INTRODUCTION:

Follett Corporation strives to ensure the security and privacy of our customer’s data. To that end, we’re providing this overview of our updated privacy policy. It’s more user-friendly and addresses the European Union (EU) General Data Protection Regulation (GDPR). We also appreciate that our customers have requirements under GDPR that are directly impacted by their use of Follett’s products and services. We’re committed to helping our customers stay in compliance with GDPR and their local requirements, and as part of our commitment, we have updated our Privacy Policy applicable to data subjects in the European Economic Area.

Privacy Policy:

Your privacy is important to us, and so is being transparent about how we collect, use, and share information about you. This policy is intended to help you understand:

• Information we collect about you and how we collect it
  • Information you give to us
  • Information we collect about you through our Website
    • Third-party ad servers and analytics providers
    • Cookies, web beacons and other technologies used on this Website
• How we use your information 
• How we disclose your information
• We may transfer your information outside the European Economic Area 
• How long we retain your information
• Your choices about how we use and disclose your information
• Your rights regarding your personal data
• How we secure your information
• Your use of third-party websites
• Our Website is not intended for children under the age of 16
• Our Data Controller Contact Information

Follett Corporation, and its wholly and majority-owned entities, are committed to protecting your privacy. References in this policy to “Follett”, “we”, “us”, and “our” are references to the entity responsible for the processing of your personal data, which generally is the entity that obtains your personal data in the respective case. In the EU, this entity is also referred to as the data controller.

This policy describes the types of information Follett may collect from you or that you may provide when you visit our websites, including but not limited to follett.com, www.efollett.com, www.bkstr.com, www.brytewave.com, www.follettlearning.com, www.titlewave.com, www.follettcommunity.com, marketplace.follett.com, www.valorebooks.com, www.baker-taylor.com, www.baker-taylor.co.uk, or www.collectionhq.com, or any other of our websites where this policy is posted (collectively the “Website”).  This policy also describes our practices for collecting, using, maintaining, protecting, and disclosing that information. This policy does not apply to information collected by us offline or through any other means, including on any other website operated by a third party, or through any application or content (including advertising) that may link to or be accessible from the Website.

Follett provides this policy to explain the type of information we collect, and to inform you of the specific practices and guidelines that secure and protect the confidentiality of your personal data. Please read this policy carefully. If any term in this policy is unacceptable to you, please do not use the Website or provide any personal data. This policy may change from time to time (see Revisions to Our Privacy Policy). 

1. Information we collect about you and how we collect it

We collect several types of information from and about users of our Website, which may include information defined as personal data or personally identifiable information under applicable law (“personal data”). For example, we may collect any of the following information about you:

• Name
• Address
• Email address
• Phone number
• User ID
• Employee ID
• Student ID 
• IP address
• Payment processing and order processing information, including credit card and financial account information
• Course information (which we may receive from your educational institution)

1A. Information you give to us
  
The information you give to us on our Website may include:

• Information that you provide by filling in forms on our Website.
  • This includes information provided when you purchase goods or services through us or sign up for our newsletters and other types of information material;
  • Information we receive when we process and respond to your inquiries related to products, customer service and technical support; and
  • Information obtained when you provide feedback on our Website.
• Records and copies of your correspondence with us (including email addresses).
• Additional personal information including resumes and other non-sensitive information, when applying for a position at Follett.

1B. Information we collect about you through our Website

As with many other websites, as you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:

• Details of your visits to our Website, including resources that you access and use on our Website, traffic data, location data, logs, language, date and time of access, frequency and other communication data.
• Information about your computer, mobile device and internet connection, including your IP address, operating system, host domain and browser type.
• Details of referring websites (URL). 

The information we collect automatically is statistical data that helps us improve our Website and deliver a better and more personalized service, enabling us to:

• Determine web site traffic patterns.
• Count web visits.
• Determine traffic sources so we can measure and improve the performance and security of our site.
• Help us to know which pages and content are the most and least popular. 
• Observe site search patterns to provide more intuitive navigation cues.
• Determine user frequency and recency. 

Third-party ad servers and analytics providers

Follett works with third party network advertisers, ad agencies, analytics service providers and other vendors to serve third party advertisements on and through the Website, to provide us with information regarding traffic on the Website, including the pages viewed and the actions users take when visiting the Website; to serve our advertisements on other websites, within mobile Apps, and elsewhere online; and to provide us with information regarding the use of the Website and the effectiveness of our advertisements. For example, if you click one of our advertisements, our service provider(s) may be able to tell us the advertisement you clicked on and where you were viewing the advertisement; likewise, if you click on an ad you see on our Website, our service provider(s) may be able to tell which page you were visiting on our Website and pass that information to the advertiser. The advertisements you see may be served by one or more third parties, who may use information about your activities on the Website, and other websites and services, to provide you targeted advertising based upon your interests.

These third-party service providers may set and access their own tracking technologies on your device (including cookies and web beacons) and may otherwise collect or have access to information about you including personal data.  These third parties may collect information about you across sites and over time. Cookies and web beacons, including those set by third-party network advertisers, may be used to, among other things, serve you targeted advertisements, prevent you from seeing the same advertisements too many times and to conduct research regarding the usefulness of certain advertisements to you.

While we may use a variety of service providers to perform advertising services, some of these companies are members of the Network Advertising Initiative (“NAI”) or the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising.

You may want to visit http://www.networkadvertising.org/managing/opt_out.asp, which provides information regarding targeted advertising and the “opt-out” procedures of NAI members. You may also want to visit http://www.aboutads.info/choices/, which provides information regarding targeted advertising and offers an “opt-out” by participating companies in the DAA Self-Regulatory Program. You may also opt out of tracking and receiving targeted advertisements on your mobile device by some mobile advertising companies and other similar entities by downloading the App Choices app at www.aboutads.info/appchoices.  Please note opting out through these mechanisms does not opt you out of being served advertising, you will continue to receive generic ads while visiting the Website and elsewhere online.

Follett participates in the Interactive Advertising Bureau (IAB) Europe Transparency & Consent Framework and complies with its Specifications and Policies.  Follett uses the Consent Management Platform with the identification number 28.  For additional information you may visit https://iabeurope.eu/tcf-2-0/.

This Website uses web analytics services provided by third parties to help us evaluate your use of the Website, compiling reports on Website activity for Website operators and providing other services relating to Website activity and internet usage. The information generated by the analytics service about your use of the Website may be transmitted to and stored by the third party on servers in the United States.

To opt-out from being tracked by Google Analytics download and install the Google Analytics Opt-out Browser Add-on for your current web browser, visit https://tools.google.com/dlpage/gaoptout?hl=en-GB.

To opt-out from being tracked by Adobe Analytics, visit https://www.adobe.com/privacy/opt-out.html.

The Website is affiliated with Publisher First, Inc. dba Freestar (“Freestar”) for the purposes of placing certain advertising on the Website, and Freestar will collect and use certain data for advertising purposes.  To learn more about Freestar’s data usage, click here.

Cookies, web beacons and other technologies used on this Website  

Cookies. A cookie is a data file, which we place on a device when it is used to visit the Website or otherwise access our online content. Cookies may be used for many purposes, including remembering you and your preferences, tracking your visits to our web pages, and for displaying offers related to your prior activity on the Website.  

Our Website uses single-session (temporary) and multi-session (persistent) cookies.  Temporary cookies last only as long as your web browser is open, and are used for technical purposes such as enabling better navigation on our Website. Once you close your browser, the cookie disappears.  Persistent cookies are stored on your computer for longer periods and are used for purposes including storing your preferences and settings, sign-in and authentication, and storing information you provide (such as when you add products to a shopping cart on the Website).

We may also use technologies such as cookies to provide you with enhanced online display advertising tailored to your interests.  For additional information on the type of information collected by cookies, including how to opt out of receiving interest-based advertising, please see the “Third party ad servers and analytics providers” section of this Policy.  

A Flash cookie is a data file placed on a device via the Adobe Flash plugin that may be built-in to or downloaded by you to your device. Flash cookies may be used for various purposes, including enabling a Flash feature and remembering your preferences.
If you want to disable the use of cookies or remove them at any time from your computer, you can disable or delete them using your browser (consult your browser’s “Help” menu to learn how to delete cookies).  If you choose to disable cookies or to adjust your Flash privacy settings on your device, some features of the Website may not function properly. 

To find out more about cookies, including how to see what cookies have been set, visit www.aboutcookies.org or www.allaboutcookies.org.

Web Beacons. Small graphic images or other web programming code called web beacons (also known as “1×1 GIFs” or “clear GIFs”) may be included in our web pages and e-mail messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a web page or e-mail can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Website, to monitor how users navigate the Website, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed.

Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Website, such as the links you click on. The code is temporarily downloaded onto your device from our web server or a third party service provider is active only while you are connected to the Services, and is deactivated or deleted thereafter. 

2. How we use your information

Below please learn how we process information collected about you (including personal data) as well as the corresponding legal basis. We may process your information where the processing is:

• Necessary for entering into or the performance of a contract with you. For example:
  • To carry out our obligations arising from any contracts entered into between you and us, your organization and us, or between your employer and us, and to provide you with the information, products, and services that you request from us.
• Necessary for us to comply with a legal obligation.
• Necessary for the legitimate interests pursued by a third party or us (to the extent it does not infringe on any data subject’s fundamental rights and freedoms). For example:
  • To improve the Website content so it is presented in the most effective manner for you and for your computer.
  • To allow you to participate in interactive features of our service (when you choose to do so).
  • To keep our site safe and secure.
  • To provide you with technical support and to improve our Website and services.
  • To provide you with information that you have requested and respond to your inquiries.
  • To notify you about changes to our service or our Website.
  • If you are an existing customer, to communicate (including by email and/or SMS) with you to provide information about goods and services similar to those that were the subject of a previous sale or negotiations of a sale to you.
  • If you contact us regarding applying for a position, we may use the information for recruiting, talent management and employment purposes (recording, examination, assessment, selection, and conclusion of an employment offer).
  • Subject to applicable law and regulations, in the event of a sale, merger, consolidation, change in control, transfer of substantial assets, reorganization, or liquidation, to transfer, sell, or assign to third parties information concerning your relationship with us, including, without limitation, personal data that you provide and other information concerning your relationship with us.
• Pursuant to valid consent provided by you, to provide you with information about goods or services we feel may interest you.  If you do not want us to use your data in this way, simply do not opt-in when we ask for your consent on the relevant forms where we collect your data. For any other purpose where you have provided valid consent where it is legally required.

3. How we disclose your information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. Subject to applicable law and regulations, we may disclose personal data that we collect, or you provide, as described in this policy:

• To any member of Follett for the foregoing described purposes.
• To contractors, service providers, and other third parties we use to support our business or in connection with the administration and support of the activities noted above, and who are bound by contractual obligations to keep personal data confidential and use it only for the purposes for which we disclose it to them (e.g., database hosting providers, managed service providers, developers, consultants).