This privacy policy describes Tellwell Talent Inc.’s (“Tellwell”) policies and procedures on the collection, use, and disclosure of information when you use our services, and explains your privacy rights. We use your personal information to contact you about your interest in Tellwell services and to deliver and monitor the services you have purchased from Tellwell.
What data do we collect?
Personal data
We collect personally identifying information so that we can identify and contact you to make you aware of Tellwell services and regarding your interest in Tellwell services. If you have purchased products or services from Tellwell, we use your personal information to deliver those products and services as per our contract with you, to pay you royalties that you have earned, and to learn about your experiences with Tellwell. Such collected-data items include:
- Your name
- Contact details such as email address, mailing address, and phone number
- Data about your preferences for and method of receiving royalties, which may include financial services account information, if applicable
- Data relevant to your publishing project
- Records of interactions and communications between you and Tellwell staff members
This data may be collected when you register for a service, when you fill out an online form, when you sign up to receive a newsletter or other communications, or during telephone or email conversations with Tellwell staff members.
Customer survey data
We periodically conduct customer surveys to help us improve our services. Participation in surveys is voluntary. Information submitted to customer surveys or to staff may be used in promotional materials unless explicitly requested by you that we not do so.
Usage data
We may collect data on website pages visited, so that we can monitor and improve our services based on webpage traffic volumes and usage patterns. We may collect:
- IP address
- Data about which browser and device you are using
- Time and date of page accesses, logins, and logouts
Tracking technologies: Cookies
Tellwell’s websites use browser cookies to track visits to analyze and improve our services, to manage sessions (logins and logouts), and to customize information presented to you. Cookies are small files stored on your device and managed by your browser. You can configure your browser to alert you to the use of cookies. You can also configure your browser to refuse cookies, but this may prevent some essential aspects of our services from working correctly.
Cookies can be “session cookies,” which are deleted when you close your web browser, or “persistent cookies” that remain on your device until you delete them from your browser. We use both types of cookies for the purposes set out below:
- Necessary or essential cookies (session cookies)
Purpose: On our web applications that require logins with a username and password, these cookies are used to authenticate user accounts, to manage sessions, and prevent the fraudulent use of user accounts. Without these cookies, we cannot provide secure access to our web applications. - “Cookie acceptance” cookies (persistent cookies)
Purpose: These cookies indicate whether you have accepted the use of cookies on our websites so that we do not need to ask you again on every webpage you visit. - Functionality cookies (persistent cookies)
Purpose: These cookies remember certain choices and preferences you may select on our websites, such as the choice of a preferred language or currency. These cookies prevent you from having to re-select your preferences on every webpage. - Third-party advertising, referral, and tracking cookies (persistent cookies)
Purpose: The third-party advertising services we use may use cookies to manage and track the advertisements that have been served to you. The third-party platform we employ to manage our referrals programs also uses cookies to display the referral "widget" in our Octavo platform and to correctly attribute successful referrals when a customer shares a referral link. We may also use third-party analytics services that use cookies to help track information about the traffic to our websites. The aggregate analytics statistics collected are used for understanding usage patterns so we can improve our services. For the advertising, referrals, and analytics services, the cookies typically use a pseudonymous identifier that is associated with your device or browser, and this information could directly or indirectly identify you as an individual visitor.
In addition to cookies, we may also use “web beacons,” such as small or transparent images in webpages or email messages, as a mechanism for tracking which pages have been visited or which emails have been opened.
Call recordings
Telephone conversations and online meetings may be recorded for quality assurance, service improvement, and training purposes. Before recording of a call is initiated, you will be notified by automated announcement or by your conversation partner, and you can decline to have the call recorded by immediately stating your preference. You have the right to request the deletion of your call recordings.
How do we use your data?
Use of data
Tellwell uses your personal information for the following purposes:
- To personalize your user experience and deliver the type of content and product offerings in which you are most interested.
- To contact you via periodic emails to provide information about our product and service offerings, special offers, and news, unless you have opted not to receive such information. You can opt out of receiving any or all newsletters and marketing communications by following the “Unsubscribe” link in any such email, or by contacting us.
- For the performance of a contract: to deliver the products and services you have purchased from us, to manage your requests, to pay you your royalties as per your payment preferences, and to contact you regarding managing your publishing project and your other products or services.
- To better serve you in responding to customer-service requests.
- To monitor the usage of our websites, in order to maintain and improve our services.
- To monitor the effectiveness of promotional campaigns.
- To enable you to send referral invites to other potential authors, and to manage your rewards earned from successful referrals.
Personal data in your book
A book published and distributed to booksellers by Tellwell becomes, by definition, available to anyone in the general public who purchases the book. Your name is usually listed as the author of the book, unless you elect to use a fictional pen name instead. It is your responsibility as the author of a book to ensure that your book does not include private or sensitive personal information about yourself or others that could cause harm to yourself or others.
Disclosure of data to third parties
We may share or disclose your personal information to other parties in the following situations:
- We electronically submit your personal data to third-party service providers on a need-to-know basis for specific operational purposes required for delivering the services you have purchased, such as processing credit card payments, issuing royalty payments, sending you automated email or SMS messages, or providing customer-support services. Tellwell will not transfer your personal data to another organization unless there are adequate controls in place for the security of your data.
- As part of our referral programs, we may share a limited number of data attributes with our third-party service provider to accurately track the status of referrals and to manage and issue rewards earned through the referral programs.
- If you have purchased a book marketing services package, your name, your photograph or likeness, an author biographical blurb, and details of your book may be included in press releases, social media campaigns, or other publicity activities according to the package you have chosen and as per your instructions and preferences.
- Under certain circumstances, Tellwell may be required to disclose your personal information to law enforcement, a court, or a government agency if required to do so by law.
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Tellwell may disclose your personal information in the good-faith belief that such action is necessary to:
- Comply with a legal obligation
- Protect and defend the rights or property of the company
- Prevent or investigate possible wrongdoing in connection with our services
- Protect the personal safety of users of the service or the public
- Protect against legal liability
Outside of the above required purposes, we will not sell, trade, or otherwise transfer your personally identifiable information to other parties (for example: for promotional, marketing, or research purposes) without your explicit informed consent.
If the company is involved in a corporate merger, acquisition, or sale, we will provide notice before your personal information is transferred and becomes subject to a different privacy policy.
Transfer of data across national borders
Tellwell employs staff in multiple countries, and during the course of a publishing project, your personal information may be accessed and processed by staff members in a country other than your own.
We also store and process personal information using applications that run on secure computer servers provided by our cloud services vendor. These servers are located in the United States and/or Canada, and these applications and servers communicate electronically with third-party service providers to facilitate operations such as processing credit card payments, issuing royalty payments, or sending you automated email or SMS messages. These third-party service providers may operate computing infrastructure located in different countries.
All information processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to, Canada, the United States, Australia, England, Ireland, the Philippines, and other countries which may have data-protection laws that are different from the laws where you live. Your consent to this privacy policy represents your agreement to such transfers, processing, and storage of data.
We endeavor to safeguard your information consistent with the requirements of applicable laws. Tellwell will not transfer your personal data to an organization or a country unless there are adequate controls in place, including contractual means where appropriate, for the security of your data.
Under the General Data Protection Regulation (GDPR), personal information may be transferred from the European Economic Area (EEA) to outside the EEA if adequate data protection laws are in place. Tellwell’s headquarters are located in Canada. The European Commission (EC) considers Canada to be a country with adequate data protection laws. Your personal information may therefore be transferred from the EEA to Canada. We rely on the GDPR standard contractual clauses for transfers of data to third parties in the United States and other countries not currently included in the EC’s list of “secure third countries”.
Retention of data
Tellwell will retain your personal data only for as long as you use our services or as necessary for the purposes set out in this privacy policy. We will retain and use your personal data to the extent necessary to comply with our legal obligations, to resolve disputes, and enforce our legal agreements and policies.
Tellwell will also retain usage data for internal purposes. Usage data is generally retained for a shorter period of time, except when this is used to strengthen the security or to improve the functionality of our services, or we are legally obligated to retain this data for longer time periods.
Security of data
Our websites and systems implement industry-standard security measures, including encrypted data communications and storage.
Your personal information is contained behind secured networks and is intended to only be accessible by a limited number of authorized persons who have special access rights and are required to keep the information confidential.
All payment transactions are processed securely through a payment processor. Tellwell does not store or process credit card numbers in its systems.
The security of your personal data is extremely important to us, but no method of electronic storage or transmission of data is 100% secure. While we strive to use every commercially acceptable means to protect your personal data, we cannot guarantee its absolute security.
Accuracy of data
Having correct and up-to-date data on file is important for us to be able to contact you, deliver your services, and issue timely royalty payments.
You are welcome to notify your Tellwell Project Manager, Publishing Consultant, or any other Tellwell staff member in writing if you would like to make any changes to your personal information (including your name, address, contact information, payment preferences, and any other details), and we will be happy to update our records. You can also update this information yourself in Tellwell’s Octavo self-service portal and we encourage you to periodically check and update your information.
If we become aware of any personal information that appears to be incorrect in Tellwell’s records while you are under an active publishing agreement with Tellwell, we will make our best efforts to contact you to correct the situation.
Privacy policies
Legal basis for processing personal data
We may process personal data under the following conditions:
- Consent: You have given your consent for processing personal data for one or more specific purposes.
- Performance of a contract: Provision of personal data is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof.
- Legal obligations: Processing personal data is necessary for compliance with a legal obligation to which Tellwell is subject.
- Legitimate interests: Processing personal data is necessary for the purposes of the legitimate interests pursued by Tellwell.
Your rights
Tellwell undertakes to respect the confidentiality of your personal data and to guarantee that you can exercise your rights.
You have the right to:
- Request access to your personal data. You may request a copy of all personal data we hold about you.
- Request correction to the personal data that we hold about you.
- Object to processing of your personal data. You can object to the processing of personal data for direct marketing purposes or for any other purpose or reason.
- Request erasure of your personal data. You have the right to ask us to delete personal data when there is no longer a good reason for us to continue processing it.
- Request the transfer of your personal data. We will provide to you, or to a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.
- Withdraw your consent. You have the right to withdraw your consent for us to use your personal data in a manner consistent with your agreement with us.
Exercising your rights
You may exercise your rights by contacting us with your request. We may ask you to verify your identity before responding to such requests. If you make a request, we will make our best efforts to respond to you as soon as possible, and no later than 30 days after you submit the request. Our Privacy Officer, or an assigned delegate if the Privacy Officer is not available, will review your request and assign it to an appropriate staff member.
If you are located in the European Economic Area, Switzerland, or the United Kingdom, you have the right to lodge a complaint with your jurisdiction’s Data Protection Authority about our collection and use of your personal data.
In Canada, you have the right to contact the Office of the Privacy Commissioner of Canada if you believe your personal data has been mishandled and if we have not responded adequately to your requests.
Disclosures specific to the California Online Privacy Protection Act (CalOPPA)
Some internet browsers include an option to set a Do Not Track (DNT) signal. Uniform standards for DNT signals have not been established and adopted, so while some of our online services may make efforts to suppress advertisements or omit registering cookies in the presence of a DNT signal, we do not make any guarantees that all of our online services respond to DNT signals. We are continuing to monitor developments towards the establishment of a standard.
A link to this privacy policy is prominently visible on the front page of Tellwell’s websites. Upon purchasing services from Tellwell, customers are required to explicitly agree to the Terms of Service, of which this privacy policy is a constituent part. Acceptance of the Terms of Service is required to receive access to the Octavo portal and before Tellwell will begin work on the deliverables of a publishing project.
Disclosures specific to the United States CAN-SPAM Act and Canada’s anti-spam legislation (CASL)
We may collect your email address in order to:
- Send information and respond to inquiries, questions, and requests
- Deliver services you have purchased and send information and updates pertaining to those services
- Send promotional information to our mailing list or continue to send emails to our customers, including after the original transaction has occurred
We agree to:
- Allow users to unsubscribe by using the link at the bottom of each email
- Honour opt-out/unsubscribe requests quickly
- NOT use false or misleading subjects or email addresses
- Identify promotional messages as an advertisement in a reasonable way
- Include the physical address of our business headquarters
- Ensure that an email address used for sending emails remains valid for a minimum of 60 days after an email is sent, and if that address is not monitored for replies, an alternate contact email will be provided in the email
- Monitor third-party email marketing services for compliance, if one is used
If at any time you would like to unsubscribe from receiving newsletters or promotional emails, you can follow the instructions at the bottom of any such email to opt out, or you can contact us.
If you have purchased services from Tellwell, the use of email communication will be necessary to complete your publishing project and to notify you of royalties earned. If you have concerns about such email communications, please contact us.
Children's privacy
Tellwell does not market its services to minors, and we do not knowingly collect personal information from minors without consent of a parent or guardian. If you are under the age of 18, you may only purchase and use Tellwell’s services with the consent and under the supervision of a responsible adult.
Links to other websites
Our service may contain links that redirect you to third-party websites that are not operated by us. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.
Data breach notifications
In the event of a data breach event involving the inappropriate disclosure or misuse of any personal information stored by Tellwell, we will notify affected customers and users via email, and additionally by other means if appropriate, within 7 business days of Tellwell becoming aware of the breach.
Changes to this policy
We may revise this privacy policy from time to time. Whenever we materially update this policy, we will notify you by email and/or in-application notifications in the Octavo portal, and we will ask again for your explicit consent.
Contact us
If you have any questions about our this privacy policy or our privacy practices, or if you wish to submit a request to exercise any of your rights as detailed in this privacy policy, please contact us:
| Email: | privacy@tellwell.ca |
| Postal mail: |
Tellwell Talent, Inc. c/o Privacy Officer 2031 Store St. Victoria, BC, Canada V8T 5L9 |
If you are a Tellwell customer and you simply wish to update or correct any personal information Tellwell has on file (such as a change of your name or address), you are also welcome to contact your Project Manager or Publishing Consultant.