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PRIVACY POLICY

Phaidon International Group - Privacy Policy

Policy Name:Online Privacy Policy
Organisation Name:Phaidon International Group
Date of Last Update:May 2018

This Privacy Policy sets out information about the online privacy practices of
the Phaidon International Group, as described below (“Phaidon”), and the choices
you can make about the way your information is collected by us, how it will be
used and for what purposes. 

The Phaidon International Group includes:
• Phaidon International (UK) Limited
• Phaidon Holdings Ltd 
• Phaidon International USA Inc 
• Phaidon International (Deutschland) GmbH
• Phaidon International (Schweiz) GmbH
• Phaidon International (PTY) Ltd Singapore 
• Phaidon International (Hong Kong) Ltd 


By submitting any information to us, or by otherwise accessing or using our
website (www.phaidoninternational.com) (“Website”), you agree to the terms of
this Privacy Policy and consent to the policies and practices described herein
for Phaidon’s processing of personal data. 


1. We process your personal data
This Privacy Policy covers the processing, including without limitation the
collection, use, disclosure, transfer, storage and deletion, of all personal
data that is collected by Phaidon through our Website.
We process your personal data in accordance with the requirements of the General
Data Protection Regulation (GDPR).  In particular, we process personal data
solely for lawful purposes, either in connection with a contract we have with
you, subject to your consent, or on another permitted basis.  We only process
the minimum amount of personal data that is required for the relevant processing
purpose, and we limit our processing to specific limited purposes necessary to
conduct our activities.  We only store your personal data as long as it is
necessary for the purpose of the specific processing activity it was collected
for, or for any longer period of time that we may be obligated by law to retain
it.
As defined in the GDPR, “personal data” is any information relating to an
identified or identifiable natural person (a “data subject”), being a natural
person who can be identified, directly or indirectly, in particular by reference
to an identifier such as a name, identification number, location data, online
identifier or to one or more factors specific to the physical, physiological,
genetic, mental, economic, cultural or social identity of that natural person. 

2. Personal data collected on our Website
We have structured our Website so that, in general, you can visit Phaidon on the
web without identifying yourself or revealing any personal data unless you
actively choose to do so. We make this Privacy Policy and notice readily
available on our Website. 
Our Website may use “cookies” to enhance your experience.  Please see our
Cookies Policy, available at https://www.phaidoninternational.com/cookies-policy
for further information about the cookies used on our Website and your rights in
respect to same.


3. How we use your personal data
Phaidon uses personal data to better understand your needs and interests and to
provide you with better service. Once you choose to provide us with personal
data, whether through this Website or by other means in the course of our
activities and interaction with you, you can be assured it will be used only as
specifically detailed below, or as otherwise explicitly consented by you.
Phaidon collects, holds, and processes the following personal data on the
Phaidon Website:





For further information on how we process your personal data, please contact
privacy@phaidoninternational.com.  The controller responsible for the processing
of your data is Phaidon International (UK) Limited.  
Where you have provided us with consent to process your personal data, you have
the right to withdraw this consent at any time.  This will however not affect
the lawfulness of processing based on consent before its withdrawal.  We provide
multiple, simple methods for withdrawing your consent, including, where
applicable, electronic unsubscribe mechanisms.  In any event, you can always
inform us that you wish to withdraw your consent in respect of a specific
processing activity and related personal data by emailing us at
privacy@phaidoninternational.com.

If you do so, please provide us with your full name, email address and
sufficient details about the consent you provided, including the scope of the
consent and the personal data the consent related to. We collect your name and
email address in this context only for the purpose of identifying you in order
to execute your consent withdrawal request.

We only retain your personal data for as long as it is necessary for the
relevant processing activity, or as otherwise required by law.  We also maintain
detailed policies and procedures regarding how and how long we retain your
personal data.  
Although we use all reasonable means to ensure that the information you provide
to us is not used by third parties for purposes other than those described in
this Privacy Policy, Phaidon is not responsible for any improper use of your
personal data that is beyond our reasonable control.

4. Who we share your personal data with 
Phaidon will not sell, rent or lease your personal data to others. Phaidon will
not share your personal data with third parties except in line with permitted
uses, as set out in Section 3 of this Policy or as specifically consented to by
you. Phaidon shares customer information across Phaidon-owned business entities
and companies working on our behalf, but only as described in this Privacy
Policy.

Certain Phaidon services may be linked with those from third-party companies,
some which offer you the option to share personal data you provide with both
Phaidon and the third party. Examples include to request communications from
Phaidon marketing or solution partners. We will not share your personal data
with third-party companies unless you make that choice.

Phaidon contracts with third-party service providers and suppliers to deliver
complete products, services and customer solutions and benefits. Suppliers and
service providers are required to keep confidential the information received on
behalf of Phaidon consistent with this Privacy Policy and may not use it for any
purpose other than to carry out the services they are performing for Phaidon.

Circumstances may arise where, whether for strategic or other business reasons,
Phaidon decides to sell, buy, merge or otherwise reorganize businesses in some
countries. Such a transaction may involve the disclosure of personal data to
prospective or actual purchasers or receiving it from sellers. It is Phaidon’s
practice to seek appropriate protection for information, including personal
data, in these types of transactions.

Phaidon may share your personal data with third parties acting on behalf of
Phaidon, which may be located in other jurisdictions. We ensure that such
transfers are lawful, including by ensuring that they are to jurisdictions that
are considered to have equivalent privacy protections, and/or ensuring that the
third parties to whom we transfer your personal data are under contract to
Phaidon and bound by appropriate data protection clauses or other approved
safeguards, as applicable in each situation. 

5. Your rights
You have certain specific rights with respect to how we process your data. 
Phaidon is committed to ensuring that your rights are protected.  The GDPR sets
out the following rights applicable to data subjects:

a) The right to be informed – We have provided this Privacy Policy to provide
you with concise, transparent, intelligible and easily accessible information
about how we use your personal data, including specific information depending on
whether or not we have obtained your personal data directly from you. 

b) The right of access – You have right to obtain from us confirmation as to
whether or not personal data concerning you are being processed, and, where that
is the case, access to the personal data and the following information:
(a) the purposes of the processing; 
(b) the categories of personal data concerned; 
(c) the recipients or categories of recipient to whom the personal data have
been or will be disclosed, in particular recipients in third countries or
international organisations; 
(d) where possible, the envisaged period for which the personal data will be
stored, or, if not possible, the criteria used to determine that period; 
(e) the existence of the right to request from the controller rectification or
erasure of personal data or restriction of processing of personal data
concerning the data subject or to object to such processing; 
(f) the right to lodge a complaint with a supervisory authority; 
(g) where the personal data are not collected from the data subject, any
available information as to their source; 
(h) the existence of automated decision-making, including profiling, and
meaningful information about the logic involved, as well as the significance and
the envisaged consequences of such processing for the data subject. 
(i) Where personal data are transferred to a third country or to an
international organisation, we will inform you of the appropriate safeguards in
place in relation to the transfer.

c) The right to rectification – We will rectify without undue delay any
inaccurate personal data we hold concerning you, including completing any
incomplete personal data.  

d) The right to erasure (also known as the ‘right to be forgotten’) – You have
the right to have us erase all personal data we hold concerning you, without
undue delay, in one of the following circumstances:
(a) the personal data are no longer necessary in relation to the purposes for
which they were collected or otherwise processed; 
(b) you withdraw your consent on which the processing is based and there is no
other legal ground for the processing; 
(c) you object to the processing and there are no overriding legitimate grounds
for the processing, or you objected to the processing in respect to direct
marketing; 
(d) the personal data have been unlawfully processed; 
(e) the personal data have to be erased for compliance with a legal obligation
in EU or member country law to which our organisation is subject; or
(f) the personal data have been collected in relation to the offer of
information society services referred to in Article 8(1).


We cannot execute your request if the personal data you are asking us to erase
is necessary:
(a) for exercising the right of freedom of expression and information; 
(b) to comply with a legal obligation which requires processing under EU or a
member state’s law to which we are subject, or to perform a task in the public
interest or in the exercise of official authority vested in us; 
(c) for certain reasons of public interest in the area of public health; 
(d) for archiving purposes in the public interest, scientific or historical
research purposes or statistical purposes in so far as erasing the personal data
is likely to render impossible or seriously impair the achievement of the
objectives of that processing; or 
(e) to establish, exercise or defend legal claims.

e) The right to restrict processing – You have the right to request that we
restrict specific processing of your personal data, and we will comply, where
one of the following applies: 
(a) you are contesting the accuracy of your personal data that we hold, while we
verify the accuracy of your personal data; 
(b) the way we are processing the personal data is unlawful and you oppose the
erasure of the personal data and request the restriction of their use instead; 
(c) we no longer need the personal data for the purposes of the processing, but
you need the personal data to establish, exercise or defend legal claims; or
(d) you have objected to processing in the public interest or in relation to our
legitimate interest, pending the verification whether any legitimate grounds we
may have override your right.

While you have restricted its processing, we will only store your personal data
in question, and may process it only with your consent or to establish, exercise
or defend legal claims or protect the rights of another natural or legal person
or for reasons of important
public interest. We will notify you before lifting the processing restriction.

f) The right to data portability – You have the right to receive from us your
personal data that you have provided to us, in a structured, commonly used and
machine-readable format, and you have the right to transmit those data to
another controller without hindrance from us, where:
(a) the processing is based on consent or on a contract; and
(b) the processing is carried out by automated means.


  Where technically feasible, we will transmit your personal data directly to
the other controller.

g) The right to object – You have the right to object to Phaidon processing your
personal data in connection with our legitimate interests in the context of our
activities (including profiling), direct marketing (including profiling), and
processing for scientific and/or historical research and statistics purposes,
where applicable.  

h) Rights with respect to automated decision-making and profiling – You have the
right not to be subject to a decision based solely on automated processing,
including profiling, which produces legal effects concerning you or similarly
significantly affects you.  You can object to your personal data being used in
this way.  We are permitted to use automated decision-making and profiling if
the decision: 
(a) is necessary for entering into, or performance of, a contract between you
and us; 
(b) is authorised by EU or a member state law to which we are subject and which
also lays down suitable measures to safeguard your rights and freedoms and
legitimate interests; or 
(c) is based on your explicit consent. 
Where we engage in automatic decision-making or profiling in connection with a
contract between us or further to your explicit consent, we implement suitable
measures to safeguard your rights and freedoms and legitimate interests, at
least the right to obtain  human intervention from us in the course
decision-making process, and the opportunity to express your point of view and
to contest the decision.


i) Right to lodge a complaint with your data protection supervisory authority -
In the event you believe that we are processing your personal data otherwise
than in accordance with the provisions of the GDPR, you have the right to lodge
a complaint with the data protection supervisory authority located in the EU
jurisdiction where you reside.  For the UK, the supervisory authority is the UK
Information Commissioner’s Office. 

6. Links to non-Phaidon websites
The Phaidon Website may provide links to third-party companies’ websites for
your convenience and information. If you access those links, you will leave the
Phaidon website. Phaidon does not control those sites, their content or their
privacy practices, which may differ from Phaidon's. We do not endorse or make
any representations about third-party websites. The personal data you choose to
give to unrelated third parties is not covered by this Phaidon Privacy Policy.
We encourage you to review the privacy policy of any company before submitting
your personal data. Some third-party companies may choose to share their
personal data with Phaidon; that sharing is governed by that third-party
company's privacy policy. 


7. Children's privacy
Phaidon is committed to protecting the privacy needs of children and we
encourage parents and guardians to take an active role in their children's
online activities and interests. Phaidon does not knowingly collect information
from children under the age of 16 and Phaidon does not target its Website or any
of its services to children under the age of 16. 


8. Keeping your personal data secure
Phaidon is committed to protecting the information you provide us. To prevent
unauthorized access or disclosure, to maintain data accuracy, and to ensure the
appropriate use of the information, Phaidon has in place appropriate
technological and operational procedures to safeguard the information we
collect. 
If you believe Phaidon has handled your personal data in a manner that does not
comply with this Privacy Policy, please contact us by the means specified below
at Section 10 of this Privacy Policy. 


9. Changes to this Privacy Policy
If there are updates to the terms this Privacy Policy, we will post those
changes and update the revision date in this document, so you will always know
what information we collect, how we use it, and what choices you have. For
material changes to this Privacy Policy, Phaidon will actively notify affected
individuals.  


10. Contacting us
We value your opinions. If you have comments or questions about our Privacy
Policy – as well as if you have any requests or questions regarding our
processing of your personal data, please contact the below: 
Email the DPO:  privacy@phaidoninternational.com 
Call us:  +44 (0) 20 3758 8800
Reach us in person or by mail:  21 Lombard Street, London, EC3V 9AH

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