Privacy & Cookie Policy
​​​​​Privacy and Cookie Policy​
INTRODUCTION
We understand that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits the Site, and those visitors who contact us directly by phone, email or by visiting us. We promise only to collect and use your personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
By using our website or communicating with us, you agree to the terms of this Privacy and Cookie Policy. Your continued use of our website signifies your acceptance of these terms.​​
1. Definitions and Interpretation
To make this Privacy and Cookie Policy easier to read, we have defined certain terms as follows:
We, Us, Our: Chapter 25 Limited. Company Number: 15684990. Registered Office 167-
169 Great Portland Street, London, England, W1W 5PF. We are registered with the
Information Commissioner’s Office under number: ZB694651
Account: means the account you have with us, which enables you to use our Services;
Cookie: means a small text file placed on your computer or device by the Site when
you visit or use certain parts of the Site. Details of the Cookies used by the Site are set
out in Part 12 below;
Cookie Law: means the relevant parts of the Privacy and Electronic Communications
(EC Directive) Regulations 2003 and any replacement of it;
Data Protection Officer: means: Sian Freeman
email: sian@chapter25bookclub.com
Data Protection Legislation: means General Data Protection Regulation (EU
Regulation 2016/679) (GDPR) and the Data Protection Act 2018; and
Site: means www.chapter25bookclub.com
​
2. What Does This Policy Cover?
​
This Privacy and Cookie Policy applies only to your use of the Site, which may contain links to other websites. Please note that we have no control over how your data is collected, stored or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.
​
​Under the UK General Data Protection Regulation (UK GDPR) and Data Protection Act 2018, personal data means any information relating to an identifiable person who can be directly or indirectly identified, for example by name, identification number, location data or online identifier.
​
3. What Is Personal Data?
​
Personal data is defined by the Data Protection Legislation as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified.
Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
Some personal data may be sensitive in its nature. That includes health records, criminal convictions and other similar data.​
​​
4. What Are My Rights?
Under the Data Protection Legislation, you have the following rights:
​
a) The right to be informed about our collection and use of your personal data.
b) The right to access the personal data we hold about you. Part 11 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete.
d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or purposes.
g) The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
h) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
i) Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
​
You can always contact us for more information about your rights and we will do our best to help you. The Citizen’s Advice Bureau is also a valuable source of help.
​
It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please tell us.
​
Please, always, contact us if you are not happy with the way we are using your personal data and we will do our best to resolve any problem. If you are not happy with any solution we offer, you have the right to lodge a complaint with the Information Commissioner’s Office.
​
​
5. What Data Do You Collect and How?
Depending upon your use of the Site, we may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table. Please also see Part 12 for more information about our use of Cookies and similar technologies.
Data Collected
​
Identity information including name, title, date of birth, and gender.
​
Contact information including address, emails address, and telephone number.
​
Payment information including card details and bank account details.
​
Profile information including preferences, habits, likes and dislikes.
​
Technical information including IP address, browser type and version.
How We Collect the Data​
We collect data using the Site or directly from you, in interviews, from completed forms and otherwise. We will use your data to send you relevant book club information, marketing material and for our book club team (staff, hosts, member champions and volunteers) to contact you directly regarding your membership.
Special Category Data: We do not routinely collect special category (sensitive) personal data. If such information is provided for example, details relating to health or personal circumstances, it will only be processed with your explicit consent or where it is necessary to comply with legal obligations.
Provision of Data: Providing certain personal data (such as contact or payment details) is necessary for us to perform a contract with you or respond to your enquiry. Other data is optional but may affect our ability to provide a complete response or service.
6. How Do You Use My Personal Data?
​
Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data, and our lawful bases for doing so:
What We Do​
​
Registering you on the Site.
​​
​
​
Providing and managing your Account.
​
​
Capture accounts data.
​​
​
Providing and managing your access to the Site.
​
Supplying our services to you or the person needing them.
​
​
Managing payments for our services.
​
Communicating with you.
What Data We Use​
​
Name, title, date of birth, address, email address, IP address.
​
​
​
Some data about likes and dislikes of you or the person needing our services.
​
Data contained within your systems.
​
IP address, browser type and version.
​
All personal data from both you and the person needing our services. This data may include certain sensitive data.
​
Card and bank details.
​​
​
Name, address, email address, telephone numbers.
Our Lawful Basis​
​
​To ensure that we can communicate with you correctly and ensure that you are entitled to use our products.
To ensure that we provide our services properly.
​
​
To ensure that we provide our services properly.
​
To ensure the proper use of the Site.
​
To ensure that we provide our services properly.
​​
​
​
To ensure the payment is made.
​​​​​​
​
To enable us to communicate with you.
Where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email and/or telephone and/or text message and/or post with information, news, and offers on our services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.
Third Parties (including payment service providers, those collecting anonymised data and others who provide services to us) may use third-party Cookies, as detailed below in Part 12. Please refer to Part 12 for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.
​
We do not use automated systems for decision making or profiling.
We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us.
If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
​
​We retain personal data only 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. In general:
- Client and enquiry data is retained up to 3 years after last contact;
- Financial records are retained for 6 years to meet legal obligations;
- Cookie and analytics data is kept for 12 months before being anonymised or deleted.
The following table outlines the lawful bases and retention periods for key processing activities:
​
​
​​
​
​
​
​
​
​
​
​
7. How Long Will You Keep My Personal Data?
​
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods after you have ceased to use our Services (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
Purpose​
​To provide and manage our services​​​
​
​​To process and manage payments
​
To communicate with clients and subscribers
​
To send marketing communications (where permitted)
​
To comply with legal obligations (e.g. record keeping, regulatory compliance)
​
​To monitor website performance and improve user experience
Lawful Basis for Processing​
​Contract / Legitimate Interests​
​
​
​​Contract / Legal Obligation
​
​
Legitimate Interests
​
​
Consent / Legitimate Interests
​
​
​
Legal Obligation
​​
​
​
​
​​Consent / Legitimate Interests
​
​
Retention Period​
​3 years after last contact
​
​
​​6 years
​
​
3 years
​
​
Until consent is withdrawn
​
As required by law
​
​​
​
​
​12 months
Type of Data​
​
​Identity information including name, title, date of birth.
​
Contact information including address, email address, telephone numbers.
​
Payment information including bank card/account details.
​
Profile information including passwords, preferences, likes and dislikes.
​
Technical information including IP address, browser, etc.
How Long We Keep It
6 years 6 months.
​​
​
6 years 6 months.
​​
​
6 months from last use.
​​
​
6 months from last use.
​​
​
6 months from last use.​
8. How and Where Do You Store or Transfer My Personal Data?
​
We may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein) as well as the UK and the EEA. These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows:
We will only transfer your personal data to third countries whose levels of data protection are deemed ‘adequate’ by the European Commission.
Please contact us, via our email address, asking for further information about the particular data protection mechanisms used by us when transferring your personal data to a third country.
The security of your personal data is essential to us and to protect your data, we take a number of important measures, including the following:
​
-
​limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
-
procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so.
​
We do not sell your data. We only share personal data with trusted service providers who assist us in operating our website, conducting our business, or providing services to you, such as IT providers, analytics platforms, and professional advisers. These third parties are contractually bound to keep your data secure and use it only for lawful purposes.
9. Do You Share My Personal Data?
We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions:
​​
-
If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.
-
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
​
If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above in Part 8.
If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy and Cookie Policy.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.​
​
10. Can I Withhold Information?
​
You may access certain areas of the Site without providing any personal data at all. However, to use all features and functions available on the Site you may be required to submit or allow for the collection of certain data.
Data Protection Impact Assessments (DPIAs):
We undertake DPIAs for any new systems, processes, or technologies that may pose high risks to individuals’ privacy. These assessments help us identify, assess, and mitigate data protection risks proactively.
You may restrict our use of Cookies. For more information, see Part 12.
​​​
11. How Can I Access My Personal Data?
​
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
​
All subject access requests should be made in writing and sent to the email or postal addresses shown above.
​
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
​
We will respond to your subject access request within 14 days and, in any case, within not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data, within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
​
12. How Do You Use Cookies?
​
Cookies are small text files placed on your device to enable website functionality and performance. We use the following categories of cookies:
Strictly necessary cookies – required for core website functionality.
Performance cookies – collect analytics to improve user experience.
Functional cookies – remember user preferences.
Targeting cookies – track browsing habits for relevant marketing, only used with consent.
You can control or disable cookies via your browser settings. However, some website features may not function properly if cookies are disabled.
The Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of the Site and to provide and improve our services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.
By using the Site, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. Third-party Cookies are used on the Site for analytic purposes. For more details, please refer to the table below. These Cookies are not integral to the functioning of the Site and your use and experience of the Site will not be impaired by refusing consent to them.
All Cookies used by and on the Site are used in accordance with current Cookie Law.
Before Cookies are placed on your computer or device, you will be shown a pop up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Site may not function fully or as intended.
Certain features of the Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown in the table below. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that the Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
The following first-party and third-party Cookies may be placed on your computer or device: a general set of Cookies designed to allow us to manage our relationship with you and analyse visitors to our website and to be able to pass you suggestions we may have from time to time.
The Site uses analytics services provided by Google and others. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how the Site is used. This, in turn, enables us to improve the Site and the services offered through it.
The analytics service(s) used by the Site use(s) Cookies to gather the required information. You do not have to allow us to use these Cookies, however whilst our use of them does not pose any risk to your privacy or your safe use of the Site, it does enable us to continually improve the Site, making it a better and more useful experience for you.
The analytics service(s) used by the Site use(s) the following Cookies:
​
Name of Cookie​
_ga
First / Third Party​
Third
Provider​
Google Inc.
Purpose
​
To provide Google Analytics service
In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
​
You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access the Site more quickly and efficiently including, but not limited to, login and personalisation settings.
​
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
​
13. Changes to this Privacy and Cookie Policy
​
We may change this Privacy and Cookie Policy from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
​
Any changes will be immediately posted on the Site and you will be deemed to have accepted the terms of this Privacy and Cookie Policy on your first use of the Site following the alterations. We recommend that you check this page regularly to keep up-to-date.
​
This Privacy and Cookie Policy was last updated in November 2025