This privacy policy, effective September 15, 2020, outlines our privacy practices exclusively as it relates to the Survey for the Penguin Random House Audit of its Publishing Houses. This page does not apply to our handling of personal data outside of that specific use case. If you are looking for our Author Portal Privacy Policy please click here.
EFFECTIVE DATE OF PRIVACY POLICY: SEPTEMBER 15, 2020
Penguin Random House LLC (“PRH”, “we”, “us”, or “our”) respects your concerns about privacy and values the relationship we have with you. This Privacy Policy describes our privacy practices with respect to information collected through the Author Survey to support the Audit of the PRH US Publishing Program (the “Survey”) only. It does not apply to information collected from you offline or through other websites or online services operated by PRH or its affiliates. If you use or link to any of those websites or services from this Survey, please take a moment to review their privacy policies.
By participating in the Survey for the Audit of the PRH US Publishing Program, you are accepting the practices described in this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not participate in the Survey. We reserve the right to modify or amend the terms of our Privacy Policy from time to time without notice.
WHAT INFORMATION WE COLLECT ABOUT YOU
Information You Provide Directly To Us:
You provide personal and non-personal information directly to us in several situations, including when you respond to the Survey. Such information includes, but is not limited to, your name, email address, and certain demographic information.
Information Collected Using Technology:
When you visit the Survey site or interact with emails we send you, we may collect certain non-personal information about your usage or device by automated means or by using the following technologies:
- Cookies (or browser cookies). A cookie is a small text file placed on the hard drive of your computer or other Internet-connected device that uniquely identifies your browser to store information or settings in your browser. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to use all of the features of the Survey site.
- Web Server Logs. In conjunction with obtaining information through cookies, our web servers may log details such as your operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone in which your device is located. The web server logs also may record information such as the address of the web page that linked you to our Survey and the IP address of the device you use to connect to the Internet.
- Web Beacons. Pages of the Survey site and our emails to you may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count how many times those pages have been visited and for other related Survey site statistics.
Third Party Web Analytics Services
We may use third party web analytics services on the Survey and in emails we send to you. The service providers that administer these services also use technologies such as cookies, web server logs, web beacons and similar technologies to help us analyze how you use the Survey and our emails.
California Do Not Track Notice
Some browsers offer a “Do Not Track” feature that lets you tell websites that you do not want to have your online activities tracked. We do not respond to these “Do Not Track” signals. At this time, we do not track your personal information about your online activities over time and across third party websites. We also do not authorize third parties to collect any personal information from you on this website for these purposes.
HOW WE USE YOUR INFORMATION
We may use the information that we collect via the Survey for a variety of purposes, including to:
- Provide you with the services you request
- Communicate with you and send you information about the Survey
- Communicate with you about changes to our policies
- Maintain or administer the Survey to perform business analyses, or for other internal purposes to optimize or improve the quality of our business, the Survey, and the products and services we offer
- Detect, investigate, and prevent activities that may violate our policies or be illegal
- As otherwise described to you at the point of collection or pursuant to your consent
WHO WE SHARE YOUR INFORMATION WITH
Except as described below, we do not disclose your personal information to any person or entity outside PRH. In no event will we sell or rent your personal information as part of a customer list or similar transaction without your express permission.
Third Party Service Providers
We may share your personal information with third party service providers that perform functions on our behalf. These entities have access to your information only as needed to perform their functions.
Corporate Parents and Affiliates
We may share your personal information with our corporate parents and other affiliated entities for a variety of purposes, including business and operational purposes.
Other Third Parties When Required By Law or In Emergency Situations
We may also use or disclose personal information if required to do so by law or in the good-faith belief that such action is necessary to (a) conform to applicable law or comply with legal process served on us; (b) protect and defend our rights or property, the Survey or our users, and (c) act under emergency circumstances to protect the personal safety of us, our affiliates, agents, or the users of the Survey or the public.
Other Parties In Connection With a Transaction
We may change our ownership or corporate organization while engaging in the Survey. We may also sell certain assets associated with the Survey. In such event, we may transfer some or all of your personal information to a company acquiring all or part of our assets or to another company with which we have merged. Under such circumstances we would, to the extent possible, require the acquiring party to follow the practices described in this Privacy Policy, as it may be amended from time to time. Nevertheless, we cannot ensure that an acquiring company or the merged company will have the same privacy practices or treat your information the same as described in this Privacy Policy.
Other Parties With Your Consent
We may share personal information about you with other third parties when you consent to such sharing.
In addition to the disclosures above, we may disclose non-personal information to third parties, such as aggregate website usage data or demographic reports that do not describe or identify individual users.
SECURITY OF YOUR PERSONAL INFORMATION
PRH takes reasonable steps to help protect and secure your personal information. However, please remember that no data storage or data transmission over the Internet, or by other means, can be guaranteed to be 100% secure. Thus, PRH cannot ensure or warrant the security of any information you transmit to us. Therefore, you understand, acknowledge and agree that you transmit your personal information to the Survey at your own risk.
THIRD PARTY CONTENT AND LINKS TO THIRD PARTY WEBSITES
The Survey may contain content hosted or served by third parties or link to websites operated by third parties. Please be advised that the practices described in this Privacy Policy for PRH do not apply to information gathered by these third parties. We are not responsible for the actions and privacy policies employed by any third party, and our hosting of third party content or linking to third party websites does not constitute an endorsement of the content or business practices of those third parties.
GOVERNING LAW
The Survey is conducted in the United States. We attempt to protect the personal information of all users of the Survey and we attempt to comply with local data protection and consumer rights laws to the extent they may apply to PRH’s services, but the Survey is conducted in the United States and our policies are directed at compliance with those laws. If you are uncertain whether this Privacy Policy conflicts with the applicable local privacy laws where you are located, you should not submit your personal information to PRH.
NOTICE TO NON-US USERS
If you are located outside the United States of America, you should be aware that your personally identifiable information will be transferred to the United States of America, the laws of which may be deemed by your country to have inadequate data protection. If you are located in a country outside the United States of America and voluntarily submit personally identifiable information to us on the Survey, you thereby consent to the general use of such information as provided in this Privacy Policy and to the transfer of that information to, and/or storage of that information in, the United States of America.
CHANGES TO THIS PRIVACY POLICY
As the Survey continues to develop, we may add new services and features to it. In the event that these additions affect our Privacy Policy, or if other changes in our privacy practices or applicable laws necessitate changes to the Privacy Policy, this document will be updated accordingly. If we make a material change in the way we use your personal information, we will provide prominent notice of the change via email.
HOW TO OPT-OUT OR CORRECT YOUR INFORMATION
You may always opt-out of receiving future commercial emails and newsletters from PRH. We provide you with the opportunity to opt-out of receiving such communications from us by clicking on the “unsubscribe” link within the email you receive. Please note that your request not to receive unsolicited commercial emails from us will not apply to messages that you request or that are not commercial in nature.
ADDITIONAL INFORMATION REGARDING CALIFORNIA
Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), we are providing the following additional details regarding the categories of Personal Information about California residents that we collect, use, disclose or sell: Under the CCPA, “Personal Information” is information that identifies, relates to, describes, or could reasonably be associated or linked with a particular California resident or household.
Collection of Personal Information
We plan to collect, and have collected within the preceding 12 months, the following categories of Personal Information:
- “Identifiers.” Identifiers, such as name, alias, contact information, unique personal identifiers, and online identifiers;
- “Protected Class Information.” Characteristics of protected classifications under California or federal law, such as sex, age and race;
- “Online Use Information.” Internet or network activity information, such as browsing history, interest data and interactions with our websites;
- “Geolocation Data.” Geolocation data such as device location and approximate location derived from IP address;
- “Audio/Video Data.” Audio, electronic, visual and similar information, such as images and audio, video or call recordings created in connection with our business activities;
- “Employment Information.” Professional or employment-related information, such as job title and work history;
Where We Obtain Personal Information From
As described above, we collect this Personal Information from you and from other categories of sources, including publicly available databases, social media platforms and third party service platforms, and our business customers, clients and partners, when they share this information with us.
Our Use of Personal Information
Also as described above, we may use this Personal Information to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives, including, for example, using Personal Information to: develop, improve, repair, and maintain our products and services; conduct research, analytics, and data analysis; maintain our facilities and infrastructure; undertake quality and safety assurance measures; conduct risk and security control and monitoring; detect and prevent fraud; perform identity verification; perform accounting, audit, and other internal functions, such as internal investigations; comply with law, legal process, and internal policies; maintain records; and exercise and defend legal claims.
Disclosure and Sale of Personal Information
We share Personal Information with the following categories of third parties:
- “Affiliates.” We share with our affiliates for the purposes described in this Privacy Policy.
- “Other Users.” We share information that is posted in public areas of our website with other users of our website.
- “Service Providers.” We share with our trusted third-party service providers, to facilitate services they provide to us, such as internet services, website hosting, data analytics, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, marketing, auditing, background checks, and other services.
- “Social Networks.” We share with social network platforms, who use the data we share in accordance with their own privacy policies.
- “Business Partners.” We share with our trusted business partners.
- “Legal Authorities.” We share with public and government authorities, including regulators and law enforcement, to respond to requests, as well as to protect and defend legal rights.
- “Other Parties in Litigation.” We share information in the context of litigation discovery and in response to subpoenas and court orders.
YOUR CCPA RIGHTS
Requests to Know, Requests to Delete and Requests to Opt-Out
If you are a California resident, you may request that we:
1. Disclose to you the following information covering the 12 months preceding your request (“Request to Know”):
- The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
- The specific pieces of Personal Information we collected about you;
- The business or commercial purpose for collecting or selling (if applicable) Personal Information about you;
- The categories of Personal Information about you that we sold and, for each, the categories of third parties to whom we sold such Personal Information (if applicable); and
- The categories of Personal Information about you that we otherwise shared or disclosed, and, for each, the categories of third parties with whom we shared or to whom we disclosed such Personal Information (if applicable).
To make a request for the disclosures, please email privacy@penguinrandomhouse.com with the subject line Author Privacy.
2. Delete Personal Information we collected from you. (“Request to Delete”)
To make a request for deletion, please email privacy@penguinrandomhouse.com with the subject line Author Privacy.
3. Opt you out of any future “sale” of Personal Information about you by emailing privacy@penguinrandomhouse.com with the subject line Author Privacy. (“Request to Opt-out”)
You may also make the requests described above by contacting us in accordance with the “How to Contact Us” section below.
We will verify and respond to your Request to Know or Request to Delete consistent with applicable law, taking into account the type and sensitivity of the Personal Information subject to the request. If you maintain a password-protected account with us, we may verify your identity through our existing authentication practices for your account and require you to re-authenticate yourself before disclosing or deleting your Personal Information. Alternatively, we may send our response to your request to the contact point in our records that is associated with the Personal Information that is requested. If you make a Request to Delete, we may ask you to confirm your request before we delete your Personal Information.
If you are the authorized agent of an author, making a Request to Know or a Request to Delete on behalf of the author, we will ask you for:
1. proof of your registration with the California Secretary of State to conduct business in California.
2. proof that the author has authorized you to make a Request to Opt-Out on the author’s behalf. This must be a permission signed by the author. “Signed” means that the permission has either been physically signed or provided electronically in accordance with the Uniform Electronic Transactions Act, Civil Code 1633.7 et seq.
If an authorized agent has not provided us with a power of attorney from the author pursuant to Probate Code sections 4000-4465, we may also:
1. require the author to provide you with a written permission signed by the author to make the request on the author’s behalf
2. verify the identity of the author as we would if the author were making the request personally.
3. Obtain verification from the author that they provided the authorized agent permission to make the request.
If you are the authorized agent of an author, making a Request to Opt-Out on behalf of the author, we will ask you for:
1. proof of your registration with the California Secretary of State to conduct business in California.
2. proof that the author has authorized you to make a Request to Know or a Request to Delete on the author’s behalf. This must be a permission signed by the author. “Signed” means that the permission has either been physically signed or provided electronically in accordance with the Uniform Electronic Transactions Act, Civil Code 1633.7 et seq.
Right to Non-Discrimination
You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.
HOW TO CONTACT US
If you have any questions about this Privacy Policy, you may contact us as follows:
By mail:
Online Privacy
Attn: Customer Service
Penguin Random House
1745 Broadway
New York, NY 10019
Phone:
(800) 793-2665