Privacy Policy for Bibliotheca Limited
Reviewed in September 2024
BIBLIOTHECA Limited (“BIBLIOTHECA”, “we”, “us” or “our”) is committed to protecting the privacy of our clients and users of our BIBLIOTHECA cloudCheck mobile (“cloudCheck mobile”) app (“App”). When you use your BIBLIOTHECA cloudCheck mobile App to borrow a book or other library item, certain information is shared with BIBLIOTHECA and others to make this a useful tool for you. This Policy is intended to help you understand the ways that your information may be collected and used when you use the BIBLIOTHECA cloudCheck mobile application services (“Services”). By indicating that you have “Read” the Privacy Policy or that you “Agree” to the terms of the Privacy Policy you are giving consent to the collection, use and disclosure of your information as described in this policy.
We want to provide a safe and secure user experience. Through this Privacy Policy we aim to inform you about the types of personal data we collect from users, the purposes for which we use the data and the ways in which the data is handled. The information in this Privacy Policy is supplemental to the Privacy Policy for BIBLIOTHECA Limited, where more information is available about how BIBLIOTHECA uses and protects your information. However, the statements and information in this Privacy Policy apply to cloudCheck mobile only, and do not necessarily apply to other products, services, mobile applications, or websites provided by BIBLIOTHECA or its partners.
For the purpose of this Privacy Policy and the App, the Joint Data Controller of personal data is BIBLIOTHECA, and our contact details are set out in the Contact Us section at the end of this Privacy Policy.
Changes to this Policy
BIBLIOTHECA reserves the right to update or modify this Policy, at any time by posting the revised version of this Policy at the Google Play Store, bibliotheca web-site or to merge this Policy into the Privacy Policy for BIBLIOTHECA Limited. We may notify you of changes or amendments made to the Policy via information about the current App version on Google Play Store. The date of the recent revision will be indicated at the top of this Privacy Policy.
How we use your Personal Information
The information you provide will be kept confidential. We will hold, use and disclose your personal information for our legitimate business purposes including:
- to identify you and authenticate you when using our App;
- to provide our Services to you as a user, including enhancing your user experience;
- to fulfill contractual obligations with our clients.
- to provide further Services to you by sharing your personal information with other companies within our Group of companies as well as trusted third parties. Further details about this are set out in the separate section below on Sharing your Personal Information; and
- to release personal information to regulatory or law enforcement agencies, if we are required or permitted to do so.
What information is collected and how is it used?
Login Information. We use the identification information such as the location of your library, your patron ID and your password to log you into the cloudCheck mobile app. BIBLIOTHECA transmits this identification information to your library and Integrated Library System (ILS)of your library to validate your account. These data are cached in the app until log out.
App operation. During app operation, the following personal data from the Integrated Library System (ILS) may be retrieved and processed: User name, User e-mail (conditional), User phone number (conditional), User items, reserved and borrowed (conditional), User account balance (conditional), User home address (conditional). These are used in application transaction and will not be stored by the App.
Email Address. When you opt in to notifications via email, we use this email address to send you information regarding the items you have checked-out. The email address and information about the checked-out items are sent to a third-party emailing service, Amazon Simple Notification Service. To ensure reliable transmission of emails we store a copy of the email for up to 14 days in the event that it needs to be re-sent. The App does not store your email address.
Transaction History. When you use our Services, we store information about transactions (borrowed books or other library items) within our Services or other BIBLIOTHECA Services. Transactions executed in application will be sent to Libraryconnect LINK(application management platform). This includes both failed and successful transactions for logging in, borrowing, and renewing items. Management of these data is out of scope of cloudcheck mobile.
Location Information. By default, our Services do not collect, use or store the location of your mobile device. If you opt-in or enable an App feature or setting requiring geolocation information, your location will be transmitted to provide the features that require the location information. Your location information for these purposes is solely used to provide the specific features requiring the information. You may opt-out of these application features at any time via setting on your mobile device.
Usage Data. Our Android app collects anonymous information relating to the performance of the App, such as application crashes. BIBLIOTHECA uses diagnostic services like Crashlytics, a business division of Google Inc. to provide our mobile application developers with information about the functioning of publicly released and beta versions of our mobile applications. This information includes, but is not limited to, device state information, unique device identifiers, device hardware and OS information, information relating to how an application functions, and the physical location of a device at the time of a crash or error event.
Technical logs. Our application collect technical information that might contain personal data. Technical logs are stored in the cloudCheck backend services, are accessible only by the bibliotheca technical department. This data is not kept permanently and will be rolled over during daily operations.
IP Address. An Internet Protocol (IP) address (a number that is automatically assigned to your computer or device when you use the Internet, and which may vary from session to session) is transmitted to our Servers when you use our services. We may store this information on our servers for up to 1 year. We may use this information for business purposes, such as customer service, fraud prevention, ensuring the security of our services, market research, improving our products and services, and for historical, statistical or scientific purposes.
Service and Support. In addition to the above, BIBLIOTHECA and its service providers may access your lending history, and the details of the transactions made with our App in the course of servicing and maintaining the Services.
The Legal Basis for Processing your Personal Information
The main grounds that we rely upon in order to process personal information of our users are the following:
(a) Necessary for entering into, or performing, a contract — in order to perform obligations that we undertake in providing a service to you, or in order to take steps at your request to enter into a contract with us, it will be necessary for us to process your personal data;
(b) Necessary for compliance with a legal obligation— we are subject to certain legal requirements which may require us to process your personal data. We may also be obliged by law to disclose your personal data to a regulatory body or law enforcement agency;
(c) Necessary for the purposes of legitimate interests — either we, or a third party, will need to process your personal data for the purposes of our (or a third party’s) legitimate interests, provided we have established that those interests are not overridden by your rights and freedoms, including your right to have your personal data protected. Our legitimate interests include, but are not limited to, responding to requests and inquiries from you or a third party, optimizing our App and customer experience and ensuring that our operations are conducted in an appropriate and efficient manner.
How we share your Personal Information
In certain circumstances we will share your personal information with other parties. We may share your login information (patron identifier), email address (to notify you about items borrowed) and transaction history with the library that you are a member of upon their request or via our services that they have entered into contract with us to use. Your library uses this information to keep their systems up to date and accurate. We may share your patron identifier and book transaction history with 3rd parties at the request of your local library system. The purpose of sharing this data is for catalog integration, library app integration and other systems the library may need access to, so as to service your account. Your library may be subscribed to book recommendation services. We may share your book transaction history via our App with these book recommendation services. Book recommendations are enabled by your library and your book transaction history is sent without your patron identifier to the book recommendation service.
Transfer of Information outside the EEA
Under the General Data Protection Regulation, we are required to tell you if we transfer or intend to transfer information which we hold on you to countries outside the European Economic Area (“EEA”). We do not transfer such information outside the EEA.
Trusted Third Parties
We will only share your personal information with trusted third parties where we have retained them to provide services that you have requested or for our legitimate business purposes, such as IT or professional support services. To the trusted Third Parties belong:
- your library
- Integrated Library System (ILS) provider of your library
- Email/SMS Notification Services provider, Amazon Web Services
- Crashlytics, a business division of Google Inc.
Regulatory and Law Enforcement Agencies
As noted above, if we receive a request from a regulatory body or law enforcement agency, and if permitted under GDPR and other laws, we may disclose certain personal information to such bodies or agencies.
New Business Owners
If we or our business merges with or is acquired by another business or company, we will share your personal information with the new owners of the business or company and their advisors.
How Long We Will Hold Your Information
We will retain your personal information for the time necessary to provide the Services we perform for you or stated by the purposes outlined in this Privacy Policy. Unless stated otherwise in this policy to be a shorter period, we will retain your information for the duration of your library’s or company’s contract with us. In the event of your library or company leaving and then returning to our service and entering into an agreement that requests user data be restored to its previous state we may retain this data in its original form, or in secure archives (backups) for up to an additional 7 years. At this time or prior we will either anonymize or delete it. If you wish your data to be anonymized prior to the expiration of this period, we will anonymize your data upon request or upon the request of your library or company. You can use the contact form on BIBLIOTHECA’s website or the email contact information at the end of this policy to make your request. Anonymizing data will remove your email address and anonymize the login information you used to access the system.
Security
We respect your information and have put in place measures to ensure the security of the information we collect and store about you. We are committed to protecting your personal data from unauthorized disclosure and/or access including through the use of network and database security measures (though these cannot always guarantee the security of any data which is collected and stored).
Children and Parents
The Services are not intended or permitted for use by persons under 18 years of age without the explicit consent of a parent or guardian. BIBLIOTHECA does not knowingly solicit or collect personal information from or about children through the Services except as permitted under applicable law. If your child has submitted personal information and you would like to request that such information be deleted from our records, you may do so by using the contact form on BIBLIOTHECA’s website or the email contact information at the end of this policy.
Internet based transfers
Given that the Internet is a global environment, using the Internet to collect and process personal data necessarily involves the transmission of data on an international basis. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site via third party networks; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
For Citizens and Residents in the EEA (European Economic Area)
You have certain rights in relation to personal information we hold about you. Details of these rights and how to exercise them are set out below. We will require evidence of your identity before we are able to act on your request.
- Right of Access
You have the right at any time to ask us for a copy of the personal information about you that we hold. Where we have good reason, and if the GDPR permits, we can refuse your request for a copy of your personal information, or certain elements of the request. If we refuse your request or any element of it, we will provide you with our reasons for doing so. - Right of Correction or Completion
If personal information we hold about you is not accurate, out of date or incomplete, you have a right to have the data rectified, updated or completed. You can let us know by contacting us by using the contact form on BIBLIOTHECA’s website or the email contact information at the end of this policy. - Right of Erasure
In certain circumstances, you have the right to request that personal information we hold about you is erased — e.g., if the information is no longer necessary for the purposes for which it was collected or processed, or our processing of the information is based on your consent and there are no other legal grounds on which we may process the information. - Right to object
To or restrict processing In certain circumstances, you have the right to object to our processing of your personal information by contacting us. For example, if we are processing your information on the basis of our legitimate interests and there are no compelling legitimate grounds for our processing which override your rights and interests. You also have the right to object to use of your personal information for direct marketing purposes. You may also have the right to restrict our use of your personal information, such as in circumstances where you have challenged the accuracy of the information and during the period where we are verifying its accuracy. - Right of Data Portability
In certain instances, you have a right to receive any personal information that we hold about you in a structured, commonly used and machine-readable format. You can ask us to transmit that information to you or directly to a third-party organization. The above right exists only in respect of personal information that: you have provided to us previously; and is processed by us using automated means. While we are happy for such requests to be made, we are not able to guarantee technical compatibility with a third-party organization’s systems. We are also unable to comply with requests that relate to personal information of others without their consent. You can exercise any of the above rights by using the contact form on BIBLIOTHECA website or the email contact information at the end of this policy. Most of the above rights are subject to limitations and exceptions. We will provide reasons if we are unable to comply with any request for the exercise of your rights. - Consent
To the extent that we are processing your personal information based on your consent, you have the right to withdraw your consent at any time. You can do this by using the contact form on BIBLIOTHECA’s website or the email contact information at the end of this policy.
Complaints
If you are unhappy about our use of your personal information, you can contact us using the Email Address: dpo@bibliotheca.com.
You have the right to lodge a complaint with a Supervisory Authority in your country or Member State. These can be found here:
Contact Us
Further Information on Data Protection and Personal Privacy If you have any inquiries or if you would like to contact us about our processing of your personal information, including to exercise your rights as outlined above, please contact us by emailing dpo@bibliotheca.com, or by using the contact form on BIBLIOTHECA’s website. When you contact us, you will be required to verify your identity.
