Riley Publishing Ltd t/a Simply Scandi
Privacy Policy
Policy Version: Version 1, dated 10 November 2023
1. Who we are
1.1. Welcome to our Website's privacy policy. For reference, our website domain name is https://www.simplyscandi.com/ (the "Website") and the owner of the Website will be referred to in this privacy policy as the "Owner" or "we".
1.2. We are Riley Publishing Limited, trading as Simply Scandi, a private limited company registered in England and Wales with company number 12942058 whose registered office address is at 5 Holland Park, Caterham, England, CR3 5WL.
1.3. We are a publishing company and provide literary content in the form of magazines and journals.
1.4. We are the controller of personal data obtained via our Website, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.
1.5. The data privacy manager who is responsible for overseeing questions in relation to this privacy policy is Jennifer Howard and can be contacted on Jennifer.morgan@rileypublishing.co.uk. They are registered with the Information Commissioner's Office (ICO). If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the contact details set out above.
2. Purpose of this privacy policy
2.1. We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share any information relating to you (your personal data) in connection with your use of our Website. It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint.
2.2. It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
2.3. We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR).
2.4. Given the nature of our Website, we do not expect to collect the personal data of anyone under 13 years old. If you are aware that any personal data of anyone under 13 years old has been shared with our Website please let us know so that we can delete that data.
2.5. This version of our privacy policy is primarily written for adults and those aged 18 and over. The Website is not intended for children and we do not knowingly collect personal data from or relating to children.
3. Contacting the Information Commissioner's Office and how to complain
3.1. You have the right to make a complaint at any time to the ICO), the UK regulator for data protection issues (https://ico.org.uk/).
3.2. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
4. Changes to this privacy policy and your duty to inform us of changes
4.1. We keep our privacy policy under regular review. This version was last updated on 10 November 2023.
4.2. We may change this privacy policy from time to time. When we make significant changes we will take steps to inform you, for example via email.
4.3. 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.
5. Third-party links
5.1. Throughout our website we may link to other websites owned and operated by certain trusted third parties, for example to make additional products and services available to you. Those third-party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to those third-party websites, please consult their privacy policies as appropriate.
5.2. 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 policy of every website you visit.
6. The data we collect about you
6.1. 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).
6.2. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
● Identity Data: includes first name, maiden name, last name, title, marital status, date of birth.
● Contact Data: includes billing address, delivery address, email address and telephone numbers.
● 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 the Website and out other products and services.
● Profile Data: includes your username and password, purchases or orders made by you, your interests, preferences and survey responses.
● Usage Data: includes information about how you use the Website and our other products and services.
● Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.
6.3. You must provide this personal data to use our Website and the services on it and to make purchases of our services and products unless we tell you that you have a choice.
6.4. 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 goods or products). In this case, we may have to cancel a product you have with us but we will notify you if this is the case at the time.
6.5. We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. 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.
6.6. 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, genetic and biometric data)
7. How your personal data is collected
7.1. We use different methods to collect personal data from and about you including:
● Direct Interactions: When you enter or send us information, such as, but not limited to, when you register an account on our Website, contact us (including via email), send us feedback, purchase products or services via our Website, post material to our website and complete customer surveys or participate in competitions via our Website.
● Indirect Interactions: When you interact with our website, such as browsing activity, we will usually collect information indirectly using, for example but not limited to, Cookies and other tracking technologies.
● Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources (sometimes based outside the UK), such as but not limited to analytics providers such as Google; advertising networks; search information providers; providers or technical, payment and delivery services; data brokers or aggregators; and/or publicly available sources.
8. How and why we use your personal data
8.1. Under data protection law, we can only use your personal data if we have a proper reason, e.g.:
● Where you have given consent;
● To comply with our legal and regulatory obligations;
● For the performance of a contract with you or to take steps at your request before entering into a contract; or
● For our legitimate interests or those of a third party.
8.2. A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us.
8.3. We have set out below, a description of 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.
8.4. 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.
8.5. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity (What we use your personal data for)
Creating and managing your account with us
Types of Personal Data
(a) Identity
(b) Contact
Lawful basis for processing (Our reasons)
(a) To perform our contract with you or to take steps at your request before entering into a contract.
Purpose/Activity (What we use your personal data for)
Providing products and/or services to you including:
(a) Managing payments, fees and charges.
(b) Processing and delivering products and/or services to you.
Types of Personal Data
(a) Identity
(b) Contact
(c) Marketing and Communications
Lawful basis for processing (Our reasons)
(a) To perform our contract with you or to take steps at your request before entering into a contract.
Purpose/Activity (What we use your personal data for)
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy.
(b) Asking you to leave a review or take a survey.
(c) Communications with you not related to marketing including changes to products and/or services and other important notices.
Types of Personal Data
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
Lawful basis for processing (Our reasons)
(e) To perform our contract with you or to take steps at your request before entering into a contract.
(f) Necessary to comply with a legal obligation.
(g) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services).
Purpose/Activity (What we use your personal data for)
Enforcing legal rights or defending or undertaking legal proceedings.
Types of Personal Data
(a) Identity
(b) Contact
(c) Profile
Lawful basis for processing (Our reasons)
Depending on the circumstances:
(a) to comply with our legal and regulatory obligations;
(b) in other cases, for our legitimate interests, i.e. to protect our business, interests and rights.
Purpose/Activity (What we use your personal data for)
Customising our Website and its content to your particular preferences based on a record of your selected preferences or on your use of our Website.
Types of Personal Data
(a) Identity
(b) Contact
(c) Profile
(d) Usage
Lawful basis for processing (Our reasons)
Depending on the circumstances:
(a) Your consent as gathered, e.g. by the separate cookies tool on our Website and other tracking technologies.
(b) Where we are not required to obtain your consent and do not do so, for our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price.
If you have provided such a consent you may withdraw it at any time by, e.g. by changing the setting on the cookies tool (this will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn).
Purpose/Activity (What we use your personal data for)
Retaining and evaluating information on your recent visits to our Website and how you move around different sections of our Website for analytics purposes to understand how people use our Website so that we can make it more intuitive or to check our Website is working as intended.
Types of Personal Data
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
Lawful basis for processing (Our reasons)
Depending on the circumstances:
(a) Your consent as gathered, e.g. by the separate cookies tool on our Website and other tracking technologies.
(b) Where we are not required to obtain your consent and do not do so, for our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price.
If you have provided such a consent you may withdraw it at any time by, e.g. by changing the setting on the cookies tool (this will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn).
Purpose/Activity (What we use your personal data for)
To administer and protect our business and this Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
Types of Personal Data
(a) Technical
(b) Usage
(c) Profile
Lawful basis for processing (Our reasons)
(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.
Purpose/Activity (What we use your personal data for)
Statistical analysis to help us understand our customer base
Types of Personal Data
(a) Identity
(b) Profile
(c) Usage
(d) Contact
Lawful basis for processing (Our reasons)
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy).
Purpose/Activity (What we use your personal data for)
Updating and enhancing customer records
Types of Personal Data
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Technical
Lawful basis for processing (Our reasons)
Depending on the circumstances:
(a) To perform our contract with you or to take steps at your request before entering into a contract.
(b) To comply with our legal and regulatory obligations.
(c) Where neither of the above apply, for our legitimate interests, e.g. making sure that we can keep in touch with our customers about existing orders and new products.
Purpose/Activity (What we use your personal data for)
To make suggestions and recommendations to you about goods or services that may be of interest to you.
Types of Personal Data
(a) Identity
(b) Usage
(c) Marketing and Communications
(d) Profile
Lawful basis for processing (Our reasons)
(a) For our legitimate interests, i.e. to promote our business to existing and former customers.
Purpose/Activity (What we use your personal data for)
To share your personal data with members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency.
In such cases information will be anonymised where possible and only shared where necessary.
Types of Personal Data
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications
Lawful basis for processing (Our reasons)
Depending on the circumstances:
(a) To comply with our legal and regulatory obligations.
(b) In other cases, for our legitimate interests, i.e. to protect, realise or grow the value in our business and assets.
9. Marketing
9.1. We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
9.2. We will use your personal data to send you updates (by email, text message, telephone or post) about our products and/or services, including exclusive offers, promotions or new products and/or services.
9.3. We have a legitimate interest in using your personal data for marketing purposes. This means we do not need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.
9.4. You have the right to opt out of receiving marketing communications at any time by:
9.4.1. Contacting us at simplyscandi@rileypublishing.co.uk for marketing opt-out.
9.4.2. Using the 'unsubscribe' link in emails or 'STOP' number in texts; or
9.4.3. Updating your marketing preferences.
9.5. We may ask you to confirm or update your marketing preferences if you ask us to provide further products and/or services in the future, or if there are changes in the law, regulation, or the structure of our business.
9.6. We will always treat your personal data with the utmost respect and never sell or share it with other organisations for marketing purposes. We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
9.7. You can ask us or third parties 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.
9.8. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
10. Cookies
10.1. A cookie is a small text file which is placed onto your device (e.g. computer, smartphone or other electronic device) when you use our Website. We use cookies and similar technologies, e.g. web beacons, action tags, single-pixel gifs on our Website. These help us recognise you and your device and store some information about your preferences or past actions.
10.2. 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 the Website may become inaccessible or not function properly.
11. Change of purpose
11.1. 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 wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
11.2. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
11.3. 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.
12. Who we share your personal data with
12.1. We routinely share personal data with:
● Third parties we use to help deliver our products and/or services to you, e.g. payment service providers, warehouses and delivery companies.
● Other third parties we use to help us run our business, e.g. marketing agencies or website hosts and website analytics providers.
● Professional advisers including lawyers, bankerts, auditors and insurers.
● HM Revenue & Customs, regulators and other authorities.
● Law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations.
● 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. Usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations.
12.2. We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data.
13. How long your personal data will be kept
13.1. We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
13.2. 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, regulatory, tax, accounting or other requirements.
13.3. In some circumstances we will 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.
13.4. Following the end of the relevant retention period, we will delete or anonymise your personal data.
14. Transferring your personal data out of the UK
14.1. Some of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.
14.2. Countries outside the UK have differing data protection laws, some of which may provide lower levels of protection of privacy.
14.3. It is sometimes necessary for us to transfer your personal data to countries outside the UK. In those cases we will comply with applicable UK laws designed to ensure the privacy of your personal data.
14.4. Whenever we transfer your personal data out of the UK and the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
14.4.1. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
14.4.2. Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
15. Data Security
15.1. We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine need to access it.
15.2. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
15.3. If you want detailed information from Get Safe Online on how to protect your personal data and other information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit https://www.getsafeonline.org/. Get Safe Online is supported by HM Government and leading businesses.
16. Your legal rights
16.1. Under certain circumstances, you have rights under data protection laws in relation to your personal data.
16.2. You generally have the following rights, which you can usually exercise free of charge:
● You have the right 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.
● You have the right to request correction (also known as 'rectification') 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.
● You have the right to 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, 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.
● You have the right to 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. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
● You have the right to 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:
○ If you want us to establish the data's accuracy.
○ Where our use of the data is unlawful but you do not want us to erase it.
○ 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.
○ You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
● You have the right to 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.
● You have the right to 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.
● You have the right to not be subject to decisions without human involvement. This means you have the right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you. Note we do not make any such decisions based on data collected by our Website.
16.3. For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us. You may also find it helpful to refer to the guidance from the UK’s Information Commissioner (https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/individual-rights/individual-rights/) on your rights under the UK GDPR.
16.4. 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 could refuse to comply with your request in these circumstances.
16.5. Time limit to respond: We try to respond to all legitimate requests within one month. Occasionally it could 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.
16.6. If you would like to exercise any of those rights, please email or write to us. When contacting us please.
16.6.1. provide enough information to identify yourself (e.g. your full name, address and customer or matter reference number) and any additional identity information we may reasonably request from you, and
16.6.2. let us know which right(s) you want to exercise and the information to which your request relates.