Privacy and Cookie Policy for Book Pass by Jellybooks
Last updated: November 2023
1. INTRODUCTION
Who are we?
We are Jellybooks Ltd, a private company incorporated and registered in England & Wales with company number 07503460 whose registered office is at 19 Villa Road, Ground Floor, London, SW9 7ND. Our affiliates include Cloud Reading Technologies ltd and Augmented Reading technologies Ltd. Where we decide the means or purpose of processing your personal data, we are the data "controller."
What’s this policy about?
This policy explains how we process your personal data as a data controller. Other businesses & websites have separate policies. We update this policy from time to time so please check back in.
Our platform, specifically our Book Pass by Jellybooks service offer ebooks and/or audiobooks, as samples or full-length books, to pupils who can choose to remain anonymous readers and listeners.
Where required by law, we will also share data with government bodies who fund us or with institutions and enforcement agencies who have a legal and legitimate right to request data from us.
How do you contact us? (if you have questions about this policy or to exercise your rights)
Write to us at: [email protected] or, if your matter is more series, to [email protected] or for a representative within the EU contact us at [email protected].
If we can’t resolve your issue, you can also get in touch with the Information Commissioner’s Office at: https://ico.org.uk/concerns or if you live outside the UK in a European country, you can submit a complaint to the supervisory authority in your country.
What are your rights?
You have the following rights, although these rights may be limited in some circumstances:
- Ask us to restrict, stop processing, or delete your account via [email protected]
Object to our processing of your data by deleting If we rely on consent to process data, or send direct marketing, you can withdraw consent by email to the address above.
2. Your Personal Data and How We Use It
2.1 Readers
Readers (“Readers”) are private individuals reading for pleasure, education or training, or professionals, including but not limited to authors, literary agents, bloggers, reviewers, journalists, editors and staff working in book shops, for publishers or companies otherwise involved in the book trade.
2.1.1 Unregistered (anonymous) Readers
Type of data and information we collect
- Type of device and browser used
- Referring source
- Date, time and length of reading session
- Types of content accessed
How we use it and the legal basis
We collect this information to provide you with our services in accordance with our terms and conditions when you read any ebook or audiobook sample, excerpt or snippet or full-length ebook provided to you for free without registration (open access books) through the Jellybooks Cloud Reader. Our legal basis is entering or performing contracts with you.
How long we keep it
Any personal data we hold for you, except for email correspondence, is deleted in accordance with our rules under 2.1.2. Any email correspondence we hold is deleted within six months.
Any data not linked to personally identifiable information is retained in accordance with our general data retention policy for reading and service engagement data.
More information
The use of the Jellybooks Cloud Reader is governed by our terms of service at https://www.jellybooks.com/book-pass/legal/tos which include the collection of reading data. To opt out of any reading data being collected, stored locally on your device and transmitted to Jellybooks, you need to activate the “deactivate data collection” button located in each ebook, which is linked to from each book’s table of contents (TOC), and can be accessed from the upper left corner of the Jellybooks Cloud Reader (if not visible click on the three dots in the upper right hand corner of the Jellybooks Cloud reader).
Sources
We collect this information from you when you interact anonymously with the Jellybooks Cloud Reader via one of our Jellybooks websites or a third party website.
Recipients
Jellybooks uses this data to optimise its services and shares the data in aggregate and anonymised form with Partners, Clients and Sponsors. Data is also shared in aggregated and anonymised form with government and media institutions where required under the terms and conditions of our sponsors or a government grant.
2.1.2 Registered Readers
Type of data and information we collect
- Email address
- school affiliation, if provided
How we use it and the legal basis
We collect this information to provide you with our services in accordance with our terms and conditions when you register for our services. Our legal basis is entering or performing contracts with you.
How long we keep it
We store your reading data until you deactivate your account via the Jellybooks settings menu. Data (and accounts) cannot be restored once the “delete account” button has been clicked and confirmed (“double confirmation”). After you delete your account, some information about your reading may be preserved, but in ways that ensure that your data is anonymised and therefore can no longer linked to you.
More information
You can view and amend this data via “My Settings” https://www.jellybooks.com/account
If you believe you have been spoofed and that your account was created without your authorisation by a third party, then send us an email forwarding (or replying to) the registration confirmation email you received. It is important your email is sent form the same email address that was used during the registration process.
You may contact us via email at [email protected], if you are unable to delete the account yourself (for example the owner is deceased). Please include suitable evidence (power of attorney, death certificate, etc.), as appropriate.
Sources
We collect this information from you when you sign up via the Jellybooks website. If you use our social media log-in options (at the time of writing, Facebook, Instagram and Twitter), then your first name, last name and email address will be provided to us by the social media service.
Recipients
This data is used for Jellybooks internal purposes. Demographic data (gender, age and location) is shared in aggregated and anonymised form with Sponsors.
2.1.3 Recipients of Newsletter for Readers Teachers and Adminstrators
Type of data and information we collect
- First and last name
- Email address
- Email delivery, open and click information
- School affiliation
How we use it and the legal basis
We collect this information to allow you to subscribe to receive information and updates from us by email about our services, where you have given your consent. Our legal basis is consent.
How long we keep it
Until the date you unsubscribe from our reader newsletter.
More information
You can unsubscribe from our newsletter at any time by clicking on the unsubscribe button at the bottom of each newsletter.
Sources
We collect this information from you when you sign up via the Book Pass by Jellybooks website as teacher of adminstrator. Our ESP is Sendgrid. You can find out more about how Sendgrid uses data by clicking here.
Recipients
This data is used for Jellybooks internal purposes only. Data is shared in aggregated and anonymised form (number of recipients and open rate) with Sponsors on a case by case basis.
2.2 Clients and Sponsors
Individuals, companies and other legal entities that make use of of Book pass by Jellybooks are referred to as “Sponsors”.
Type of data and information we collect
- First and last name
- Email address
- Password
- Address
- Contact and company details if provided
- Emails and other correspondence exchanged
- Billing information including bank details (or where applicable) credit card details
How we use it and the legal basis
We collect this information to provide you with our services in accordance with our contract with you. Our legal basis is entering or performing contracts with you.
How long we keep it
Until 6 years after you stop using our services.
More information
We might require and retain information from multiple individuals at the same company or legal entity.
Sources
We collect this information from you when you enter into an agreement with us or from our payment provider, if you use a credit card as form of payment.
Recipients
This data is used for Jellybooks internal purposes. Data may be shared with tax authorities, investors, lenders, regulators, grant providers or public institutions where appropriate and required by law to do so or to provide the services to you.
2.3 Reading and Engagement Data
Type of data and information we collect
- Browser type and settings, IP address, approximate location, access logs, device type and settings, operating system, and other information provided by your browser
- Times you open and close the reading app
- Times you open and close a book chapter
- Times during which your reading app is open (its heartbeat)
- Times you highlight or select text
- Times you click on a link in the book
- Times you change the font or typeface settings
- In-book location data for your actions with books
- Survey responses
How we use it and the legal basis
We process this information: (a) to allow you to subscribe and receive free ebooks and/or audiobooks in whole or as samples; (b) to help us improve our products and services; (c) to promote our products and services; (d) to help our Sponsors to better understand their audience and create better books; and (e) to provide you with insights and data on your reading behaviour. Our legal basis is legitimate interest in providing and improving our services.
How long we keep it
Any personal data we hold for you, except for email correspondence, is deleted in accordance with our rules under 2.1.2. Any email correspondence we hold is deleted within six months.
Any data not linked to personally identifiable information is retained in accordance with our general data retention policy for reading and service engagement data.
More information
You can access the reading and engagement data we hold via “My Data” at https://www.jellybooks.com/my_data.
Sources
We collect this information from you via our reader analytics software (a piece of JavaScript with the name candy.js, crowberry.js or cassis.js) that was developed by us and which was embedded by us either in the ebook and/or audiobook you received or forms part of the Jellybooks Cloud Reader developed by us.
Please note that some of this data may be temporarily stored in your browser cache or your local device storage (“local storage”).
Recipients
Jellybooks uses this data to optimise its services and shares the data in aggregate and anonymised form with Partners, Clients and Sponsors. Data is also shared in aggregated and anonymised form with government and media institutions where required under the terms and conditions of our sponsors or a government grant.
We also use this information to nudge you to open, continue reading, finish or review a book, as appropriate. You can opt out from such nudge emails on a book and campaign-specific basis, if desired, by clicking the unsubscribe link at the end of any nudge email.
2.4 Service and Enquiry Information
Type of data and information we collect
- Information you send us as part of enquiries by email or social media
- Any personal and device information you provide to us in order for us to provide our services to you or correct issues that may arise or have occurred
How we use it and the legal basis
We process this information: (a) to respond to your enquiries; (b) to promote our products and services; and (c) to understand how our users use our services in order to improve them; and (d) to provide our services. Our legal basis is legitimate interest in providing and improving our services.
How long we keep it
For as long as we are dealing with your enquiries or providing services to you, and for 6 months thereafter. We reserve the right to delete it sooner.
More information
You may be required to provide us with certain information in order for us to respond to your enquiries.
Sources
We collect this information from you when you make an enquiry.
Recipients
This data is used for Jellybooks internal purposes.
If you contact us via email, data is also stored with Freshdesk. You can find out more about how Freshdesk uses data by clicking here: https://www.freshworks.com/privacy/sub-processor-oct-15-2020/?_ga=2.106026629.703590840.1615751705-492689321.1615751705
If you contact us via social media, data is also stored with the applicable social medial provider.
2.5 Social Media Information
Type of data and information we collect
- Name (and/or your social media unique user name)
- Email address
- Gender and/or age
- General interests and preferences (e.g. Likes, Shares, Posts)
- Other personal data you send to us
How we use it and the legal basis
To: (a) engage with our users; (b) promote our products and services; and (c) understand how our users use our services in order to improve them. Our legal basis is legitimate interest in marketing and improving our services.
How long we keep it
Until 6 years after you stop using our services.
More information
Please refer to the applicable social media provider.
You can find out more about how Facebook uses data by clicking here: https://www.facebook.com/policy.php
You can find out more about how Twitter uses data by clicking here: https://twitter.com/en/privacy
Sources
We use social media providers such as Facebook and Twitter to collect this data from you when you visit or link to our social media channels.
Recipients
Jellybooks and the applicable social media provider.
Where explicit retention periods are not described above, we hold data for as long as necessary bearing in mind the purpose for which it was collected. At the end of the retention period, we assess whether it is necessary to continue to retain information to achieve the purposes for which it was collected. To determine appropriate retention periods, we consider the amount, nature, and sensitivity of the data, the potential risk of unauthorised access, and legal requirements.
3. Cookies, Analytics and Similar Technologies
Cookies, pixels and other technologies store and access data on your device to help websites and apps work. This table explains their purpose, how long they last, and who else can access their data. We get your consent to use them unless they’re essential for our sites, apps or services.
Most browsers allow control over cookies, for more information:
- Cookies: _ga, _gat, _gid
- Duration: Up to 24 months
- Purpose: To collect information about how visitors interact with our website & generate reports based to identify problems, understand how visitors use our website, and improve it.
- Access: We use Google Analytics to set these cookies. You can find out more about how Google uses data by clicking here: https://support.google.com/analytics/answer/6004245 . You can opt-out here: Google Analytics. You can opt-out here: https://tools.google.com/dlpage/gaoptout
4. Storage, Transfers and Disclosure
Storage & Transfers
Save where indicated otherwise in this policy, your personal data is securely stored in the UK, or the European Economic Area. Where we use data processors outside the UK and European Economic Area, and transfer personal data to a country which does not provide an adequate level of protection, we use contracts which give personal data the same protection it has in Europe and the UK. For more information drop us a line using the contact details at the start of this policy. Your personal information can be removed on request.
Disclosure
Other than as set out above, we may disclose your personal data:
- Where required by law, government, competent authorities or the courts or to establish, exercise or defend our legal rights, and for the purposes of preventing crime and fraud (for example, we may share personal data with our professional advisors, investigators, or credit reference agencies).
- With members of our corporate group, suppliers and subcontractors, as necessary for the purposes set out in this policy.
- If involved in an investment, merger, acquisition, or sale of our organisation or assets, personal data we hold may be shared on the basis of the legitimate interests of us, our shareholders, customers and other parties to a transaction, unless those interests are outweighed by prejudicial impacts upon you.