The London Review of Books (LRB) has created this statement to demonstrate our commitment to your privacy, to explain how we collect information and to explain how we use the information we collect about our web site users.
If you have any questions about this privacy statement, please address them to privacy@lrb.co.uk
Scope
This privacy statement refers to the London Review of Books Ltd, which encompasses all its brands and entities, a full list of which can be found below.
This statement is subject to change at any time. The way we use any information will be subject to the privacy statement that is current when that information is gathered. Please check this page regularly to see any changes.
London Review of Books Brands and Entities
The London Review of Books magazine
The London Review of Books Bookshop
The London Review of Books Café
The London Review of Books podcast
The London Review of Books events
www.lrbstore.co.uk
www.lrb.co.uk
www.londonreviewbookshop.co.uk
www.londonreviewbookbox.co.uk
Controller
LRB LIMITED (Company number 01485413) registered address 28-30 Little Russell Street, London, WC1A 2HN, is the controller and responsible for your personal data (collectively referred to as "LRB", "we", "us" or "our" in this privacy statement).
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy statement. If you have any questions about this privacy statement, including any requests to exercise your legal rights please contact the data privacy manager using the details set out below.
Contact details
If you have any questions about this privacy statement or our privacy practices, please contact our data privacy manager in the following ways:
Full name of legal entity: LRB LIMITED
Email address: privacy@lrb.co.uk.
Changes to the privacy statement and your duty to inform us of changes
We keep our privacy statement under regular review. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
This website may 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 statement of every website you visit.
The data we collect about you
The term ‘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 of the original data subject has been removed or from which an individual data subject cannot be accurately identified (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account and payment card details. This information is not required by us as the transactional provider will deal with Financial Data.
- 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.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services.
- 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 for any purpose. Aggregated Data of this kind is anonymous data, as described above. 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 statement.
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 fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel an order for a product or service you have requested from us, but we will notify you if this is the case at the time.
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 post, phone, email or otherwise. This includes personal data you provide if you:
- create an account on our website;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us feedback or contact us.
- Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie statement for further details. For information on cookies used on London Review Bookshop please refer to our Bookshop Cookie Statement.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- DSB – our subscription bureau
- EventBrite – our ticketing partner
- Campaign Monitor – our email service provider
- Dotdigital - our email service provider
- Amazon – our app partner
- ACast – our Podcast service provider
- Vimeo – our video service provider
- YouTube – our video platform provider
- Google – our website performance and advertising partner
- Airship – our mobile messaging partner
- Sub(X) – AI Subscription and Paywall Marketing Platform Provider
- PugPig – our app developer
- Technical Data from the following parties:
- analytics providers such as Google Analytics and Cabin
- search information providers such as Google
- advertising networks such as Google AdWords
- website tracking from Dotdigital
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as:
- PayPal
- Stripe
- Identity and Contact Data from publicly available sources such as Companies House.
How we use your personal data
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:
- 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.
- Where we need to comply with a legal or regulatory obligation.
- Where we need to do so in order to perform a contract we have entered into with you;
Generally, we do not rely on consent as a legal basis for processing your personal data although we will obtain your consent before sending marketing messages from ourselves, via the use of Data Protection Statements. You have the right to withdraw consent to marketing at any time by clicking on the unsubscribe links provided in the relevant communication or by contacting us using the following email address privacy@lrb.co.uk.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use 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.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
To register you as a new user | (a) Identity (b) Contact | Performance of a contract with you |
To enable us to perform our contractual obligations. | (a) Identity (b) Contact (c) Financial (d)Marketing and Communications | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) (d) consent - Data Protection Statement is shown at the point of purchase |
To manage our relationship with you which will include but not be limited to: (a) Notifying you about changes to our terms or privacy statement (b) Asking you to leave a review or take a survey (c) processing and delivery of your magazine subscription | (a) Identity (b) Contact (c) Profile (d) Marketing and Communications | (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) (d) consent - Data Protection Statement is shown at the point of purchase |
To administer and protect our business and websites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact (c) Technical | (a, c) 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) (b) Necessary to comply with a legal obligation |
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | (a) Identity (b) Contact (c) Profile (d) Usage (e) Technical (f) Marketing and Communications | 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) (d) consent - Data Protection Statement is shown at the point of purchase |
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) |
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) |
To send marketing communications to our existing customers and subscribers | (a) Marketing and Communications | Consent, only those customers who have requested and accepted our data protection statement appear on these lists. |
Web behaviour tracking to inform segmentation within dotdigital to allow better targeting of content and email marketing messages | (a) Identity (b) Profile | Consent via the OneTrust cookie consent platform |
Content generated by our users / readers or the public | (a) Identity (b) Contact (c) Financial | Necessary for our legitimate interests to provide additional content for our editorial endeavours |
Letters to the editorial team | (a) Identity (b) Contact | Necessary for our legitimate interests to provide additional content for our editorial endeavours |
Renewal / reactivation direct mail | (a) Identity (b) Contact | Necessary for our legitimate interests to provide our customers with retention offers |
Email newsletter data | (a) Identity (b) Contact | Consent, only those customers who have requested and accepted our data protection statement appear on these lists. |
Email marketing messages (retention or acquisition or winback) | (a) Identity (b) Contact | Consent, only those customers who have requested and accepted our data protection statement appear on these lists. |
Letters to the Customer Service team | (a) Identity (b) Contact | Necessary for our legitimate interests to provide customer service to our customers |
Marketing
We may use your personal data to form a view on which products and/or services we think you may want or need, or which may be of interest to you. This is how we decide which services and offers may be relevant for you in marketing communications.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established a privacy centre where you can view and make certain decisions about your personal data use, see the following personal data control mechanisms.
Opting out
You can ask us to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time.
You may also contact us or the third party directly if you do not wish to receive any marketing materials from us or them.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see here. For information on cookies used on London Review Bookshop please refer to our Bookshop Cookie Statement.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to receive an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at privacy@lrb.co.uk.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table above.
- Our Brands and Entities as set out in the ‘Scope’ paragraph above.
- External Third Parties as set out in the Glossary below.
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.
International transfers
Many of our external third parties are based outside the jurisdiction (the UK) so their processing of your personal data will involve a transfer of data outside the jurisdiction.
Whenever we transfer your personal data out of the jurisdiction, we ensure a similar degree of protection is afforded to it by only transferring your personal data to countries that have been deemed to provide an adequate level of protection for personal data or by having in place a data transfer agreement with the third party which obliges them to afford a similar degree of protection to it as is required in the UK
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the jurisdiction.
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.
Data retention
How long will you use my personal data for?
We will only 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 for the following reasons: in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you; or for the purposes of understanding customer behaviour over time.
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.
In some circumstances you may ask us to delete your data: see below for further information.
In some circumstances we will 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 data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us using the email address privacy@lrb.co.uk.
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.
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 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.
Complaints to the ICO
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance privacy@lrb.co.uk.
Glossary
Lawful basis
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us privacy@lrb.co.uk.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Third parties
External Third Parties
- Service providers acting as processors based in jurisdictions including the UK, US and Germany who provide IT and system administration services.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK and US who provide services such as consultancy, banking, legal, insurance and accounting services.
- regulators and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances.
Your rights
Request access 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. It is not a right that allows you to request personal data about other people, or a right to request specific documents from us that do not relate to your personal data. You can exercise this right at any time by writing to us by contacting us and telling us that you are making a subject access request. You do not have to fill in a specific form to make this kind of request.
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. 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:
- 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.
- 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 withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
How we collect and use information
We collect Device Information using the following technologies:
- “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
- “Log files” track actions occurring on the LRB Websites (Sites) see Scope above, and collect data including your IP address, browser type, internet service provider, referring/exit pages, and date/time stamps.
- “Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the Site.
Cookies
Cookies are short strings of text sent to your browser and stored by your computer. Most commercial web sites use cookies. We use cookies to remember your preferences and to reference information about the time and extent of your use of the Sites and LRB app (App). We use this information for purposes of system administration and to track potential abuse of our terms and conditions of use. We also use this information in an aggregated form for purposes of marketing and as information to potential advertisers and subscribers. We do not use this information in any way that is personally identifying.
We also use cookies for authentication and to remember the logged-in status of registered users and subscribers who use our extended subscriber services.
In order to gain consent for the use of Cookies we provide you with the means to set your Cookie Preferences. This is accomplished by the means of an overlay the first time you enter the Site. You can select the cookies you agree to being processed. If you choose to reject all cookies except Essential (Strictly Necessary) Cookies you will still be able to use the Sites and App, but functionality may be reduced, and subscribers may be unable to use our extended subscriber services or view subscriber-only content.
We may associate information referenced by cookies with personal information which you provide to us online. We will not disclose your personal information to third parties except in the following cases:
(1) When it is necessary to provide you with a service you have requested.
(2) If you are resident in the US or Canada, we may share personal data with 3rd party marketing companies for commercial use. If you wish to opt out of data being shared with 3rd parties, you can email us at privacy@lrb.co.uk.
(3) Under circumstances required by law: when we believe in good faith that a law or legal process requires it or where we believe disclosure is necessary to protect or enforce our rights, the rights of our contributors whose copyright material is under our control, or the rights of other users of the LRB Website and App whose personal information is under our control.
For further information about our use and the types of cookies we use please refer to our full Cookie Statement. For information on cookies used on London Review Bookshop please refer to our Bookshop Cookie Statement.
Sharing your personal information
We share your Personal Information with third parties to help us use your Personal Information, as described above. For example, we use Shopify to power our online store--you can read more about how Shopify uses your Personal Information here. We also use Google Analytics to help us understand how our customers use the Site -- you can read more about how Google uses your Personal Information here. You can also opt-out of Google Analytics here.
This site also uses Facebook Pixel, a third-party cookie that collects and shares customers’ browsing behaviour on your online store.
We may remarket your information. Remarketing is a way for us to connect with users, based upon your past interactions with the LRB Website and App. Third-party marketing vendors may be hired by the LRB to perform remarketing services. As a result, third-party vendors, including Google, may show LRB ads on sites on the internet. Third-party vendors, including Google, use cookies to serve ads based on a user’s prior visits to the LRB Website and App.
To opt out of customized Google Display Network ads click here. To find out more about how Google uses any data it collects please visit this page.
Any information collected is used only for remarketing purposes and will not be used by them for any other purpose.
Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.
IP address
Your IP address is a numeric code which is assigned to your computer every time you connect to the internet. Typically for home users it will not identify your computer exactly but will identify the service provider via whom you connect to the internet. We use aggregated IP address information to compile reports on the demographics of the usage of the LRB Website and App for purposes of system administration, marketing, as information to potential advertisers and subscribers, and to track potential abuse of our terms and conditions of use. We do not use IP address information in a form that is personally identifiable except where the users of that IP address have been responsible for violation of our terms and conditions of use.
We do IP address information in the form of Web Behaviour Tracking which uses code running in your web browser to provide us with information about the pages you are viewing and activities you are undertaking on the Site and App. This data will in many cases become linked to your email address and can then be used to:
- segment users into groups in order to target marketing messages
- personalise messages sent to users on the basis of their individual activity data
- analyse site usage
- see the activity of an individual user, for example to troubleshoot a technical support issue
Research
To enable us to improve our products and services for your benefit we may, providing we have your permission, contact you to ask if you wish to participate in our customer research programme. This may include an invite to join website usability testing which helps us to find ways to improve our website. You will always have the option to ignore the request or to decline.
Newsletter and information sign up
If you sign up for any newsletter, we might offer on the LRB Website and App we will hold your e-mail address securely in a list. We will make sure that each newsletter carries information about how to opt out of the list and how to remove your name from the list so that you will be able to choose to stop receiving the newsletter at any time if you so wish.
Advertisers and commercial associates
The LRB Website and App contains advertisements and promotional links to web sites operated by third parties. While we would never knowingly link to a site which we believed to be trading in bad faith, the LRB is not responsible for the content of these web sites and we take no responsibility for the content, privacy practices, goods or services offered by these sites. Specific provisions in the LRB Website and App’s terms and conditions of use apply to the content of all advertisements and access to all promotional linked web sites.
BEHAVIOURAL ADVERTISING
As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
You can opt out of targeted advertising by using the links below:
Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info
Accepting this privacy statement
By using the LRB Websites and App you signify your acceptance of this privacy statement and our terms and conditions of use. If you do not agree, or are not comfortable with anything in this statement, your only remedy is to not use the LRBWebsite and App. If you are concerned about any cookies which have already been issued to you by the LRB Website and App, you can delete cookies served to your browser by the servers at “lrb.co.uk”, “www.lrb.co.uk”, “lrbshop.co.uk”, https://www.londonreviewbookshop.co.uk/ and www.lrbshop.co.uk.
If this privacy statement is not accepted in full, use of the LRB Website and App must be terminated immediately.