Adam Matthew Digital Limited values our relationship with you and recognises the importance of respecting and protecting your personal information and privacy.
This policy (together with any other resources referred to in it) sets out the basis on which any personal information you provide to us (or data we collect about you from other sources) will be processed (meaning collected, stored, and otherwise used) by us.
Please read this policy carefully as it sets out what you can expect from us and gives you our contact details if you wish to ask any questions or raise concerns about how we are processing your personal information.
For the purposes of the Data Protection Act 1998 (the Act) and the General Data Protection Regulation (GDPR), the data controller is Adam Matthew Digital Ltd, Pelham House, Pelham Court, London Road, Marlborough, SN8 2AG.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include information where the identity has been removed (anonymous information).
Adam Matthew is an academic publisher of primary source collections for teaching and research. Our digital resources are used for educational purposes and our customers are academic institutions and libraries.
We process the following different types of personal information: licensed material personal data, copyright personal data and user personal data. More information on each is set out below.
To produce our digital resources, we license primary source material from libraries and archives around the world for inclusion in our digital resources. This primary source material sometimes contains personal information, such as names, images, as well as special category personal information. Special category personal information includes information such as details about your ethnicity, religious beliefs, political opinions. We call all of this information Licensed Material Personal Data.
Licensed Material Personal Data is processed in the following ways:
- we create digital copies of the material for inclusion in our published, digital resources
- we view digital copies for quality assurance purposes, to ensure they are appropriate and functional in the published resource.
- we index the primary source material to make it searchable (capturing e.g. names, keywords, places)
- we create transcripts and databases of the text to make it searchable
- we may create searchable databases within our resources for data analysis purposes
- we use a limited number of primary sources in our marketing material
- we may redact or remove personal data, including special category personal data, from our primary sources to protect an individualâ€™s personal data using a third-party supplier in a third country.
As a data controller, the law imposes certain obligations on us in relation to the use, storage and processing of personal information.
However, under Data Protection legislation an exemption applies to processing personal information for journalistic purposes and academic, artistic or literary expression (the academic exemption). This exemption means that the majority of the obligations under Data Protection law do not apply to our processing of Licensed Material Personal Data.
In particular, for special category personal information and relying on the academic exemption, we can process Licensed Material Personal Data without your consent and transfer it to countries outside the UK and outside the European Economic Area, including to third party service providers who provide services to us. However, we put in place appropriate security measures in respect of Licensed Material Personal Data.
Sometimes we obtain personal information, such as names and addresses and other contact details, from libraries and other archive holders. This information is used by us for researching and contacting copyright holders to request permission to include primary source material in our resource. We call this Copyright Personal Data.
We collect, store and process personal information from employees of our customers and of our prospective customers, as well as personal information of users (such as students) accessing our digital publications. We call this User Personal Data and it includes:
Identity and contact data: user names and email addresses of users accessing our digital publications; names, email addresses, telephone number, academic institution, affiliation, job title and subject specialism of employees of our customers and prospective customers;
Financial data: financial or credit card details, details about payments from our customers and what has been purchased;
Technical data: internet protocol (IP) address, 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 our customers employees and users use to access our publications and our websites;
Usage Data: information about how our customers employees and prospective customers employees use our website, products and services;
Marketing Data: our customersâ€™ employees and prospective customersâ€™ employees preferences in receiving marketing from us and their communication preferences.
The law imposes certain obligations on us in relation to Copyright Personal Data and User Personal Data.
Data protection legislation also gives you a number of rights to protect you against an organisation mishandling this type of personal information. It is important that you understand your rights and in this document, we have set out what those rights are and how you can exercise your rights in respect of Adam Matthew processing those types of personal information.
Information you provide to us â€“ you may provide us with User Personal Data when you are:
- accessing our websites. This includes information that you provide when you register to use any of our websites, products or services, subscribe to one of our services, search for a product, place an order, participate in a discussion group, request a complimentary copy of a book, or report a problem with our site or request content or other information from us.
- corresponding with us by post, telephone, email or otherwise.
Information we collect about you â€“ we may also process certain personal information about you which you have not provided to us yourself, for example, information we collect from archives or libraries to research and contact copyright holders.
In limited circumstances, we may collect User Personal Data that you have made available in the public domain, such as your contact details, research interests, courses that you teach and the institution that you are based at. When we do this, we carefully consider whether do so is in your interest and any impact on your rights.
Information from other sources â€“ we also work with third parties and may receive User Personal Data about you from them.
We work with business partners, such as web hosting providers, email service providers and list brokers, to deliver our products, services and communications, and they may provide us with additional information about you. This could include details of content that you have viewed or requested through their websites, or details of which email communications from us you viewed or clicked on.
Cookies â€“ We may also obtain User Personal Data about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer's hard drive. They help us to improve our site and to deliver a better and more personalised service. They enable us:
- To estimate our audience size and usage pattern.
- To store information about your preferences, and so allow us to customise our site according to your individual interests.
- To speed up your searches.
- To recognise you when you return to our site.
We use Google Analytics to analyse the use of our site. Google Analytics generates statistical and other information about website use by means of cookies. The information generated relating to our site is used to create reports about the use of our site. Google will store this information.
The User Personal Data we may collect about you in this way may include the Internet Protocol (IP) address used, your browser type and version, the type of device used, and time zone setting, etc. We may also collect information about each visit you make to our website, including which website you were on immediately before you navigated to our sites, and how you have progressed through and from our sites â€“ as well as content you have searched for or viewed on our sites.
We use User Personal Data in the following ways.
(a) To deliver our products and services to you â€“ we may use this information to:
- carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us (as is necessary for the performance of those contracts.) ;
- notify you about changes to our service (as is necessary for the performance of a contract to which you are a party and/or as is necessary for our legitimate interests.);
- allow you to access restricted areas of our websites, when you choose to do so (which may rely on your consent for the processing of your personal information which is necessary for giving you access to those restricted areas);
(b) To improve the effectiveness of our products, services and marketing communications â€“ we may use this information (in each case as is necessary for our legitimate interests) to:
- administer our websites and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- improve our websites to ensure that content is presented in the most effective manner for you and for your computer or device;
- keep our websites safe and secure;
- measure or understand the effectiveness of advertising we deliver to you and others, and to deliver relevant advertising to you;
- provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about, provided that you have not told us that you do not wish to receive this information (as is necessary for our legitimate interests);
- make suggestions and recommendations to you about goods or services that we believe may interest you, based on your previous transactions, behaviour, subject interests and other information that we may hold about you and your institution or organization.
We use Copyright Personal Data to contact you if you are, or you might know, a copyright holder (as is necessary for our legitimate interests) and in particular to research copyright holders and request permission from copyright holders to include primary source material, as is necessary for our legitimate interests to ensure our published materials are copyright cleared, or as is necessary for us to comply with the law.
References to our "legitimate interests" in this policy include our commercial interests in operating our business (and the business of Adam Matthew more generally) in an efficient and sustainable manner, in accordance with all applicable legal and regulatory requirements.
If you would like to update your User Personal Data details, including details of how you prefer to be contacted for marketing purposes, you can do this by:
- Calling +44 (0)1672 511921 between 0900 and 1730 GMT Monday to Friday and ask for Sales Support.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.
If you decide to change your Marketing preferences you may still be contacted by Adam Matthew in relation to other business activities or transactions.
Please note that it may take up to one week for unsubscribes to be processed.
For the purposes referred to in this policy and relying on the bases for processing as set out above, we may share User Personal Data with our parent company, SAGE Publishing, namely:
- SAGE Publications, Ltd in the United Kingdom, for global business management purposes;
- SAGE Publications, Inc in the United States, for global business management purposes;
- SAGE Publications, PVT Ltd in India, which provides publishing support services, including invoice processing and customer support functions;
- SAGE Publications, Pte Ltd in Singapore, which provides marketing support for the Asia Pacific region;
Adam Matthew may also share Copyright Personal Data and User Personal Data with our business partners who are providing a service to us, for example:
- a platform for Adam Matthewâ€™s web-based product;
- a provider of web analytics services; or
- for the purposes of fulfilling an order that you have placed with us, delivering a product or otherwise carrying out a contract that we have with you.
In addition, where the products or services that you have accessed via Adam Matthew are provided by us on behalf of a third party such as an academic society or association, we may share your User Personal Data with them, unless you have asked us not to.
If you register for a sponsored event, then we may share your User Personal Data with event sponsors, where we have informed you that we will do this at the point at which you register for the event.
Adam Matthew is a global company and our systems and management team are integrated throughout the organisation. Copyright Personal Data and User Personal Data will be accessible to Adam Matthew employees and business partner service providers based outside the EEA. We have an agreement in place across the organisation to safeguard this personal information and to ensure the same high standards of data protection exist across Adam Matthew.
Licensed Material Personal Data is transferred outside the EEA as it is accessed by our customers who are based worldwide.
Where we use third parties to process personal information on our behalf we will ensure that there are the appropriate EU approved transfer mechanisms in place â€“ and incorporating the European Commission approved model clauses where necessary - to provide a lawful basis for the transfer of personal information outside the EEA. This personal information includes Copyright Personal Data, Licensed Material Personal Data and User Personal Data.
This section applies to all types of personal information that we refer to in this policy, namely Licensed Material Personal Data, as well as Copyright Personal Data and User Personal Data.
We have put in place appropriate security measures to prevent personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process personal information on our instructions and they are subject to a duty of confidentiality.
However, if you are a user of our digital publications, it is important that you keep any log in information confidential and not pass it to a third party.
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.
However, the internet is not totally secure so security cannot be guaranteed.
We will only retain your personal information 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 information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In respect of User Personal Data on customers, we will normally retain this information for seven (7) years after the last recorded interaction with Adam Matthew.
Under the Act you have the following rights in relation to Copyright Personal Data and User Personal Data:
- to obtain access to, and copies of, the personal information that we hold about you;
- to require us to correct the personal information we hold about you if it is incorrect;
- to require us to erase your personal information;
- to require us to restrict our data processing activities;
- where our processing is based on your consent, the right to withdraw that consent (without affecting the lawfulness of our processing based on consent before its withdrawal);
- where the processing is carried out by automated means, to receive from us the personal information we hold about you which you have provided to us, in a reasonable format specified by you (including for the purpose of you transmitting that personal information to another data controller); and
- to object, on grounds relating to your particular situation, to any of our particular processing activities where you feel this has a disproportionate impact on your rights.
Please note that these rights are not absolute, and we may be entitled to refuse requests where exceptions apply. If you wish to exercise any of these rights, please contact us using the contact details set out below.
If you are an EU Citizen and are not satisfied with how we are processing your personal information, you can refer us to the Information Commissioner. You can find out more about your rights under data protection legislation from the Information Commissioner's Office website available at: www.ico.org.uk.
If we make changes to this policy, we will detail them on this page. If it is appropriate we may provide you with details by email; we suggest that you regularly visit this page to see any changes or updates to this policy.
This policy was last updated in October 2020.
Compliance with law or with a legal obligation: means processing your User Personal Data or Copyright Personal Data where it is necessary for compliance with a legal obligation that we are subject to.
Copyright Personal Data: means personal information, such as names and addresses and other contact details, from libraries and other archive holders, to enable us to research and contact copyright holders.
Legitimate interest: means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your User Personal Data or Copyright Personal Data for our legitimate interests. We do not use your User Personal Data or Copyright Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Licensed Material Personal Data: means personal information, such as names, images, as well as special category personal information, in our digital resources.
Performance of a contract: means processing your User Personal Data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Personal data or personal information: means any information about an individual from which that person can be identified. It does not include information where the identity has been removed (anonymous information).
Special category personal information: 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 information).
User Personal Data: means personal information from employees of our customers and of our prospective customers, as well as personal information of users (such as students) accessing our digital publications.