Privacy Policy

Agatha Christie Ltd (ACL) is aware of its obligations under the General Data Protection Regulation (GDPR) and is committed to processing your data securely and transparently. This privacy notice will inform you how we look after your personal data and tell you about your privacy rights and how the law protects you.

1. IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this Privacy Notice

This privacy notice aims to give you information on how ACL collects and processes your personal data, including any data you may provide through this website when you sign up to our newsletter or take part in a competition.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller

ACL is the controller and responsible for your personal data.

We have appointed a data privacy manager 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 data privacy manager using the details set out below.

Contact Details
Our full details are:
Full name of legal entity: Agatha Christie Limited
Title of data privacy manager: Legal and Business Affairs Manager
Email address: [email protected]
Postal address: 161 Drury Lane, London WC2B 5PN
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 (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the Privacy Notice and your duty to inform us of changes

We reserve the right to make changes to this Privacy Notice from time to time. We will post any such changes to our site and, where appropriate, notify you of any material changes by e-mail.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-Party links on our website

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 statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

The information we collect and process about you will include (depending on the circumstances):

• Identity Data: first name, last name, username.
• Contact Data: addresses, email addresses, and phone numbers.
• Technical Data: internet protocol (IP) address, your 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.
• Profile Data: your username and password and survey responses.
• Usage Data: information about how you use our website.
• Marketing and Communications Data: your preferences in receiving marketing from us and our third parties and your communication preferences.
• Information contained in correspondence: information contained in any correspondence between us. For example, if you contact us using a query button on our website or by email or telephone, we will keep a record of that correspondence.
• We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. 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 do not collect any Special Categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

• Direct interactions: You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email, via our website or otherwise. This includes personal data you provide when you:
  • enter a competition, promotion or survey.
  • request marketing to be sent to you; and
  • subscribe to our newsletters, articles, bulletins, and other mailing lists;
  • create an account on our website;
  • make an enquiry or provide feedback;
• Automated technologies or interactions: As you interact with our website, we may 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.
• Third parties. We may receive personal data about you from various third parties as set out below:
  
  • Technical Data from the following parties:
    • analytics providers;
    • search information providers
  • Identity and Contact Data from data brokers or aggregators.
  • Service providers: we may collect personal information from our third party service providers who are based inside the EU;
  • Website security: we will collect information from our website security service partners who are based inside the EU, about any misuse to the website, for instance, the introduction of viruses, Trojans, worms, logic bombs, website attacks or any other material or action that is malicious or harmful; and

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where it is necessary for our legitimate interests (the interest of our business in conducting and managing our business to enable us to give you the best and most secure experience) or those of a third party and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.
• Where you have provided your consent.
• Purposes for which we will use your personal data
• We use your personal data for the following purposes:
• To provide our services to you: to provide our services to you, or otherwise take steps as set out in our website Terms of Use (on the basis of performing our contract with you, or otherwise on the basis of our legitimate interest to conduct our business);
• To respond to enquiries: to respond to any enquires you make over the phone, by email, or via our website you (on the basis of your consent, on the basis of our legitimate interest to respond to enquiries and to operate a lawful business, or otherwise to comply with our legal obligations);
• To provide access to our website: to provide you with access to our website in a manner convenient and optimal and with personalised content relevant to you including sharing your information with our website hosts and developers (on the basis of our legitimate interest to ensure our website is presented in an effective and optimal manner);
• Relationship management: to manage our relationship with you, including by maintaining our database of contacts, notifying you about changes to our terms of use and/or privacy notice (on the basis of performing our contract with you, to comply with our legal obligations and on the basis of our legitimate interests to keep our records updated and study how our website and services are used);
• User and customer support: to provide customer service and support in relation to your use of our website (on the basis of our contract with you or on the basis of our legitimate interests to provide you with customer service), and to deal with enquiries or complaints about the website (on the basis of our legitimate interest in providing the correct services to our website users and to comply with our legal obligations);
• Marketing: to keep in contact with you about our news, events, new website features, and services that we believe may interest you, provided that we have the requisite permission to do so (either on the basis of your consent where we have requested it, or our legitimate interests to provide you with marketing communications where we may lawfully do so). You will receive marketing communications from us if you have requested information from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing;
• Analytics: to use data analytics to optimising the use of our website, to improve our website, products/services, marketing, customer relationships and experiences (on the basis of our legitimate interests in personalising, enhancing, modifying or otherwise improving the services and/or communications that we provide to you, developing our business, and informing our marketing strategy); and
• Compliance with policies, procedures and laws: 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 and share your information with our technical and legal advisors (on the basis of our legitimate interests to operate a safe and lawful business or where we have a legal obligation to do so).
• Where we use your information for our legitimate interests, we make sure that we take into account any potential impact that such use may have on you. Our legitimate interests don’t automatically override yours and we won’t use your information if we believe your interests should override ours unless we have other grounds to do so (such as your consent or a legal obligation).

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.

5. DISCLOSURES OF YOUR PERSONAL DATA

In connection with the purposes and on the lawful grounds described above and in addition to the recipients of your information as described above, we will share your personal information when relevant with third parties such as:

• Our service providers: Service providers we work with to deliver our business, who are acting as processors and provide us with:
  • website development and hosting services based in the EU;
  • IT, system administration and security services based in the EU; and
  • fraud prevention and detection services based in the UK.
• Governmental bodies: HM Revenue & Customs, governmental bodies and other authorities acting as processors or joint controllers based in the United Kingdom, who require reporting of processing activities in certain circumstances;
• Marketing parties: any selected third party that you consent to our sharing your information with for marketing purposes;
• Prospective buyers of our business: any prospective buyer of our business or assets, only in the event that we decide to sell our business or assets; and
• Other third parties (including professional advisers): any other third parties (including legal or other advisors, courts, law enforcement agencies 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.

We require third parties to maintain appropriate security to protect your information from unauthorised access or processing.

6. INTERNATIONAL TRANSFERS

Some of our third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. COOKIES

We use cookies to ensure that you get the most out of our website. Cookies are small amounts of information in the form of text files which we store on the device you use to access our website. Cookies allow us to monitor your use of the software and simplify your use of the website.
If you do not wish for cookies to be installed on your device, you can change the settings on your browser or device to reject cookies. For more information about how to reject cookies using your internet browser settings please consult the “Help” section of your internet browser (or alternatively visit http://www.aboutcookies.org). Please note that, if you do set your Internet browser to reject cookies, you may not be able to access all of the functions of the website.

The names of the cookies used on our website and the purposes for which these cookies are used are set out below:
Cookie name: _ga
Purpose: Used to distinguish users
Cookie name: _gid
Purpose: Used to distinguish users
Cookie name: _git
Purpose: Used to distinguish users
Cookie name: AWSELB
Purpose: Used to optimize your use of the website
Cookie name: CraftSessionId
Purpose: Used to improve and optimize your use of the website
Cookie name: locale
Purpose: Used to track what language you want to view the site in

8. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised 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 on 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 of a breach where we are legally required to do so.

9. DATA RETENTION

How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil 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 unauthorised 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.
In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

10. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

You have the:

• Right to be informed. This means that we must tell you how we use your data, and this is the purpose of this Privacy Notice.
• Right of access. You have the right to access the data that we hold on you. To do so, you should make a subject access request. You can read more about this in our Subject Access Request policy which is available from the Executive Assistant
• Right for any inaccuracies to be corrected. If any data that we hold about you is incomplete or inaccurate, you may require us to correct it.
• Right to have information deleted. If you would like us to stop processing your data, you have the right to ask us to delete it from our systems where you believe there is no reason for us to continue processing it.
• Right to restrict the processing of your data. For example, if you believe the data we hold is incorrect, we will stop processing the data (whilst still holding it) until we have ensured that the data is correct.
• Right to portability. You may request that we transfer the data that we hold on you for your own purposes.
• Right to object to the inclusion of any information. You have the right to object to the way we use your data where we are using it for our legitimate interests
• Right to regulate any automated decision-making and profiling of personal data. You have a right not to be subject to automated decision making in way that adversely affects your legal rights.
• Lodge a complaint about us with the UK Information Commissioner’s Office (https://ico.org.uk/) as well as a right to lodge a complaint with the relevant authority in your country of work or residence.

Where you have provided consent to our use of your data, you also have the unrestricted right to withdraw that consent at any time. Withdrawing your consent means that we will stop processing the data that you had previously given us consent to use. There will be no consequences for withdrawing your consent. However, in some cases, we may continue to use the data where so permitted by having a legitimate reason for doing so.

How to exercise your rights

You may exercise your rights above by contacting us using the details in paragraph 1 of this Privacy Notice and we will comply with your request unless we have a lawful reason not to do so.

Please note that your objection to processing (or withdrawal of any previously given consent) could mean that we are unable to perform the actions necessary to achieve the purposes set out above. Please note that even after you have chosen to withdraw your consent we may be able to continue to process your personal information to the extent required or otherwise permitted by law.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

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

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.