This version was last updated on 24th May 2018.
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The OmniScriptum Group respects your privacy and is committed to protecting your personal data.
Our Site, products and services are not intended for children and we do not knowingly collect data relating to children.
Important information and who we are
Fromm Verlag is a brand of OmniScriptum
Our full details are:
Full name of legal entity: OmniScriptum S.R.L.
Title of data privacy manager: Data Protection Representative
Email address: email@example.com
Str. Armeneasca 28/1, office 1
Republic of Moldova
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.
The data we collect about you
We may collect, use, store and transfer (please note that the transfer happens only insofar as it is necessary to ensure the conditions of your publishing agreement and fulfill any orders received from you) different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, last name, username or similar identifier and title.
- Contact Data includes billing address, email address and telephone numbers.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us including the type of card used for a particular transaction (but not any other card details).
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location.
- Profile Data includes your username and password in encrypted form (unretrievable for us), purchases or orders made by you, preferences, feedback and survey responses.
- Usage Data includes information about how you use our Site, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
- Content Data includes any content which you upload onto the Site such as comments and other text or images that contain personal data.
How is your personal data collected?
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Direct interactions. You may give us your Identity and Contact by filling in forms or by corresponding with us by post, phone, email, online or otherwise. This includes personal data you provide when you:
- apply for our products or services; complete a form on our Site requesting us to contact you; create an account on our Site; subscribe to our service or publications; request marketing to be sent to you; enter a competition, promotion or survey; or give us some feedback.
- Data you upload onto our Site. You may upload Content Data (like, e.g. that of your manuscript) on our Site when you use our services.
- Automated technologies or interactions. As you interact with our Site, we may automatically collect Technical Data about your equipment and Usage Data about your 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. Please see section 5 below (“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:
- Contact and Transaction Data from providers of payment services.
- Identity, Profile and Contact Data from publicly available sources such as your educational institution or social networks
- Identity, Profile and Contact Data from data providers who obtain such data from publicly available sources.
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 (e.g. when we need to list your title to be sold internationally with book wholesalers) and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
You have the right to withdraw consent to marketing at any time by contacting us.
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 mo1re than one ground has been set out in the table below.
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new customer/user
(a) Performance of a contract with you (where you are using the Site as an individual)
(b) Necessary for our legitimate interests (where you are using the Site as an author, in order for us to perform our contract with you, to optimise your onboarding and user experience by ensuring you receive relevant instructions and tutorials regarding the use of our Site, products and service)
To process and deliver orders for our products and services including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us and verify you are entitled to any discount we offer)
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(c) Dealing with your enquiries and complaints
(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 Site, products and services)
To administer and protect our business and this Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Performance of a contract with you (e.g. to ensure you always have access to your account on our website)
(b) 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 use data analytics to improve our Site, products and services, marketing, customer relationships and experiences
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Site updated and relevant, to develop our business and our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you
Necessary for our legitimate interests (to develop our products/services and grow our business)
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
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 products, services and offers may be relevant for you.
You will receive marketing communications from us if you have requested information from us or purchased products or 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.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. You can also opt-out from the my account page on our Site.
The types of cookies we use on our Site are:
- Strictly Necessary Cookies. We use Strictly Necessary Cookies to operate our Site. These cookies are essential to enable you to move around the Site, use its features and to log into secure areas of the Site.
- Functionality Cookies. We use Functionality Cookies to recognise you when you return to our Site. This enables us to personalise our content for you, greet you by name and remember your preferences and various settings on our Site
- Analytical/Performance Cookies. These cookies collect information about how many people are using our Site and how they are moving around it when they are using it. For example, the pages visited most often, how people are moving from one link to another, and if they get error messages from certain pages. This helps us to improve the way our Site works, for example, by ensuring that users are finding what they are looking for easily.
Please contact us if you want further information on the specific cookies used by us.
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 in paragraph 4 above.
- Service providers who provide IT and system administration services.
- Other companies within the OmniScriptum Group carrying out services for us in terms of customer relations, support, sales and accounting
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- Third parties if we are required to do so by law, or if we believe that such action is necessary to: (a) fulfil a government, or regulatory authority request; (b) conform with the requirements of the law or legal process; (c) protect or defend our legal rights or property, our Site or customers.
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.
Our third party service providers may be 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 ensure a similar degree of protection is afforded to it. We only transfer your personal data to ensure the fulfillment of our obligations as your Publisher according to our contract, and we do so taking into account the assessment of European Commission regarding an adequate level of protection for personal data in third party countries.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
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.
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, contractual, 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.
You can request further details of retention periods for different aspects of your personal data by contacting us.
In some circumstances you can ask us to delete your data: see “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
Your legal rights
Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:
- 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). 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.
- 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 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 (c) 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.
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 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.