Last Updated on May 18, 2021
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When you use the Services by, for example, providing registration details, subscribing to a newsletter, browsing our sites, completing a survey, entering a sweepstakes, requesting information from us or otherwise interacting with our Services, we gather personal information. “Personal Information” is information that identifies you as an individual or relates to an identifiable individual. Several different types of Personal Information can be gathered when you interact with the Services. Collection of Personal Information is necessary to provide the Services to you or to enhance your consumer experience.
We and our service providers collect Personal Information in a variety of ways, including:
Through the Services
- Newsletter subscriptions: We collect your email address when you subscribe to our newsletters. For certain newsletters, we collect additional personal information that may be relevant including your name, job title, interests and similar information.
- Sweepstakes, contests and other promotions: We collect personal information such as your name, email address and mailing address when you participate in sweepstakes, contests or similar promotions.
- Registration for programs and events: When you register for our programs, events or conferences, we collect personal information such as your name and email address.
- Reading preferences and market research: We collect personal information from you including your reading preferences (e.g., author, genre) you provide through the Services and any information you provide through voluntary surveys or feedback conducted through the Services, through our service providers’ platforms, by phone or during in-person interviews or focus groups.
- Job applications: We collect personal information in connection with your application for a job at PRH.
- Contact with our Customer Service: We collect personal information for you in offline contexts, including, for example, when you place an order over the phone or contact customer service.
From Other Sources
- Publicly available databases, including marketing and data analytics resources. For example, we may receive email addresses, mailing addresses and demographic information (e.g., age, sex, household income) from these sources.
- Authors and joint marketing third parties, when they share the information with us.
- Social media platforms and other third party service platforms.
- Third party business customers, clients and partners, when they share the information with us (e.g., sales data).
We and our service providers use Personal Information for the following purposes:
Providing the functionality of the Services and fulfilling your requests
- To provide the Services’ functionality to you, such as arranging access to your registered account, and providing you with related customer service.
- To respond to your inquiries and fulfill your requests, when you contact us via one of our online contact forms or otherwise, for example, when you send us questions, suggestions, compliments or complaints, or when you request a quote for or other information about our Services.
- To enable you to participate in surveys, panels or research, and public forms on our websites.
- To complete your transactions, verify your information, and provide you with related customer service.
- To send administrative information to you, such as changes to our terms, conditions, and policies.
We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.
Providing you with our newsletter and/or other marketing materials and facilitating social sharing
- To send you marketing related emails, with information about our services, new products and other news about our company. To opt out of these emails, please see the section labeled Choices and Access.
- To facilitate social sharing functionality that you choose to use.
We will engage in this activity with your consent or where we have a legitimate interest.
Analyzing Personal Information for business reporting and providing personalized services
- To analyze or predict our users’ preferences so we can improve our Services.
- To better understand your interests and preferences, so that we can personalize our interactions with you and provide you with information and/or offers tailored to your interests.
- To better understand your preferences so that we can deliver content via our Services that we believe will be relevant and interesting to you.
We will provide personalized services based on our legitimate interests, and with your consent to the extent required by applicable law.
Allowing you to participate in sweepstakes, contests or other promotions
- We may offer you the opportunity to participate in a sweepstakes, contest or other promotion.
- Some of these promotions have additional rules containing information about how we will use and disclose your Personal Information. Please read those additional rules before choosing to participate.
We use this information to manage our contractual relationship with you.
Accomplishing our business purposes
- For data analysis, for example, to improve the efficiency of our Services;
- For audits, to verify that our internal processes function as intended and to address legal, regulatory, or contractual requirements;
- For fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft;
- For developing new products and services;
- For enhancing, improving, repairing, maintaining, or modifying our current products and services, as well as undertaking quality and safety assurance measures;
- For identifying usage trends, for example, understanding which parts of our Services are of most interest to users;
- For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users; and
- For operating and expanding our business activities, for example, understanding which parts of our Services are of most interest to our users so we can focus our energies on meeting our users’ interests.
We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or based on our legitimate interest.
Aggregating and/or anonymizing Personal Information
- We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose, as it no longer identifies you or any other individual.
Combining Personal Information
- To perform the above functions, we may match information collected from you through different means or at different times, including Personal Information and Other Information (as defined below, see the section labeled Other Information) and use such information along with information collected from other sources, such as demographic information and updated contact information. We or our third party service providers may also use your information to assess the level of interest in, and use of the Services, our emails, and our other campaigns both on an individual basis and in the aggregate. We may also use and/or combine information we collect off-line or from third party sources to check the accuracy of, enhance and supplement your user records, and to better customize your experience with us.
We also use your Personal Information as necessary or appropriate, in particular when we have a legal obligation or legitimate interest to do so:
- To comply with applicable law and regulations
- This may include laws outside your country of residence.
- To cooperate with public and government authorities
- To respond to a request or to provide information we believe is necessary or appropriate. These can include authorities outside your country of residence.
- To cooperate with law enforcement
- For example, when we respond to law enforcement requests and orders or provide information we believe is important.
- For other legal reasons
- To enforce our terms and conditions; and
- To protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
- In connection with a sale or business transaction
- We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
We disclose Personal Information:
- You can learn more about our parent company and consult the list and location of our affiliates here.
- To our third party service providers, to facilitate services they provide to us
- These can include providers of services such as website design and hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, ad serving, research survey/interview/focus group management and analysis, marketing, auditing, and other services.
- To our joint marketing partners
- By using the Services, you may elect to disclose Personal Information.
- On message boards, chat, profile pages, blogs, and other services to which you are able to post information and content. Please note that any information you post or disclose through these services will become public and may be available to other users and the general public.
- With other third parties
- We may also disclose your Personal Information for the other uses described above (e.g., to comply with applicable laws, cooperate with law enforcement, and in connection with a sale or business transaction).
“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. The Services collect Other Information such as:
- Browser and device information
- Information collected through cookies, pixel tags and other technologies
- Demographic information and other information provided by you that does not reveal your specific identity
- Information that has been aggregated in a manner such that it no longer reveals your specific identity
Collection of Other Information
We and our service providers may collect Other Information in a variety of ways, including:
- Your browser or device
- Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services you are using. We use this information to ensure that the Services function properly.
- Pixel tags and other similar technologies
- Pixel tags. Pixel tags (also known as web beacons and clear GIFs) such as Amazon’s may be used to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns, compile statistics about usage of the Services and response rates, and identify similar audiences to whom we can market our Services.
- Physical Location
- We may collect the physical location of your device by, for example, using satellite, cell phone tower or WiFi signals. We may use your device’s physical location to provide you with personalized location-based services and content.
- We may also share your device’s physical location, combined with information about what advertisements you viewed and other information we collect, with our marketing partners to enable them to provide you with more personalized content and to study the effectiveness of advertising campaigns. In some instances, you may be permitted to allow or deny such uses and/or sharing of your device’s location, but if you do, we and/or our marketing partners may not be able to provide you with the applicable personalized services and content.
Uses and Disclosures of Other Information
We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.
We may use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use the Services and other websites or online services.
Your choices regarding our use and disclosure of your Personal Information
We give you choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt out from:
Email newsletters. If you no longer want to receive marketing related emails from us on a going-forward basis, you may opt out by clicking the email footer link to unsubscribe or by emailing email@example.com. You may not be able to unsubscribe from communications that are not related to marketing; otherwise, you might miss important information about your account, the Services, or transactions you engage in on the Website.
Joint marketing promotions. As described above (see section labeled With Whom We Disclose Your Personal Information), you may withdraw your consent to our sharing of your Personal Information with our joint marketing partners at any time by sending us an email at firstname.lastname@example.org.
We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt out of receiving marketing related emails from us, we may still send you important administrative messages, from which you cannot opt out.
How you can access, change, or delete your Personal Information
If you would like to request to access, correct, update, suppress, restrict, or delete Personal Information, object to or opt out of the processing of Personal Information, or if you would like to request to receive a copy of your Personal Information for purposes of transmitting it to another company (to the extent these rights are provided to you by applicable law), you may contact us. We will respond to your request consistent with applicable law. If you are a California resident, please refer to the “Additional Information Regarding California” section at the end of this Policy for more information about the requests you may make under the CCPA.
In your request, please make clear what Personal Information you would like to have changed or whether you would like to have your Personal Information suppressed from our database. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion.
Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, political opinions, religion or other beliefs, health, biometrics or genetic characteristics or criminal background) on or through the Services or otherwise to us.
We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include:
- The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services);
- Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
- Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the Contacting Us section below.
In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as LinkedIn, Facebook, Google, or any other social media platform provider.
ADDITIONAL INFORMATION REGARDING CALIFORNIA
email@example.com (newsletter unsubscribe requests)
By phone: (800) 793-2665
Attn: Customer Service
Penguin Random House
New York, NY
Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.
Collection of Personal Information
We plan to collect, and have collected within the preceding 12 months, the following categories of Personal Information:
A. “Identifiers.” Identifiers, such as name, alias, contact information, unique personal identifiers, and online identifiers;
B. “Customer Records Information.” Personal information as defined in the California customer records law, such as financial information (credit and debit card information and billing information);
C. “Online Use Information.” Internet or network activity information, such as browsing history, interest data and interactions with our websites;
D. “Geolocation Data.” Geolocation data such as device location and approximate location derived from IP address;
Where We Obtain Personal Information From
As described above, we collect this Personal Information from you and from other categories of sources, including publicly available databases, authors and joint marketing partners, social media platforms and third party service platforms, and our business customers, clients and partners, when they share this information with us.
Our Use of Personal Information
Also as described above, we may use this Personal Information to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives, including, for example, using Personal Information to: develop, improve, repair, and maintain our products and services; personalize, advertise, and market our products and services; conduct research, analytics, and data analysis; maintain our facilities and infrastructure; undertake quality and safety assurance measures; conduct risk and security control and monitoring; detect and prevent fraud; perform identity verification; perform accounting, audit, and other internal functions, such as internal investigations; comply with law, legal process, and internal policies; maintain records; and exercise and defend legal claims.
Disclosure and Sale of Personal Information
We share Personal Information with the following categories of third parties:
- “Book Authors.” We share with book authors for marketing purposes.
- “Service Providers.” We share with our trusted third-party service providers, to facilitate services they provide to us, such as internet services, website hosting, data analytics, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, marketing, auditing, background checks, and other services.
- “Ad Networks.” We share with third-party ad networks and online advertising partners to permit them to send you marketing communications.
- “Marketing Partners.” We share with our marketing partners to permit them to send you marketing communications, consistent with your choices.
- “Social Networks” We share with social network platforms, who use the data we share in accordance with their own privacy policies.
- “Business Partners.” We share with our trusted business partners.
- “Contest Sponsors.” With your consent, we share with third-party sponsors of sweepstakes, contests, and similar promotions.
- “Legal Authorities.” We share with public and government authorities, including regulators and law enforcement, to respond to requests, as well as to protect and defend legal rights.
- “Other Parties in Litigation” We share information in the context of litigation discovery and in response to subpoenas and court orders.
In the preceding 12 months, we disclosed for our operational business purposes or sold the following categories of Personal Information to the following categories of third parties: