USA 
Privacy Policy And Then There Were None
AGATHA CHRISTIE LIMITED
ATTWN - ULTIMATE MYSTERY EDITION, PROOF GIVEAWAY & FINAL CHAPTER EMAIL
PRIVACY POLICY
Agatha Christie Ltd (ACL) is aware of its obligations under the UK 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 form “And Then There Were None” (ATTWN) by ACL.
We have a separate privacy policy for our website and other data processing activities which can be found here.
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
Full name of legal entity: Agatha Christie Limited
Title of data privacy manager: Senior Lawyer
Email address: [email protected]
Postal address: 6th Floor, Imperial House, 8 Kean Street, London, WC2B 4AS
2. HOW AND WHEN WE COLLECT YOU PERSONAL DATA
We collect personal data about you from a variety of sources, including:
- From you directly when you submit the ATTWN form
- From information we generate about you during the completion of the ATTWN form
3. THE DATA WE COLLECT ABOUT YOU
We collect the following personal data from you when you submit the ATTWN form or contact us:
- Full name
- Email address
- Your answer and thoughts on who you think is responsible for the deaths on Soldier Island
- Any other information you provide
We collect the following personal data that is generated during the completion of the ATTWN form:
- How long it took you to complete the ATTWN form
- When you completed the ATTWN form such as date and time
4. HOW WE USE YOUR PERSONAL DATA AND THE LEGAL BASIS FOR WHICH WE USE IT
Purpose |
Activity |
Legal Basis |
To send you the final chapter of ATTWN, we use the following personal data:
|
We use your personal data to send you the final chapter of ATTWN. |
This is on the basis of our legitimate interests to operate the ATTWN activities. |
To add you to the ACL mailing list to receive marketing communications such as the ACL monthly newsletter and HarperCollins UK newsletter, we use the following personal data:
|
When you opt-in to receiving the ACL monthly newsletter, we add you to the ACL mailing list to send you other marketing communications such as promotions, special offers, events and more. When you opt-in to receiving the HarperCollins UK newsletter, we share your personal data with HarperCollins UK for their marketing purposes. For more information about how HarperCollins UK’s process personal data, its privacy policy can be found here. |
This is on the basis of your opt in consent and you may opt out at any time as you have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal. |
To operate and improve our business, we use the following personal data:
|
We use your personal data as part of running and improving our business, including communicating with you, analytics, feedback and testing. We also use your personal data where it is necessary to verify your identity and to satisfy legal or regulatory requirements. Personal data is also used to exercise and protect our legal rights. For example, to detect, prevent and respond to: (i) fraudulent activity and claims (ii) intellectual property infringement claims; (iii) violations of law or our terms and policies; and (iv) to prevent or detect breaches against other laws. |
It is in our legitimate interest to operate and improve our business in an efficient, safe and lawful way and protect it from fraudulent or other unlawful activity. In some cases, we are under a legal obligation (whether by a regulatory authority or a court order) to conduct certain checks and disclose personal data. |
5. HOW AND WHEN WE SHARE YOUR PERSONAL DATA
We may share your personal data with third parties under the following circumstances:
- companies that help us process the ATTWN from, such as our quiz tool, IT service and software providers.
- professional service providers, such as messaging services, telephony providers, IT software providers, marketing and research agencies, profile and behavioural analytics companies and website hosts who help us run our business.
- any selected third party that you consent to our sharing your information with such as for marketing purposes. For example, HarperCollins UK when you opt-in to receiving the HarperCollins UK newsletter, we share your personal data with HarperCollins UK for their marketing purposes. For more information about how HarperCollins UK’s process personal data, its privacy policy can be found here.
- law enforcement agencies, courts, government authorities or other third parties where we believe it is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of a third party.
- companies which are part of our Group. We may share your personal data with such companies for the purposes of security, optimisation of our products and services, as well as internal reporting.
- potential partners, service providers, advisors, and other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell or transfer all or a portion of our assets or business. Should such a sale or transfer occur, we will use reasonable efforts to obligate the entity to which we transfer your personal data to use it in a manner that is consistent with this Privacy Policy.
6. DATA RETENTION
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.
We will delete your personal data provided on the ATTWN form within 30 days of the date you receive the final chapter of ATTWN unless you opt-in to receiving the marketing communications from ACL and/ marketing communications from HarperCollins UK, in which case we will retain your personal data until you opt-out.
7. INTERNATIONAL DATA TRANSFERS
In some cases, your personal data will be transferred to, stored, and processed in a country that is not regarded as providing the same level of protection for personal data as the UK. We have put in place appropriate safeguards (such as regulator approved standard contractual terms, certified mechanisms and adequacy decisions) to provide adequate protection of your personal data in accordance with applicable legal requirements. For more information on these safeguards or to obtain a copy of such safeguards, please contact us at: [email protected]
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. YOUR RIGHTS
You may, in certain circumstances, have rights in relation to the personal data that we hold about you. These may include the rights to access, correct, delete, restrict or object to our use of, or the processing of your personal data. You may also request a portable copy of your personal data in a usable electronic format. Where you have provided your consent to any use of your personal data, you can withdraw this consent at any time.
We encourage you to contact us to update or correct your information if it changes or if the personal data we hold about you is inaccurate.
Please note that we may require additional information from you in order to honour your requests. There may be situations in which we will not be able to comply with your request due to our legitimate interests or legal obligations.
If you would like to discuss or exercise any rights you may have, please contact us at [email protected]. If you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to the UK data protection regulator, the Information Commissioner’s Office: https://ico.org.uk/.
10. CHANGES TO THIS PRIVACY POLICY
We may modify or update this Privacy Policy from time to time. If we make any revisions that materially change the way in which we process your personal data, we will notify you of these changes before applying them.
Dated: 6th September 2024
