Version 1.0. Newer version available here.
Last Updated: 17 September 2018
About This Policy
Ex Libris (USA) Inc. is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
Data Controller or Data Processor
Ex Libris is the data controller for data described by this policy except as specified below, which means that Ex Libris determines the purposes and means of the processing of personal data.
Ex Libris is the data processor with respect to personal data submitted to and stored on the Ex Libris Services for hosting and processing purposes as further described below under Ex Libris Services-Customer Data.
Types of Information We Collect About You
Information you or your Institution may provide
Depending upon the Ex Libris Sites you are accessing or other method of contact, we may collect information such as
- Contact details such as (for example) your full (i.e., first and last) name, institutional affiliations, phone number, email address, and postal address
- Educational and professional background information
- Usernames and passwords that may be used on some of the Ex Libris Sites
- Comments, feedback, posts and other content you submit to the Ex Libris Sites
- Information you provide to or post on message boards or chat rooms that are part of the Ex Libris Sites
- Interests and communication preferences.
Where we are collecting directly (and not being provided the information by your institution), you will be given advanced notice of what information specific to you we are collecting. Posting information on message boards or in chat rooms is never required.
Information collected automatically
As you navigate the Ex Libris Sites, Ex Libris may also automatically collect information about you or your computer or device that does not directly identify you. This information may include IP address and device identifiers, information about your Internet connection and information about the equipment or software you use to access the Ex Libris Sites. Such information is only collected to the extent that it is necessary for us to provide services that you use, to optimize your user experience, and/or to make improvements to the Ex Libris Sites and service offerings. Ex Libris does not serve third party advertising.
You have the ability to choose to opt out of inclusion of your personal information at the point of disclosure. You may choose whether your personal information is (i) to be disclosed to a third party or (ii) to be used for a purpose that is materially different from the purpose(s) for which it was originally collected or subsequently authorized by you. You may also opt out of use of your personal information as outlined below under Access, Correction, and Erasure.
How We Collect Information About You
We collect information about you in three main ways:
- Information Directly Provided by You or Your Institution: We collect information about you when you register for services, download an app, sign up for email or text alerts, request products or services, respond to surveys, fill out registration forms on an Ex Libris Site or otherwise for events, register for or view webinars; create a profile, publicly post or share content, contact us, use social media connections, and/or otherwise interact with Ex Libris Sites. We may receive and store information provided by your institution to the extent required to perform a contracted service.
- Information Collected Through Third Parties: We may receive information about you from customers and business partners for referral and reference purposes.
Cookies and Similar Technologies
How We Use and Share Information About You
Ex Libris uses the information we collect to perform the services requested, for the purposes of authorizing and processing transactions, authenticating users, customer service, customer support, content processing, content classification, and providing you with information concerning Ex Libris services. We will retain this information for as long as the customer account is active or as needed to provide the Ex Libris services, comply with our legal obligations, resolve disputes, and as needed to comply with or enforce our licenses and other agreements.
To be clear, we do not access or use Customer Data (as defined below) processed through the Ex Libris Services except for the purposes set forth in our agreement with the relevant customer. Please see below under Ex Libris Services-Customer Data.
Please keep in mind that any information you disclose publicly – either in a public profile or through message boards or other public areas – may be collected and used by others, may be indexable by search engines, and might not be able to be erased from public view to the extent they have been copied to external sites. Please be careful when disclosing personal information in these public areas.
The following is a list of instances where we may share your information with third parties:
- Institutions or Businesses. If you access a service through your affiliation with an institution or through your employer, your information and certain usage data gathered through the Ex Libris service may be shared with the institution or business for the purposes of usage analysis, access and license management, collection management, contract and regulatory compliance, and cost allocation.
- Publishers/Content Providers: We may provide anonymized information to publishers so that they understand how their content is being used and consumed.
- Message Boards and Other Public Areas: Information you post on message boards, chat rooms, or other public areas that are part of the Ex Libris Sites is public and will not be kept private. Should you wish to remove your postings from message boards or other public areas, follow the instructions under the Access, Correction, and Erasure section of this policy.
- Affiliates: To facilitate Ex Libris’ global operations, Ex Libris may share and transfer information we collect with its affiliates located in countries around the world. For example, Ex Libris may need to share such information with other companies within the Ex Libris corporate family for customer support, marketing, technical operations and account management purposes.
- Contests and Sweepstakes: We may publicly disclose the name, city and state of contest and sweepstakes winners as permitted by the contest/sweepstakes rules or as required by law. You may be required to consent to such disclosure if you wish to enter a given contest or sweepstakes.
- Legal Reasons: We will disclose information to cooperate with law enforcement, government or regulatory bodies, content protection organizations, or judicial processes as required by the applicable laws and regulations. We may also use or disclose information to enforce or protect the rights or safety of Ex Libris Services users, us, or others. We will provide notice to individuals prior to such disclosures, to the extent it is practicable to do so and allowed by law.
Ex Libris takes commercially reasonable security measures to protect against unauthorized access to, or unauthorized alteration, disclosure or destruction of, data that you share and that we collect and store. These security measures may include practices such as keeping your data on a secured server behind a firewall, internal reviews of our data collection practices and platforms, industry-standard encryption technologies, and physical security measures to guard against unauthorized access to systems where we store your information.
If you have reason to believe that a third-party has gained unauthorized access to your information, please contact us immediately at email@example.com. If Ex Libris becomes aware of any data breach, we will notify affected individuals or, with respect to Ex Libris Services, affected institutions as soon as reasonably possible.
Your Rights and Choices
Communication Preferences and Opt-outs
If you have subscribed to one or more of our email newsletters or are receiving marketing emails from us and you don’t want them anymore, you can unsubscribe. Follow the instructions contained in the email message to opt-out of receiving future messages of that type. However, you cannot unsubscribe from some service related messages so long as you maintain an account with Ex Libris.
Access, Correction, and Erasure
Postings from message boards or other public areas, may be deleted by using the tools provided when you are logged-in to the particular service; or you may contact Ex Libris at firstname.lastname@example.org with the details and location of the content (such as a direct link to the information), and Ex Libris will make commercially reasonable efforts to remove the content.
You may request to review, correct or delete the personal information that you have previously provided to us through the Ex Libris Sites. For requests to access, correct or delete your personal information, please send your request along with any details you may have regarding the method by which the information was submitted to email@example.com. Requests to access, change, or delete your information will be addressed within a reasonable timeframe.
To the extent applicable, you may also have the right to data portability, the right to restriction of the processing of your personal information and/or the right to file a complaint with the relevant data protection supervisory authority in charge in the EU.
To help protect your privacy and security, we will take reasonable steps to verify your identity, such as requiring a password, user ID, or other verification before granting access to or removing your information.
Please note that where we are acting as a processor of personal data for our customer, we may first refer your request to the customer that submitted your personal data, and we will assist our customer as needed in responding to your request, as further described below under Ex Libris Services-Customer Data.
Please contact firstname.lastname@example.org for more information about exercising these rights.
Data Retention and Deletion
If you request to delete your personal information, we will endeavor to fulfill your request but some personal information may persist in backup copies for a certain period of time and may be retained as necessary for legitimate business purposes or to comply with our legal obligations.
Ex Libris may retain your information for a period of time consistent with the original purpose of collection, and for a reasonable time thereafter in accordance with applicable law. We also may retain your information during the period of time needed for Ex Libris to conduct audits, comply with our legal obligations, resolve disputes and enforce our agreements.
The Ex Libris Sites are typically general audience websites, intended for use by users aged 13 and older.
We do not market to nor intentionally collect any personally identifiable information from children under thirteen (13) years of age. If you are under 13, please do not register for any of our services or Sites or provide us with any personally identifying information (such as your name, email address or phone number). Please contact email@example.com if you are aware of any personal information supplied to one of Ex Libris Sites by a child under the age of thirteen (13).
Links to Other Services and Websites
The Ex Libris Sites may contain links to information created and/or maintained on third-party websites. The third-party website will be displayed in a new browser window and the user will no longer be in the Ex Libris environment. When users select a link to an outside website, they are leaving the Ex Libris Site and are subject to the privacy and security policies of the owners of the third-party website. We are not responsible for, and we do not endorse or control, the policies or practices of any such website or services.
Ex Libris Services – Customer Data
Ex Libris will not use or share any such Customer Data except as provided in its agreements with such customers, or as may be required by law. In accordance with such agreements, Ex Libris may access, transfer and process Customer Data only for the purpose of providing the Ex Libris Services, preventing or addressing service or technical problems or other purposes as set forth in such agreements or required by law. Additional information about the Company’s privacy and security practices with respect to Customer Data is available on our website, currently at https://knowledge.exlibrisgroup.com/Cross_Product/Security .
Ex Libris acknowledges that you have the right to access, correct, amend and delete your personal information. If personal information pertaining to you as an individual has been submitted to us by an Ex Libris customer and you wish to exercise any rights you may have to access, correct, amend, or delete such data, please inquire with our customer directly. Because Ex Libris is subject to our agreements with customers (as the data controller) with respect to your personal information stored on the Ex Libris Services, if you wish to make your request directly to Ex Libris, please provide the name of the Ex Libris customer who submitted your data to the Ex Libris Services. We will refer your request to that customer, and will support the customer as needed in responding to your request within a reasonable timeframe.
GDPR – DPO & Representative
We have designated a Group Data Protection Officer who serves for the group of companies. You can contact our Group Data Protection Officer at firstname.lastname@example.org.
Ex Libris Ltd., Ex Libris Asia Pacific PTE. LTD and Ex Libris (USA) Inc. have each designated as their respective representative in the EU in accordance with Art. 27 GDPR:
Ex Libris (Deutschland) GmbH
Tasköprüstraße 1 D
22761 Hamburg, Germany
Attention: Data Protection Officer
EU-US and Swiss-US Privacy Shield Frameworks
To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/. Personal data from the European Union or Switzerland and/or on EU or Swiss citizens may be collected by Ex Libris and may be stored and processed in the United States or any other country in which Ex Libris or its affiliates, subsidiaries or agents maintain facilities.
You have the right to access your personal data, and to have the data corrected, amended or deleted where it is inaccurate or processed in violation of the Privacy Shield Principles.
In compliance with the EU-US Privacy Shield Principles and the Swiss-US Privacy Shield Principles, Ex Libris commits to resolve complaints about your privacy and our collection or use of your personal information.
Step 1: Contact Ex Libris.
By mail to:
Ex Libris (USA) Inc.
Attn: Data Privacy Officer
1350 East Touhy Avenue
Des Plaines, IL 60018
By email at: email@example.com
Ex Libris will acknowledge your Complaint within 24 hours, and respond to your complaint within 45 days. Ex Libris may ask that you provide additional information and/or request a one-on-one discussion or conference.
Step 2: Third Party Dispute Resolution.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
If you have a complaint left unresolved by all available recourse mechanisms, you may invoke binding arbitration. For additional information go here: www.privacyshield.gov/article?id=How-to-Submit-a-Complaint
Ex Libris has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved Privacy Shield complaints concerning data transferred from the EU and Switzerland.
Last Updated: 17 September 2018