Effective 22/12/2023
Wolters Kluwer (being either Wolters Kluwer (UK) Limited, a company incorporated in England & Wales or Wolters Kluwer (Ireland) Limited, a company incorporated in Ireland) (collectively, “Wolters Kluwer”, “we”, “us” or “our”) wants to inform you about the ways we process your personal data. In this Privacy & Cookie Notice we explain what personal data we collect, use, disclose or otherwise process.
Personal data means any data relating to an individual who can be identified, directly or indirectly, based on that information. This may include information such as names, contact details, (online) identification data, online identifiers or other characteristics specific to that individual.
This Privacy & Cookie Notice applies when we process your personal data as controller, for example when you visit our websites, access our solutions and other services, including events and web chat communications, that refer or display a link to this notice (“Services”). This Privacy & Cookie Notice may be supplemented or replaced by additional privacy statements or terms provided to you from time to time.
1. WHO WE ARE
Wolters Kluwer is a global organization consisting of many companies worldwide. This Privacy & Cookie Notice applies to personal data provided to, or collected by, Wolters Kluwer (being either Wolters Kluwer (UK) Limited, a company incorporated in England & Wales or Wolters Kluwer (Ireland) Limited, a company incorporated in Ireland) and/or one of its affiliates or subsidiaries.
- We are committed to safeguarding the personal data of our customers, users, employees and other stakeholders, while helping our customers, employees, investors and society create a deeper impact and make the right decisions.
- If you wish to contact us in relation to questions regarding your personal data, we refer you to the ‘HOW YOU CAN CONTACT US’ section below.
2. THE DATA WE COLLECT ABOUT YOU
The type of personal data that we collect depends on your relationship with us and the Services we deliver to you. To that end, we may collect the following personal data about you:
- Name and contact details, such as, first and last name, email address, postal address, telephone number;
- Work-related information, such as, job title and other employment or education information;
- Account Credentials, such as, passwords and other security information for authentication and access;
- Financial Information, such as, bank account, credit and debit card numbers for processing of payments;
- Usage information, such as, behavioural information about how you navigate within our Services and which elements of our Services you use the most and information regarding the products and/or services you wish to order, wish list, preferences, interest, etc.;
- Computer, device and connection information, such as, IP address, browser type and version and location;
- Audio and Visual Information, such as your voice and image as captured in photographs, video, or audio recordings if you attend our events or leave us a message;
- Any other information shared by you through our websites, apps, and other products and services, including web chat communications;
If you are under 18 years of age, please do not use or access the Services. Wolters Kluwer does not knowingly collect or maintain personal information from persons under 18 years of age. If Wolters Kluwer learns that personal information of persons under 18 has been collected on or through the Services, we will take appropriate steps to delete this information.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We may collect personal information from the following sources:
- Direct Interactions, such as when you register for our Services, make a purchase, or communicate with us, including through our web chat features;
- Data from Third Parties, such as information on third-party websites or other information you may have made publicly available, or information provided by third party sources, including but not limited to government entities and data resellers;
- Automated tracking technologies, such as information automatically collected about your interaction with our Services and websites using various technologies such as cookies, web logs and beacons and internet tags.
4. HOW WE USE YOUR PERSONAL DATA
Personal data is used for the purposes for which it has been collected and might be further used for statutory or other legitimate purposes only. As an example, if you make use of our service contact form or web chat features on our website, we will use the information you provided in the first place to respond to your service request. We might further use that information to improve the quality of our customer service process.
Lawfulness of the processing is one of the main principles relating to the processing of your personal information - we apply the following legal processing grounds:
- processing is necessary for the performance of a contract, or in order to take steps prior to entering into a contract;
- processing is necessary for the purposes of our legitimate interests - for example, to improve the quality of our products and Services;
- processing is necessary for compliance with a legal obligation to which we are subject, or that is otherwise lawful under the applicable data protection laws;
- with your given consent.
Depending on how you interact with us and the Service, we may use your personal data for the following purposes:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account/banking information and payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data includes cookie data, internet protocol (IP) address, your login data, browser type, settings and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website(s), products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Visual Data includes visual images, personal appearance and behaviours.
|
Purpose/Activity |
Type of data |
Lawful basis for processing including basis of legitimate interest |
|
To register and/or accept you as a new/ ongoing customer |
(a) Identity (b) Contact (c) Financial (d) Transaction |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to perform credit checks and protect the financial health of our business) |
|
To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us |
(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) |
|
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy notice (b) Asking you to leave a review or take a survey |
(a) Identity (b) Contact (c) Profile (d) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
|
To enable you to partake in a prize draw, competition or complete a survey, attend a webinar |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
|
To administer, provide, update, maintain and protect our products/services, our business and our website(s) (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data), to investigate and help prevent security issues and abuse. |
(a) Identity (b) Contact (c) Profile (d) Technical (e) Usage |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (c) Necessary to comply with a legal obligation |
|
To deliver relevant website(s) content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical |
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
|
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences |
(a) Technical (b) Usage |
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
|
To make suggestions and recommendations to you about goods or services that may be of interest to you |
(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
|
Business premises security, CCTV and crime prevention |
(a) Identity (b) Contact (c) Visual |
Necessary for our legitimate interests (To maintain the security of property and premises and for preventing and investigating crime.) |
|
User experience (UX) research |
(a) Identity (b) Contact (c) Technical (d) Profile (e) Usage (f) Visual |
Consent |
|
Calls recording/monitoring |
(a) Identity (b) Contact (c) Technical (d) Transaction (e) Usage (f) Profile |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to identify or confirm facts for query clarification including dispute resolution, for record-keeping, quality assurance and training purposes). |
|
Video calls/ conferences & recording |
(a) Identity
(b) Contact (c) Technical (d) Visual |
(a) Performance of a contract with you. (b) Necessary for our legitimate interests (for running our business, for record-keeping, to connect and communicate with you face to face (and with others) across multiple locations in relation to virtual meetings, webinars, product demos, interviews etc. (c) Consent |
| Wolters Kluwer Support Portal |
(a) Identity (b) Contact (c) Technical (d) Transaction (e) Usage (f) Profile |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (for running our business, for providing an online platform where customers can self-serve and connect to find answers fast from multiple sources, for delivering a personalised customer service, for record-keeping, quality assurance and training purposes). (c) Consent. |
| LiveChat |
(a) Identity (b) Contact (c) Technical (d) Transaction (e) Usage (f) Profile (g) Visual |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (for running our business, for providing an online platform where customers can self-serve and connect to find answers fast from multiple sources, for delivering a personalised customer service, for record-keeping, quality assurance and training purposes). (c) Consent. |
| AVA ChatBot |
(a) Identity (b) Contact (c) Technical (d) Transaction (e) Usage (f) Profile |
Necessary for our legitimate interests (for running our business, for providing an online platform where customers can self-serve and connect to find answers fast from multiple sources, for delivering a personalised customer service, for record-keeping, quality assurance and training purposes; for the purpose of providing customer service & for statistical purposes (used to follow-up and improve the AVA Chatbot functionality and use of the AVA Chatbot).
|
| Wolters Kluwer Club |
(a) Identity Data (b) Contact Data (c) Technical Data (d) Usage Data (e) Marketing and Communications Data (f) Visual Data |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (for running our business, to connect and communicate with you on industry trends and thought leadership on operating a contemporary accountancy practice, for customer relationship management, to provide a rewards program for engaged customers who advocate for us). (c) Consent
|
5. SHARING YOUR PERSONAL DATA
To be able to provide you the best possible Services and further our business operations, we may share certain information internally or with selected third parties. There might also be a certain statutory or legal obligation that we believe in good faith requires us to disclose your personal information externally. Parties we might share data with include:
- other Wolters Kluwer affiliates or subsidiaries, e.g. for customer data management or providing underpinning technology to support the Services we are delivering;
- our service providers, e.g. for managing or hosting services and/or underpinning technology for the Services we are providing;
- our business partners, to the extent you have purchased or expressed interest in a product or service of such a business partner, interacted with them or otherwise authorized the sharing of your personal information with such a business partner;
- subscribing, accrediting or professional organizations, e.g. for providing utilization information to organizations that provide you with access to our Services and/or sharing tracking and redeeming credits for professional accreditation;
- organizations involved in business transfers, e.g. to a purchaser or successor entity in the event of a sale or any other corporate transaction involving some or all of our business;
- other parties, e.g. as needed for external audits, compliance, risk management, corporate development and/or corporate governance related matters; or
- governmental authorities and regulators, as required under the applicable law.
Whenever we share personal data internally or with third parties in other third countries, we have appropriate safeguards in place in accordance with the applicable data protection laws, including as applicable the EU Model clauses and the UK Addendum. As required under the applicable law, third parties are required to use appropriate safeguards to protect your personal data, and they can only access the personal data that is necessary for performing their specific tasks.
6. HOW LONG DO WE KEEP YOUR PERSONAL DATA
Your personal data will be processed to the extent necessary for the performance of our obligations, and for the time necessary to achieve the purposes for which the data is collected, in accordance with our data retention policies and the applicable data protection laws. When the retention period is reached for your personal data we will take all reasonable steps to remove it from our systems and records or take steps to properly anonymize it so that you can no longer be identified from it.
7. HOW DO WE PROTECT YOUR PERSONAL DATA
We have put in place an internal framework of policies and minimum standards across all our businesses to keep your personal data safe. In addition, we limit access to personal data by our employees, business partners, service providers and third-party service providers on a ‘need-to-know’ basis. More specifically and in accordance with the law, we take appropriate technical and organizational measures (policies and procedures, IT security and others) to ensure the confidentiality and integrity of your personal data and the way it is processed.
8. WHAT ARE YOUR RIGHTS
You can exercise the following data subject rights mostly free of charge; however, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. (alternatively, we may refuse to comply with your request in these circumstances):
- Right of access (‘an overview of your personal information’): the right to get an overview of your personal data that we process.
- Right to rectification (‘correct your personal data’): if your personal data is inaccurate or incomplete, the right to ask us to rectify or complete your personal data.
- Right to erasure (‘right to be forgotten’): the right to request that we delete your personal data to the extent permitted by the applicable law. In certain circumstances, it may not be possible for us to accept your request; for example, when the processing is necessary to comply with a legal obligation, or if the processing is necessary for the performance of a contract. In some cases, your personal data is necessary in order to provide the Services and if you do not provide such data to us then you may be precluded from accessing and using the Services or using certain Services features.
- Right to data portability (‘transfer your personal data’): the right to ask us to transfer your personal data directly to you. This applies to certain personal data if processed by automated means and with your consent, or based on a contract you have with us. On your request, and where technically feasible, we will transfer your personal data to another party of your choice.
- Right to restrict processing: the right to request that we restrict or stop the processing of your personal data held by us for a certain period of time, or for an indefinite period. In certain circumstances, it may not be possible for us to accept your request; for example, when the processing is necessary to comply with a legal obligation, or if we can demonstrate compelling legitimate grounds otherwise.
- Right to object to processing: the right to object to the processing of your personal data. The reasons for an objection should relate to your particular situation, and be related to processing based on the legitimate interest condition. We will then no longer process the personal data, unless we can demonstrate compelling reasons otherwise. In certain circumstances, you have the unconditional right to object; for instance, in the context of direct marketing activities.
- Withdrawal of Consent: the right to withdraw your consent to the processing of your personal information at any time; for instance, after you consented to us keeping you informed about our Services, you have the right to withdraw this consent at any time. Withdrawal of your consent will not affect the lawfulness of the processing of your personal data prior to the withdrawal. ([email protected])
- Right not to be subject to a decision based solely on automated processing, including profiling
To exercise your rights (if applicable) and/or for any other questions about the handling of your personal data, we refer you to the ‘HOW YOU CAN CONTACT US‘ section below.
If you feel we are unresponsive or disagree with our data privacy practices, you can also file a complaint to the local Data Protection Authority (https://ico.org.uk/).
9. THE USE OF COOKIES
We use cookies to optimize our websites and analyze website traffic. On occasion we may use third party cookies, notably social media plugins, to enable you to share ideas and information related to us instantly and for our own marketing purposes.
Cookies or similar techniques (referred to collectively as “Cookies”) are small text files or pixels, which might be stored on your computer or mobile device. Cookies may be necessary to facilitate website browsing and making it more user-friendly. Cookies may also collect information to analyze personal browsing behaviour.
We may use Cookies belonging to one of the four categories listed below.
- Strictly Necessary Cookies - these mandatory Cookies are needed for our websites to function properly.
- Functional Cookies - these Cookies add additional functionality to our websites.
- Performance Cookies - these Cookies support analytic services that help us to improve our website’s functionality and user experience.
- Advertising Cookies - these Cookies can be applied to collect insights, to issue personalized content and advertising on our own and other websites.
If you do not want cookies to be stored, then you may turn off certain cookies described above individually or you can select the appropriate options on your web browser or in the cookie-tool provided on some of our websites to block or delete some or all cookies. Please note, however, that if you block some or all cookies you may not be able to use or access all or parts of our websites, such as being able to log on to member-specific areas.
You can set up your preference below
10. LINK TO OTHER WEBSITES
Our websites may contain links to other Wolters Kluwer or third-party websites, which may have privacy & cookie notices that differ from ours. We are not responsible for the collection, processing or disclosure of personal information data collected through such other websites.
We are also not responsible for any information or content contained on such websites. Links to other websites are provided solely for convenience. Your usage and browsing on any such website is subject to that website’s own policies. Please review the privacy notices posted on other websites that you may access through our website.
Wolters Kluwer may provide you with additional or different privacy notices, in specific instances, on how your personal information data is collected and used for a specific Service.
11. HOW YOU CAN CONTACT US
If you have any questions about how we process your personal information data or if you want to exercise one of your rights, you can contact us at [email protected].
If you feel we are unresponsive or disagree with our data privacy practices, you also have a right to file a complaint with the local Data Protection Authority (https://ico.org.uk/).
In response to a request, we might ask you to verify your identity if needed, and to provide information that helps us to understand your request better. If we do not grant your request, whether in whole or in part, we will explain why.
12. UPDATE TO THIS STATEMENT
From time to time we may update this Privacy & Cookie Notice or any other specific privacy statement. When making changes to this Privacy & Cookie Notice, we will add a new date to this privacy statement. This version is effective as of 22/12/2023
13. MARKETING
Link to OneWeb privacy & cookies notice