Bolinda Digital Privacy Policy

Bolinda Digital Pty Ltd (“Bolinda Digital”) is the provider of this online library service to your library. We provide eMedia, such as eAudiobooks and eBooks, and make them available for you to borrow and enjoy via this online library service.

This Privacy Policy governs the collection, use, and disclosure of personal information that may be collected by Bolinda Digital as a data controller any time you interact with the online library service. By using the service, you are accepting the practices described in this Privacy Policy. Please take a moment to read the following to learn more about our information practices, including what type of information is gathered, how the information is used and for what purposes, and how we safeguard your personal information. Your privacy is a priority at Bolinda Digital and we go to great lengths to protect it.

This Privacy Policy does not apply to, and Bolinda Digital is not responsible for, any third party websites which may be accessible through links from this website or our service.

Why do we collect personal information?

We collect personal information to deliver our service to you and to help us deliver a superior level of customer service. Your personal information helps us keep you up to date with the latest eMedia releases, online library service updates, special offers, and other relevant information from Bolinda Digital or our partners. We tailor this information based on your preferences, what we think you might like to hear about, and where you have indicated you would like to receive these from us. Also, via the choices you make and the feedback you may provide, we learn ways to improve our service and its delivery. This includes customising future borrowing for you and making improvements in our content so that it is presented in the most effective and secure manner for you and the device on which you are accessing our services and allows us to troubleshoot and improve our online services.

We also collect personal information to respond to your enquiries; to carry out our obligations in providing the service; to facilitate our internal business operations, including to fulfil our legal or regulatory requirements; to maintain and develop our relationship with you. As well as for our business purposes, including data analysis, detecting, preventing, and responding to actual or potential fraud; illegal activities, or intellectual property infringement, to maintain and update our records including our database of contacts; and to provide you ongoing information and services.

We process personal information where we believe it is reasonably necessary or appropriate to: comply with our legal obligations; respond to legal process or requests for information issued by government authorities or other third parties; or protect your, our, or others’ rights.

We may not be able to do some or all of these things without your personal data.

What personal information do we gather?

Information you give to us:

You provide information when you search, borrow, post, participate in a contest or questionnaire, or communicate with customer service. For example, you provide information when you search for a title; borrow a title; provide information in your My Account; communicate with us by phone, e-mail, or otherwise; complete a questionnaire or a contest entry form; participate in discussion boards or other community features; provide and rate reviews; and specify a special occasion reminder. As a result of those actions, you might supply us with such information as your name, address, and phone numbers; content of reviews and e-mails to us; and personal description and photograph in your profile. You can choose not to provide certain information, but then many of our service features will not be available to you.

Automatically:

Examples of the information we collect and analyse include the Internet Protocol (IP) address used to connect your computer to the Internet; login; e-mail address; password; computer and connection information such as browser type, version, and time zone setting, browser plug-in types and versions, operating system, and platform; borrowing records; the full Uniform Resource Locator (URL) clickstream to, through, and from our website, including date and time; cookie number. We may also use browser data such as cookies. During some visits we may use cookies to measure and collect session information, including page response times and length of visits to certain pages.

Information from other sources:

We may collect information from other sources, such as social media platforms that share information about how you interact with our social media content, and any information gathered through these channels will be governed by the privacy settings, policies, and/or procedures of the applicable social media platform, which we strongly encourage you to review. Other examples of information we receive from other sources include ID and password information from client libraries or other third parties, which we use to correct our records and account information. We obtain further detailed information from libraries only if there has been a breach of copyright or other laws.

We will handle any unsolicited information in accordance with the law, including destroying or de-identifying such information where we are required to do so.

How do we use cookies?

Cookies are alphanumeric identifiers that we transfer to your computer's hard drive through your web browser to enable our systems to recognise your browser and store information between visits.

The Help portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Additionally, you can disable or delete similar data used by browser add-ons, such as Flash cookies, by changing the add-on's settings or visiting the website of its manufacturer. If you block cookies, it may prevent the delivery of the complete service to you.

What is our legal basis for usage of personal data?

Where we intend to use your personal data, we rely on the following legal grounds:

Performance of a contract: We may need to collect and use your personal data to enter into a contract with you for the BorrowBox service. For example, in order to deliver an audiobook to you in accordance with our Terms & Conditions.

Legitimate interests: Where we consider use of your information as being (a) non-detrimental to you, (b) within your reasonable expectations, and (c) necessary for our own, or a third party’s legitimate purpose, we may use your personal data, which may include for our own direct marketing or continued communication; the prevention of fraud; our own internal administrative purposes; personalisation of the service(s) we provide to you; ensuring network and information security, including preventing unauthorised access to electronic communications networks and stopping damage to computer and electronic communication systems; and/or reporting possible criminal acts or threats to public security to a competent authority.

Compliance with a legal obligation: We may be required to process your information due to legal requirements, including copyright infringement and other regulatory provisions applicable to Bolinda Digital as a provider of eMedia services.

Consent: You may be asked to provide your consent in connection with certain services that we offer, for example in respect of any processing of your personal data for our marketing purposes where you are not a customer of Bolinda Digital. Where we are reliant upon your consent, you may withdraw this at any time by contacting us using the details below, however please note that we will no longer be able to provide you with the products or services that rely on having your consent.

Do we share information with third parties?

We share information only with referring libraries, content providers, third party service providers and security monitoring agents.

We do not sell information to third parties. We do not provide information to third parties for the purposes of marketing products to you, other than to your library and only where you have indicated you would like to receive the information.

We provide information only for the following purposes:

  1. To ensure compliance with the Terms and Conditions of using the Bolinda Digital Service
  2. To assist with the provision of services to you
  3. To share with law enforcement bodies or other government authority
  4. When we need to enforce or apply our terms and conditions to which you have agreed
  5. When we are under a legal, regulatory or professional obligation to do so (for example, in order to comply with a Court Order).

Business Transfers: As we continue to develop our business, we might sell or buy subsidiaries or business units. In such transactions, customer information generally is one of the transferred business assets but remains subject to the protections in any pre-existing Privacy Policy (unless, of course, the customer consents otherwise). If Bolinda Digital Pty Ltd is acquired, customer information will be one of the transferred assets. However, if you are using the Bolinda Digital Service through a community library, the information supplied by the library will not be part of the transferable business assets.

Third party services: We use third party service providers to provide services that involve data processing, for example archival, web-hosting, analytics providers in connection with the operation of our online services, information technology providers, auditing, professional advisory (including legal and business consulting), mailing vendors, delivery, technology, website, research, client contact, data processing, insurance, litigation support, marketing and security services.

Protection of Bolinda Digital and Others: We release account and other personal information when we believe release is appropriate to comply with the law; enforce or apply our Conditions of Use and other agreements; or protect the rights, property, or safety of Bolinda Digital, our content providers, our users, or others. This includes exchanging information with other companies and organisations for copyright infringement and fraud protection. This does not include selling, renting, sharing, or otherwise disclosing personally identifiable information from customers for commercial purposes in violation of the commitments set forth in this Privacy Policy.

With Your Consent: Other than as set out above, you will receive notice when information about you might go to third parties, and you will have an opportunity to choose not to share the information.

International Transfers

Where you are submitting personal data from within the European Economic Area (“EEA”), such information may be transferred to other countries outside the EEA.

For example, this may happen if one or more of our third-party service providers with whom we share personal data in accordance with the previous section are located, or have their servers located, outside your country or the country from which the data was provided.

If we transfer your information outside the EEA in this way, we will take steps to ensure that your privacy rights continue to be protected.

How secure is information about me?

We work to protect the security of your information in electronic or physical form, including during transmission by using Secure Sockets Layer (SSL) software, which encrypts the information you input.

Our information security policy is supported by a variety of processes and procedures, and we store information in access-controlled premises or electronic databases requiring logins and passwords. All employees, officers or contractors of Bolinda Digital and third party providers with access to confidential information are subject to access controls and confidentiality obligations, and we require our third-party data storage providers to comply with appropriate information security industry standards.

Whilst we continually strive to ensure that our systems and controls are updated to reflect technological changes, the transmission of information via the internet is not completely secure, and as such we cannot guarantee the security of your data transmitted to our online services which is at your own risk.

If you communicate with us using non-secure web platforms, you assume the risks that such communications between us are intercepted, not received, delayed, corrupted or are received by persons other than the intended recipient.

Once we have received your information, we will take reasonable steps to use procedures and security features to try to prevent unauthorised access, modification or disclosure.

You can help us to keep your information secure by ensuring that any user name or password in relation to our online services is kept strictly personal to you and not be made available to any other person.

It is important for you to protect against unauthorised access to your computer. Be sure to sign off when you have finished using a shared computer.

What information can I access and what rights do I have?

You can update your information at any time by clicking on "My Account". You can also contact us to update or correct your information if this changes or if you believe that any information that we have collected about you is inaccurate using the details below.

You are entitled to request that we provide you with a copy of all information we store in relation to your account. You can always choose not to provide information. If the information is needed for a transaction - such as to borrow an eAudiobook - then the transaction will not proceed.

You can add or update certain information on pages such as "My Account". When you update information, we usually keep a copy of the prior version for our records.

If you do not want to receive e-mails or other mail from us, please adjust your Customer Communication Preferences. (If you do not want to receive Conditions of Use and other legal policies from us, such as this Privacy Policy, those policies will still govern your use of BorrowBox. You will need to agree to changes to proceed.)

Where you have consented to our processing of certain personal data, you can at any time withdraw such consent and/or tell us not to contact you with updates and information regarding our products and services (or part of them) either at the point such information is collected, (by leaving the relevant box unticked) or, where you do not wish us to continue to use your information in this way, by following the unsubscribe instructions on any communications sent to you. Please note that where you withdraw your consent we will no longer be able to provide you with the products or services that rely on having your consent. You can also exercise this right at any time by contacting us using the contact details at the end of this Privacy Policy.

You can request:

  1. corrections or updates to your details
  2. the erasure of your personal data
  3. the portability of personal data that you have provided to us in a structured, commonly used and machine-readable format
  4. the identity and contact details of the person or organisation that has determined how and why to process your data
  5. The purpose of the processing as well as the legal basis for processing
  6. If the processing is based on the legitimate interests of Bolinda Digital or a third party, information about those interests
  7. The categories of personal data collected, stored and processed
  8. Recipient(s) or categories of recipients that the data is/will be disclosed to
  9. How long the data will be stored
  10. The source of personal data if it wasn’t collected directly from you
  11. Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

You also have the right to object to, or request the restriction of, our use of your personal data.

If you would like to exercise any of the rights set out in this section, please contact us using the details below. We may refuse to provide access where we have legitimate reasons for doing so under applicable data privacy laws, and in exceptional circumstances may charge a fee for access if the relevant legislation allows us to do so, in which case we will provide reasons for our decision.

You may submit a complaint to the Information Commissioners Office, details of which can be found at https://ico.org.uk/global/contact-us. If you make a privacy complaint, we will respond to let you know how your complaint will be handled. We may ask you for further details, consult with other parties and keep records regarding your complaint.

Are children allowed to use BorrowBox?

Yes, but any person under the age of 18 must review this Privacy Policy and the Bolinda Digital Terms and Conditions with a parent or guardian before agreeing to make sure that they and their parent or guardian understand their legal rights and obligations.

Conditions of Use, Policies, and Revisions

If you choose to visit BorrowBox, your visit and any dispute over privacy is subject to this Policy and our Conditions of Use, including limitations on damages, resolution of disputes, and application of the law of the state of Victoria, Australia. If you have any concern about privacy at Bolinda Digital, please contact us with a thorough description, and we will try to resolve it. Our business changes constantly, and our Privacy Policy and the Conditions of Use will change also. We may e-mail periodic reminders of our policies and conditions, unless you have instructed us not to, but you should check our website frequently to see recent changes. Unless stated otherwise, our current Privacy Policy applies to all information that we have about you and your account. We stand behind the promises we make, and will never materially change our policies and practices to make them less protective of customer information collected in the past without the consent of affected customers.

Information you can access

Examples of information you can access easily on BorrowBox include up-to-date information regarding recent titles accessed or borrowed; personally identifiable information (including name, e-mail, password and communications preferences); e-mail notification settings; and recommendations.

Contact

If you have any questions, concerns or comments about this Privacy Notice, or want to submit a written complaint about how we handle your personal data, please contact us:

Our contact details are as follows:

Privacy Officer at Bolinda Digital Pty Ltd
Email: Privacy@bolindadigital.com

EU Representative at Bolinda UK Ltd
Email: Privacyeu@bolindadigital.com