Last Modified: January 1, 2023
We at HarperCollins Focus, LLC. (“HarperCollins Focus,” “Company,” “we,” “us”), including our affiliates, respect your privacy and understand that you care about your personal data and how it is used. We value your trust in sharing your personal data with us and are dedicated to protecting your privacy, as further described in this Privacy Notice.
This Privacy Notice (“Notice”) applies to personal consumer data collected by the Company through its websites, services and mobile applications (collectively, the “Services”). This Privacy Notice describes in detail the types of data we collect about you; how we use your data (the purposes for processing your data) and with whom we share it; the choices and rights you have with regard to your data; how we protect your data; and how you can contact us about our privacy practices.
2. INFORMATION WE COLLECT AND OBTAIN
We obtain personal data about you from a variety of sources. This includes personal data you provide to us directly, data we obtain from other sources, and data we gather through automated means.
Data you provide to Company. When you register for or participate in certain services, seek access to certain content or features, or directly correspond with us, we may collect certain types of data from you:
- Contact information (such as name, postal address, email address and telephone and/or mobile numbers);
- Certain biographical and product preference information that you elect to provide, such as your date of birth, gender and/or reading preferences, to customize our Service for you;
- Financial information (such as credit card or banking information required to pay for our products or services);
- Username and password when you register through our Services;
- Survey responses, reviews and/or comments; and
- Other information you may provide to us, such as through our “Submit a Request” or “Contact Us” feature; and
Data obtained from other sources. We may obtain personal data about you in connection with the Services from publicly and commercially available sources and from our Company affiliates and/or business partners, including:
- Demographical data (such as gender, age range, educational level, household income range, number of children in household, to the extent permitted);
- Purchasing data, including membership in loyalty programs or information about advertisements you have seen or acted upon, including your interaction with advertisers’ products and services;
- Preferences and shopping interests;
- Your activities on other Internet sites or mobile Apps;
- Your Internet Protocol (IP) address;
- Device information, including unique identifiers and connection information, including mobile device advertising IDs (e.g., Apple’s IDFA or Google’s AAID) and the means of internet connection (e.g., WiFi connection, ISP) that can identify the physical location of such devices, in accordance with applicable law;
- Your device type and settings, software used, browser type and operating system;
- Language preferences;
- Websites or other services you visited before and after visiting the Services (referring URL);
- Web pages and advertisements you view and links you click on within, and what search queries you may have run on, the Services (clickstream);
- Viewing behavior, including the content you view, how long you watch each video, the quality of the service you receive, and advertisements you have been shown or interacted with;
- Dates and times you access or use the Services;
- Location information, including the city, state and zip code associated with your IP Address, information derived through WiFi triangulation, and precise location information from GPS-based functionality on your mobile Apps, with your consent; For more information on the various types of automated means we use to gather information, please see our Cookie Notice.
3. HOW WE USE THE INFORMATION WE OBTAIN
We, or service providers acting on our behalf, may use the information collected from and about you to:
Provide our products and services, including authorizing a purchase, or completing a transaction that you requested;
Create and manage online accounts;
Send promotional materials, alerts regarding available offers and other communications, including text/SMS messages if you provided your mobile number and opted into receive such messages (for information on our text messaging program, please see our Text/SMS Messaging Program Terms;
- Communicate about, and administer participation in, special events, promotions, programs, offers, surveys, contests and market research;
- Respond to inquiries from you and other third-parties, including inquiries from law enforcement agencies;
- Anonymize or de-identify personal information to provide third parties with aggregated data reports showing anonymized information and other non-personal information;
- Provide technical support;
- Generate suggestions about the type of content you may enjoy;
- Supplement your personal information collected directly from you and/or from automated means with additional information from publicly and commercially available sources, and/or information from Company affiliates and our business partners;
- Associate your browser and/or device with other browsers or devices you use for the purpose of providing relevant and easier access to content and other operational/business purposes;
- Operate, evaluate and improve our business (including developing, enhancing, analyzing and improving our Services; managing our communications; reviewing and processing employment applications, performing data and statistical analytics; and performing accounting, auditing and other internal functions);
- Protect against, identify and prevent fraud and other unlawful activity, claims and other liabilities;
- Comply with and enforce applicable legal requirements, relevant industry standards, contractual obligations and our terms of service and other policies; and
- In other ways for which we provide specific notice at the time of collection.
As described in this Privacy Notice and/or our Cookie Notice, we, as well as our third-party service providers, may obtain information about your online activities to provide you with advertising about products and services tailored to your individual interests. We and our third party service providers also may obtain information for this purpose from third party websites and apps. We engage third-party advertising networks to help us target our messaging to visitors through interest-based and contextual means.
Through these ad networks, we can track your online activities (such as your visits to websites and your use of apps that serve our advertisements, including the pages or ads your view and actions you take on those sites or apps) over time and across third-party websites and apps by obtaining information through automated means, as described above. This data collection takes place both on our sites, apps and emails and on third-party websites and apps that participate in these ad networks. The networks use this information to show you advertisements on our Services or other third-party websites and apps that may be tailored to your individual interests. This information also helps us track the effectiveness of our marketing efforts. To the extent required by applicable law, we will obtain your consent before using your information for interest-based advertising.
The section below entitled Your Choices and Rights provides details on and explains how to exercise your choices regarding interest-based advertising.
By electing to submit your mobile phone number, you consent to receive text message alerts from the Company containing product/service and event information or promotions that may be sent using automated dialing systems (“Text Messages”). Your consent to receive Text Messages is not otherwise required to purchase any goods or services from us. You may not consent to receive Text Messages on behalf of someone else or provide someone else’s phone number. You agree to enter into, sign and receive your consent to receive Text Messages electronically.
The number of recurring Text Messages you receive per month may vary based upon the Service you have subscribed to. We do not charge a fee for you to receive Text Messages from us, however, your mobile service provider may charge you for sending and/or receiving text messages and air-time, as well as any other standard applicable rates charged by your mobile service provider.
To receive help with Text Messages or any related issues, such as our participating carriers, contact us as outlined in the How to Contact Us Section below.
You may unsubscribe from receiving our Text Messages by contacting us as outlined in the How To Contact Us Section below or by replying “STOP” to any Text Message received in connection with such subscription.
4. INFORMATION WE SHARE
We share your personal data with:
- Our subsidiaries and affiliated businesses. We share the collected personal information as described in this notice with our subsidiaries and affiliated businesses within the Company, each of which use your personal information consistent with this Privacy Notice. Those businesses may also use your personal information for each of their own purposes, including marketing purposes.
- With our Service Providers. We share some or all of your personal data identified above, as necessary for the specific services, with our service who perform services on our behalf.
- With our Clients or Business Partners. Where permitted by law, with our third party clients or business partners, such as companies offering products or services of interest to our customers, advertising partners and other third parties for those third parties’ own commercial or marketing purposes, such as to serve targeted advertisements.
- For Legal Requirements and Proceedings. We may disclose your personal data to law enforcement authorities or other government officials if we are required to do so to comply with subpoenas, court orders, legal process or other law enforcement or other government measures, and to comply with other legal obligations. We may also disclose information if we believe disclosure is necessary or appropriate in connection with an investigation of suspected or actual fraudulent or illegal activity. In each such case, we will only share the personal data requested and otherwise necessary.
- To Protect our Services and Users. We may disclose your personal data to protect and defend the rights, interests and safety of the Services, our subsidiaries and affiliates, and their employees, contractors and agents; to protect the security and safety of our users of the Services, including when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss.
- For Business Transfers. In the event of a proposed or completed sale or transfer of all or a portion of our business or assets (including in the event of a reorganization, dissolution or liquidation), we may share any or all of the personal data we collected or obtained of you with the acquiring business.
- Non-personal Information. When the information collected from or about you is not defined as personal information under applicable law, we may share such non-personal, de-identified information or aggregated information with third parties at our discretion.
5. YOUR CHOICES AND RIGHTS
We offer you certain choices and you also may have certain rights in connection with the personal information we collect about you.
A. YOUR CHOICES
To ask us to remove your information from our marketing mailing lists, please contact us as outlined in the HOW TO CONTACT US Section below. You also can unsubscribe from our marketing mailing lists by following the “Unsubscribe” link in our emails. Even if you unsubscribe from our marketing communications, we may still need to send you communications relating to your use of the Company websites, such as service announcements where you are using our Service.
You also have choices about whether cookies and other similar technologies are placed on your computer or mobile device. For more information, visit our Cookie Notice.
We may use third-party analytics services on our Services, such as Google Analytics. The analytics providers that administer these services use technologies such as cookies, web beacons and similar technologies to help us analyze your use of the Services, as further described in our Cookie Notice. To learn more about how to opt out of Google Analytics services, please visit the link below:
• Google Analytics: https://tools.google.com/dlpage/gaoptout
We and our third party service providers also may obtain information for this purpose from third-party websites or apps. To learn more about how to opt out of ad network interest-based advertising, please see the How to Manage Your Cookies section of our Cookie Notice or visit the customer opt-out pages at http://www.aboutads.info/choices/ and http://www.networkadvertising.org/choices/.
B. YOUR RIGHTS
Subject to applicable law, you may have certain rights to access, review, update, correct inaccuracies in, and/or port your personal data in our custody and control by submitting a request through our Data Subject Request Portal. For security purposes, we will verify your identity when you request to exercise your data privacy rights. For certain types of requests, we may also need to ask you for additional information to verify your identity.
Once we have verified your identity (and your agent, as applicable), we will respond to your request as appropriate.
The right to access and rectification or correction. You may have the right to access, correct and update your personal data at any time. Additionally, if you have an account with us, you may access certain of your information (including your preferences) through that account and update or correct it.
The right to deletion. Under certain circumstances, you may have the right to request that we delete your data. If you wish to delete the personal data we hold about you, please let us know and we will take reasonable steps to respond to your request in accordance with applicable legal requirements. If the personal data is no longer needed for any purposes that justify its retention and we are no required by law to retain it, we will do what we can to delete, destroy or permanently de-identify it. Certain data may be exempt from such requests under applicable law. We may need certain types of data so that we can provide our Services to you. If you ask us to delete it, you may no longer be able to access or use our Services.
The right to data portability. Under applicable laws, in addition to the general right of access described above, you may have, subject to certain exceptions, the right to (i) receive a copy of your personal data in a structured, commonly used and machine-readable format, (ii) transmit the data to another business or data controller, and (iii) depending on the circumstances, have us perform that transmission.
C. CALIFORNIA PRIVACY RIGHTS
For additional information for residents of the State of California click here.
D. CO, CT, VA & UT PRIVACY RIGHTS
For additional information for residents of the States of Colorado, Connecticut and Utah and the Commonwealth of Virginia, click here.
E. CANADIAN PRIVACY RIGHTS
For additional information for residents of Canada, click here.
6. HOW WE PROTECT PERSONAL DATA
We maintain administrative, technical and physical safeguards designed to protect the personal data we have about you against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. However, no data transmission or storage, or use of the Internet, can be guaranteed to be 100% secure.
7. TRANSFERS OF PERSONAL DATA
The Services are hosted in and managed from Canada and the United States. We may transfer the personal data we collect about you to another country, which may not be deemed to have the same data protection laws as the country in which you initially provided the data. Applicable laws in the United States and/or other countries may allow the courts, law enforcement and national security authorities to access your personal data when in such country.
If you are a user located outside of Canada and the United States or the country to which your information may be transferred, you understand (and, as permitted under applicable law, consent to) having any personal data processed in the United States and/or such country. When we transfer your information, we will protect that information as described in this Privacy Notice.
8. LINKS TO THIRD-PARTY SITES, APPS AND SERVICES
For your convenience and information, our Services may provide links to third-party sites, apps and services that may be operated by companies not affiliated with Company. These companies may have their own privacy notices or policies, which we strongly suggest you review. We are not responsible for the privacy practices of any non-Company sites, apps or services.
9. CHANGES TO OUR PRIVACY NOTICE
From time to time, we may change our Privacy Notice to reflect changes to our privacy practices and Services. If we modify the Privacy Notice, we will update the “Last Modified Date” and the changes will be effective as of the date we post such Notice. For material changes, we will notify you by posting a prominent notice on our Services indicating at the top of the Privacy Notice when it was most recently updated.
10. HOW TO CONTACT US
If you have any questions or comments about this Privacy Notice or the manner in which we or our service providers treat your personal information, would like to exercise your choices, or would like us to update information we have about you or your preferences, please contact us as follows:
By email: [email protected]
You also may write to:
Legal Department / Global Compliance and Data Privacy Attorney
New York, NY 10007
Canadian residents may also contact our Privacy Officer at:
HarperCollins Canada Limited
Internet Development Group
Bay Adelaide Centre, East Tower
22 Adelaide St. W, 41st Floor
Toronto, Ontario M5H 4E3
Tel. No.: 1-844-327-5757
e-mail: [email protected]