Privacy Policy

1. Who we are

This policy explains how Winfrey Publishing Group LLC, trading as Winfrey Publishing ("we", "us"), collects and uses personal information when you visit this website, contact us or become a client. We are responsible for that information as its controller. Our main office is in New York and we also have an office in London.

2. Information you give us

• Enquiries and consultation requests. Your name, email address, phone number and country, and what you tell us about your book: its genre, stage, approximate length, your budget, when you prefer to be contacted, and any message you write.
• Bookings. The details you enter when you book a call through our scheduling calendar.
• Chat. Anything you type into the chat window on this website, including any contact details you give there.
• Manuscripts and project files. The work and materials you send us. These can contain personal information about you and about other people, such as the real people in a memoir. We treat all of it as confidential project material.
• Newsletter. Your email address and, if you give it, your name.
• Clients. Billing and contract details, correspondence, call notes and payment records. Card payments are handled by our payment provider, [PAYMENT PROVIDER]; we do not see or store your full card number.

3. Information collected automatically

• Where an enquiry came from. When you submit a form we record the page you submitted it on, the page that referred you, and any campaign tags in the link you followed (such as utm_source or gclid), so we can tell which of our advertising works.
• Your country. We use your IP address to work out which country you are in, so we can show prices in the right currency. If our hosting provider has not already identified your country, your IP address is sent to a geolocation service (ip-api.com, ipwho.is or ipapi.co), which returns a country code. Your IP address and country are then kept in a cookie on your device, and the country is cached on our server against a one-way hash of the address, both for up to 30 days.
• Usage analytics. Google Analytics records the pages you view, how you arrived, your device and browser type, and your approximate location. We look at this in aggregate to understand how the site is used.
• Advertising measurement. On our landing pages for paid advertising only, the Meta Pixel tells Meta when a visit or booking came from one of our ads.
• Server logs. Our web server records IP addresses, the pages requested and browser details for security and troubleshooting.

4. How we use your information

We use personal information to:

• reply to your enquiry and arrange the consultation you asked for;
• prepare quotes, deliver the services you commission, and manage your account and payments;
• send you our newsletter, if you signed up for it;
• show prices in your currency and keep the website working and secure;
• measure and improve the website and our advertising;
• keep the records the law requires, and establish or defend legal claims.

If you are in the United Kingdom or the European Economic Area, the law requires us to name a legal basis for each use. We rely on consent, which you give when you tick the box on our forms or subscribe to the newsletter, to contact you about your enquiry and send you the newsletter; contract to quote for and deliver services you ask for; legitimate interests to secure the site, understand how it is used and measure our advertising; and legal obligation for tax and accounting records.

5. Cookies and similar technologies

A cookie is a small file a website stores in your browser. We use the following.

• winfrey_session (essential, deleted when you close your browser). Protects our forms against forgery, keeps what you typed if a form needs correcting, and remembers the campaign that brought you to the site during your visit.
• winfrey_region (essential, one year). Remembers the region you chose with the currency switcher.
• winfrey_geo (functional, 30 days). Stores your IP address and the country detected from it, so it does not have to be looked up again on every page.
• Google Analytics (_ga and _ga_*, analytics, up to two years). Distinguishes one visitor from another so that usage can be counted.
• LeadConnector (functional, set by LeadConnector). Our enquiry forms, booking calendars and chat window are provided by LeadConnector and load from its servers, which may set cookies of their own to run them. A LeadConnector search optimisation script also runs on every page.
• Meta Pixel (_fbp, advertising, 90 days). Set on our paid-advertising landing pages only.

You can block or delete cookies in your browser settings, although blocking the essential cookies will stop our forms from working. You can opt out of Google Analytics on every website with Google's opt-out browser add-on. [DESCRIBE THE COOKIE CONSENT TOOL ONCE ONE IS INSTALLED.]

6. Who we share it with

We do not sell your personal information for money. We share it only as follows.

• Service providers that process it for us: LeadConnector (HighLevel) for our forms, booking calendars, chat and client records; Google for website analytics; the geolocation services named in section 3; our website host; our email providers; and [PAYMENT PROVIDER] for payments.
• Meta, when you visit one of our paid-advertising landing pages, to measure whether our ads led to a visit or booking.
• Specialists working on your project, such as editors, designers, illustrators, narrators and printers, who receive only what they need for their part of the work and are bound by confidentiality.
• Retailers and distributors you ask us to publish through, who receive the book metadata and author details your listing needs.
• Professional advisers, such as our lawyers and accountants.
• Authorities, where the law requires it or to protect our rights or someone's safety.
• A buyer or successor, if our business or its assets are sold or reorganised, on terms that keep this policy in effect.

Under some US state laws, letting Meta measure ad performance on our landing pages may count as "sharing" personal information for targeted advertising. You can opt out as described in section 9.

7. International transfers

We operate from the United States and the United Kingdom, and our service providers may process information in other countries. When personal information from the UK or EEA is transferred to a country without an adequacy decision, we rely on [SAFEGUARD, E.G. THE UK INTERNATIONAL DATA TRANSFER ADDENDUM OR EU STANDARD CONTRACTUAL CLAUSES]. Contact us for a copy.

8. How long we keep it

• Enquiries that do not become projects: [24 MONTHS] from our last contact with you.
• Client, contract and payment records: [7 YEARS] after the engagement ends, for tax and legal purposes.
• Manuscripts and project files: for the engagement and [PERIOD] afterwards so we can supply replacement files, unless you ask us to delete them sooner.
• Newsletter details: until you unsubscribe.
• Country lookups: 30 days.
• Google Analytics data: [14 MONTHS].

9. Your rights

Everyone. You can ask us what personal information we hold about you, ask us to correct it and ask us to delete it. You can unsubscribe from our emails at any time with the link in each one.

UK and EEA. You also have the right to restrict or object to our use of your information, to receive it in a portable format, and to withdraw consent at any time without affecting what we did before you withdrew it. You can complain to the Information Commissioner's Office (ico.org.uk) or your local data protection authority, though we would appreciate the chance to put things right first.

US states with privacy laws, including California. You have the right to know what we collect and why; to access, correct and delete it; and to opt out of the sale or sharing of your personal information and of targeted advertising. We will not treat you differently for exercising these rights. An authorised agent may make a request for you with your signed permission. [STATE WHETHER THE SITE HONOURS GLOBAL PRIVACY CONTROL SIGNALS.]

To make a request, email authorsupport@winfreypublishing.com with the subject "Privacy request". We may need to verify your identity before we act on it. We respond within one month in the UK and EEA and within 45 days in the US, and will tell you if we need longer.

10. Security

We protect personal information with measures including encrypted connections, restricted access to enquiry and client records, and confidentiality obligations on everyone who handles them. No system is completely secure, so please do not send sensitive documents, such as identity documents, through our website forms.

11. Children

This website and our services are intended for adults. We do not knowingly collect personal information from children under 16. If you believe a child has sent us their details, contact us and we will delete them. Information about children that appears in a manuscript, for example in a family memoir, is handled as confidential project material as described in section 2.

12. Changes to this policy

We update this policy when our practices change and revise the date at the top of the page. If a change materially affects how we use information we already hold, we will tell clients directly.

13. Contact

Questions about this policy or how we handle your information can be sent to authorsupport@winfreypublishing.com or by post to the address below. [NAME A DATA PROTECTION CONTACT OR UK REPRESENTATIVE IF COUNSEL ADVISES ONE.]