Privacy policy

Privacy Policy

Introduction

This privacy policy tells you how CompletelyNovel uses your personal data when you visit our website, interact with us, and buy our goods and services.
In addition, it tells you about your privacy rights and the way the law protects you.
It is important to read this policy, along with any other privacy policies we may provide, so that you are aware of how and why we are using your data.
This privacy policy was last updated on 23rd of May 2018. Historic versions can be obtained by contacting us.
If you have questions or would like to exercise your privacy rights please follow the instructions below.

Our website

Our website at CompletelyNovel.com sells books and publishing services which are aimed at authors, aspiring authors and book purchasers. This website is not intended for children and we do not knowingly collect data relating to children.
Our registered address is Unit A1, Masterlord Industrial Estate, Leiston, Suffolk, IP16 3QQ, United Kingdom.
Completely Novel Limited is the data controller responsible for this website. When we mention “CompletelyNovel”, “we”, “us” or “our” in this privacy policy, we are referring to Completely Novel Limited.

Personal data which we collect about you

  • Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
    We collect a variety of information about our customers and visitors to the MOO website. This personal data falls into these categories:
  • Identity Data includes title, first name, last name, username or similar identifier and an encrypted version of your login/password. If you interact with us through social media, this may include your social media username.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Financial Data includes payment card details.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • Profile Data includes your username and password, purchases or orders made by you, preferences, feedback, as well as any profile data which we have added (for example, using analytics and profiling).
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  • Usage Data includes information about how you use our website, products and services.
  • Tracking Data includes information we or others collect about you from cookies and similar tracking technologies, such as web beacons, pixels, and mobile identifiers.
  • Marketing and Communications Data includes your preferences in receiving direct marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.

However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes 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). Nor do we collect any information about criminal convictions and offences. If you use any of these types of personal data on products you design or create on CompletelyNovel.com, we will not be able to tell. We will treat all the personal data included in designs or products as ordinary personal data.

If you choose not to share personal data with us, or refuse certain contact permissions, we might not be able to provide the products and services you’ve asked for.

How is your personal data collected?

We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by email or through social media.

This includes personal data you provide when you:

  • sign up to receive the newsletter;
  • make enquiries or request information be sent to you;
  • create an account on our website;
  • create designs for products on our website;
  • order/purchase our products or services;
  • ask for marketing to be sent to you;
  • engage with us on social media;
  • enter a competition, promotion or survey;
  • contact customer services; or
  • leave comments or reviews on our products or services.

Automated technologies or interactions. As you interact with us, including via the completelynovel.com website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We may also collect Tracking Data when you use our website, or when you click on one of our adverts (including those shown on third party websites).

Third parties or publicly available sources. We may receive personal data about you from various types of third parties, including:
Technical Data and/or Tracking Data from analytics providers, advertising networks and search information providers;
Contact, Financial and Transaction Data from providers of payment and fraud prevention services;
Identity and Contact Data from data partners; and
Data from any third parties who are permitted by law or have your permission to share your personal data with us, such as via social media or review sites We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

How we use your personal data

Where we need to perform the contract we are about to enter into or have entered into with you e.g. when you purchase our products or services.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. For example, when we carry out fraud screening as part of the check-out process.
Where we need to comply with a legal or regulatory obligation. For example, keeping records of our sales for tax compliance.
Generally, we do not rely on consent as a legal basis for processing your personal data other than where the law requires it, for example in relation to sending certain direct marketing communications. Where our legal basis is consent, you have the right to withdraw consent any time.

Explaining the legal bases we rely on to process personal data

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new customer a) Identity b) Contact c) Profile Performance of a contract with you.
To process and deliver your order, including: managing payments, fees and charges; and managing your queries through our Customer Service team a) Identity b) Contact c) Financial d) Transaction e) Marketing and Communications Performance of a contract with you. We may also use some of the data related to your queries for our legitimate interests of ensuring our customer service quality standards are met.
To collect and recover money owed to us in respect of your order a) Identity b) Contact c) Financial d) Transaction Necessary for our legitimate interests (to recover debts due to us).
To carry out fraud assessments a) Identity b) Contact c) Financial d) Transaction e) Technical Necessary for our legitimate interests of ensuring payments are not fraudulent
To process your purchase of a gift voucher from us a) Identity b) Contact c) Financial d) Transaction Performance of a contract with you.
To notify you in relation to our legal obligations and documents, including changes to our terms or Privacy Policy a) Identity (b) Contact © Profile Necessary for our legitimate interests of ensuring our customers are updated on these changes.
To help us improve our offering to our customers, including asking you to leave a review or take a survey, or provide customer insights (a) Identity (b) Contact © Profile (d) Marketing and Communications Necessary for our legitimate interests (to study how customers use our products/services, to improve our offering to our customers, to develop them and grow our business).
To enable you to partake in a prize draw or competition a) Identity b) Contact c) Profile d) Usage e) Marketing and Communications Performance of a contract with you to fulfil the promotion and run the competition/prize draw. We may also subsequently use your entries for the legitimate interests of understanding our customer base more effectively.
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) a) Identity b) Contact c) Profile d) Technical 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).
To deliver relevant website content, advertisements and other marketing material to you and measure or understand the effectiveness of the advertising we serve to you a) Identity b) Contact c) Profile d) Usage e) Marketing and Communications f) Technical Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business to inform our marketing strategy and to improve our offering to you). Please note that where cookies are used for this purpose, this is covered separately by our Cookies Policy.
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical (b) Usage 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). Please note that where cookies are used for this purpose, this is covered by our Cookies Policy.
To make suggestions and recommendations to you about goods or services that may be of interest to you a) Identity b) Contact c) Technical d) Usage e) Profile Necessary for our legitimate interests (to develop our products/services and grow our business, and to improve our offering to you).

We do not conduct any automated decision making or online behavioural tracking.

Advertising, marketing and your communications preferences

We may use your Identity, Contact, Technical, Tracking, Usage and Profile Data to form a picture of what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you and tell you about them. This is what we call direct marketing.
We may carry out direct marketing by email such as the CompletelyNovel Newsletter.
We try to make it really clear what we are doing and what communications you will be sent, whether deciding to sign up to receive our Newsletter or as part of creating an account or the purchase journey – and you have a right at any time to opt out. The easiest way to opt out is to use the unsubscribe link at the bottom of the communication.
We have established a privacy page where you can view and make certain decisions about your personal data use.
If you want more information about Tracking Data, in particular cookies, see Cookies below.

Cookies

By visiting this website with your browser settings adjusted to allow cookies, you are consenting to CompletelyNovel using cookies for the purposes outlined below in order to provide you with a fully functional publishing experience.

What is a cookie?

A cookie is a small text file which is downloaded and stored on your computer or mobile device by websites that you visit. Where cookie technology is not available, an anonymous identifier may be used. An anonymous identifier is a random string of characters used for the same purposes as a cookie.

Your browser accesses the cookie file only when you visit the website that generated it. This helps to ease your navigation by automatically logging you in and remembering things like your preferences and what’s in your shopping basket. Cookies allow sites to deliver you a personalised experience.

The information stored within any given cookie can only be accessed by the website that created it and cookies are limited to communicating only the information that you have disclosed to the site.

We use the following types of cookie:

Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.

Performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

The list below details the cookies used on CompletelyNovel. We have outlined who sets these cookies and their purpose. If the party reads something other than CompletelyNovel, these are our third party business partners who help us to enhance your browsing experience.

Category Party Purpose
Strictly necessary CompletelyNovel CompletelyNovel uses cookies to enable some of the basic functionality that is required for you to browse and shop on our website, such as remembering which products you have added to your basket. The information collected through these cookies is only used for this purpose and is never shared or sold on to third parties.
Performance Google Analytics (including Universal Analytics and Google Analytics for Display Advertisers) Google Analytics use cookies (or, if applicable, anonymous identifiers) to collect data that helps us understand how people are using the site. We use this information to identify how and where we can improve the customer experience, and to help us determine where our ads will be most effective online. The data collected through these cookies is anonymous, does not collect specific customer data and is never shared with other third parties, other than Double Click Campaign Manager, which is a fully owned Google product.
Functionality Share This Share This allows customers to share content, products and web pages from our website with other websites and social networking sites. The cookies used by Share This allow us to track the type of content, products and pages that our users are sharing to help us better understand which content is most engaging for our customers so that we can improve the content and customer experience in other areas of the website.
Performance Social Media plugins Sites such as Facebook and Pinterest, serve cookies in order to be able to share and discuss CompletelyNovel’s products on social networks.

Duration of cookies:

Session (or Transient) Cookies
Session cookies are stored in your computer’s memory for the length of your browsing session. They become inaccessible after the session has been inactive for a time and are automatically deleted from your computer when the browser is closed. They allow you to move from page to page without having to log-in repeatedly.

Persistent (or Permanent) Cookies
Persistent cookies are stored in your computer memory and are not deleted when the browser is closed. They are used to keep your preferences for the website, so they will be remembered for next time you visit the website. They are also used to collect information about the numbers of visitors, the average time spent on a particular page and analyse shopping behaviour on the website. This information is used to find out how well the website works and where it can be improved.

Flash Cookies (or Locally Shared Objects)
You probably have Adobe Flash installed on your computer. Websites that contain Flash can also store small files on your computer that are used in the same way as cookies.
Flash cookies can also back up the data that is stored in other cookies. When you delete cookies, your Flash cookies are not affected. So a website may still recognise you if it backed up the deleted cookie information on a Flash cookie.

Sharing with social networks
If you use the buttons that allow you to share products and content with your friends via social networks like Twitter and Facebook, these companies may set a cookie on your computer memory. Find out more about these here:
https://www.facebook.com/about/privacy/
http://twitter.com/privacy
http://www.google.com/intl/en-GB/policies/privacy/

Managing cookies:
If cookies aren’t enabled on your computer, it will mean that your experience on our website will be limited to browsing and researching; you won’t be able to use our Book Creator, add products to your basket or buy them. To enable and manage cookies, you can use your browser to do this. Each browser is different, so check the ‘Help’ menu of your particular browser (or your mobile phone’s handset manual) to learn how to change your cookie preferences.

  • Google Chrome
  • Internet Explorer
  • Mozilla Firefox
  • Safari
  • Opera
  • Google Analytics Opt Out

Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in this privacy policy. We may also share your personal data if the law otherwise allows it.

We may share personal data with the following categories third parties:
Suppliers and service providers (such as technology service providers, payment processing and fraud prevention providers, manufacturers and post and courier services);
auditors and professional advisers like bankers, lawyers, accountants and insurers; and
government, regulators and law enforcement.

We share personal data with the following specific third parties:

  • MailChimp
  • PayPal
  • FrontApp

We also share data with third parties connected to analytics. Please see Cookies above, including the cookie list, for more information about who those third parties are.

We may also share data with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Payment information

MOO uses third party payment processor PayPal to process payments made for products and services via the Website. All online payments will be conducted in accordance with Payment Card Industry (PCI) data security standards and your billing information (which is only used by these payment processors for the purpose of performing fraud protection) is encrypted before being communicated to them. Subject to the below exceptions, your credit card details are communicated directly from your browser to these payment processors – CompletelyNovel never sees your full Permanent Account Number (PAN). This means that the payment form is either off-site or displayed in a frame on the payment page.
For PayPal we only store the tokens required to identify the transaction with PayPal, issue refunds and identify transactions made using PayPal.

International transfers

Whenever we transfer your personal data out of the EEA, we will comply with applicable data protection law. Some of the mechanisms we may choose to use when undertaking an international transfer are:
The transfer of your personal data is to a country that has officially been deemed to provide an adequate level of protection for personal data by the European Commission.
We may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe (called the “EU Model Clauses”).
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. If the provider is not EU-US Privacy Shield certified, we may use the EU Model Clauses.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Third-party links

This website may include links to third-party websites, plug-ins and applications (for example, the ability to sign in with Facebook). 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. We recommend you read the privacy policy of every website you visit.

Data retention

We will only keep your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers for tax purposes.
We also make a promise to you that you can come back at any time in the future and re-print books you have created and ordered from us in the past. So, unless you actively delete this information, we keep it, so we can keep our promise to you.
In some circumstances you can ask us to delete your data; see Your legal rights below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Your legal rights

Under certain circumstances, you have rights under UK data protection laws in relation to your personal data.
You have the right to:

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it for example where you consider that we do not need it any longer for the purposes for which we originally collected it as explained to you in this Privacy Policy, where you have withdrawn your consent to our using it and we had relied on that consent according to this Policy, where you consider that we cannot show a ‘legitimate interest’ in continuing to process it and we have relied on that legitimate interest to process it as explained to you in this Policy . You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; © where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or 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 initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.

If you wish to exercise any of these rights, please Contact Us, marking your query for the attention of the DPL.

No fee usually required
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.

What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right 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.

Time limit to respond
We 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.

How to contact us about privacy

If you have any questions about this privacy policy, or would like to exercise any of your rights, please email us at team@completelynovel.com.