BACKGROUND:

Hillbury Publishing Ltd understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our publication readers and website visitors and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

Information About Us

We are Hillbury Publishing Ltd.We are a Limited Company registered in England under company number 03511866.Registered address: 25A Hillbury Road, London SW17 8JT.Main trading address: 25A Hillbury Road, London SW17 8JT. Data Protection Officer: Mark Hayes.Email address: mark.hayes@autismeye.com.Telephone number: +44 (0)20 8673 8496.

Postal Address: Hillbury Publishing Ltd, 25A Hillbury Road, London SW17 8JT.

What Does This Notice Cover?

This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.

What is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.The personal data that we use is set out in Part 5, below.

What Are My Rights?

Under the GDPR, you have the following rights, which we will always work to uphold:

11. The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
12. The right to access the personal data we hold about you. Part 10 will tell you how to do this.
13. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
14. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 11 to find out more.
15. The right to restrict (i.e. prevent) the processing of your personal data.
16. The right to object to us using your personal data for a particular purpose or purposes.
17. The right to data portability. This means that if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
18. Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

What Personal Data Do You Collect?

We may collect some or all of the following personal data (this may vary according to your relationship with us):

• Name;
• Address;
• Email address;
• Business name if you voluntarily supply this as part of a paid subscription;
• Occupation, but only extending to basic information supplied when subscribers tick a choice of box that forms part of our subscription sign-up form;
• Location, again only extending to basic information provided when subscribers tick a choice of box that forms part of our subscription sign-up form. In fact, this is restricted to a choice of just four: UK, US, Europe and Rest of the World;
• Basic payment information if you take out a paid subscription, but only insofar as it enables us to administer a database of such paid subscriptions and send timely copies of our publications or subscription reminders. This does not include financial information, which is processed securely elsewhere;

How Do You Use My Personal Data?

Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for one of the following purposes:

• Providing and managing your account.
• Supplying our products or services to you. Your personal details are required in order for us to enter into a contract with you.
• Communicating with you. This may include responding to emails or calls from you.
• Supplying you with information by email or post that you have opted-in to (you may unsubscribe or opt-out of email communications at any time by clicking the unsubscribe link in every Autism Eye Newsletter email or Autism Eye digital issue email that we send you. You may also unsubscribe by sending an email to Mark Hayes at mark.hayes@autismeye.com, stating sufficient details about your subscription for us to be able to find it within our systems.

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email or telephone or post with information, news, and offers on our products or services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.

How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

• We keep name and address details of print issue subscribers for one to two years so that we can send reminders to readers suggesting they may like to re-subscribe after a 12-month subscription runs out. We also keep name and address details of print issue subscribers who have auto-renewing print issue subscriptions for one to two years in order to streamline our administration when these subscriptions renew;
• With regard to digital issue subscribers, the details provided at sign-up remain on a MailChimp database. This records whether you have unsubscribed or whether our emails to you bounce, so that we no longer send you emails unless you choose to re-subscribe.

How and Where Do You Store or Transfer My Personal Data?

We share your data with external third parties, as detailed below in Part 9, that are based outside of the EEA. The following safeguards are applied to such transfers:We will only transfer your personal data to countries that the European Commission has deemed to provide an adequate level of personal data protection. More information is available from the European Commission.Where we transfer your data to a third party based in the US, this may be protected if they are part of the EU-US Privacy Shield. This requires that third party to provide data protection to standards similar levels of data protection to those in Europe. More information is available from the European Commission.Please contact us using the details below in Part 11 for further information about the particular data protection mechanism used by us when transferring your personal data to a third country.The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:

• Storing digital subscription details with a reputable third party, MailChimp; and storing print issue subscription details with another reputable third party, Dropbox. Access to both of these sources is password-protected and restricted to our publisher and website designer in the case of MailChimp, and only to our publisher in the case of Dropbox. We do not hold any personal financial information such as credit card details.

Do You Share My Personal Data?

We may sometimes contract with the following third parties to supply products or services to you on our behalf. These may include payment processing, delivery, and marketing. In some cases, those third parties may require access to some or all of your personal data that we hold.

• We use PayPal for the processing of payments to us, such as for paid subscriptions or downloads of digital issues.
• We use MailChimp for the processing of our emails to subscribers of our Autism Eye Newsletter and digital versions of our Autism Eye Magazine.
• We use a magazine printer, and we may use a mailing house if we choose to do so. This is only for the purpose of mailing out printed copies of Autism Eye Magazine.
• We do not sell or rent any details of subscribers to other companies for their own marketing purposes.

If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8.

If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above in Part 8.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11.There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.We will respond to your subject access request usually within two weeks and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Mark Hayes):

Email address: mark.hayes@autismeye.com Telephone number: +44 (0)20 8673 8496 Postal Address: Hillbury Publishing Ltd, 25A Hillbury Road, London SW17 8JT

Changes to this Privacy Notice

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.Any changes will be made available within this section of our privacy policy and will also be added elsewhere if this is appropriate.