(a) We use your data for fulfilling your orders for goods and services, managing your relationship with Muddy Pearl, for our internal administration, on occasion for surveys in order to improve how we work and the products we produce and for our own legal and financial records. In all cases where we process your data, it will be on one of the following legal bases:
- We have a contract with you and need to process your data in order to fulfil the terms of the contract;
- You have given us consent to process your data in order for us to provide you with goods or services which you have requested;
- We have a legal requirement to process your data
- We have a legitimate interest as a company in processing your personal data, inasmuch as it relates to the operation of our business, is a use which you would reasonably expect us to make of your data and has a minimal impact upon your privacy.
Further information on data protection law and legal bases for processing is widely available in the public domain. Each paragraph below refers to a way in which you might relate to Muddy Pearl and explains what data we process in each case and the legal basis on which we process it.
You can update your contact preferences at any time via our Update Preferences Page but this will not override our legal obligations in respect of contracts we may have with you, or under financial law.
(b) If you register on our websites, in person, at an event or over the phone, for newsletters or promotional material, we will collect your name, email address and contact preferences so that we can send you that information by email, in accordance with your request. We pass your details onto to our bulk email service provider, Mailchimp, which processes your data for the purpose of fulfilling your communication request. In this capacity, Mailchimp acts as a data processor on our behalf. They also reserve the right to process your data for their own legitimate interests, including but not limited to product development and business operations. With respect to these purposes, they act as a data controller. You can opt out or manage your preferences here or by contacting us at the address given above.
(c) If you shop on our website, either as a guest or as an account holder, our merchant services provider (BCL NuMedia Ltd, trading as The Firsty Group) will collect your name, email address, postal address, phone number, and payment details (if required) and will pass these on to our fulfilment company (Norwich Books and Music, trading as Hymns Ancient & Modern Limited, only so that they can handle your order and contact you if there are any problems with it, in order to fulfil our contract with you. Muddy Pearl will use your email address to send you newsletters and promotional material. For this purpose, we pass your data to Mailchimp to process on our behalf. Mailchimp may also process your personal data for their own legitimate interests, including but not limited to product development and business operations. If you no longer wish to receive our newsletters or promotional material, you can opt-out or manage your preferences here or by contacting us at the address given above.
(h) As a publisher, Muddy Pearl has a legitimate interest in using publicly available information to identify people who show an interest in supporting organisations like Muddy Pearl, or who may be interested in association with Muddy Pearl as an author, as a supporter or in some other capacity. This information may include, for example, media coverage and open postings on social media. If an individual enters into such a relationship with Muddy Pearl they will discuss with the Director or their Editor which data they are happy for Muddy Pearl to continue to hold.
(i) If you are an organisation such as a church or school wishing to set up a credit account we may search the files of credit reference agencies, who will record the search. Information may be shared with other credit grantors and used for making credit decisions, fraud prevention and occasionally for tracing debtors. In order to comply with our legal obligations under Financial Law, we will seek your consent to such searches in the course of your application for a credit account.
(j) If you contact us via one of the contact forms on one of our websites, you give us your consent to retain your data for as long as we need to process your feedback.
(k) If you apply for a job, you consent to us holding the information you have supplied to us for a time in order to process your application. We will not hold your data longer than is necessary for fair consideration of your application. If we interview you, we are likely to hold your data for up to six months.
(l) If you have submitted a book idea, you give us your consent to retain your proposal and personal details. If your submission is initially unsuccessful, we may still hold your data for up to three years after you first approach us in case of query or the opportunity arises to consider the idea again.
(m) If you become an author we will retain all the personal information, including your bank details, address and biographical details necessary in order to promote your book and for as long as we pay you or your estate royalties, according to your contract with MUDDY PEARL.
(n) Interns and volunteers enter into a contract with MUDDY PEARL. We will retain the personal data of interns and volunteers for up to six months after the period of their work placement with us, unless specifically requested by the intern or volunteer to maintain files on them for the purposes of supplying employer references in the future.
(o) Casual workers, freelancers or employees of MUDDY PEARL will have their data processed in accordance with the terms of their contract with MUDDY PEARL and MUDDY PEARL’s internal policies
(p) If you fill in one of our survey forms on one of our websites or via social media, you give us your consent to retain your data for as long as we need to process your feedback.
- Do you process data about my philosophical and religious beliefs?
Some of the information we hold about you might reveal your philosophical or religious beliefs. This is known as a ‘special category’ of personal data. For example, the fact of your interest in MUDDY PEARL might be taken to imply that you are of the Christian faith, or you may have informed us of your denomination, or that you are ordained. We have safeguards in place to process this type of data appropriately. For example, we use industry-recommended access control, encryption, firewalls and virus protection. Where you have given us explicit consent to the processing of categories of personal data relating to your philosophical or religious beliefs, for example, where you have supplied us with information about your churchmanship or affiliations and have asked to be kept up to date on MUDDY PEARLs endeavours in those areas, we will process this data for that purpose only.
- Information about other people.
If you provide information to us about any person other than yourself, such as people on whose behalf you are enquiring or placing an order, you must ensure that they understand how their information will be used and that they have given their permission for you to disclose it to us and for you to allow us, and our service providers, to use it.
- In all cases where we hold your data.
You may change your preferences or opt-out of communications at any time by:
- Clicking the unsubscribe link on the bottom of any e-newsletter. This will unsubscribe you from that particular newsletter.
- Using our Update My Preferences Page.
- Emailing us on firstname.lastname@example.org.
- Writing to us at MUDDY PEARL, Mull, Central Hall, 2 West Tollcross, Edinburgh, EH3 9BP
- Phoning us on 020 7592 3900
- For how long will MUDDY PEARL hold my data?
We will hold all transactional data for at least 7 years after the transaction to fulfil the requirements of Financial Law. If you continue to have a relationship with us (defined as having some kind of interaction with us in the past 3 years) we will continue to hold all your data to the extent it is necessary for us to manage your relationship with MUDDY PEARL. For all other purposes, we keep data no longer than is necessary for the purposes of processing it.
- Where is my data stored?
MUDDY PEARL and the third party data processors who handle your data on our behalf may store your data outside the European Economic Area. Where possible we ensure that these third parties are certified by the EU-US Privacy Shield, but it may be that these processors need to transfer data to other countries in which their sub-processors operate. If this is the case, we make sure that they always do this in accordance with the provisions of the General Data Protection Regulation.
- How safe is my data?
We work hard to ensure that sending your personal data over the internet (e.g. your credit card details and your postal address when you buy a book) is completely secure and use SSL certified processes but, as with any organisation operating over the internet, we can’t guarantee the security of your data while it’s in transit, so any data you send is at your own risk. We have procedures and security features in place to keep your data secure once we receive it. For example, we only engage third parties which provide sufficient guarantees that any personal data will be processed in a manner which complies with data protection law, and we use industry-recommended access control, encryption, firewalls and virus protection.
- With whom will my data be shared?
We will not pass your information on to third parties for their own marketing purposes. Some third party data processors will use their data for their own legitimate interests, including but not limited to product development and business operations.
Your data may be handled by third parties acting on our behalf such as mailing houses who are helping us to keep in touch with you, merchant services or fulfilment companies, e-book publishers, donation processors, payment processors and cloud data storage providers. These data processing partners are also bound by Data Protection laws and will store your data carefully while it is needed and not hold it any longer than is absolutely necessary. We have assessed these suppliers in relation to their use of personal data on our behalf, and have contracts in place with them to set out adequate contractual obligations to ensure proper management of your personal data, and to prohibit transfers outside the UK.
If you post or send offensive, inappropriate or objectionable content to or anywhere on the MUDDY PEARL website, or otherwise engage in any disruptive behaviour on any MUDDY PEARL service, we may use your personal data to stop such behaviour. Where MUDDY PEARL reasonably believes that you are or may be in breach of any of the laws of England and Wales (or the law of Scotland if applicable) (e.g. because content you have posted may be defamatory), we may use your personal data where we consider it appropriate to do so, to inform relevant third parties such as your employer, internet provider or law enforcement agencies about the content and your behaviour. We may disclose your personal information to third parties if we are under a duty to disclose or share your personal data in order to comply with any legal obligation.
- What if I don’t want to share my data in this way?
If you are a consumer purchasing MUDDY PEARL products and services, our merchant services provider will process your payment card and address details in order to process your payment and deliver your products and services. Both guests and account holders will receive marketing emails from MUDDY PEARL unless they opt out. You can update your preferences here.
If you wish to make an anonymous donation you can send a cheque with no other identifying information payable to MUDDY PEARL to MUDDY PEARL, Mull, Central Hall, 2 West Tollcross, Edinburgh, EH3 9BP. We will need to hold a record of your name and the donation for financial reasons and because we are required to by money laundering regulations but we will not store any other personal data.
- How do I know what data you have stored about me?
You can ask us to disclose what personal data we hold about you and you may ask us to change what we keep if it is not up to date or accurate.
- What should I do if I’m not happy with the way you’ve collected, stored and used my data?
You have a right to withdraw your consent for us to store your personal data or keep in touch for marketing purposes at any time.
You are also entitled to ask us to restrict our processing of your personal data. For example, where you are concerned about the accuracy of the data or the purposes for which we are using that data.
You may request that we erase all the data that we hold relating to you. Where you have supplied data to us on the basis of consent, you may withdraw that consent; or if your personal data is no longer necessary for us to process, you may inform us of this. However, we will still hold any data which we are required to hold for legal and tax purposes, or in order to fulfil your transaction.
Where we process your personal data for our legitimate interests, then you may ask us to stop such processing.
If you have any complaints about the way we have handled your data please see our customer services complaints policy. You may also make a complaint about how we have processed your personal data to the Information Commissioner here in the UK.
- How do I update the data you hold on me?
You may write to us at MUDDY PEARL, Mull, Central Hall, 2 West Tollcross, Edinburgh, EH3 9BP.
Contact us via our online page https://muddypearl.com/my-account
or phone 020 7592 3900
- How can I be sure this is notice is up-to-date?