1 INTRODUCTION

1.1 Who we are

Basilica Services Ltd trading as ‘Novabook’ (we, us or our), is registered in England and Wales with company number 15483290, with its registered address at 70 Westgate, Hale, Altrincham, England, WA15 9BB. 

Welcome to our Privacy and Data Protection Notice (Privacy Notice). 

We are committed to protecting and respecting your privacy and Personal Data (as defined below) in compliance with the United Kingdom General Data Protection Regulation (GDPR), the Data Protection Act 2018 and all other mandatory laws and regulations of the United Kingdom. 

We are your data controller and responsible for your Personal Data. This Privacy Notice explains how we collect, process and keep your data safe. The Privacy Notice will tell you about your privacy rights, how the law protects you, and how we inform our employees and staff members of their obligations and protocols when processing data. 

1.2 How your Personal Data is collected 

We only collect and process data about you where we have a reason for doing so that is permitted under applicable laws. 

We may collect and use data gathered from different sources: 

• Direct interactions with customers. You may give us your Personal Data through corresponding with us by post, phone, email or otherwise. This includes Personal Data you provide when you:
• purchase our services;
• submit a form via our website;
• agree that marketing can be sent to you;
• interact with us on social media; or 
• give us feedback or contact us. 
• Automated technologies or interactions. As you interact with our website, we will automatically collect technical data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies, server logs and other similar technologies. Please see the Cookies Policy for further details. 
• Third parties or publicly available sources. We will receive Personal Data about you from various third parties and public sources as set out below:

- technical data from analytics providers, advertising networks and search information providers;

- identity, contact, financial and transaction data from credit reference and fraud prevention agencies, as well as other sources such as electoral roll, court records of debt judgements and bankruptcies, and other providers of technical, payment and delivery services; and

- identity and contact data from other affiliates or partners, as well as publicly available sources.

1.3 Monitoring of communications

Subject to applicable laws, we may monitor and record your communications with us such as calls, video calls, emails, texts and social media messages. We do this for regulatory compliance, quality control and staff training.

1.4 Types of data we collect about you

Personal Data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed. 

We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together below. Not all of the following types of data will necessarily be collected from you, but this is the full scope of data that we may collect for one or more of the purposes stated in this Privacy Notice. 

If you provide any Personal Data on behalf of other named individuals, you must have their authority to provide such Personal Data to us and share this Privacy Notice and any related data protection statement with them beforehand. 

General data captured: 

• profile/identity data: this is data relating to your first name, last name and company name;
• contact data: this is data relating to your phone number, address and email address;
• marketing and communications data: this is your preferences in receiving marketing information and other information from us;
• billing data: this is information relating to your billing arrangements such as the name attached to your payment details, billing address, account number and sort code; 
• transactional data: this is information of details and records of all payments you have made for our services;
• technical data: including internet protocol (IP) address, access times, any websites you linked from, pages you visit, the links you use, the ad banners and other content you view, your login data, browser type and version, information about your device, 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 our website;
• usage data: including information about how you use our services;
• vulnerability data: including information on any personal circumstances affecting you such as age, disabilities or health conditions, so that we can be mindful when we interact with you; and
• biometric data: such as face and voice recordings which may be used for the purposes of identification, fraud prevention and training and monitoring. 

We also collect, use and share aggregated data of our customers. 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 Notice. 

We may also aggregate data to enable research or analysis so that we can better understand and serve you and others. For example, we may conduct research on your demographics and usage. Although this aggregated data may be based in part on Personal Data, it does not identify you personally. We may share this type of anonymous data with others, including service providers, our affiliates, agents and current and prospective business partners. 

We do not collect details of your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions or trade union membership. 

1.5 The legal basis for collecting that data 

There are a number of justifiable reasons under the GDPR that allow collection and processing of Personal Data. The main avenues we rely on are: 

Consent: Certain situations allow us to collect your Personal Data, such as when you tick a box that confirms you are happy to receive email newsletters from us, or ‘opt in’ to a service. If you provide us with consent, you may withdraw it any time by contacting us. 

Performance of contract: We may require certain information from you in order to fulfil our contractual obligations and provide you with the promised service. 

Legal obligation: We are required by law to collect and process certain types of data, such as fraudulent activity or other illegal actions. 

Legitimate interest: We might need to collect certain information from you to be able to meet our legitimate interests. These cover aspects that can be reasonably expected as part of running our business, which will not have a material impact on your rights, freedom or interests. Examples could be your address, so that we know where to deliver something to, or your name, so that we have a record of who to contact moving forwards. 

2 HOW WE USE YOUR PERSONAL DATA 

2.1 Our uses 

We will only use your Personal Data when the law allows us to. Please refer to section 1.5 for more information on the lawful basis for the data uses listed below. 

Examples provided in the list below are indicative in nature. The purposes for which we use your data may be broader than described, but we will never process your data without a legal basis for doing so and it is for a related purpose.  

• Registering you as a new customer and maintaining such records.
• Processing your order, including invoicing, managing payments and collecting money.
• Monitoring payment performance, ongoing account management and recovering overdue payments.
• Communicating with you about any enquiry.
• Managing our relationship with you which will include verifying your identity if you contact us, notifying you about changes to our terms or this Privacy Notice, and asking you to leave a review or take a survey.
• Administering and protecting our business and our website, including troubleshooting, testing, data analysis, testing, system maintenance, support, reporting, hosting of data, research and risk management.
• Delivering relevant website content (including pop ups) and advertisements to you, and measuring and understanding the effectiveness of the advertising we serve to you. Such processing includes matching and aggregating of your Personal Data with internal and external sources.
• Using data analytics including which parts of our website you visit to improve our website, services, marketing, customer relationships and experiences.
• Calling you on the telephone to discuss our services and to offer any other services. 
• Complying with legal obligations and preventing crime, and to conduct anti money laundering checks. 
• Improving our service quality including providing training for our employees to ensure that we provide you with the best possible service and call recording for training, compliance and legal or regulatory reasons.

2.2  Marketing and content updates

We may use your identity, contact and technical data to form a view on what we may think you may want or need, or what may be of interest to you. 

You will receive marketing and new content communications from us unless you specifically request that you do not want to receive these communications. From time to time, we may make suggestions and recommendations to you about services that may be of interest to you, provided you have not opted out of receiving that marketing. 

2.3 Change of purpose 

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. 

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. 

3  HOW YOUR DATA IS PROTECTED BY US AND YOUR RIGHTS 

3.1 How we protect your Personal Data

Keeping your data secure and protecting it from inappropriate disclosure is important to us. Once we receive your data, we apply these security measures in line with good practice and GDPR: 

• Step One: Protect from cyber threats - we store your data on our secure servers, or those of our third party data storage providers. 
• Step Two: Define permitted purposes – for which we are able to use that data in accordance with this Privacy Notice. 
• Step Three: Limit accessibility - where reasonably possible only to those employees or third parties that need it for those permitted purposes. 
• Step Four: Protect from physical threats – all our employees’ computers and also our offices have security measures to prevent unauthorised access. Third parties with their limited access, do so in accordance with the security measures we put in our agreements with them. 
• Step Five: Secure disposal of data - when it is no longer needed in line with this Privacy Notice. 

3.2 Control you have over our use of your Personal Data

You may have the following rights: 

• access – request a copy of your data and information relating to how it is processed;
• rectify – request any inaccuracies in the data we hold about you to be corrected;
• erasure – request that we erase your data from our records;
• restrict – request that your data is no longer processed by us;
• object – object to certain ways that we process your data; 
• transfer – request that your data be shared with a third party; 
• withdraw your consent – where we are relying on your consent to process your data, you can withdraw your consent at any time; and
• lodge a complaint – you may be entitled to lodge a complaint with your local data protection authority. 

You will need to contact us to exercise any of your rights. We try to respond to all legitimate requests without undue delay but within no longer than one month. Occasionally it could take longer than a month if your request is particularly complex or you have a number of requests. In this case we will notify you and keep you updated. 

3.3  How to request your data and the process for obtaining it 

You will not have to pay a fee to access your Personal Data or to exercise any of the other rights. However, if your request is clearly unfounded, we could refuse to comply with your request. 

We may need to request specific information from you to help us confirm your identity and ensure you have the 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. 

3.4  Opting out of marketing promotions 

You can ask us to stop sending you marketing messages at any time by using the ‘unsubscribe’ option in emails or your customer account on our website, or contacting us via email.  

Where you opt out of receiving these marketing messages, we will continue to retain other Personal Data provided to us as a result of interactions with us not related to your marketing preferences. 

4 YOUR DATA AND THIRD PARTIES 

4.1 Will we share your data with third parties? 

We may share your Personal Data with the third parties set out below for the purpose set out in section 2 above. We have agreements in place with these parties to ensure compliance with GDPR, and to use your Personal Data only for the purposes for which we disclose it to them and pursuant to our instructions. 

• Suppliers – for the purposes of delivering, installing and maintaining services purchased from us. 
• Partners – to help you explore or sign up to services provided by them if you indicate to us that you are interested in them. Please note that we will always ask for your consent before sharing your data. 
• IT service providers – including hosting providers, service providers and telecommunications providers to manage our business and support our environment and operations. 
• Marketing service providers – who may, through the course of their professional services to us be required to have access to our services for providing required hosting services, database marketing and customer analytics. 
• Third party payment providers – to process payments from you. 
• Debt recovery and tracing agencies – only as a last resort if there are overdue payments that we were unable to resolve directly with you and in accordance with applicable laws. 
• Professional advisors – including lawyers and other professional advisors to support compliance and corporate governance functions. 
• Prospective purchasers and assignees – if our business, or part of it, is sold or reorganised we may transfer your Personal Data to the buyer, but only to the extent that we need to and to be used in accordance with this Privacy Notice. We do this because we have a legitimate interest to ensure the business can be continued by the buyer. 

We may share your Personal Data at any time if required for legal reasons or in order to enforce our terms or this Privacy Notice. 

4.2  Third-party links

Our website may include 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 and are not responsible for their privacy notices. When you leave our website, we encourage you to read the privacy notice of every website you visit. 

5 HOW LONG WILL WE RETAIN YOUR DATA FOR? 

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 than usual in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. 

By law we have to keep basic information about our customers relating to purchases (including contact, identity, financial and transaction data) for six years after they cease being customers for tax and other regulatory purposes. As a legal requirement we retain your transaction data for a period of ten years after your purchase. 

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 such case we may use this information indefinitely without further notice to you. 

6 AGE LIMIT FOR OUR USERS 

You must not use our services unless you are aged 18 or older. If you are under 18 and you access our services by lying about your age, you must immediately stop using our services. 

7 INTERNATIONAL TRANSFERS OF DATA 

Whilst we are based in the UK, we work with third parties based elsewhere. Their processing of your data may involve us needing to transfer it outside of the European Economic Area (EEA). Whenever we do this, we will always ensure appropriate safeguards are in place so there is a similar degree of protection as if it were being processed in the UK. For example, our contracts with third parties stipulate the standards they must always follow. If you wish for more information about these contracts, please contact us using the details below. Any transfer of Personal Data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Notice. 

8 NOTIFICATIONS OF CHANGES AND ACCEPTANCE OF THIS PRIVACY NOTICE

We keep this Privacy Notice under review and will place any updates on our website. By using our services, you consent to the collection and use of data by us as set out in this Privacy Notice. Continued access or use of our services will constitute your express acceptance of any modifications to this Privacy Notice. 

9 CONTACT DETAILS

Should you require any further details regarding our treatment of Personal Data, please contact our Data Protection Officer, Lukas Feddern by email at lukas@novabook.com or by letter to Lukas Feddern, Novabook, 123 Buckingham Palace Road, London SW1W 9SH. 

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. You can access their website for further information and also live chat (www.ico.org.uk), or call them on 0303 123 1113. We would, however, appreciate the chance to deal with your concerns before you approach the ICO. 

10 INTERPRETATION 

All uses of the word including mean ‘including but not limited to’ and the enumerated examples are not intended to in any way limit the term which they serve to illustrate.  

Our staff are not authorised to contract on our behalf, waive rights or make representations (whether contractual or otherwise). The only exception to this is genuine correspondence expressed to be from our legal department.

Last updated 12 June 2024