Privacy Policy This is the privacy notice of Best Books Limited .
In this document, "we", "our", or "us" refer to Best
Books Limite d.Our registered office is at Les Papillons, Rue des
Renouardes, Castel, Guernsey, GY5 7TX.
Our registered company number is 36252.
Introduction 1.
This privacy statement informs you about how we
process information that we record about you, whether provided by you, or by
another person or organisation. It applies to information that could identify you
as an individual (“personal information”) and information that does not,
including that which relates to your business. In the context of the law and
this notice, “process” means collect, store, transfer, use or otherwise act on
information.
2.
We are committed to the protection of your
privacy and confidentiality. We recognise that you are entitled to know that your
data will not be used for any unintended purpose and will not accidentally fall
into the hands of a third party.
3.
We undertake to preserve the confidentiality of
all information you provide to us and hope that you reciprocate.
4.
We have in place procedures and training for
data protection, confidentiality and information security. These are regularly
reviewed to ensure that they remain effective.
5.
Our policy complies with UK law accordingly
implemented, including that required by the EU General Data Protection
Regulation (GDPR).
6.
The law requires us to tell you about your
rights and our obligations to you regarding the processing and control of your personal
data. We do this now, by requesting that you read the information provided at www.knowyourprivacyrights.org .
7.
Except as set out below, we do not share, or
sell, or disclose to a third party, any information collected through our
website.
8.
Data we process We provide a range of services to
businesses and personal clients. We aim to process data, whether personal data
or not, only to the extent necessary for us to provide our clients with our
services and for other agreed purposes.
Often, we may aggregate information in a general way
and use it to provide class information. If we use it for this purpose, you as
an individual will not be personally identifiable.
Personal clients
If you are a personal client,
personal data that we may process may include contact information, information
about your business activities, information about your family members, and
financial information such as that relating to your income, expenses, taxation
and investments. Some of our services may also require us to process
information deemed to be “special category” information, such as your race or
ethnic origin, information about your health and medical history, information
about your sexual life and orientation, criminal records, and information about
your political, religious or philosophical beliefs.
In most cases, your personal data
will have been provided to us by you. However, with your consent, or if it is
necessary in order to provide you with our services, we may have obtained your
personal data from a third-party source.
Third parties connected to clients and suppliers
We may process your personal data
if you have a personal or business connection with any of our clients or
suppliers. For example, you may be a family member, business partner, other adviser,
supplier or transaction counterparty.
The data we process may include
contact information, information about business activities, information about
partners, directors, employees, information relating to employment remuneration
and payroll, and financial information such as that relating to income,
expenses, taxation and investments.
We may be given your personal
data by our clients or suppliers, or by third parties acting on the
instructions of a client or a supplier.
We ask our clients and suppliers
to bring this privacy notice to your attention as soon as they become aware
that we process your personal data.
Suppliers
If you supply our business with
goods or services, including subcontracted services that we supply to our
clients, then we may process your personal information. However, we do so only
to the extent necessary to contract with you.
In most cases, your personal data
will have been provided to us by you. However, sometimes we use third parties
such as credit rating agencies to make decisions regarding our relationship.
The bases on which we process personal information The law requires us to determine under which of
six defined bases we process different categories of your personal information,
and to notify you of the basis for each category.
If a basis on which we
process your personal information is no longer relevant, then we shall
immediately stop processing your data.
If the basis changes then if
required by law, we shall notify you of the change and of any new basis under
which we have determined that we can continue to process your information.
9.
Information we process because we have a
contractual obligation We may process personal information when a contract
has been formed with our business and processing is necessary to carry out our obligations
under that contract, or when processing personal data is necessary in order to
form a contract.
We shall continue to process this information until
the contract between us ends or is terminated by either party under the terms
of the contract.
10.
Information we process with your consent Only when you have given us explicit permission to
do so, do we process your personal information under the basis of consent.
For example, you might have agreed that we may pass
your name and contact information to selected associates whom we consider may
provide services or products you would find useful.
We continue to process your information on this
basis until you withdraw your consent, or it can be reasonably assumed that
your consent no longer exists.
You may withdraw your consent at any time by
instructing us at admin@bestbooks.gg . However, if you do so, you may not be able to
use our website or our services further.
11.
Information we process for the purposes of
legitimate interests We may process information on the basis there is a
legitimate interest, either to you or to us, of doing so.
Where we process your information on this basis, we
do after having given careful consideration to:
·
whether the same objective could be achieved
through other means
·
whether processing (or not processing) might
cause you harm
·
whether you would expect us to process your data,
and whether you would, in the round, consider it reasonable to do so
For example, we may process your data on this basis
for the purposes of:
·
record-keeping for the proper and necessary
administration of our business
·
responding to communication from you to which we
believe you would expect a response
·
protecting and asserting the legal rights of any
party
·
insuring against or obtaining professional
advice that is required to manage business risk
·
protecting your interests where we believe we
have a duty to do so
12.
Information we process because we have a legal
obligation Sometimes, we must process your information in order
to comply with a statutory obligation.
For example, we may be required to give information
to legal or tax authorities if they so request or if they have the proper
authorisation such as a search warrant or court order.
This may include your personal information.
Specific uses of information you provide to us 13.
Communicating with you When you contact us, whether by telephone, through
our website or by e-mail, we collect the data you have given to us in order to
reply with the information you need.
We record your request and our reply in order to
increase the efficiency of our business.
We keep personally identifiable information
associated with your message, such as your name and email address so as to be
able to track our communications with you to provide a high-quality service.
14.
Dealing with complaints When we receive a complaint, we record all the
information you have given to us.
We use that information to resolve your complaint.
If your complaint reasonably requires us to contact
some other person, we may decide to give to that other person some of the
information contained in your complaint. We do this as infrequently as
possible, but it is a matter for our sole discretion as to whether we do give
information, and if we do, what that information is.
If the complaint relates to information on our
website and we feel it is justified or if we believe the law requires us to do
so, we shall remove the information while we investigate.
If we think your complaint is vexatious or without
any basis, we shall not correspond with you about it.
We may compile statistics from information relating
to complaints to assess the level of service we provide, but not in a way that
could identify you or any other person.
15.
Office visitors If you visit our office, you will be required to
sign in at reception. We keep a record of your visit in order to maintain the
security of our premises, your safety and the safety of other visitors.
We keep the record of your visit only for as long as
necessary, and in any case, for less than one year.
16.
Customer relationship management system We use a customer relationship management (CRM)
system to process personal data.
Data subjects include existing, former and prospective
clients and their agents and representatives.
Personal data that we process may include the name
of the person, information about his or her employer and job position, and
contact information.
We process this data on the basis of consent for
purposes that include:
·
managing and developing our business or services
·
informing clients and prospective clients about
our services
·
determining relationships between clients and
our partners and employees
·
analysing whether we provide clients with a high
level of service
We do not sell or share any personal data with third
parties unless we have explicit consent to do so from the data subject.
17.
Job applications and employment If you send us information in connection with a job
application, we may keep it for up to three years in case we decide to contact
you at a later date.
If we employ you, we collect information about you
and your work from time to time throughout the period of your employment. This
information will be used only for purposes directly relevant to your
employment. After your employment has ended, we may keep your file for up to
six years before destroying or deleting it.
Use of information we collect through automated systems when you visit our
website 18.
Cookies Cookies are small text files that are placed on your
computer's hard drive by your web browser when you visit any website. They
allow information gathered on one web page to be stored until it is needed for
use on another, allowing a website to provide you with a personalised
experience and the website owner with statistics about how you use the website
so that it can be improved.
Some cookies may last for a defined period of time,
such as one day or until you close your browser. Others last indefinitely.
Your web browser should allow you to delete any you
choose. It also should allow you to prevent or limit their use.
Our website uses cookies. They are placed by
software that operates on our servers, and by software operated by third
parties whose services we use.
When you first visit our website, we will ask whether you
wish us to use cookies. If you choose not to accept them, we shall not use them
for your visit except to record that you have not consented to their use for
any other purpose.
If you choose not to use cookies or you prevent their use
through your browser settings, you will not be able to use all the
functionality of our website.
We may use cookies in the following ways:
18.1.
to track how you use our website
18.2.
to record whether you have seen specific
messages we display on our website
18.3.
to keep you signed in our site
18.4.
to record your answers to surveys and
questionnaires on our site while you complete them
19.
Personal identifiers from your browsing activity Requests by your web browser to our servers for web
pages and other content on our website are recorded.
We record information that could identify your
location, such as your IP address. We also record information reported by the
software you are using to browse our website, such as the type of computer or
device and the screen resolution.
We use this information in aggregate to assess the
popularity of the webpages on our website and how we perform in providing
content to you.
If combined with other information we know about you
from previous visits, the data possibly could be used to identify you
personally, even if you are not signed in to our website. However, our policy
is not to use such data for the purpose of personal identification.
20.
Our use of re-marketing Re-marketing involves placing a cookie on your
computer when you browse our website in order to be able to serve to you an
advert for our products or services when you visit some other website.
We do not use our website for re-marketing.
Disclosure and sharing of your information 21.
Information we obtain from third parties Although we do not disclose your personal
information to any third party (except as set out in this notice), we sometimes
receive data that is indirectly made up from your personal information from
third parties whose services we use.
No such information is personally identifiable to you.
22.
Third party advertising on our website We do not allow third parties to advertise on our
website.
23.
Data may be processed outside the UK and Channel
Islands Our website is hosted in the United Kingdom.
We may also use outsourced services in countries
outside the UK and Channel Islands from time to time in other aspects of our
business.
Accordingly, data obtained within the UK and Channel
Islands or any other country could be processed outside these regions.
With respect to data transferred outside the UK and
Channel Islands, the
data protection clauses in our contracts with data processors include transfer
clauses written by or approved by a supervisory authority in theUK
and Channel Islands.
Access to your own information 24.
Access to your personal information 24.1.
At any time, you may review or update personally
identifiable information that we hold about you.
24.2.
To obtain a copy of any information that is not
provided through our website you may send us a request at admin@bestbooks.gg.
24.3.
After receiving the request, we will tell you
when we expect to provide you with the information, and whether we require any
fee for providing it to you.
25.
Removal of your information If you wish us to remove personally identifiable
information, you may contact us at admin@bestbooks.gg .
This may limit the service we can provide to you.
26.
Verification of your information When we receive any request to access, edit or
delete personal identifiable information we shall first take reasonable steps
to verify your identity before granting you access or otherwise taking any
action. This is important to safeguard your information.
27.
Retention period for personal data Except as otherwise mentioned in this privacy
notice, we keep your personal information only for as long as required by us:
27.1.
to provide you with the services you have
requested;
27.2.
to comply with other law, including for the
period demanded by our tax authorities;
27.3.
to support a claim or defence in court.
Other matters 28.
If you are not happy with our privacy policy 28.1.
If you are not happy with our privacy policy or
if have any complaint, then you should tell us.
28.2.
If a dispute is not settled, then we hope you
will agree to attempt to resolve it by engaging in good faith with us in a
process of mediation or arbitration.
28.3.
If you are in any way dissatisfied about how we
process your personal information, you have a right to lodge a complaint with
the Information Commissioner's Office. This can be done at https://ico.org.uk/concerns/
29.
Compliance with the law Our privacy policy has been compiled to comply with
the law of every country or legal jurisdiction in which we aim to do business.
If you think it fails to satisfy the law of your jurisdiction, we should like
to hear from you.
30.
Review of this privacy policy We may update this privacy notice from time to time
as necessary. The terms that apply to you are those posted here on our website
on the day you use our website. We advise you to print a copy for your records.
If you have any question
regarding our privacy policy, please contact us