Privacy policy
Introduction
Welcome to Scholastic UK Limited's (collectively referred to as "we", "us" or "our") Privacy Policy.
We respect your privacy and are committed to protecting your personal data. This Privacy Policy will inform you as to how we look after your personal data when we provide our various services to you (our “Services”) and/or when you visit www.scholastic.co.uk (our “Website”) (regardless of where you visit it from) and tell you about your privacy rights and how the law in the United Kingdom protects you.
1. IMPORTANT INFORMATION AND WHO WE ARE
Purpose of this Privacy Policy
This Privacy Policy aims to give you information on how we collect and process your personal data through our provision of our Services to you and your use of our Website, including any data you may provide when you register or make an enquiry in order to be able to purchase our Services.
If children or young people under the age of 18 use our Website including for Clubs Kids, We are Writers, Mary Glasgow Magazines or Horrible Histories we recommend they do so under the supervision of a responsible adult. Where we obtain the consent of children aged under 13 to process their data in any way, for example to join our Clubs Kids site, we will confirm this with their parent/guardian first before carrying out any processing.
For Scholastic Reading Pro we may collect data about children and young people, specifically their name, school, school year, class name, reading standard and reading preferences. Where we do collect data relating to children and young people we will endeavour to provide them with clear and user-friendly information about what data we are collecting about them, why we need that data and what we use that data for. We will also confirm consent through the child’s school before processing.
It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so you are fully aware of how and why we are using your data. This Privacy Policy supplements the other notices and is not intended to override them.
Controller
We are the controller and responsible for your personal data.
Human Resources are responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please use the contact details as set out below.
Contact details
Our full details are:
Full name of legal entity: Scholastic UK Limited
Title: Group Human Resources Manager
Email address: privacy@scholastic.co.uk
Postal address: Scholastic UK Limited, Westfield Road, Southam, Warwickshire, CV47 0RA
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority 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 using the details above.
Changes to the Privacy Policy and your duty to inform us of changes
This version was last updated on 24th October 2018 to reflect the changes made to the data protection law in the UK which came into effect on 25 May 2018.
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
Our 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 notice or privacy policy of every website you visit.
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you collected through our website or services which we provide, which we have grouped together as follows:
- Identity Data includes first name, last name, username, pseudonym or similar identifier, title, date of birth, gender, job title, student number, study dates and the school you go to, your child goes to or you work at.
- Contact Data includes correspondence address, billing address, shipping address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of the services you have purchased from us.
- 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 our 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 and our 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 may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you 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 services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
3. 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, by corresponding with us by post, phone, email or otherwise or through the use of our Services. This includes
- personal data you provide when you:
- apply for and/or use our Services;
- register an account on our Website;
- purchase one of our service or publications;
- request marketing to be sent to you;
- send us fan mail to forward to our Authors;
- make an enquiry to our customer services support;
- enter a competition, promotion or survey; or
- give us some feedback.
Automated technologies or interactions. As you interact with our Website and/or our Services, we may 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. Please see our Cookie Policy [www.scholastic.co.uk/cookies] for further details.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from the following parties:
(a) Analytics providers such as Google based outside the EU and Hotjar based inside the EU.
(b) Advertising networks such as Facebook based outside the EU, Google based outside the EU, VE Interactive based inside the EU.
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Sage based inside the EU.
- Contact, Subscriber and Transaction Data from Independent Education Sales Consultants
- Identity and Contact Data from data brokers or aggregators such as The Education Company based inside the EU and Mary Glasgow Magazine agents based both inside and outside the EU.
- Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.
4. 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 we need to perform the contract we are about to enter into or have entered into with you.
- 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.
Generally we do not rely on consent as a lawful basis for processing your personal data other than in relation to sending marketing communications to you via email or text message which may include marketing on behalf of our carefully selected partners. You have the right to withdraw consent to marketing at any time by contacting us using the details provided above.
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 lawful 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 basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific lawful basis we are relying on to process your personal data where more than one basis has been set out in the table below.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
| To respond to any enquiries you have made to us | (a) Identity
(b) Contact |
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to provide good customer service to prospective clients and users of our website) |
| To register you as a new client and/or enrol you in any particular groups that we run via the Website and/or our Services | (a) Identity
(b) Contact |
Performance of a contract with you |
| To process and deliver the Services you have ordered including:
(a) Manage payments, fees and charges (b) Collect and recover money owed to us (c) Create print-on demand content (d) Complete online assessments |
(a) Identity
(b) Contact (c) Financial (d) Profile (e) Transaction (f) Marketing and Communications |
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us) |
| To manage our relationship with you which will include:
(a) Notifying you about changes to our Terms and Conditions or Privacy Policy (b) Asking you to leave a review or take a survey |
(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 clients use our services) |
| To enable you to partake in a prize draw, promotion, competition or complete a survey | (a) Identity
(b) Contact (c) Profile (d) Usage (e) Marketing and Communications |
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how clients use our products/services, to develop them and grow our business) |
| To provide remote technical support to you in the event that you are unable to use our Services | (a) Identity
(b) Contact (c) Profile |
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to provide our clients with a good level of customer service) |
| To administer and protect our business and Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity
(b) Contact (c) Technical |
(a) 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, email newsletters and advertisements to you and measure or understand the effectiveness of the advertising we serve to you. Content to include updates and corrections to our printed products | (a) Identity
(b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical |
Necessary for our legitimate interests (to study how clients use our Services, to customise and develop them, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve our Website, products/services, marketing, client relationships and experiences | (a) Technical
(b) Usage (c) Profile |
Necessary for our legitimate interests (to define types of clients 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 enable you to submit contributions and content to us and/or the Website and to moderate that content where appropriate | (a) Identity
(b) Contact (c) Profile |
Necessary for our legitimate interests (to enable us to receive feedback from you on our Services and for you to be able to interact with us and other users of our Website and/or our Services) |
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which books, Services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased Services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party company for their marketing purposes. Should you consent to this sharing of your personal data you will need to contact each third party company directly should you later wish to opt out of such marketing.
Opting out
You can ask us to stop sending you marketing messages at any time by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, warranty registration, service experience or other transactions.
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 our Cookie Policy.
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 require an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the lawful basis which allows us to do so.
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.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table above.
- Other companies in the Scholastic Group acting as joint controllers or processors and who are based within the EEA and the rest of the world, and provide IT and system administration services and undertake leadership reporting.
- Service providers who provide IT, remote support, software development, software testing, technical support, online database services, system administration services and mailing delivery support, such as ADM, JEM Education Direct, UPS and Campaign Monitor.
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services,
- Sponsors, partners and distributors who work with us to enable us to deliver our Services to you such as Happy Monkey Drinks, Merlin Entertainments, Travelling Books, Mary Glasgow Magazine agents and Education Sales Consultants.
- HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.
- Market researchers, who may carry out research and provide and share information in relation to publishing, education and sales on our behalf.
- Affiliate Partners and advertisers through Awin, such as easyfundraising.co.uk and moneysavingexpert.com
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.
- We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. INTERNATIONAL TRANSFERS
Due to the nature of the services we provide to you, some of our external third parties as well as our Scholastic International team are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we will only do so either:
- obtaining your prior written and explicit consent to such transfer;
- where the transfer is necessary in order for the performance of a contract between you and us (for example, to provide you with remote technical support from our support teams based outside the EEA in relation to your use of our Services);
- ensure a similar degree of protection is afforded to it by either:
- transferring your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; and/or
- using specific contracts approved by the European Commission which give personal data the same protection it has in
7. 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.
8. DATA RETENTION
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances you can ask us to delete your data: see the “Request Erasure” section of Your Legal Rights below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data to:
- Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. 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 basis as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is seen as necessary but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you 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.
If you wish to exercise any of the rights set out above, please contact us.
Fees
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10. 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.
- 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 or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
