This policy covers:
•The kind of personal information we hold and collect
•How we hold and collect this personal information
•The purposes for which we collect, hold, use and disclose it
•How we protect your personal information
•Privacy information for minors and their parents, and
•How you can access and complain about your personal information held by us.
‘Personal information’ includes information obtained through our websites such as those at harlequinbooks.com.au, millsandboon.com.au and escapepublishing.com.au.
WHAT KIND OF INFORMATION DO WE COLLECT?
We collect personal information from you when it is reasonably necessary to do so. In most cases, you will have given us the information.
Types of personal information we collect may include your name, mailing address, e-mail address, telephone number, gender, date of birth, purchase history, credit card number, chat room communications, complaints about our products or services, a record of promotions offered to you, and your reading preferences such as favourite authors and themes.
We collect information that has been voluntarily provided by you when you order a product, enter a contest or sweepstakes, answer our polls or surveys, register as a member on our websites, or sign up for newsletters.
If you are one of our contracted authors or service providers, we collect and hold your personal information to communicate and make payments to you.
We do not collect sensitive information, such as information about your race, religion or political affiliations.
Unsolicited personal information
If you provide us with personal information we didn’t ask for, for example on our blog or social media pages, and the information is not something we would normally ask for, we will destroy or de-identify the information as soon as possible.
If you provide personal information about someone other than yourself, you must have that person’s consent to provide such information for the purpose for which you provide it to us.
We may also collect information about you that is not personal information. For example, we may collect data relating to your activity on our websites (including the type of internet browser you use, your operating system, address of referring site, your IP address and other clickstream information) via tracking technologies such as cookies, or we may collect information from you in response to a survey, promotion or competition. We generally use this information to report statistics, analyse trends, administer our services, diagnose problems and target and improve the quality of our products and services.
HOW WE COLLECT YOUR PERSONAL INFORMATION
We may collect your personal information from a variety of sources, including from you directly, indirectly from advertisers, mailing lists, recruitment agencies, contractors and business partners, and from our websites, forums, blogs and social media pages such as Facebook. We may combine data about you to better understand your preferences.
We collect personal information when you order a product, fill out forms, register with us as a subscriber or member, apply for a job, enter a competition or event, contribute to a fundraising event, answer our polls or surveys, through face-to-face interviews, business cards, electronic communications, telephone conversations, written communications and from third parties (including representatives, agents and credit reporting agencies).
When you connect with us online, we may collect information from you by means not obvious to you, such as using ‘cookies’ which are small pieces of information stored on your hard drive. Cookies allow us to better understand how users in general use our sites, which in turn helps us to focus our resources on features that are most popular with our users. You are always free to decline our cookies if your browser permits, but some parts of our sites may not work properly if you do.
Note: We may place advertising and/or links on our sites that originate from outside advertisers. In some cases, if you click on or view these ads, a cookie may be assigned by the advertisers. We do not control these cookies nor are we responsible for any marketing or other use of your name by the advertisers. We encourage you to investigate before disclosing information to third parties.
THE PURPOSES FOR WHICH WE USE YOUR PERSONAL INFORMATION
Personal information is collected so that we can serve you better through enhanced products, customer service and promotional efforts which may be of interest to you. We use your personal information:
•To provide you with the products or services you have requested, send correspondence, solicit your opinion on our products and services, process payments and make promotional offers for products similar to the ones you have already ordered and that we believe will be of interest to you
•To gain an understanding of your interests so that we can develop better products and services for you
•To properly investigate and respond to any complaints about our products or services
•To determine customer eligibility for our products and services
•To maintain a list of individuals who have indicated to us that they do not want to be contacted by us or any other companies, so that such requests can be honoured
•To transfer information (name and mailing address) to other reputable companies who may have a product or service of interest to you, except the information of those customers who indicate to us that they do not wish to be contacted by such companies.
Reasonable Disclosure to Third Parties
We may collect, hold, use and disclose your personal information for other purposes which are within reasonable expectations or where permitted or required by law. For example, your personal information may be used to perform specialised services such as self-publishing, prize fulfilment of our sweepstakes and skill contests, collection of overdue accounts and the provision of various marketing services, including, but not limited to, telemarketing, research and list processing, or may be provided to a prospective or actual purchaser of our business.
We are careful to share information only with third parties who provide assurances that the information will be used for legitimate business purposes and in a manner that complies with applicable industry guidelines and privacy legislation.
We may disclose personal information to overseas recipients. This may apply to disclosures between our group companies. Our main business locations are in Australia, Europe, Canada and the USA, but some of our group companies are based in other countries.
We may on occasion make your name and mailing address available to reputable third parties who may want to use this personal information for their marketing purposes. We do not disclose this personal information unless doing so is reasonably expected or if you first consent. We give you the option of opting out of direct marketing communications.
If you use our referral service to tell a friend about our site or product offering, you will be asked to provide your name, e-mail address and your friend’s e-mail address. You may also add any comments to the e-mail message. We use your name and e-mail address only to let your friend know who sent the e-mail. We use the friend’s e-mail address for the purpose of transmitting your e-mail. We do not collect or retain any of the information provided by you when you use this referral service in our database or any other place and do not use it for any other purpose.
PROTECTING YOUR PERSONAL INFORMATION
We go to great lengths to protect your information from error, loss or unauthorised access. We protect your information by:
•Using passwords, firewalls and Secure Socket Layers
•Implementing confidentiality agreements between Harlequin, our employees and third parties, and
•Restricting access to those who ‘need to know’.
You also have the option of remaining anonymous or using a pseudonym. This will not apply where it isn’t practicable, for example when you purchase from us online, or where a court of tribunal orders us to deal with individuals who have identified themselves.
If we no longer need your personal information, we will take reasonable steps to destroy or de-identify it.
INFORMATION FOR MINORS AND THEIR PARENTS
Minors under 18 years of age are welcome to use our subscription services and to participate in our competitions or other promotional activities, as long as they have the permission of their parent or legal guardian.
Parents and guardians of children/minors are personally responsible for monitoring their child’s access to, and use of, our services and for providing valid approvals for their child’s participation in our subscription, competitions and other promotional activities.
OTHER POLICIES AND LIMITS OF THIS POLICY
This is a policy and does not form a term of any contract we may have with you. There may be other privacy policies relevant to you depending on how you deal with us and on our particular businesses. This policy does not apply to the personal information of employees in their capacity as employees.
CORRECTION, ACCESS AND COMPLAINTS
You can request access to the personal information we hold about you (except in limited circumstances recognised by law) and we may charge a reasonable fee for this depending on the effort required of us.
Where reasonable, we will take reasonable steps to ensure that the personal information we collect and disclose is accurate, up-to-date and complete. However, you may also ask us to correct your personal information by contacting our Privacy Officer.
If you have a complaint about a breach of your privacy by us, we ask you to put it in writing. Our Privacy Officer will then investigate the matter and within a reasonable time, will inform you of the outcome in writing.
You can contact the Privacy Officer at the following address or phone number:
The Privacy Officer
Telephone: 02 9415 9229
Level 13, 201 Elizabeth Street
Sydney NSW 2000 Australia
More information about privacy law and privacy principles is available from the Privacy Commissioner. The Privacy Commissioner may be contacted at email@example.com or at www.oaic.gov.au
AUTHORS AND SERVICE PROVIDERS THAT ARE INDIVIDUALS – SUPPLEMENT
If you are an individual contracted to us as an author or service provider then the following applies to your information, in addition to the other matters in this policy:
•We will obtain personal information from you as needed for our contract with you, such as your name, address, telephone number and banking details.
•Access to your personal information is limited to those within the Harlequin organisation, including its subsidiaries and affiliates, and to authorised agents acting on behalf of them, on a need-to-know basis, in order to accomplish the purposes for which such information was collected.
•Your personal information is never used for marketing purposes, nor is it ever transferred to third parties for their marketing purposes.
•You may request access to your personal information by writing to the PO at the address above.