This version was revised and came into force as of 25 March, 2020.
INTRODUCTION
Welcome to the Send-to-PocketBook privacy notice.
Send-to-PocketBook respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you use Send-to-PocketBook service when it is connected to Wi-Fi and tell you about your privacy rights and how the law protects you.
This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
1. IMPORTANT INFORMATION AND WHO WE ARE
3. HOW IS YOUR PERSONAL DATA COLLECTED
2. THE DATA WE COLLECT ABOUT YOU
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how Pocketbook International SA collects and processes your personal data through your use of Send-to-PocketBook service under the brand PocketBook (“Send-to-PocketBook”), including any data you may provide through Send-to-PocketBook. We also own, operate and offer related services, like Bookland, Readrate, Cloud and Support for e-readers. We also create, develop, produce, distribute, and support e-readers (“Reader”) and mobile applications. We refer to Send-to-PocketBook as “Services” or sometimes as “Send-to-PocketBook Service” in this policy. Services are part of the PocketBook Group Services and Products, which belong to PocketBook International SA, based in Lugano, Switzerland. More information about PocketBook International SA is available at https://www.pocketbook.ch.
Services are not intended for children under 16 and Pocketbook International SA do not knowingly collect data relating to children. Users must be at least 16 years old or older to register for a Services Account to use the PocketBook Services. If a parent or guardian believes that Pocketbook International SA has in its database the personal information of a child under the age of 16, please contact us at privacy@pocketbook-int.com and we will use our best efforts to remove the information from our records.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice 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 notice supplements the other notices and is not intended to override them.
If you do not agree with this policy, do not access or use our Services or interact with any other aspect of our business.
CONTROLLER
Pocketbook International SA is the company which produces e-readears under the brand PocketBook (“Products”).
Pocketbook International SA is the controller and responsible for your personal data (collectively referred to as “PocketBook”, “we”, “us” or “our” in this privacy notice).
If you have any questions about this privacy notice, including any requests to exercise your legal rights under the GDPR, please contact us by email privacy@pocketbook-int.com .
CHANGES TO THE PRIVACY NOTICE AND OUR DUTY TO INFORM YOU OF CHANGES
We may revise the provisions of this Privacy Notice as necessary. The latest version of the Privacy Notice will govern the terms of use of your personal data by us and it will always be published at https://legal.pocketbook-int.com/send-to-pocketbook/PRIVACYNOTICE
THIRD-PARTY LINKS
Send-to-PocketBook may have links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites, plug-ins and applications and are not responsible for their privacy statements.
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).
When you connect to Wi-Fi and use Send-to-PocketBook Service, we collect only your e-mail details and e-mail addresses of users in your “whitelist”. To find more about “whitelist” please refer to Send-to-PocketBook Terms of Use.
NOTE: By adding an e-mail address in your “whitelist”, you confirm, warrant, and represent that you are the owner of the e-mail address or you have obtained the consent from the owner of the respective e-mail address for legal use of such address while running Service.
We can collect such non-identified information concerning the Reader that is needed for proper Send-to-PocketBook Service providing, such as serial number of your Reader.
We may collect, use and store different kinds of personal data about you which we have grouped together as follows:
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, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
IF YOU FAIL TO PROVIDE PERSONAL DATA
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 services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
PLEASE NOTE!
In case you are using any of our additional Services or Products, which collect Personal data please read their Privacy notices:
We use Automated technologies or interactions as the method to collect data from and about you. As you interact with us and our Support team, we may automatically collect your contact data and technical data about your Reader.
We collect your data for direct interactions with you. You may give us your Contact Data by filling in forms or by corresponding with us by phone or writing us an email or otherwise, including giving your Contact details for Customer Support services we provide you with per your request.
We use your personal data when you interact with us. Our other Services listed in Section 2 The data we collect about you will collect the different personal data.
PURPOSES FOR WHICH WE WILL USE YOUR DATA
We have set out below, in a table format, a description of all the ways we plan to use data we collect in the process of Service you use, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
|
Purpose/Activity |
Type of data |
Lawful basis for processing including basis of legitimate interest |
|
(1) To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy notice; (b) interaction with you and provide you with our Customer Support |
Contact |
(a) Performance of a contract with you (b) Necessary to perform you a Customer Support for our Service |
|
To administer and protect our business and Send-to-PocketBook Service (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
Contact Technical |
(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 |
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it.
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.
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.
We do not disclose and share your identified data, but with an exception of the parties set out below and for the purposes set out in the table in paragraph 2:
Internal Third Parties as set out in the Glossary.
To the Public Authorities in accordance with appropriate law in case when they will make a request for the information
PocketBook is a worldwide company, which collect information globally and we primarily store that information in the Netherlands. By using Services, you authorize us to transfer and store your information outside your home country, for the purposes described in this policy. The privacy protections and the rights of authorities to access your information in these countries may not be the same as in your home country.
We take additional measures when information is transferred from the European Economic Area (EEA). This includes having standard clauses approved by the European Commission in our contracts with parties that receive information outside the EEA. We also rely on European Commission adequacy decisions about certain countries, as applicable, for data transfers to countries outside the EEA.
We have put in place appropriate security measures to prevent your data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your 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.
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
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, 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 unauthorized use or disclosure of your data, the purposes for which we process your data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
In some circumstances we may anonymize your Contact 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.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. As a user of our Service you have such rights:
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 our use of the data is unlawful but you do not want us to erase it; (c) 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 (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
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.
If you wish to exercise any of the rights set out above, please contact us by email privacy@pocketbook-int.com and write about your request.
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.
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best Services and Products and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by Contacting us privacy@pocketbook-int.com
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
THIRD PARTIES
INTERNAL THIRD PARTIES
Other companies in the PocketBook Group acting as joint controllers or processors and who are based EEA and outside of EEA and provide IT and system administration services and undertake leadership reporting.
Customer Support means the provision of end-customer support via telephone or email to customers before, during and after a purchase of products and services under the brand PocketBook.