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Privacy Policy

Last modified: 30/07/2024

This Privacy Policy sets out how International Literary Properties LLC and International Literary Properties UK Ltd (together "ILP") uses and protects your personal data. ILP comprises various legal entities and this Privacy Policy is issued on behalf of ILP, its subsidiaries and group companies, so when we mention "ILP", "we", "us" or "our" we are referring to the relevant ILP entity responsible for processing your data.

We recognise that it is important for you to understand how we use your personal data. Therefore, please read the following information carefully as it contains important information about our websites and how we collect and use your personal data using our websites, including any data you may provide when you sign up to our newsletter or contact us via our "contact us" form.  

Our websites are not intended for children under 18, and we do not knowingly collect data relating to children. We will only use personal data in ways that are described in this Privacy Policy and that are consistent with our obligations and your rights under applicable data protection laws.

This Privacy Policy is provided in a layered format so you can click through to the specific areas set out below. Alternatively, you can download a copy of the policy.

1. Who we are

For the purposes of applicable data protection laws, ILP is the "data controller" (in other words, the organisation that determines how and for what purposes your data is used). If you have any question about this Privacy Policy, including any requests to exercise your legal rights, please contact us using the information set out in the "contact details" section below.

2. The types of personal data we collect about you

Personal data means any information about a living individual from which that person can be identified. When you visit our websites or get in touch with us, we may collect, generate, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes your first name, last name, any previous names, title and date of birth.
• Contact Data includes your postal address, email address and telephone number(s).
• Technical Data includes the internet protocol (IP) address used to connect your computer to the internet, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access our websites.
• Usage Data includes information about how you interact with and use our websites.
• Marketing and Communications Data includes your preferences in receiving 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 which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' usage data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our websites to help improve the websites and our service offering.

3. How your personal data is collected

We use different methods to collect data from and about you, including through:

• Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • fill in forms on our websites; or
  • give us feedback or contact us.
• Automated technologies or interactions. As you interact with our websites, we will automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies. For further information about the cookies we use and how to opt out of such cookies, please see our Cookie Policy.
• Third party sources. We will receive personal data about you from various third party sources as set out below:
  • Technical data is collected from analytics providers such as Google Analytics and Squarespace. For more information, please see Google Analytics' Privacy Policy here and Squarespace's Privacy Policy here. Technical Data is also collected from search information providers such as Google and other search engines based outside the UK.
  • Where you contact us or ask us for any information (for example, if you contact us through our "contact us" form, or sign up to our mailing list), the data you provide will be processed by Mailchimp and shared with us. For more information, please see Mailchimp's Privacy Policy here.

4. How we use your personal data

Legal basis

Whenever we process your personal data, we are required to identify and maintain a valid "lawful basis" (i.e., a legally compliant justification) for doing so. We rely on one or more of the following legal bases:

• Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests – for example to prevent fraud and enable us to give you the best and most secure experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
• Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. Where legally permitted and required, we will identify the relevant legal obligation when we rely on this legal basis.
• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose – for example if you subscribe to an email newsletter.

Purposes for which we will use your personal data

To help you understand what we do with data and why, we have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Where we rely on our legitimate interests, we will always make sure that we balance these interests against your rights.

5. Direct marketing         

You will receive marketing communications from us if you have signed up to our mailing list and you have not opted out of receiving the marketing.

6. Third-party marketing

We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

7. Change of purpose

We will only use your personal data for the purposes for which we collected it. If we need to use your personal data for a purpose other than that for which it was collected, we will provide you, prior to that further processing, with information about the new purpose, our legal justification for doing so and any relevant further information. We may also issue a new Privacy Policy to you.

8. Cookies

Our websites use cookies to distinguish you from other users. This helps us to provide you with a good experience when you browse our website. For more information on how we use cookies, please see our Cookie Policy.

9. How we share your personal data

Third party suppliers and service providers involved in our contractual relationship with you

Like most businesses, we work with third party suppliers and service providers as part of the day-to-day operations of our business. Some of these trusted suppliers will process your personal data on our behalf and provide services to us.

We will always make sure that these trusted suppliers meet agreed standards for the protection of your personal data and they will only ever be allowed to use your personal data in order to provide us with services and not for their own commercial purposes. We require all third parties to take appropriate technical and organisational security measures to protect your personal information and to treat it subject to a duty of confidentiality and in accordance with applicable data protection law.

Other scenarios in which we might share your personal data

We may also share your personal information:

• with government authorities or professional bodies, such as HM Revenue & Customs in the United Kingdom (for tax purposes);
• with our professional advisors including tax, legal or other corporate advisors who provide professional services to us;
• with our media, film and/or TV agents if you contact us with an enquiry regarding our portfolio;
• with regulators, law enforcement or fraud prevention agencies, as well as our legal advisers, courts, the police and any other authorised law enforcement bodies, for the purposes of investigating any actual or suspected criminal activity or other regulatory or legal matters etc.;
• in the event that we consider selling or buying any business or assets we will disclose your personal information to any prospective sellers or buyers of such business or assets;
• in the event of any insolvency situation (e.g., administration or liquidation);
• if we, or substantially all of our assets, are acquired by a third party, in which case your personal information will be one of the transferred assets;
• to protect the rights, property or safety of our employees, workers, contractors, clients, or others. This includes exchanging your personal information with other companies and organisations (including without limitation the local police or other local law enforcement agencies) for the purposes of our employee, worker, contractor and client safety, crime prevention, fraud protection and credit risk reduction; or
• if we are under a duty to disclose or share your personal information in order to comply with any legal obligation or regulatory requirements, or otherwise for the prevention or detection of fraud or crime.

10. International transfers

We may share your personal data within the ILP Group companies. This will involve transferring your data outside the UK to our overseas offices in the United States of America.

Whenever we transfer your personal data out of the UK to countries which have laws that do not provide the same level of data protection as the UK law (including to service providers that carry out certain functions on our behalf), we always ensure that a similar degree of protection is afforded to it by ensuring that the following safeguards are implemented:

• We ensure your personal data is protected by requiring all our group companies to follow the same set of rules when processing your personal data.
• We use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK, namely the International Data Transfer Agreement. To obtain a copy of these contractual safeguards, please contact us using the details provided in part 17 of this Privacy Policy.  

11. How we protect your personal data

We take the security of your personal data seriously and 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 will always keep these under review to make sure that the measures we have implemented remain appropriate.

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.

12. How long we keep your personal data for

We will retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data – see part 13 of this Privacy Policy below for further information.

13. Your legal rights in relation to your personal data

It is important that the personal information we hold about you is accurate and up to date. Please keep us informed if your personal information changes so that our records can be updated. We cannot be held responsible for any errors in your personal information in this regard unless you have notified us of the relevant change.

Data protection law grants you a number of specific rights in respect of your data in addition to the broad and general right to have your data protected. We have set out some information in respect of each of those specific rights below:

• Right to be informed about how your personal information will be processed. This enables you to receive information about how we use your personal information. We have set this information out in this Privacy Policy.
• 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 in certain circumstances (commonly known as "the right to be forgotten"). This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. 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) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object. You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see part 4 of this Privacy Policy for details of how to object to receiving direct marketing communications).
• 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 (see the table in part 4 of this Privacy Policy for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. We will advise you if this is the case at the time you withdraw your consent.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
  • if you want us to establish the data's accuracy;
  • 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
  • you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Not to be subject to a decision solely based on automated processing. We do not anticipate making decisions about you based solely on automated decision making where that decision would have a significant impact on you. If we ever make a decision about you automatically by a computer or an algorithm without human intervention you can ask us to have that decision reviewed by a human.

If you wish to exercise any of the rights set out above, please see our contact details at part 17 of this Privacy Policy.

14. 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 could refuse to comply with your request in these circumstances.

15. 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.

16. Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could 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.

17. Contact details

If you have any questions about this Privacy Policy or about the use of your personal data or you want to exercise your privacy rights, please contact us at legal@ilpliterary.com.   

18. Complaints

We encourage you to contact us first if you have any queries, comments or concerns about the way we handle your data (our details are at part 17 of this Privacy Policy above). We will try to put things right.

However, if you are not satisfied with our handling of any request by you in relation to your rights or concerns, you also have the right to make a complaint at any time to a data protection supervisory authority, which, if you are based in:

• the UK, is the UK's Informational Commissioner's Office ("ICO"). You can contact the ICO at: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF; 0303 123 1113; or https://ico.org.uk/; or
• Europe, is your local representative, details of which can be found here.

We would, however, appreciate the chance to deal with your concerns before you approach any of the above authorities, so please contact us using the details provided at part 17 of this Privacy Policy above in the first instance.

19. Changes to this Privacy Policy

We keep our Privacy Policy under regular review and reserve the right to update or amend this Privacy Policy at any time, including where we intend to further process your personal data for a purpose other than that for which the personal data was collected or where we intend to process new types of personal data.

20. Third-party links

Our websites may, from time to time, 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 our website, we encourage you to read the Privacy Policy of every website you visit.