Privacy Policy

We collect your personal information in order to provide and continually improve our products and services. Here are the types of personal information we collect:

Information you give us

We receive and store any information you provide in relation to Verno Services. You can choose not to provide certain information, but then you might not be able to take advantage of many of our Verno Services. It is mandatory to provide certain information to enable you to access our services and products; the mandatory information is indicated on the different fields and forms when you subscribe.

Automatic information

We automatically collect and store certain types of information about your use of Verno Services, including information about your interaction with products, content, and services available through Verno Services. Like many websites, we use “cookies” and other unique identifiers, and we obtain certain types of information when your web browser or device accesses Verno Services and other content served by or on behalf of Verno on other websites. Our physical stores may use cameras, computer vision, sensors, and other technology to gather information about your activity in the store, such as the products and services you interact with.

Information from other sources

We might receive information about you from other sources. For example, our carriers may provide us with updated delivery and address information, which we use to keep our records current and make delivery of your future purchases easier, and third-party platforms may provide us with your feedback about our services and products.

We use your personal information to operate, provide, develop, and improve the products and services that we offer our customers. These purposes include:

• Purchase and delivery of products and services. We use your personal information to take and handle orders, deliver products and services, process payments, and communicate with you about orders, products and services, and promotional offers.
• Provide, troubleshoot, and improve Verno Services. We use your personal information to provide functionality, analyse performance, fix errors, and improve the usability and effectiveness of the Verno Services. In so doing, we use machine learning and artificial intelligence to support and enhance the customer experience across our products and services. This includes using data to develop or deploy our generative AI models and services.
• Recommendations and personalisation. We use your personal information to recommend features, products, and services that might be of interest to you, identify your preferences, and personalise your experience with Verno Services.
• Provide voice, image and camera services. When you use our voice, image and camera services, we use your voice input, images, videos, and other personal information to respond to your requests, provide the requested service to you, and improve our services.
• Comply with legal obligations. In certain cases, we collect and use your personal information to comply with laws. For instance, we collect from authors and publishers information regarding place of establishment and bank account information for identity verification and other purposes.
• Communicate with you. We use your personal information to communicate with you in relation to Verno Services via different channels (for example, by phone, video calls, email or chat).
• Advertising. We use your personal information to display interest-based ads for features, products, and services that might be of interest to you. We do not use information that personally identifies you to display interest-based ads.
• Fraud prevention and credit risks. We use personal information to prevent and detect fraud and abuse in order to protect the security of our customers, Verno, and others. We may also use scoring methods to assess and manage credit risks.

To enable our systems to recognise your browser or device and to provide and improve Verno Services, we use cookies and other identifiers. For more information about cookies and how we use them, please read our Cookies Policy.

Information about our customers is an important part of our business, and we are not in the business of selling our customers’ personal information to others. We share customers’ personal information only as described below and with subsidiaries Vernobooks.com, Inc. controls that either are subject to this Privacy Policy or follow practices at least as protective as those described in this Privacy Policy.

• Transactions involving third parties. We make available to you services, products, applications, or skills provided by third parties for use on or through Verno Services. We also offer services or sell product lines jointly with third-party businesses. You can tell when a third party is involved in your transactions, and we share customers’ personal information related to those transactions with that third party.
• Third-party service providers. We employ other companies and individuals to perform functions on our behalf. Examples include fulfilling orders for products or services, sending postal mail and email, removing repetitive information from customer lists, analysing data, providing marketing assistance, providing search results and links, processing payments, transmitting content, scoring, assessing and managing credit risk, and providing customer service. These third-party service providers have access to personal information needed to perform their functions, but may not use it for other purposes.
• Business transfers. As we continue to develop our business, we might sell or buy other businesses or services. In such transactions, customer information generally is one of the transferred business assets but remains subject to the promises made in any pre-existing Privacy Policy.
• Protection of Verno and others. We release accounts and other personal information when we believe release is appropriate to comply with the law; enforce or apply our Terms of Use and other agreements; or protect the rights, property, or safety of Verno, our users, or others. This includes exchanging information with other companies and organisations for fraud protection and credit risk reduction.

Other than as set out above, you will receive notice when personal information about you might be shared with third parties, and you will have an opportunity to choose not to share the information.

We design our systems with your security and privacy in mind.

• We work to protect the security of your personal information during transmission by using encryption protocols and software.
• We follow the Payment Card Industry Data Security Standard (PCI DSS) when handling credit card data.
• We maintain physical, electronic, and procedural safeguards in connection with the collection, storage, and disclosure of customer personal information. Our security procedures mean that we may ask to verify your identity before we disclose personal information to you.
• Our devices offer security features to protect them against unauthorised access and loss of data. You can control these features and configure them based on your needs.

It is important for you to protect against unauthorised access to your password and to your computers, devices, and applications. We recommend using a unique password for your Verno account that is not used for other online accounts. Be sure to sign off when finished using a shared computer.

Third-party advertisers and links to other websites

Verno Services may include third-party advertising and links to other websites and apps. Third-party advertising partners may collect information about you when you interact with their content, advertising, and services.

Use of third-party advertising services

We provide ad companies with information that allows them to serve you with more useful and relevant Verno ads and to measure their effectiveness. We never share your name or other information that directly identifies you when we do this. Instead, we use an advertising identifier like a cookie, a device identifier, or a code derived from applying irreversible cryptography to other information like an email address.

While we do not share your specific shopping actions like purchases, product views, or searches with ad companies, we may share an advertising identifier and an estimate of the value of the ads they show you on our behalf so they can serve you with more effective Verno ads. Some ad companies also use this information to serve you relevant ads from other advertisers.

You can access your information, including your name, address, payment options, profile information, subscription, household settings, and purchase history in the “Your Account” section of the website.

If you have any questions as to how we collect and use your personal information, please email hello@vernobooks.com. Many of our Verno Services also include settings that provide you with options as to how your information is being used.

As described above, you can choose not to provide certain information, but then you might not be able to take advantage of many of the Verno Services.

If you do not want to receive email or other communications from us, please make the relevant selection during sign-up, or email hello@vernobooks.com after you have signed up to amend your privacy settings manually. If you don’t want to receive in-app notifications from us, please adjust your notification settings in the app or device.

The Help feature on most browsers and devices will tell you how to prevent your browser or device from accepting new cookies or other identifiers, how to have the browser notify you when you receive a new cookie, or how to block cookies altogether. Because cookies and identifiers allow you to take advantage of some essential features of Verno Services, we recommend that you leave them turned on. For instance, if you block or otherwise reject our cookies, you will not be able to sign in or use any Services that require an account. For more information, see our Cookies Policy.

If you want to browse our websites without linking the browsing history to your account, you may do so by signing out of your account and blocking cookies on your browser.

If you are an author or publisher, you can add or update certain information in your account dashboard, update your account information by accessing your Account Information, and adjust your email or other communications you receive from us by updating your Notification Preferences.

In addition, to the extent required by applicable law, you may have the right to request access to or delete your personal information. If you wish to do any of these things, you may email datacontroller@vernobooks.com or hello@vernobooks.com. Depending on your data choices, certain services may be limited or unavailable.

Verno does not sell products for purchase by children. We sell children’s products for purchase by adults. If you are under 16, you may use Verno Services only with the involvement of a parent or guardian. We do not knowingly collect personal information from children under the age of 13 without the consent of the child’s parent or guardian.

Vernobooks.com, Inc. participates in the EU-US Data Privacy Framework, the UK Extension to the EU-US Data Privacy Framework, and the Swiss-US Data Privacy Framework.

If you choose to use Verno Services, your use and any dispute over privacy is subject to this Notice and our Terms of Use, including limitations on damages, resolution of disputes, and application of the law of the state of Washington, Laws of England and Wales, and EU Laws, depending on where you are residing and accessing the services from. If you have any concern about privacy at Verno, please contact us with a thorough description, and we will try to resolve it.

Our business changes constantly, and our Privacy Policy will change also. You should check our websites 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, however, 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.

We use a number of different social media platforms to communicate with you, promote our products and services and to understand how people feel about our brand and business. We process your personal information using these platforms in a variety of ways, as follows:

• Pages. We use your personal information when you post content or otherwise interact with us on our official pages on Facebook, Instagram, TikTok and other social media platforms.
• Page Insights. We also use the Page Insights service for Facebook to view statistical information and reports regarding your interactions with the pages we administer and their content. Where those interactions are recorded and form part of the information we access through the Page Insights service, we and Meta are joint controllers of the processing necessary to provide that service to us.
• Monitoring. We monitor your posts and other content on our and other social media pages and accounts to understand how you feel about our businesses and brands and those of others in our industry. We may collect any personal information you make available in any post or other social media content, but we only use relevant posts that have been published by you. Once received, we may create aggregate data and reports from that content. In limited circumstances, we may share that content with our service providers and other third parties.
• Cookies and ad-targeting. Social media cookies can be used to track you across different sites, building up a profile of your interests. We may then use cookies and similar technologies on our website to collect and send information to social media platforms about actions you take on our website and applications. You can find out more about these technologies by visiting our Cookies Policy.

We are joint controllers for certain processing with Meta (who operates Facebook and Instagram) as a result of our use of its services. We and Meta are joint data controllers of the processing involved in collecting and sending your personal information to Meta using its cookies and similar technologies and also in relation to the Facebook Insights service, as each of us has a business interest in Meta receiving this information.

As we are joint data controllers with Meta for certain processing, where applicable, we and Meta have:

• entered into agreements in which we have agreed each of our data protection responsibilities for the processing of your personal information described above;
• agreed that we are responsible for providing to you the information in this privacy policy about our relationship with Meta; and
• agreed that Meta is responsible for responding to you when you exercise your rights under data protection law in relation to Meta’s processing of your personal information as a joint data controller.

The Meta company that is a joint data controller of your personal information is Meta Platforms, Inc., 1601 Willow Road, Menlo Park, CA 94025, USA (if you are a UK-registered user) or Meta Platforms Ireland Limited, Block J, Serpentine Avenue, Dublin 4, Ireland (if you are an EEA-registered user).

Meta also processes, as our processor, contact information that we submit for the purposes of matching, online targeting, measurement, reporting and analytics purposes. This service includes the processing Meta carries out when it displays our advertisements to you in your news feed at our request after matching contact details for you that we have uploaded to the platforms Meta operates.

We use artificial intelligence, commonly known as “AI”, in a variety of ways within our business. AI enables computers to perform tasks that typically require human intelligence, such as recognising patterns, understanding language, or making predictions based on information, including in certain cases, your personal information.

How we use AI

Some of our uses of AI allow us to provide improved or AI-powered versions of our existing services as well as developing new ones. Others allow us to put AI to use in the background, helping our business to operate more efficiently and effectively. This means that we may use AI in connection with any of the purposes and types of information mentioned in this privacy policy.

• Online chat: this feature is included in some of our websites and is designed to assist you by responding to your queries, for example in relation to new products.
• Personalisation: certain content in our website, applications and emails may be personalised for you using AI. Where the law requires us to obtain your consent to do so, we will always request this before personalising content for you.
• Surveys: we may use AI to help analyse the responses you provide to us when completing customer surveys.
• Internal tools: we may use AI to make existing processes faster, for instance by transcribing call recordings or creating meeting minutes or other summaries of internal communications, or automation of customer service tasks.

AI-powered features

When you are interacting with features on our websites or other directly accessible services that use AI, we will always aim to make this clear to you. One common type of AI that we may use is generative AI, which produces a response based on patterns learned from material it was trained on. Depending on the feature, you may be asked not to provide any personal information about yourself or others.

Use of information to train AI models

The AI features we use have often been pre-trained by other companies or by us, or both, to improve the way they operate. In some cases, we may use your personal information to train models that power the AI features you interact with, and in some cases the AI tools we use in the background. When we refer to training, this includes fine-tuning, testing, enhancing or carrying out a similar activity designed at developing or improving the AI we use or the underlying model that helps it produce a result. We will never use your sensitive information, such as health data, for training any AI models.

The safeguards we apply when using AI

We take steps, including by carrying out risk assessments and implementing security measures, to ensure we use AI in ways that are responsible, fair, and secure. This includes, where appropriate, limiting access to your information, anonymising information, preventing any training based on your information by unauthorised third parties, and monitoring AI outputs for accuracy and bias.

We retain your information for a range of purposes which determine the period of time for which we need to keep such information. We do not retain personal information in an identifiable format for longer than is necessary.

We will always retain your personal information for the period that you have an active account, except for details of your transactions, complaints and legal requests, which we will hold for 3 years from the date of your last transaction. If you do not hold an account, we retain your personal information for 3 years from the date we collect it or, where applicable, the date you are unsubscribed from our marketing lists, if later.

Your account will become inactive if you do not engage with us for more than 3 years — for example, if you do not log into your account, make a purchase with us, or engage with our direct marketing campaigns. After that period ends, or at any point you choose to delete your account with us using the relevant settings, we will delete or anonymise the records we hold about you so that we no longer hold your personal information. Exceptions apply to these periods, including but not limited to where:

• the law requires us to hold your personal information for a longer period, or delete it sooner;
• you exercise your right to have the information erased, where it applies, and we do not need to hold it in connection with any of the reasons permitted or required under the law;
• you exercise your right to require us to retain your personal information for a period longer than our stated retention period;
• we record our calls with you, in which case we will store the recording for 15 days from the date of the call;
• your personal information is included in the social media content we collect, in which case we may retain that information for up to 10 years; or
• we bring, defend or investigate a legal claim or other proceedings during the period we retain your personal information, in which case we will retain it until those proceedings or our investigations have concluded and no further appeals are possible.

Additionally, we care about the security of your personal information. We deploy administrative, technical, organisational, and physical measures designed to ensure a level of security appropriate to the risk of processing the personal information we collect. We evaluate these safeguards on an ongoing basis to help minimise risks from new security threats as they become known, although no information system can be 100% secure. We need your help too: it is your responsibility to make sure that your personal information is accurate and up to date, and we encourage you to ensure that your password is unique, robust, secure, and not shared with third parties.

To protect your information, Verno has policies and procedures in place to make sure that only authorised personnel can access the information, that information is handled and stored in a secure and sensible manner, and that all systems that can access the information have proportionate and reasonable security measures in place. To achieve this, employees, contractors, sub-contractors and third-party suppliers have contracts with defined roles and responsibilities. While we take commercially reasonable measures to ensure the safety and security of your data, due to the inherent risks with the internet, we are unable to guarantee the absolute security of your data when using our services.

We may from time to time need to transfer your personal information to support partners and other companies which are located outside the UK, for the purpose of ensuring our websites are operating correctly or in relation to third parties with whom we share your data.

Where we transfer your information outside of the UK, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this privacy policy. These steps include:

• relying on decisions issued by the relevant UK Secretary of State or European Commission declaring that a country or a company certifying to an international framework is adequately protective of personal information to a degree that allows us to safely transfer your personal information to that country or company;
• imposing contractual obligations on the recipient of your personal information using standard clauses issued by the UK Information Commissioner’s Office or European Commission; or
• relying on binding corporate rules put in place by recipients of your personal information that have been approved by relevant data protection regulators.

Please contact us using the details at the end of this privacy policy for more information about the protections that we put in place and to obtain a copy of the relevant documents. If you use our services whilst you are outside the UK, your information may be transferred outside the UK in order to receive those services.

We do not envisage making decisions that have a legal or significant effect on you using purely automated means, however we will update this privacy policy and inform you if this position changes.

In order to process any of the requests listed below, we may need to verify your identity for your security. In such cases your response will be necessary for you to exercise these rights.

The right to access information we hold about you

At any point you can contact our customer services team to request details concerning the information we hold about you, why we have that information, who has access to the information and where we got the information. In most cases you are entitled to copies of the information we hold concerning you. Once we have received your request we will usually respond within 1 month, but in some cases may take up to 3 months to respond, where the law allows us to do so.

The right to correct and update the information we hold about you

If the data we hold about you is out of date, incomplete or incorrect, you can inform us and we will ensure that it is updated.

The right to have your information erased

If you feel that we should no longer be using your data or that we are illegally using your data, you can request that we erase the data we hold. When we receive your request, we will confirm whether the data has been deleted or tell you the reason why it cannot be deleted.

The right to object to processing of your data or restrict our processing

You have the right to request that we stop processing your data or to restrict our processing, including by suspending certain processing or retaining your information. Upon receiving the request, we will contact you to tell you if we are able to comply or if we have legitimate grounds to reject your request. If data is no longer processed, we may continue to hold your data to comply with your other rights.

The right to ask us to stop contacting you with direct marketing

You have the right to request that we stop contacting you with direct marketing. On promotional emails we provide an unsubscribe link at the bottom of the email which will unsubscribe you from that service. You can also unsubscribe by updating your profile preference centre or via your Verno account on our website.

If you wish to opt out with respect to more than one email address, you must complete a separate request for each email address. Please note, unsubscribing from marketing communications will not opt you out from receiving customer satisfaction surveys.

It is not possible to opt out of receiving communications from us which relate to your orders or updates to our terms, policies or other legal information, which are not considered marketing for these purposes. This ensures that we can always contact you as a result of circumstances that may affect your account and supply legal and other important information to you.

The right to data portability

You have the right to request that we transfer your data to another controller. Once we have received your request, we will comply where it is feasible to do so.

The right not to be impacted by automated decision making

You have the right to request that no automated decisions are made, including profiling, where these have a legal or other significant impact on you. As we mention above, we do not process information to make such decisions but will notify you if that position changes.

The right to complain

You have the right to complain to us if you think that there is an infringement of data protection law in connection with your personal data. To make this process easier you may use our online complaint form, write to us at hello@vernobooks.com or datacontroller@vernobooks.com, write to us at the postal address below, complain in person by visiting our office address during normal opening hours, or contact us through our social media pages.

We will acknowledge receipt of your complaint within 30 days starting when the complaint is received. Without undue delay, we will take appropriate steps to respond to your complaint, which will include making appropriate enquiries into it and informing you about its progress, and inform you of the outcome of the complaint. If you contact us through social media it may take us longer to respond and we may invite you to use one of the secure channels above.

If you are located in the United Kingdom or European Union, you also have the right to make a complaint to your local data protection regulator, which in the UK is the Information Commissioner’s Office. Please see the European Data Protection Board website for contact details regarding the data protection regulators in the European Union.

In those cases where we need your consent to process your information, we will ask you to make a positive indication, for example to tick a box or insert your contact details on the relevant form or web page requiring consent. In the case of our use of biometric information we use to verify your identity, we will ask you explicitly for your consent.

Once you have provided your consent you can withdraw it at any time. Our processing of your personal information based on your consent prior to the time you withdrew it will remain lawful.

The information and data we collect is important for Verno and we understand that you care about the use and storage of your personal information. We value your trust in allowing us to do this. We will not share this with anyone else unless we have a lawful basis for doing so, and we will never rent, trade or sell your personal information to any third parties for their marketing purposes.

We do disclose or transfer your data or personal information to service providers, agents or other data processors engaged by us to perform any necessary functions on our behalf, such as hosting and maintaining our website, providing us with data management systems, market research, artificial intelligence technology including the use of models and related services, customer satisfaction surveys and support services, and to help us analyse and tailor our marketing to you.

When sending your information to such third-party processors, we only disclose to them any personal information that is necessary for them to provide their service, and we have a contract in place that requires them to keep your information secure and not to use it other than in accordance with our specific instructions.

We may share your information with other companies in our corporate group. They may use your personal information in the ways set out in this policy, in connection with the services they provide including where they complement our own.

We may disclose your personal information with other third parties who are controllers, who may make their own decisions regarding your personal information. These may include professional advisers, consultants, social media platforms, our insurers, business partners, and public authorities. When we share your personal information with such third parties, they may disclose or transfer it to other organisations in accordance with their privacy policies. This does not affect any of your data subject rights as detailed above.

We may disclose your personal information to other third parties as follows:

• In the event that Verno or any part of its business is sold to or integrated with another business or restructured or reorganised, Verno may disclose your personal information to the new owners and their professional advisers on the transaction, to be used by the new owners and their group of companies in the same ways as set out in this privacy policy.
• If we are under, or consider that we have, a duty to disclose or share your information in order to comply with any legal or regulatory obligation or request, including by the police and other law enforcement bodies, tribunals, regulators, local or central government or related agencies.
• We may also provide information, including pseudonymised data, to third parties that receive it in aggregated or otherwise anonymous form, including statistics about our customers, sales, traffic patterns and related site information, in order to better understand our services, website and overall customer satisfaction. In certain limited cases, we may provide such companies with personally identifying information.

If you have any queries about this policy, need further information or wish to lodge a complaint you can use the details below to contact us.

Verno Alphabet Ltd, 1st Floor, North Westgate House, Harlow, Essex, CM20 1YS, United Kingdom.

datacontroller@vernobooks.com or hello@vernobooks.com

We may change this policy from time to time by updating this website or notifying you by email, or both. You should check this policy occasionally to ensure that you are aware of the most recent version that will apply each time you access the website.

Information you give us when you use Verno Services

You provide information to us when you:

• search or shop for products or services in our stores;
• add or remove an item from your cart, or place an order through or use Verno Services;
• download, stream, view, or use content on a device or through a service or application on a device;
• provide personal information in your subscription or registration account;
• talk to or otherwise interact with our AI voice, video and chat service;
• configure your settings on, provide data access permissions for, or interact with a Verno device or service;
• provide information in your author or publisher account, or any other account we make available that allows you to develop or offer software, goods, or services to Verno customers;
• offer your products or services on or through Verno Services;
• communicate with us by phone, email, or otherwise;
• complete a questionnaire, a support ticket, or a contest entry form;
• participate in discussion boards or other community features;
• provide and rate reviews.

As a result of those actions, you might supply us with such information as:

• identifying information such as your name, address, and phone numbers;
• payment information;
• your age;
• your location information;
• your IP address;
• email addresses of your friends and other people;
• content of reviews and emails to us;
• personal description and photograph in your profile or dashboard;
• voice recordings when you speak to customer service;
• images and videos collected or stored in connection with Verno Services;
• information and documents regarding identity;
• corporate and financial information;
• credit history information; and
• device log files and configurations.

Automatic information

Examples of the information we collect and analyse include:

• the internet protocol (IP) address used to connect your computer to the internet;
• login, email address, and password;
• the location of your device or computer;
• content interaction information, such as content downloads, streams, and playback details, including duration and number of simultaneous streams and downloads, and network details for streaming and download quality;
• device metrics such as when a device is in use, application usage, connectivity data, and any errors or event failures;
• Verno Services metrics, for example the occurrences of technical errors, your interactions with service features and content, your settings preferences and backup information;
• version and time zone settings;
• purchase and content use history, which we sometimes aggregate with similar information from other customers;
• the full Uniform Resource Locator (URL) clickstream to, through, and from our websites, including date and time; products and content you viewed or searched for; page response times, download errors, length of visits to certain pages, and page interaction information; and
• phone numbers used to call our customer service number.

We may also use device identifiers, cookies, and other technologies on devices, applications, and our web pages to collect browsing, usage, or other technical information.

Information from other sources

Examples of information we receive from other sources include:

• updated delivery and address information from our carriers or other third parties;
• account information, purchase or redemption information, and page-view information from some merchants with which we operate co-branded businesses or for which we provide technical, fulfilment, advertising, or other services;
• information about your interactions with products and services offered by our subsidiaries;
• information about how you interact with ads served by Verno on third-party websites and apps;
• content we receive from third parties to provide, develop, and improve Verno Services; and
• credit history information from credit bureaus, which we use to help prevent and detect fraud and to offer certain credit or financial services to some customers.

Information you can access

Examples of information you can access through Verno Services include:

• status of recent orders, including subscriptions;
• your complete order history;
• personally identifiable information, including name, email, password, and address book;
• payment settings;
• email notification settings;
• recommendations and the titles you recently viewed that are the basis for recommendations;
• your content, devices, services, and related settings, and communications and personalised advertising preferences;
• content that you recently viewed; and
• your profile, including your reviews and personal profile.

If you are an author or publisher, you can access your account and other information, and update your accounts, on the dashboard in the Verno portal.