Privacy Policy

1. Totally Entwined Group Limited (“the Company” “Totally Entwined Group”) is committed to ensuring that customers’ (“you” “your”) privacy is protected. This privacy policy explains how we intend to and will use the data we collect about you on www.entwinedpublishing.com, www.entwinedstore.com www.fictionwide.com, www.bookbooster.io, (“the Websites”), how you can instruct us if you prefer to limit the use of that data and the procedures that we have in place to safeguard your privacy.

2. The information we collect and how we use it

i. New Customer registration

When you first visit the Website, before you can place an order you would be required to register as a member. During this registration we collect personal data including your name, postal address, e-mail address and telephone number (“Customer Information”).

We gather Customer Information to allow us to process your orders, and to collect payment when required. The relevant data is then used by us to communicate with you on any matter relating to your order and use of the service.

Customer Information will be stored on our servers in a database for the duration of your registration, after which time they will be archived and kept for six years in line with the Statute of Limitations Act.

We do not store debit/credit card details and each time you place an order you would be prompted to enter your payment details.

We may also collect certain information about how you use our website and the device that you use to access our website. This might include your IP address, geographical location, device information (such as your hardware model, mobile network information, unique device identifiers), 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 may be collected by Google Analytics or another third-party website analytics service provider on our behalf and/or may be collected using cookies.

Except where specifically stated above, we will not share this information with any third party except where required to do so by law.

By registering on our Website you are consenting to the use of your data by the Company.

ii. Use and Disclosure by the Company

Your personal data will be used to provide you with the services you have requested from us, and if you consent to receive marketing from us then we will also use your data to contact you with offers that might be of interest, via email and Facebook. The Company may also use aggregate information and statistics for the purposes of monitoring website usage and developing lookalike audiences on Facebook in order to help us develop the Websites and our services. These statistics are to examine trends - not individual site usage and as such will not include information that can be used to identify you as an individual.

3. Use of Cookies

The use of cookies is common in the computer industry. We use cookies in two ways: With most web browsers it is possible to configure your Internet browser so that it can refuse new cookies, prompt you to accept a cookie or disable cookies altogether. How you do this will depend on the Internet browser you use (for example Internet Explorer 5, Netscape etc). By refusing to accept Totally Entwined Group cookies our Websites will not operate correctly. For further details on cookies we recommend that you visit www.allaboutcookies.org

i. per-session cookies - these are used while you are logged on to the website to help us monitor traffic through the website and do not store any personal information; and

ii. auto logon cookies - these store some personal data in order to allow you to log on automatically when you visit the Websites.

4. How we protect your information

The Internet is not a secure medium. However security and controls are built into the Websites to offer you a greater degree of protection.

We also keep your data confidential subject to the purposes described above for which the details were collected. The internal procedures of the Data Controller cover the storage, access and disclosure of your data.

5. Sale of business

If the Company is sold or integrated with another business your data may be disclosed to our advisers and any prospective purchasers and their advisers and will be passed on to the new owners of the business.

6. Updating Your Details

If any of the data that you have provided to the Company changes, for example if you change your e-mail address, name or address, please let us know the correct details by sending an e-mail to [info@totallyentwinedgroup.com].

7. Your Consent

By submitting your data you consent to the use of your data as set out in this policy and as set out in the Websites' Terms and Conditions. If we change our privacy policy we will post the changes on this page, and may place notices on other pages of the Websites, so that you may be kept informed of the information we collect and how we use it at all times. Continued use of the service will signify that you agree to any such changes.

We take all steps necessary to ensure that any of your information is adequately protected and processed in accordance with this Privacy Notice, including aiming to ensure that all data is stored and processed within the European Union and by using all appropriate cross-border transfer solutions such as the European Commission's Standard Contractual Clauses or the EU-US Privacy Shield Framework;

• Data Protection and Confidentiality

i. Totally Entwined Group is registered for the purposes of the General Data Protection Regulation 2018 and will comply with its provisions.

ii. All information collected by Totally Entwined Group is strictly confidential and will not be shared with any third party except as required by law, and we will only use information collected about you in accordance with the General Data Protection Regulation 2018 as detailed in our privacy policy.

iii. Customers' personal data (limited to names, address and phone details) accessed by Totally Entwined Group during a sale transaction will be securely stored in a database in accordance with the rules under the General Data Protection Regulation 2018.

iv. The information collected will be used to process your order. It will not be passed on to any third parties or used to inform you of any offers from any third parties.

v. We will only send you news and information on special offers from Totally Entwined Group if you tick the option when creating a new account on the Websites, otherwise it will be used exclusively for the provision of our services to you.

YOUR RIGHTS TO THE INFORMATION WE HOLD ABOUT YOU

vi. You have certain rights in respect of the information that we hold about you, including:

• the right to ask us not to process your personal data for marketing purposes;

• the right to request access to the information that we hold about you; and

• in certain circumstances, the right to ask us to stop processing information about you.

vii. You may exercise your rights above by contacting us using the details in paragraph 2 of this Privacy Notice, or in the case of preventing processing for marketing activities also 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 marketing, by updating your marketing preferences via your account with us, or by clicking Unsubscribe on any email marketing correspondence that you receive from us.

viii. Please note that we may need to retain certain information for our own record-keeping and research purposes. We may also need to send you service-related communications relating to your website user account even when you have requested not to receive marketing communications.

ix. Note that if you make a request to access information that we hold about you in accordance with paragraph 9.1.2, we have the right to charge you a fee of £10 to assist us with the administration of your request.

x. From 25 May 2018, in accordance with new data protection laws which will be in force from that date, you will have certain additional rights in respect of the information that we hold about you, including:

• the right to lodge a complaint about us to the UK Information Commissioner’s Office (https://ico.org.uk/) or the relevant authority in your country of work or residence;

• the right to withdraw your consent for our use of your information in reliance of your consent (refer to paragraph 4 to see when we are relying on your consent), which you can do by contacting us using any of the details at the top of this Privacy Notice;

• the right to object to our using your information on the basis of our legitimate interests (refer to paragraph 4 above to see when we are relying on our legitimate interests); and

• the right to receive a copy of any information we hold about you in connection with the performance of our contract with you or on the basis of your consent (or request that we transfer this to another service provider) in a structured, commonly-used, machine readable format; and

• the right to ask us to limit or cease processing or erase information we hold about you in certain circumstances.

xi. You may contact us with the details at the top of this Privacy Notice if you wish to action any of these additional rights and we will comply with your requests unless we have a lawful reason not to do so.