Effective Date: 16 January 2023
- Introduction
At Pony Books (“Pony Books”, “we”, “our” or “us”), we respect your privacy and are committed to protecting your personal data.
As an international publisher engaged in publishing, translation, licensing and distribution activities, Pony Books works with authors, translators, illustrators, literary agents, publishers, booksellers, distributors, business partners, customers and website visitors around the world.
This European Privacy Notice (“Privacy Notice”) explains how Pony Books collects, uses, stores, discloses and otherwise processes your personal data when you interact with us, including through our website, publications, licensing activities, online services, events and business relationships.
We process personal data in accordance with applicable data protection laws, including:
• the EU General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”);
• the UK General Data Protection Regulation (“UK GDPR”);
• the UK Data Protection Act 2018;
• the Privacy and Electronic Communications Regulations 2003 (“PECR”), where applicable; and
• the Act on the Protection of Personal Information of Japan (“APPI”), where applicable.
Pony Books is committed to ensuring that personal data is processed lawfully, fairly and transparently, and that appropriate technical and organisational measures are implemented to protect personal data. - Scope of this Privacy Notice
This Privacy Notice applies to individuals whose personal data is processed by Pony Books and who are located in:
• the European Economic Area (“EEA”);
• the United Kingdom (“UK”); or
• other jurisdictions where applicable data protection laws apply.
This Privacy Notice applies when you:
• visit or use our website;
• contact us by email, online form or other communication channels;
• purchase books or other products from us;
• subscribe to newsletters or marketing communications;
• submit publishing, translation or licensing enquiries;
• enter into or negotiate agreements with Pony Books;
• participate in exhibitions, book fairs, seminars or other events;
• communicate with us as an author, translator, illustrator, literary agent, publisher, bookseller, distributor or business partner; or
• otherwise interact with Pony Books.
This Privacy Notice should be read together with any additional privacy information provided at the time your personal data is collected. - Data Controller
For the purposes of the GDPR and UK GDPR, Pony Books is the data controller responsible for the processing of personal data described in this Privacy Notice.
As the data controller, Pony Books determines the purposes and means of processing personal data.
Where Pony Books processes personal data together with another organisation, the parties may determine their respective responsibilities in accordance with applicable data protection laws. - Personal Data We Collect
The personal data collected by Pony Books depends on your relationship with us and how you interact with our services.
We may collect the following categories of personal data.
4.1 Contact Information
We may collect:
• name;
• email address;
• postal address;
• telephone number;
• company or organisation name;
• job title;
• country of residence or business location; and
• other contact details you provide.
4.2 Professional and Business Information
Where you interact with Pony Books in a professional capacity, we may process information relating to our business relationship, including:
• professional position and organisation;
• publishing interests;
• manuscript submissions;
• translation projects;
• licensing enquiries;
• contract negotiations;
• publishing history;
• records of meetings and correspondence; and
• information relating to business activities.
This may apply to:
• authors;
• translators;
• illustrators;
• literary agents;
• publishers;
• booksellers;
• distributors; and
• other publishing professionals.
4.3 Customer and Transaction Information
Where you purchase products from Pony Books, we may process:
• order details;
• delivery information;
• billing information;
• payment status;
• purchase history;
• customer service records; and
• communications relating to your purchase.
Payment card information is generally processed by authorised payment service providers.
Pony Books does not normally store complete payment card details.
4.4 Website Usage Information
When you visit our website, we may automatically collect technical information, including:
• IP address;
• browser type and version;
• device information;
• operating system;
• language settings;
• pages visited;
• date and time of access;
• referral sources;
• website interaction information; and
• information collected through cookies and similar technologies.
Further information is provided in Section 9 (Cookies and Analytics Technologies).
4.5 Communications and Marketing Information
We may process information relating to communications with you, including:
• enquiries;
• emails;
• customer support requests;
• event registrations;
• survey responses;
• newsletter subscriptions;
• marketing preferences; and
• records of interactions with Pony Books.
4.6 Special Categories of Personal Data
Certain types of personal data are considered “special categories of personal data” under the GDPR and UK GDPR.
These include information relating to:
• health;
• racial or ethnic origin;
• political opinions;
• religious or philosophical beliefs;
• trade union membership;
• genetic data;
• biometric data; and
• information concerning a person’s sex life or sexual orientation.
Pony Books does not intentionally collect special categories of personal data unless:
• there is a specific purpose for doing so;
• processing is permitted under applicable law; and
• appropriate safeguards are implemented.
We encourage you not to provide unnecessary sensitive personal data when communicating with us.
- How We Collect Your Personal Data
Pony Books may collect personal data from the following sources.
5.1 Directly from You
We may collect personal data when you:
• contact us;
• purchase books or products;
• subscribe to newsletters;
• submit manuscripts or proposals;
• enter into agreements;
• participate in events; or
• communicate with us.
5.2 From Third Parties
We may receive personal data from:
• literary agents;
• publishing partners;
• distributors;
• booksellers;
• event organisers;
• professional organisations; and
• service providers.
Where required by law, we will provide information regarding the source of personal data obtained from third parties.
5.3 Through Technology
We may collect certain information automatically through:
• cookies;
• analytics services;
• website security tools; and
• similar technologies.
- How We Use Your Personal Data
Pony Books processes personal data only where we have a lawful basis under applicable data protection laws.
We may process personal data for the following purposes.
6.1 Publishing, Translation and Licensing Activities
We may process personal data to:
• manage relationships with authors, translators, illustrators, publishers and agents;
• evaluate publishing and licensing opportunities;
• negotiate and manage agreements;
• administer royalties and payments;
• communicate regarding publishing projects; and
• provide professional services.
Lawful bases:
• Performance of a contract
(Article 6(1)(b) GDPR / UK GDPR)
• Legitimate interests
(Article 6(1)(f) GDPR / UK GDPR)
6.2 Customer Orders and Support
We may process personal data to:
• process purchases;
• arrange delivery;
• respond to enquiries;
• provide customer support;
• manage complaints and returns; and
• maintain transaction records.
Lawful bases:
• Performance of a contract;
• Compliance with legal obligations; and
• Legitimate interests.
6.3 Business Communications
We may process personal data to communicate with you regarding:
• publishing opportunities;
• licensing matters;
• events;
• exhibitions;
• business discussions; and
• services relevant to your relationship with Pony Books.
Lawful bases:
• Performance of a contract;
• Legitimate interests; or
• Consent where required.
6.4 Website Management and Improvement
We may process website information to:
• operate our website;
• improve user experience;
• analyse website performance;
• identify technical issues;
• protect website security; and
• prevent misuse.
Lawful bases:
• Legitimate interests; and
• Consent where required for cookies or tracking technologies.
7. Legal Bases for Processing Personal Data
Under the GDPR and UK GDPR, Pony Books processes personal data only where there is a lawful basis for doing so.
Depending on the circumstances, we rely on the following lawful bases.
7.1 Performance of a Contract
We may process personal data where it is necessary:
• to perform a contract with you; or
• to take steps at your request before entering into a contract.
Examples include:
• publishing agreements;
• translation agreements;
• licensing arrangements;
• product purchases; and
• business relationships with publishing partners.
7.2 Compliance with Legal Obligations
We may process personal data where necessary to comply with legal obligations, including:
• accounting and tax requirements;
• financial record keeping;
• regulatory obligations;
• responding to lawful requests from authorities; and
• maintaining records required by law.
7.3 Legitimate Interests
Pony Books may process personal data where necessary for our legitimate interests or those of a third party, provided that your fundamental rights and freedoms do not override those interests.
Our legitimate interests may include:
• managing and developing our publishing business;
• maintaining relationships with authors, translators, partners and customers;
• promoting relevant publications and services;
• improving our website and services;
• protecting our intellectual property;
• ensuring website security; and
• preventing fraud or unlawful activity.
When relying on legitimate interests, Pony Books carefully considers whether the processing is proportionate and whether your rights are adequately protected.
7.4 Consent
In certain circumstances, Pony Books may rely on your consent.
Where we rely on consent:
• consent will be freely given, specific, informed and unambiguous;
• you may withdraw consent at any time; and
• withdrawal will not affect the lawfulness of processing carried out before withdrawal.
- Marketing Communications
Pony Books may send information about our publications, translation projects, licensing activities, events, exhibitions and other services that may be relevant to you.
We will only send marketing communications where we have a lawful basis to do so.
Depending on your location and applicable laws, we may rely on:
• your consent; or
• legitimate interests, where permitted.
For recipients in the United Kingdom, electronic marketing communications are also subject to the requirements of the Privacy and Electronic Communications Regulations 2003 (“PECR”).
You may unsubscribe from marketing communications at any time by:
• clicking the unsubscribe link included in our emails; or
• contacting Pony Books directly.
Unsubscribing from marketing communications will not affect other communications relating to contractual, business or administrative matters. - Cookies and Analytics Technologies
Pony Books uses cookies and similar technologies on our website.
Cookies are small text files stored on your device when you visit a website. They help websites function properly, remember preferences, improve performance and provide information about visitor behaviour.
Cookies used by Pony Books may include:
9.1 Strictly Necessary Cookies
These cookies are required for essential website functions, including:
• website security;
• basic functionality; and
• technical operations.
These cookies generally do not require consent.
9.2 Analytics Cookies
Analytics cookies help us understand how visitors use our website.
They may collect information such as:
• pages visited;
• time spent on pages;
• visitor interactions;
• device information; and
• approximate location information.
Where required by law, we will obtain your consent before placing analytics cookies.
9.3 Managing Cookies
You can manage cookies through:
• our cookie consent tool (where available); or
• your browser settings.
Please note that disabling certain cookies may affect website functionality.
- Google Analytics 4
Pony Books may use Google Analytics 4 (“GA4”), a web analytics service provided by Google LLC, to analyse website usage and improve our online services.
GA4 may process information including:
• website interactions;
• pages visited;
• device information;
• browser information;
• approximate location information; and
• technical identifiers.
Where required by applicable law, GA4 cookies will only be activated after obtaining your consent.
Google processes information in accordance with its own privacy documentation.
Where GA4 involves international transfers of personal data, appropriate safeguards will be implemented in accordance with applicable data protection laws.
You may withdraw your consent to analytics cookies at any time through our cookie management settings. - Sharing Your Personal Data
Pony Books does not sell, rent or trade your personal data.
We may share personal data with trusted recipients where necessary for legitimate business purposes, contractual obligations or legal compliance.
Recipients may include:
11.1 Service Providers
Including:
• website hosting providers;
• cloud service providers;
• payment processors;
• e-commerce providers;
• email service providers;
• analytics providers;
• logistics providers;
• accounting providers; and
• professional advisers.
Where such providers process personal data on our behalf, we require appropriate contractual protections.
11.2 Publishing and Business Partners
Where necessary, we may share relevant information with:
• authors;
• translators;
• illustrators;
• literary agents;
• publishers;
• distributors;
• booksellers;
• event organisers; and
• licensing partners.
We only share information necessary for the relevant purpose.
11.3 Legal and Regulatory Authorities
We may disclose personal data where required by law or necessary to:
• comply with legal obligations;
• respond to lawful requests;
• protect our rights;
• establish, exercise or defend legal claims.
- International Data Transfers
As an international publisher based in Japan, Pony Books may transfer personal data outside the EEA and the UK.
This may occur where:
• service providers are located overseas;
• publishing partners operate internationally;
• authors or business partners are located in different countries; or
• our IT systems involve international infrastructure.
Pony Books ensures that appropriate safeguards are implemented before transferring personal data internationally. - Transfers from the EEA
Where personal data is transferred from the EEA to countries without an adequacy decision, Pony Books relies on appropriate safeguards under Chapter V GDPR.
These may include:
13.1 Adequacy Decisions
The European Commission has recognised Japan as providing an adequate level of protection for personal data.
Where applicable, Pony Books may rely on such adequacy decisions.
13.2 Standard Contractual Clauses
Where appropriate, Pony Books may use the European Commission’s Standard Contractual Clauses adopted under Commission Implementing Decision (EU) 2021/914.
These clauses provide contractual safeguards designed to ensure protection of personal data transferred outside the EEA.
- Transfers from the United Kingdom
For transfers subject to the UK GDPR, Pony Books may rely on:
• UK adequacy regulations;
• recognised adequacy decisions;
• the UK International Data Transfer Addendum to the EU Standard Contractual Clauses; or
• other approved transfer mechanisms.
Where required, Pony Books will assess whether additional safeguards are necessary. - Security of Personal Data
Pony Books implements appropriate technical and organisational measures to protect personal data against:
• unauthorised access;
• accidental loss;
• destruction;
• alteration;
• disclosure; and
• unlawful processing.
Measures may include:
• access controls;
• confidentiality obligations;
• secure systems;
• authentication procedures;
• regular review of security practices; and
• appropriate safeguards required from service providers. - Data Retention
Pony Books retains personal data only for as long as necessary for the purposes described in this Privacy Notice.
Retention periods depend on:
• the nature of the personal data;
• the purpose of processing;
• legal requirements;
• contractual obligations; and
• legitimate business needs.
When personal data is no longer required, it will be securely deleted or anonymised. - Your Rights Under GDPR and UK GDPR
Depending on your location and applicable laws, you may have the following rights.
17.1 Right of Access
You may request confirmation of whether Pony Books processes your personal data and request a copy of that data.
17.2 Right to Rectification
You may request correction of inaccurate or incomplete personal data.
17.3 Right to Erasure
You may request deletion of your personal data where applicable.
This right is subject to certain exceptions, including where retention is required by law or necessary for legal claims.
17.4 Right to Restriction
You may request that processing of your personal data is restricted in certain circumstances.
17.5 Right to Object
You may object to processing based on legitimate interests.
You also have an absolute right to object to direct marketing.
17.6 Right to Data Portability
Where applicable, you may request your personal data in a structured, commonly used and machine-readable format.
17.7 Right to Withdraw Consent
Where processing is based on consent, you may withdraw consent at any time.
- Complaints
If you believe Pony Books has processed your personal data unlawfully, you have the right to lodge a complaint with a relevant supervisory authority.
For individuals in the UK:
Information Commissioner’s Office (ICO)
For individuals in the EEA, you may contact the data protection authority in your country of residence or place of alleged infringement.
We encourage you to contact Pony Books first so that we can attempt to resolve your concern. - Third-Party Websites
Our website may contain links to third-party websites.
Pony Books is not responsible for the privacy practices, security or content of third-party websites.
We recommend reviewing the privacy notices of third-party websites before providing personal data. - Children’s Privacy
Pony Books does not knowingly collect personal data from children without appropriate consent where required by law.
If you believe that a child has provided personal data to us unlawfully, please contact us. - Changes to this Privacy Notice
Pony Books may update this Privacy Notice from time to time to reflect:
• changes in our services;
• legal developments;
• regulatory guidance;
• technology changes; or
• updates to our privacy practices.
The latest version will always be published on our website. - Contact Us
If you have any questions regarding this Privacy Notice or wish to exercise your data protection rights, please contact:
Pony Books
Email: info@ponybooks.org