Flip Page Publishing Ltd. End-
What this policy covers
This policy sets forth in detail the following general principles that we apply to the processing of any personal information at Flip Page Publishing Ltd. These principles include:
· Personal information will be processed lawfully, fairly, and in a transparent manner;
· We collect and store personal information only for specified, explicit, and legitimate purposes;
· The personal information we request is adequate, relevant, and limited to what is necessary to provide the Services;
· The personal information we collect and store is accurate and kept up-to-date and, if found to be inaccurate, will be updated without delay as soon as we are notified;
· We collect and store personal information for no longer than is necessary to provide the Services and protect our legitimate interests (Note: Flip Page Publishing Ltd. Customers are responsible for letting us know when any End Reader data handled by Flip Page Publishing Ltd. on their behalf is no longer necessary);
· We process personal information with integrity and confidentiality and in a manner that ensures appropriate security of the information; and
· We will be accountable and responsible for complying with this policy.
Flip Page Publishing Ltd. offers Services compliant with the GDPR. Flip Page Publishing Ltd. Customers must separately enter into a Processing Contract with Flip Page Publishing Ltd. to obtain GDPR Services. Flip Page Publishing Ltd. also offers a version of its GDPR Services that limits the collection, storage, and processing of applicable End Reader Data to the EEA and avoids any international transfers of personal data covered by the GDPR ("EEA-Only GDPR Services"). Flip Page Publishing Ltd.’s EEA-Only GDPR Services applies only to our processing of End Reader personal information on Customer's behalf for specific publications and does not apply to our collection and processing of Customer data as a user of the Services. Where applicable, this policy references how certain End Reader information is handled when EEA-Only GDPR Services have been elected by the Customer.
If you do not agree with this policy, do not access or use our Services or interact with any other aspect of our business.
1. What information we collect about End Readers
We collect information about End Readers when a Flip Page Publishing Ltd. Customer provides it to us or when a Flip Page Publishing Ltd. Customer uses our Services to collect End Reader information.
A. End Reader Information provided by Flip Page Publishing Ltd. Customers
We collect information about End Readers when a Flip Page Publishing Ltd. Customer uploads or inputs it into the Services or otherwise provides it directly to us for the purpose of controlling access to Flip Page Publishing Ltd. Customer Content.
End Reader Login Credentials: We may collect and use End Reader usernames and passwords to control access to certain Flip Page Publishing Ltd. Customer Content.
End Reader Email Addresses: We may collect and use End Reader email addresses for the purpose of sending emails to End Readers to notify them when new Flip Page Publishing Ltd. Customer Content is available, as login names, and/or for password recovery.
End Reader Contact Information: In addition to login credentials and email addresses, we may collect and use limited contact information about End Readers, including an End Reader’s: 1) name; 2) company name; 3) address; 4) postal code; 5) telephone number; and 6) facsimile number.
B. End Reader Information provided by End Reader
We collect information about End Readers when the End Reader provides it directly to us for the purpose of gaining access to certain Flip Page Publishing Ltd. Customer Content. The End Reader Information we may collect includes any of the information identified above in Section A, including:
· Email Address
· Company Name
· Postal Code
· Telephone Number
· Facsimile Number
C. End Reader Information provided by other End Readers
End Readers of Content may provide us with email addresses for other End Readers in order for us to facilitate the sharing of Flip Page Publishing Ltd. Customer Content with that End Reader through the Services. The ability to share Content by email using the Flip Page Publishing Ltd. Service is automatically disabled as part of Flip Page Publishing Ltd.’s EEA-Only GDPR Services.
D. Information we collect automatically when End Readers view Content
We collect information about End Readers when they view Flip Page Publishing Ltd. Customer Content.
End Reader Interactions with Content: We keep track of certain information about End Readers when they view and interact with Flip Page Publishing Ltd. Customer Content. This information includes, but is not limited to, the content viewed, the links that are clicked on, the time spent viewing content, and how content is shared.
End Reader IP Address: We identify and store the IP address of End Readers in order to properly deliver Flip Page Publishing Ltd. Customer Content to the End Reader and in order to record certain location-based information about the End Reader. However, IP addresses are removed from any analytic data made available to Customers who have elected Flip Page Publishing Ltd.’s EEA-Only GDPR Services.
Device and Connection Information: We collect information about the computer, phone, tablet, or other devices End Readers use to view Flip Page Publishing Ltd. Customer Content.
2. How we use End Reader information we collect
How we use the information we collect depends in part on the Services selected by the Flip Page Publishing Ltd. Customer publishing Content to End Readers. Below are the specific purposes for which we use the information we collect about End Readers.
To control access to Flip Page Publishing Ltd. Customer Content: We use information about End Readers to control access to Flip Page Publishing Ltd. Customer Content, including requiring login credentials, registration, or subscription prior to providing access to an End Reader.
To notify End Readers when new Content is available: We use information about End Readers to send email notifications to End Readers when new Flip Page Publishing Ltd. Customer Content is available.
For research and development: We use collective learnings about how people use our Services and feedback provided directly to us to troubleshoot and to identify trends, usage, activity patterns, and areas for integration and improvement of the Services.
Flip Page Publishing Ltd. Customer support: We may use End Reader information to provide support to Flip Page Publishing Ltd. Customers, for themselves or on behalf of End Readers. Specifically, we may use End Reader information to resolve technical issues encountered, to respond to requests for assistance, and to repair and improve the Services.
To protect our legitimate business interests and legal rights: Where required by law or where we believe it is necessary to protect our legal rights, interests, and the interests of others, we use information about End Readers in connection with legal claims, compliance, regulatory, and audit functions, and disclosures in connection with the acquisition, merger, or sale of a business.
Legal bases for processing: The laws in some jurisdictions require companies to explain the legal ground they rely on to use or disclose personal data. For example, if an End Reader is in the EEA, that End Reader is protected by the GDPR. To the extent such laws apply, our legal grounds for collecting and processing End Reader information are as follows:
· To facilitate the contractual commitments between Flip Page Publishing Ltd. Customers and End Readers;
· To make available Flip Page Publishing Ltd. Customer Content to End Readers;
· To satisfy a legitimate interest (which is not overridden by an End Reader’s data protection interests or fundamental rights and freedoms), such as for research and development, to market and promote the Services, to protect our users, personnel, and - - - - To comply with a legal obligation.
3. How we share End Reader information we collect
We share information we collect about End Readers in the ways discussed below, including in connection with possible business transfers, but we are not in the business of selling information about End Readers to advertisers or other third parties.
A. Sharing with other End Readers
When an End Reader uses the Services to share Flip Page Publishing Ltd. Customer Content with another End Reader by email, we will disclose the email of the End Reader who shared the Content. The ability to share Content by email using the Flip Page Publishing Ltd. Service is automatically disabled as part of Flip Page Publishing Ltd.’s EEA-Only GDPR Services.
B. Sharing with Flip Page Publishing Ltd. Customers
End Reader information is controlled by Flip Page Publishing Ltd. Customers and is therefore shared by Flip Page Publishing Ltd. with Flip Page Publishing Ltd. Customers as part of providing the Services.
C. Sharing with third parties
We may share End Reader information with certain third parties.
Service Providers: We work with third-party service providers to provide website and application development, hosting, maintenance, backup, storage, virtual infrastructure, payment processing, data entry, email services, and other services for us, which may require them to access or use information about End Readers. If a service provider needs to access information about End Readers to perform services on our behalf, they do so under close instruction from us, including policies and procedures designed to protect End Reader information.
Flip Page Publishing Ltd. Customer Fulfillment Providers: We may integrate our Services with third party fulfillment solutions when requested by Flip Page Publishing Ltd. Customers. If so, we may share End Reader information with these third party fulfillment solutions to help fulfill End Reader subscriptions or requests to view Flip Page Publishing Ltd. Customer Content.
Compliance with Enforcement Requests and Applicable Laws; Enforcement of Our Rights: In exceptional circumstances, we may share information about End Readers with a third party if we believe that sharing is reasonably necessary to (a) comply with any applicable law, regulation, legal process, or governmental request, including to meet national security requirements, (b) enforce our agreements, policies, and terms of service, (c) protect the security or integrity of our products and services, (d) protect Flip Page Publishing Ltd., our customers, or the public from harm or illegal activities, or (e) respond to an emergency which we believe in good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person.
Aggregated or Non-identifiable Data: We may also share aggregated or non-personally identifiable information with partners or third parties for business purposes.
GDPR Services: When a Flip Page Publishing Ltd. Customer has elected Flip Page Publishing Ltd.’s EEA-Only GDPR Services, we will not share End Reader personal information outside of the EEA without the consent of the Flip Page Publishing Ltd. Customer.
4. How we store and secure End Reader information we collect
A. End Reader information storage
Flip Page Publishing Ltd. is based in Canada. Flip Page Publishing Ltd.’s uses third party email service providers located in the United States and EEA. Accordingly, End Reader information is stored in the United States or in the EEA. If a Flip Page Publishing Ltd. Customer has elected Flip Page Publishing Ltd.’s EEA-Only GDPR Services, End Reader personal information will only be stored and accessed in the EEA.
B. End Reader information security
Flip Page Publishing Ltd. Security Measures include administrative, technical, and physical safeguards designed to protect and help prevent unauthorized access to End Reader information that we collect and store as part of the Flip Page Publishing Ltd. Service. These safeguards include intrusion detection services, active internal and external monitoring, firewalls, penetration testing, code audits, and corporate security policies. Flip Page Publishing Ltd. reserves the right in its sole discretion to substitute similar services and safeguards, provided that such updates and modifications do not result in the degradation of the overall security of the Services.
While we have taken reasonable steps to secure the personal and other information provided to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online is vulnerable to interception and misuse by unauthorized parties. Users of our sites are responsible for maintaining the security of any password, user ID, or other form of authentication involved in obtaining access to password protected or secure areas of any of our websites. To protect you and your information, Flip Page Publishing Ltd. may suspend your use of a website, without notice, pending an investigation, if any breach of security is suspected. Access to and use of password protected and/or secure areas of any Flip Page Publishing Ltd. site is restricted to authorized users only. Unauthorized access to such areas is prohibited and may lead to criminal prosecution.
C. How long we keep End Reader information
We will keep the information we collect about End Readers for so long as we are instructed by the Flip Page Publishing Ltd. Customer.
5. How to access and control End Reader information
Flip Page Publishing Ltd. processes End Reader information on behalf of and at the direction of Flip Page Publishing Ltd. Customers. Any requests to modify or delete End Reader information should be directed to the Flip Page Publishing Ltd. Customer responsible for publishing the relevant Content to the End Reader. To the extent Flip Page Publishing Ltd. receives a request from an End Reader regarding his or her information, such request will be directed to the appropriate Flip Page Publishing Ltd. Customer for handling or further direction.
Flip Page Publishing Ltd. will comply with any reasonable direction or instruction received from a Flip Page Publishing Ltd. Customer regarding End Reader information, including any request for a copy of End Reader information, objection to our use of End Reader information, request for the erasure or restriction of End Reader information, or request for End Reader information in a structured, electronic format.
6. How we transfer information we collect internationally
As more specifically described above, End Reader information, specifically, is transferred and stored in the United States and through our third party email service providers located in the United States and EEA. End Reader information is not distributed through our global content distribution network.
If Customer has elected Flip Page Publishing Ltd.’s EEA-Only GDPR Services, Flip Page Publishing Ltd. will not transfer End Reader Data outside of the EEA. At all times, Flip Page Publishing Ltd. Customers are the collectors of End Reader personal information and Flip Page Publishing Ltd. is the data processor. Flip Page Publishing Ltd. Customers must obtain and maintain any required End Reader approvals or consents necessary to permit the processing of End Reader personal information through the Flip Page Publishing Ltd. Service in compliance with any data protection regulations. Flip Page Publishing Ltd. Customers are also responsible for deleting End Reader personal information when it is no longer needed as part of their use of the Flip Page Publishing Ltd. Service.
Whenever we transfer End Reader information, we take steps to protect it. The possible risk of this transfer is that our protection efforts fail and a third party gains access to End Reader information, which is limited to name, company name, address, phone number, fax number, email, username, and password.
7. Other important privacy information
We do not request, collect, or store in any way sensitive information like credit card data, social security numbers, driver’s license numbers, racial or ethnic information, political or religious opinions, financial information, or health information. We ask that you not send or otherwise share with us any sensitive personal information of this nature and disclaim any responsibility for such information if you do provide it.
Our policy towards children
The Services are not directed to individuals under 16. We do not knowingly collect personal information from children under 16. If we become aware that a child under 16 has provided us with personal information, we will take steps to delete such information. If you become aware that a child has provided us with personal information, please contact us.
End Reader information is processed by Flip Page Publishing Ltd., Inc. For questions or concerns about how End Reader information is handled, please direct any inquiry to the below contact information or, for residents of the EEA, please contact our representative in the EEA, identified below.
Flip Page Publishing Ltd.,
26 Summerhayes Crescent
Brantford, ON N3R 5J1
Telephone: 519-756-3547 (FLIP)