately 5 years; and
- we maintain a suppression list of email addresses of individuals who no longer wish to be contacted by us. So that we can comply with their wishes we must store this information permanently.
Help keep your information safe
You can also play a part in keeping your information safe by:
- choosing a strong account password and changing it regularly;
- using different passwords for different online accounts;
- keeping your login and password confidential and not sharing these details with others;
- making sure you log out of your Shulph account each time you have finished using it. This is particularly important when using a shared computer;
- letting us know if you know or suspect that your account has been compromised, or if someone has accessed your account without your permission;
- keeping your devices protected by using the latest version of your operating system and maintaining any necessary anti-virus software; and
- being vigilant to any fraudulent emails that may appear to be from us. Any emails that we send will come from an email address ending in ‘@shulph.com’.
International transfers of your information
Our company is located in the United Kingdom.
Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following transfer solutions are implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries;
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, European Commission: Model contracts for the transfer of personal data to third countries; and
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
A list of the countries outside of the EEA to which we may transfer your personal information is available here:
- United States of America.
Please contact us using the contact details at the top of this Privacy Notice if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
Your rights to the information we hold about you.
You have certain rights in respect of the information that we hold about you, including:
- the right to be informed of the ways in which we use your information, as we seek to do in this Privacy Notice;
- the right to ask us not to process your personal data for marketing purposes;
- the right to request access to the information that we hold about you;
- the right to request that we correct or rectify any information that we hold about you which is out of date or incorrect;
- the right to withdraw your consent for our use of your information in reliance of your consent (refer to section 2 above to see when we are relying on your consent), which you can do by contacting us using any of the details at the top of this Privacy Notice;
- the right to object to our using your information on the basis of our legitimate interests (refer to section 2 above to see when we are relying on our legitimate interests) (or those of a third party)) and there is something about your particular situation which makes you want to object to processing on this ground;
- the right to receive a copy of any information we hold about you (or request that we transfer this to another service provider) in a structured, commonly-used, machine readable format, in certain circumstances;
- in certain circumstances, the right to ask us to limit or cease processing or erase information we hold about you; and
- the right to lodge a complaint about us to the UK Information Commissioner’s Office (https://ico.org.uk/) as well as a right to lodge a complaint with the relevant authority in your country of work or residence.
Please note that we may need to retain certain information for our own record-keeping and research purposes. We may also need to send you service-related communications relating to your Shulph user account even when you have requested not to receive marketing communications.
How to exercise your rights
- You may exercise your rights above by contacting us using the details in the 'company information' section of this Privacy Notice, or in the case of preventing processing for marketing activities also by checking certain boxes on forms that we use to collect your data to tell us that you don’t want to be involved in marketing.
- You may contact us via the details in the 'company information' section of this Privacy Notice if you wish to action any of these additional rights and we will comply with your requests unless we have a lawful reason not to do so.
What we need from you to process your requests
- We may need to request specific information from you to help us confirm your identity and to enable you to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
- In most circumstances, you will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We will try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Sharing data directly with third parties
- You might end up providing personal information directly to third parties as a consequence of your interactions with the Shulph service and other services offered by us. For example, your name and other personal information will be shared if you attend an event hosted by us where you communicate personal information directly with other attendees. We are not responsible for how such third parties use personal data provided by you.
- Please be responsible with personal information of others when using the Shulph service and the services available on it. We are not responsible for your misuse of personal information, or for the direct relationship between you and others when takes place outside of the Shulph service.
Third party links
- The Shulph service may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave the Shulph service, we encourage you to read the privacy notice of every website you visit.
Changes to this privacy notice and your duty to inform us of changes
- We may make changes to this Privacy Notice from time to time. We will post any changes to our site or apps, or notify you of any material changes by e-mail.
- It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us by updating your profile account information or contacting us via the contact details at the top of this Privacy Notice.
This Privacy Notice was updated on 13 May 2018.