This Privacy Notice (Privacy Notice), together with our Cookies Policy, sets out the ways in which GASP PUBLISHING LTD (we, us, our) use and share your personal data (your information) in connection with our publishing business. It also explains your rights to access or change your information.

We are the data controller, which means that we decide how we use and protect your information. We take this responsibility very seriously. You will find the following information in this privacy notice:

• Who we are

• What information we collect about you

• How we use your information

• Who can see your information

• When we share your information

• How we look after your information

• How long we keep your information

• International transfers of your information

• Your rights and choices

WHO WE ARE

GASP Publishing Ltd is registered in England under company number 11586899, with its registered address at Brierly Place, New London Road, Chelmsford, Essex, England, CM2 0AP. You can contact us at connect@gasp.life.

WHAT INFORMATION WE COLLECT ABOUT YOU

Information you provide: you might provide us with: your name, postal address, email address, phone number, gender and date of birth. If you're ordering books from us you’ll provide your payment details. If you’re submitting a manuscript or job application, you’ll provide additional information about your academic and work history, references and any other information you choose to supply. Your information includes anything which identifies you.

Information we collect: we collect your information when you: • interact or correspond with us in letters, by phone, SMS, email or via our website; • attend events we hold or interact with us in person • subscribe to our mailing lists; • complete one of our surveys; • submit manuscripts to us by post, email or via our website; • enter into a contract with us; • apply for a job with us; • order books or other products from our website; • enter a competition or prize draw;• visit our webpage (in regards to retargeting adverts) and • provide us with biographical information about you (e.g. by completing an author questionnaire).

Information about how you use our website and apps: we also collect certain information about how you use our website and apps. This includes your IP address, geographical location, information about the devices that you use to access our website and apps, browser type, referral source, length of visit to the website, number of page views, the search queries you make on the website and similar information. This information is collected by Google Analytics on our behalf and by some of our apps using cookies. For more information on cookies, please read our Cookies Policy. Our website may include links to third party websites, plug-ins and applications. By clicking on those links or enabling these connections you may allow third parties to collect or share data about you. We don’t control these websites and aren’t responsible for their privacy arrangements.

Information we receive from third parties: in certain circumstances, we will receive information about you from third parties. For example: • we may use third party providers to verify information provided by you in connection with any manuscript you submit to us for publication - e.g. to confirm your publication history; • we will receive information about you from third parties if they are referring you to us for publication – e.g. if you have a literary agent making submissions on your behalf, your agent will provide us with information about you; • if you’re a job applicant, we may contact your referees to provide information about you; • if you give permission for us to connect you to a bookseller or other third party running a competition or other event involving one of our books or authors; and • when we acquire publishing rights from other publishers.

HOW WE USE INFORMATION ABOUT YOU

We use your information lawfully and we will never sell your information to third parties. If we share your information, we will do so in accordance with the section of this policy called ‘When we share your information’.

This is how we use your information and the legal bases for our use:

When we have your consent to contact you, we may use your information to: • to keep in contact with you and provide you with marketing communications about our news, events, authors or books that we believe may interest you; • tell you about new website features or services; • send you newsletters; • share your information with third parties such as authors, co-publishers or marketing partners so that they can contact you with information that might interest you (as described in the section, ‘When we share your information’);

In the following circumstances we will use your information to carry out our contract with you: • to process your requests to purchase our products from our website; • to provide customer service and support; • if you’re an author, illustrator or other licensor to administer your publishing contract including receipt, review, editing, production, marketing of your manuscript and payment of your royalties.

Sometimes we will use your information on the basis of our 'legitimate business interests' (legitimate interests). This means our legitimate interests in conducting and managing our business and our relationship with you.

Where we use your information for our legitimate interests, we make sure that we take into account any potential impact of such use on you. Our legitimate interests don’t automatically override yours and we won’t use your information if we believe that your interests should override ours unless we have other grounds to do so (such as your consent or a legal obligation). If you have any concerns about how we process your information, you have rights and choices including the right to object (please see the section headed ‘Your Rights and Choices’).

We may use your information for the following purposes on the basis of our legitimate interests: • to contact you about products you bought from us; • to contact you about submissions you made or content you provided to us; • to respond to your queries and correspondence; • to administer your account with us; • to process any job applications that you submit to us; • to deal with enquiries or complaints about our website as necessary to provide customer support in providing the correct products and services to our website users; • to carry out aggregated and anonymised research about general engagement with our website in providing the right kinds of products and services to our website users; • to operate a safe and lawful business or where we have a legal obligation; • to enable us to comply with our policies and procedures and enforce our legal rights, or to protect the rights, property or safety of our employees; • to measure or understand the effectiveness of our advertising; • to deliver relevant advertising and make relevant recommendations and suggestions to you about our products and services; • to analyse your use of our websites and apps and your responses to our communications; • to personalise, enhance, modify or otherwise improve the services and/or communications that we provide to you; • to detect and prevent fraud and unauthorised access or illegal activity; • to improve security and optimisation of our network sites and services including trouble shooting, testing and software development and support; • to work with third party recruitment agencies to process any job applications you submit to us.

gasp.life also uses 3rd party vendor re-marketing tracking cookies, including the Google Adwords tracking cookie. This means we will continue to show ads to you across the internet, specifically on the Google Content Network (GCN). As always we respect your privacy and are not collecting any identifiable information through the use of Google’s or any other 3rd party remarketing system.

The third-party vendors, including Google, whose services we use – will place cookies on web browsers in order to serve ads based on past visits to our website. – Third party vendors, including Google, use cookies to serve ads based on a user’s prior visits to your website. This allows us to make special offers and continue to market our services to those who have shown interest in our service.

In addition to using cookies and related technologies as described above, we also may permit certain third party companies to help us tailor advertising that we think may be of interest to users and to collect and use other data about user activities on our Sites and/or Services (e.g., to allow them to tailor ads on third party services). These companies may deliver ads that might also place cookies and otherwise track user behavior.

This website uses the Google AdWords remarketing service to advertise on third party websites (including Google) to previous visitors to our site. It could mean that we advertise to previous visitors who haven’t completed a task on our site, for example using the contact form to make an enquiry. This could be in the form of an advertisement on the Google search results page, or a site in the Google Display Network. Third-party vendors, including Google, use cookies to serve ads based on someone’s past visits to the [CLIENT NAME] website. Of course, any data collected will be used in accordance with our own privacy policy and Google’s privacy policy.”

We use Google AdWords Remarketing to advertise trigger across the Internet. AdWords remarketing will display relevant ads tailored to you based on what parts of the TriggerApp website you have viewed by placing a cookie on your machine. THIS COOKIE DOES NOT IN ANYWAY IDENTIFY YOU OR GIVE ACCESS TO YOUR COMPUTER The cookie is used to say “This person visited this page, so show them ads relating to that page.” Google AdWords Remarketing allows us to tailor our marketing to better suit your needs and only display ads that are relevant to you.”

WHO CAN SEE YOUR INFORMATION

Our staff or the staff of third party service providers may process your information on our behalf. Processing can mean any activity that involves the use of information about someone that can identify them. All uses of your information - for example, obtaining, recording, storing, disclosing, organising, retrieving, deleting and destroying - are types of data processing.

We take measures to ensure that third parties who process your information on our behalf are acting lawfully in accordance with our instructions and are subject to appropriate confidentiality requirements. We also have adequate technical and organisational safeguards in our company and with third party processors to protect your information. Third party processors of your information include: • our website hosts and operators, IT support providers, database operators, site analytics providers and software developers; • our marketing or publicity services providers; • our editorial and production service providers; • our royalty system software provider; • our electronic signature service provider; • our financial services and payment service provider; • our warehousing and delivery service providers; • our auditors, technical consultants and legal advisors; and • our fraud detection services.

WHEN WE SHARE YOUR INFORMATION

Where we share your information outside our group of companies, we will ask you to consent to a third party sharing your information and if you choose to give your permission any interaction you have with a third party is governed by their privacy terms. The third party becomes a joint data controller of your information with us. This means that the third party can make decisions about how to use your information. Before we share your information, we require third parties to enter into a data sharing agreement which stipulates that they must maintain appropriate security to protect your information from unauthorised access, processing or use. We will share your information with the following third parties: • selected publishing partners and authors; • selected marketing partners; • any prospective seller or buyer of businesses or assets, only if we decide to acquire, transfer or sell any business or assets; • any other third parties (including legal or other advisors, regulatory authorities, courts and government agencies) where necessary to enable us to enforce our legal rights, or to protect the rights, property or safety of our employees or where such disclosure may be permitted or required by law or where we have a legal obligation to do so.

HOW LONG WE KEEP IT FOR

We will retain your information for as long as is necessary to provide you with the services that you have requested from us or for as long as we reasonably require to retain the information for our legitimate interests. We operate a data retention policy and look to find ways to reduce the amount of information we hold about you and the length of time that we need to keep it.

For example: • we operate a best practice email retention policy requiring password protected folders and departmental shared drives to provide restricted access to information; • we conduct regular access reviews to keep access profiles and policies up to date; • we retain information relating to orders, refunds and customer queries for approximately 10 years; • we retain information relating to commercial contracts for approximately 7 years after expiration or termination whichever is the sooner; • we maintain a suppression list of email addresses of individuals who no longer wish to be contacted by us. So that we can comply with their wishes we must store this information permanently

INTERNATIONAL TRANSFERS OF YOUR INFORMATION

Our company is located in the UK. Whenever we transfer your personal information out of the European Economic Area (EEA), we will take all steps necessary to ensure that it is adequately protected and processed in accordance with this Privacy Notice by using all appropriate cross-border transfer safeguards such as: • by entering into the European Commission's Standard Contractual Clauses with the provider which give personal data the same protection it has in the EEA; and • where the provider is in the US, the EU-US Privacy Shield if the provider is part of the EU-US Privacy Shield Framework. Please contact us if you would like additional information on the specific means used by us when transferring your personal data outside of the EEA.

YOUR RIGHTS AND CHOICES

Your Right to Object - you can object to us using your information for direct marketing and on the basis of our legitimate interests (refer to section ‘How we use your information’ above to see when we are relying on our legitimate interests). If you want to do this, you can contact us using the details in the section 'Who we are'.

Your Right to Withdraw Consent – you can withdraw your consent for us using your information in reliance of your consent (refer to section ‘How we use your information’ to see when we are relying on your consent). You can do this by contacting us using any of the details in the section 'Who we are'.

Your Other Rights and Choices – in addition, you can also: • request access to the information that we hold about you to check that we are acting lawfully; • receive a copy of any information we hold about you in a format of your choice; • request that we transfer your information to another service provider in a structured, commonly used, machine-readable format; • ask us to correct information we hold about you if it is inaccurate or incomplete; • ask us, in certain circumstances, to delete information we hold about you; • ask us, in certain circumstances, to restrict processing of your information. You may exercise your rights and choices by contacting us using the details above in the 'Who We Are' section. You can also prevent processing for marketing activities by checking certain boxes on forms that we use to collect your data to tell us that you don’t want to be involved in any marketing.

Your Right to Complain - if you have any questions or are unhappy about the way we have used your information, please contact us using the details above in the 'Who We Are' section. We hope that we can resolve any problems or issues that you may have. You can also have lodge a complaint about us and our use of your information to the UK Information Commissioner’s Office (https://ico.org.uk/) or the relevant authority in your country of work or residence.