Safety Policy

At Two Windmills Ltd the issue of safety is taken very seriously. It is our aim to be proactive by liaising with government bodies and trading standards, and we have excellent relationships with UK and overseas testing houses.

We also have a dedicated full-time safety coordinator, who undertakes and documents full risk assessments on all components included with our titles.

After evaluation the components will be tested to ensure that they conform to the EN71 European standard, ASTM USA standard and GPS standards.

Safety test reports are available upon request. Please contact our Customer Service Department. 

Additional testing can be undertaken in order to comply with client/country specific safety standards.

We have an ethical sourcing policy.

 

Privacy Policy

This is the privacy notice of Two Windmills Ltd. In this document, “we”, “our”, or “us” refer to Two Windmills Ltd.

We are company number 08524541 registered in the UK.

Our registered office is at Marine House, Tide Mill Way, Woodbridge, Suffolk, IP12 1AP, United Kingdom

Two Windmills Ltd is a Subsidiary of Gemini Children's Books Ltd, who is part of Gemini Books Group Ltd

 

Introduction

• This is a notice to inform you of our policy about all information that we record about you. It sets out the conditions under which we may process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information.
• We take seriously the protection of your privacy and confidentiality. We understand that all visitors to our website are entitled to know that their personal data will not be used for any purpose unintended by them, and will not accidentally fall into the hands of a third party.
• We undertake to preserve the confidentiality of all information you provide to us, and hope that you reciprocate.
• Our policy complies with UK law accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR).
• The law requires us to tell you about your rights and our obligations to you in regards to the processing and control of your personal data. We do this now, by requesting that you read the information provided at knowyourprivacyrights.org
• Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.

 

Information we collect about you

The information you provide to us might include: your name, postal address, email address, phone number. 

If you are submitting a manuscript or job application you will provide additional information about your academic and work history, references and any other information you choose to supply. Your information includes anything which identifies you so if you contribute to a blog or provide other user generated content to us it may include personal information.

If you provide us with more sensitive information this is known as Special Category (“Sensitive”) information and may include details about a person’s racial or ethnic origin, political opinions, religious, philosophical or similar beliefs, trade union membership, genetics, biometrics, health, sexual life, sexual orientation or about criminal offences or proceedings. This type of information will be treated differently and we will explain why we are collecting it and it will only be used with your explicit consent.

We collect your information when you:

• Interact or correspond with us in letters, by phone, SMS, email or via our website;
• attend events we hold or interact with us in person;
• submit information via our website;
• subscribe to our mailing lists;
• submit manuscripts to us by post, email or via our website;
• enter into a contract with us;
• submit an application to a job vacancy;
• enter a competition or prize draw;
• provide us with biographical information about you

We will also collect certain information about how you use our website and apps and the devices that you use to access them. This includes your IP address, geographical location, device information (such as your hardware model, mobile network information, unique device identifiers), browser type, referral source, length of visit to the website, number of page views, the search queries you make on the website and similar information. This information is collected by Google Analytics on our behalf and by some of our apps using cookies. To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout.

 

Information we receive from third parties:

In certain circumstances, we will receive information about you from third parties. For example,

• we use third party providers to verify information provided by you in connection with any manuscript you submit to us for publication. For example, we will use third-party databases or websites to confirm your publication history;
• we will receive information about you from third parties if they are referring you to us for publication. If you have a literary agent making submissions on your behalf, your agent will provide us with information about you;
• if you are a job applicant we may contact your referees to provide information about you;
• distribution services who have provided your information to and have consented their sharing that information;
• when we acquire rights from other publishers.

 

The bases on which we process information about you

The law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category.

If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data.

If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.

We do not sell your information to third parties. 

 

Information we process because we have a contractual obligation with you

When you buy a product or service from us, or otherwise agree to our terms and conditions, a contract is formed between you and us.

In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information.

We may use it in order to:

• verify your identity for security purposes
• sell products to you
• provide you with our services
• provide you with suggestions and advice on products, services and how to obtain the most from using our website

We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.

Additionally, we may aggregate this information in a general way and use it to provide class information, for example to monitor our performance with respect to a particular service we provide. If we use it for this purpose, you as an individual will not be personally identifiable.

We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.

In the following circumstances we will use your information to carry out our contract with you:

• to process your requests to purchase our products from our website;
• to provide customer service and support;
• if you are an author, illustrator or other licensor to administer your publishing contract including receipt, review, editing, production, marketing of your manuscript and payment of your royalties;

 

Information we process with your consent

Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, including job opportunities and our products and services, you provide your consent to us to process information that may be personal information.

Wherever possible, we aim to obtain your explicit consent to process this information.

Sometimes you might give your consent implicitly, such as when you send us a message by e-mail to which you would reasonably expect us to reply.

Except where you have consented to our use of your information for a specific purpose, we do not use your information in any way that would identify you personally. We may aggregate it in a general way and use it to provide class information, for example to monitor the performance of a particular page on our website.

If you have given us explicit permission to do so, we may from time to time pass your name and contact information to selected associates whom we consider may provide services or products you would find useful.

We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.

You may withdraw your consent at any time by instructing us info@twowindmills.com. However, if you do so, you may not be able to use our website or our services further.

When we have consent to contact you, we may use your information to:

• to keep in contact with you and provide you with marketing communications about our news, events, authors or books that we believe may interest you;
• tell you about new website features or services;
• send you newsletters;

 

Information we process for the purposes of legitimate interests

We may process information on the basis there is a legitimate interest, either to you or to us, of doing so.

Where we process your information on this basis, we do after having given careful consideration to:

• whether the same objective could be achieved through other means
• whether processing (or not processing) might cause you harm
• whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so

We may use your information for the purposes listed below on the basis of our legitimate interests:

• to contact you about products you bought from us;
• to contact you about submissions you made or content you provided to us;
• to respond to your queries and correspondence;
• to administer your account with us;
• to process any job applications you submit to us;
• to deal with enquiries or complaints about the website as necessary to provide customer support in providing the correct products and services to our website users;
• to carry out aggregated and anonymised research about general engagement with our website in providing the right kinds of products and services to our website users;
• to operate a safe and lawful business or where we have a legal obligation; 
• to enable us to comply with our policies and procedures and enforce our legal rights, or to protect the rights, property or safety of our employees;
• To detect and prevent fraud and unauthorised access or illegal activity;
• To improve security and optimisation of our network sites and services including trouble shooting, testing and software development and support;
• To work with our third party recruitment agency to process any job applications you submit to us;

 

Specific uses of information you provide to us

Job application and employment

If you send us information in connection with a job application, we may keep it for up to [three years] in case we decide to contact you at a later date.

If we employ you, we collect information about you and your work from time to time throughout the period of your employment. This information will be used only for purposes directly relevant to your employment. After your employment has ended, we will keep your file for six years before destroying or deleting it.

 

Sending a message to our support team

When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us in order to reply with the information you need.

We record your request and our reply in order to increase the efficiency of our business.

We keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service.

 

Complaining

When we receive a complaint, we record all the information you have given to us.

We use that information to resolve your complaint.

If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is.

We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.

 

Use of information we collect through automated systems when you visit our website

Cookies

Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.

Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely.

Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.

Our website uses cookies. They are placed by software that operates on our servers, and by software operated by third parties whose services we use.

If you choose not to use cookies or you prevent their use through your browser settings, you will not be able to use all the functionality of our website.

We use cookies in the following ways:

to track how you use our website

 

Personal identifiers from your browsing activity

Requests by your web browser to our servers for web pages and other content on our website are recorded.

We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.

We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.

If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.     

 

Who can see your information

Your information may be processed by our staff or by the staff of third parties we work with to deliver our business. Processing can mean any activity that involves the use of information about someone that can identify them. All uses, for example, obtaining, recording, storing, disclosing, organising, retrieving, deleting and destroying are types of data processing. We take measures to ensure that third parties processing your information on our behalf are acting lawfully in accordance with our instructions and are subject to appropriate confidentiality requirements. We also have adequate technical and organisational safeguards in place in our company and with third party processors to protect your information. Third party processors of your information include:

• our website hosts and operators, IT support providers, database operators, site analytics providers and software developers;
• our marketing or publicity services providers;
• our editorial and production service providers, peer-reviewers, third-party manuscript readers
• our warehousing and delivery service providers;
• our auditors, technical consultants and legal advisors;
• our fraud detection services;

 

How we look after your information

We look for opportunities to minimise the amount of personal information we hold about you. Where appropriate we anonymise and pseudonymise your information. We use appropriate technological and operational security measures to protect your information against any unauthorised access or unlawful use, such as:

• ensuring the physical security of our offices, warehouses or other sites;
• ensuring the physical and digital security of our equipment and devices by using appropriate password protection and encryption;
• maintaining a data protection policy for, and delivering data protection training to, our employees;
• limiting access to your personal information to those in our company who need to use it in the course of their work.

 

How long we keep it for

We will retain your information for as long as is necessary to provide you with the services that you have requested from us or for as long as we reasonably require to retain the information for our legitimate interests, such as for the purposes of exercising our legal rights or where we are permitted to do so for purposes of academic, literary expression and research purposes. We operate a data retention policy and look to find ways to reduce the amount of information we hold about you and the length of time that we need to keep it. For example,

• We operate a best practice email retention policy requiring password protected folders and departmental shared drives to provide restricted access to information;
• Deleted emails are auto-deleted periodically;
• We conduct regular access reviews to keep access profiles and policies up to date;
• we retain information relating to commercial contracts for approximately 7 years after expiration or termination whichever is the sooner;
• we maintain a suppression list of email addresses of individuals who no longer wish to be contacted by us. So that we can comply with their wishes we must store this information permanently;
• we delete information collected through marketing channels 2 years after our last interaction with you;

Access to your personal information

At any time you may review or update personally identifiable information that we hold about you

To obtain a copy of any information that is not provided on our website you may send us a request at info@twowindmills.com.

After receiving the request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.

 

Removal of your information

If you wish us to remove personally identifiable information from our website, you may contact us at info@twowindmills.com.

This may limit the service we can provide to you.

 

Verification of your information

When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.

 

Use of site by children

Our Site is not intended for or directed to children under 13 years of age nor does Two Windmills Ltd knowingly collect or store personal information from children under 13. If a parent or guardian becomes aware that his or her child has provided us with personal information without the parent or guardian’s consent, he or she should contact us at info@twowindmills.com. We will delete such information from our files within a reasonable amount of time.

 

How you can complain

If you are not happy with our privacy policy or if have any complaint then you should tell us by email. Our address is info@twowindmills.com

If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.

If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner’s Office. This can be done at https://ico.org.uk/concerns/

 

Compliance with the law

Our privacy policy has been compiled so as to comply with the law of every country or legal jurisdiction in which we aim to do business. If you think it fails to satisfy the law of your jurisdiction, we should like to hear from you.

 

Review of this privacy policy

We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.

If you have any question regarding our privacy policy, please contact us at info@twowindmills.com.

This privacy notice was published on 21 March 2024.