Privacy Policy

Privacy Policy

Last updated: November 2023

Who are we?

We are HarperCollins Publishers L.L.C. (“we” “our” “us” or “HarperCollins”). You can see who our group members are by clicking on the link below:

https://newscorp.com/news-corp-businesses-and-brands/

What is our Privacy Commitment to you?

We respect your privacy and are committed to protecting your personal data. This privacy notice describes how we collect, use, share, and protect personal data that you provide on Christian Book Insiders https://www.christianbookinsiders.com (the “site”) when you become a community member and participate in our surveys and/or research studies (“surveys”). It also explains your privacy rights and how laws that are applicable to you may protect you.

This Privacy Notice tells you about:

• Who are we?
• What is our Privacy Commitment to you?
• What personal data do we collect about you and how do we use your personal data?
• Who do we share your personal data with?
• Who is the data controller?
• What are the legal bases we rely on when processing your personal data?
• Do we transfer your personal data to other countries?
• What cookies do Toluna use on the site?
• What other tracking technologies do Toluna use?
• What is our winner’s policy?
• What security measures do we undertake to protect your personal data?
• What are our data retention and destruction policies?
• Links
• Children’s privacy
• Your rights
  • How do you access your information; use the member services area and/or update, correct, or delete your information?
  • How do you opt out from your community membership?
    • How long will you use my data for?
  • How do you ask a question or make a complaint?
• Your other rights
• Your legal rights if you reside in California
• Changes to the privacy notice and your duty to inform us of changes
• Privacy contact details

What personal data do we collect about you and how do we use your personal data?

Being a Community Member

When you agree to become one of our community members and complete the registration form on the site, you are able to participate in our surveys. As part of your registration, you will provide us with your Identity data and Contact data, and we will, through your participation in the Surveys, obtain, use, and share certain other data about you, such as: Demographic/Profile data, Technical data, and Pseudonymized data.

We use your Identity data and Contact data for:

• Contacting you for any reason connected with your community membership;
• Incentive fulfillment - when you earn incentive points through your participation in the surveys, the points are deposited into your account. When you wish to redeem them, we will use your Identity data and Contact data to send you your rewards.
• Sending you invitations for your participation in surveys - to ask you if you are interested in participating in our upcoming surveys. We may also make you aware via your online community membership account of surveys you may be suitable to participate in, based on our knowledge of your personal data.

If allowed under applicable law, we may from time to time ask you to provide us with Special Categories of personal data about yourself for specific surveys, and if required by applicable law, we will ask you for your consent before processing such Special Categories of personal data.

We use your Demographic/Profile data for matching you with appropriate surveys to see if you qualify for particular surveys, and your birth date is automatically updated so that we may ensure we select individuals based on their age as may be required for the relevant survey.

We use the personal data collected about you via the site to match and link with data we previously collected about you.

Public forums and blogs

The site offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them.

Personal testimonials of satisfied customers are displayed on the site in addition to other endorsements. With your consent, we may post such testimonials along with your first name and the first letter of your surname. If you wish to update or delete your testimonial, you can contact us at support@christianbookinsiders.com.

You should be aware that any personal data you choose to make public on the site, in the community area (under a message on your wall, as an opinion, topic, battle, thumb it) can be read, collected, stored, and/or used by other users and could be used to send you unsolicited messages. We strongly discourage you from disclosing any of your personal data in the community area that you may find on the site, and in particular, we would never ask you to provide your Contact data or Identity data on a public community area as part of a survey. We cannot guarantee that third parties with whom you share your personal data via those community areas will keep them secure and confidential. Please be aware that we are not responsible for the personal data you choose to submit or make public in the community areas. In addition, we are not responsible for the content you publicly post on the site that can be found via web-based search engines.

Categories of personal data we may process about you

• (A) Identity data – name (includes first, last, maiden and married names), date of birth, marital status, gender, membership id and username.
• (B) Contact data – postal address, email address, and telephone number.
• (C) Demographic/Profile data - interests, preferences, feedback, and survey responses including, but not limited to; age, marital status, gender, birthday, household size, income, education, and employment status.
• (D) Technical data includes internet protocol (IP) addresses, 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 this website.
• (E) “Pseudonymized data” is identifiable data as unique identifiers such as membership IDs are used; however, direct identifiers, such as name and Contact data, are removed.

Who do we share your personal data with?

All of the responses we collect from you via our surveys are collected by us at an individual level, but your responses to the surveys will be anonymous.

We have appointed Toluna to host the site on its online platforms for us. Toluna helps us to recruit online community members - like you, and they build and manage the site and process all personal data we collect from you as part of your community membership. We require Toluna to respect the security and confidentiality of your personal data and to treat it in accordance with the law. We do not allow Toluna to use your personal data for their purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Toluna has engaged Amazon Web Services (AWS) (located in Ireland) to host the Community platform and to provide backup services.

From time to time, we may engage third parties to issue you with checks or process the delivery of your rewards, and they will need to use your Identity data and Contact data for those purposes. Such third parties are not permitted to use this data for any other purpose.

From time to time, Toluna may use third-party software for fraud, quality checking, and validation purposes, including, but not limited to speeding.

Though we make every effort to preserve your privacy, we may be required to disclose your personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, or to comply with a subpoena or other legal process when we believe in good faith that disclosure is necessary to protect our rights, to protect your safety or the safety of others, to investigate fraud or breaches of the site terms, or to respond to a government request.

Who is the data controller?

We are the controller and responsible for your personal data.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Do we transfer your personal data to other countries?

From time to time, your personal data is transferred and/or accessed from a Toluna company that is located in a different country.

Toluna uses the following companies to process your personal data for the reasons set out below:

What Cookies do Toluna use on the site?

Cookies are used on the site to distinguish you from other users of the site, helping Toluna to provide you with a good experience when you browse the site and allowing Toluna to improve their site.

If allowed under applicable law, Toluna uses technology to collect and retrieve information from your computer, smartphone, or tablet’s browser when you become a member of the online community such as cookies, pixels, tags, or web beacons (“Cookies”). These Cookies are necessary to make the Toluna platforms and services work and for ensuring you experience better surveys. Most of the cookies are only deployed on your browser when you log in to your account to take a survey.

For detailed information on the cookies used and the purposes for which they are used, see the Cookie Policy attached.

What other Tracking Technologies do Toluna use?

Automated technologies or interactions. As you interact with the site, Toluna will automatically collect on our behalf Technical data about your equipment, browsing actions, and patterns. We collect this Technical data by using cookies, server logs, digital fingerprinting technologies, and other similar technologies. We may also receive Technical data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

Server log files: Toluna may collect on our behalf Internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. This Technical data may be combined with other information collected about you for the purposes of improving our services, site functionality, and collecting analytical data.

Fingerprint technologies: In general, digital fingerprinting technologies assign a unique identifier or "Machine-ID" to a user's computer to identify and track your device (“Technology”). The Technology will analyze publicly available information and data obtained from your computer's web browser and from other publicly available data points, including the technical settings of your computer, the characteristics of your computer, and its IP Address, to create a unique identifier, which will be assigned to your device. Toluna uses the Technology for quality control, validation, and fraud detection and prevention purposes, including assisting us in ensuring the integrity of survey results. Appropriate technical and operational processes and procedures will be put in place to ensure that the Technology is safe, secure, and does not cause undue privacy or data security risks, and the Technology will be used and distributed in a professional and ethical manner and in accordance with (a) this privacy notice, (b) any other statements and/or disclosures made to you as a member of the community, and (c) applicable laws and market research codes of practice. In the event any unethical conduct is discovered in connection with the use of the Technology or that the Technology is being used in a manner that is inconsistent with the privacy notice, immediate action will be taken to prohibit such unethical conduct and to ensure the proper administration of the Technology.

What security measures do we undertake to protect your personal data?

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data in accordance with 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 or supervisory authority of a breach where we are legally required to do so.

What are our data retention and destruction policies?

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfill 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 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 requirements.

As the results of the surveys and other aggregated or Pseudonymized data are used for research and/or statistical purposes, we and other third parties may use this information in accordance with the terms indefinitely without further notice to you.

Links

From time to time, we may offer visitors the ability to voluntarily link to other sites. Toluna does not review and is not responsible for the content or effect of the privacy policies of these sites.

Children’s privacy

We will not knowingly collect any information online from a minor without permission from his/her parents, legal guardian, or an adult responsible for the care of the child. We comply with local applicable law and the ESOMAR guidelines in relation to online surveys concerning minors.

Your rights

How do you access your information; use the member services area and/or update, correct, or delete your information?

Upon request, we will provide you with information about what personal data we may hold about you. You may access, correct, or request deletion of your personal data or terminate your membership by logging into your Community Account. By following the appropriate directions, your information should be automatically updated in our database. For these purposes, and if you are unable to correct your personal data yourself via your Community Account, you may write to us at the postal address found at the end of this Privacy notice or contact us by email at support@christianbookinsiders.com. We will respond to all requests within a reasonable timeframe.

How do you opt out from your community membership?

If you choose to end your membership with the Community or require us to cease processing your personal data, you may discontinue your membership by going to “Account” and selecting “Unsubscribe Options” in the footer. By following the appropriate directions, your record will be marked as "do not contact," and you will no longer receive invites to participate in future Surveys from Toluna. In addition, you will forfeit any incentive balance that has not been requested as of the time you opt out. In most cases, it will take 2 to 3 days to process this change, but please allow up to two full weeks for your status to be finalized. Please note that you may continue to receive communications during this short period after changing your preferences while our systems are fully updated.

You may also send an email directly to contact@toluna.com requesting to be removed. Email links are provided on the site so that you may contact us directly with any questions or concerns you may have. Each email we receive is read and responded to individually; please allow two to three business days for us to get back to you.

How long will you use my data for?

If you decide to terminate your membership, we will no longer use your personal data to contact you, but in accordance with our backup procedures, we will retain your personal data until your personal data are eventually destroyed in accordance with our Data Retention and Destruction Policies and we will continue to employ the security procedures and technologies to keep your personal data safe.

How do you ask a question or make a complaint?

You can direct any questions or complaints about the use or disclosure of your personal data to our Privacy Contact. We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your personal data within 30 days of receiving your complaint.

Your other rights

You may:

• Request access to your personal data, and we may conduct ID checks before we can respond to your request.
• Have your personal data erased, corrected, or restricted if it is inaccurate or requires updating. You may also have the right under certain circumstances to request deletion of your personal data; however, this is not always possible due to legal requirements and other obligations and factors. You can update your account information via your Account or by contacting us at the address given below.
• Object to the processing of your personal data if we are not using your personal data for the purposes set out in this privacy policy.

Your legal rights if you reside in California

You have certain rights under the California Consumer Privacy Act 2018 (CCPA) if you are a citizen of California. You can exercise the above rights by:

• calling us on the toll-free number 877-438-4224.
• emailing us at support@christianbookinsiders.com.
• writing to us at the address given under the Privacy Contact Details; or
• following the process under the paragraph How do you opt out of your community membership? Above.

If you wish to opt out of our Membership program, you may do so in accordance with the process under the paragraph How do you opt out of your community membership? above. Once you make an opt-out request, we will remove you from our community, and we will not contact you again unless you decide to re-register with us.

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not exclude you from participating in any activities you may be eligible for on the basis that you are exercising your CCPA rights.

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on the date at the top of this privacy policy.

If we decide to change our privacy notice, we will post those changes to this privacy statement on the homepage, or other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.

We reserve the right to modify this privacy statement at any time, so please review it frequently. If we make material changes to this policy, we will notify you here, by email, or by means of a notice on our home page prior to the change becoming effective.

It is important that the personal data we hold about you is accurate and current. Please keep your Account details updated if your personal data changes during your relationship with us.

Privacy contact details

You may contact us by email at privacypolicy@harpercollins.com or writing to: