Privacy Policy — Oriental Club Library app

Effective date: 7 October 2026 (replaces the version of 3 March 2026)

This policy explains how the Oriental Club Library app (the “App”) handles personal information. The App was developed by FS Enterprises LLC, a Delaware limited liability company, on behalf of the Oriental Club, 18 Stratford Place, London W1C 1ES (the “Club”).

Who is responsible for your data. The Club decides how information sent through the App is used and is the data controller under UK data protection law (UK GDPR and the Data Protection Act 2018). FS Enterprises LLC develops and maintains the App on the Club’s behalf and does not receive your form submissions.

1. Information we collect

We collect personal information only when you choose to enter it in one of the App’s forms:

• Book requests, returns and enquiries: your name and email address, and optionally your phone number, Club membership number or reciprocal club.

• Members Archive corrections: your name, your email address and the details of your report.

• Emailing online book links: the email address you want the links sent to.

The App does not use analytics, advertising or tracking tools, does not ask for your location, and does not require you to create an account or sign in.

2. How we use it

Your information is used only to deal with what you asked for: handling a book request or return, answering an enquiry, reviewing a correction to the Members Archive, or sending you links to online books. If you tick the newsletter box, we also use your email address to send the Library’s quarterly e-newsletter.

We do not use your information for profiling, advertising, or any purpose unrelated to your request.

Legal basis:

• Requests, returns, enquiries and corrections: our legitimate interest in running the Club library and responding to you.

• Newsletter: your consent, which you can withdraw at any time.

3. How emails are sent

On the Club’s library iPads, your form is sent as an email to the library staff from the Library’s own Google (Gmail) account. The App connects to that account with permission only to send email (Google’s “gmail.send” permission). It cannot read the mailbox, contacts or any other data.

If you use the App on your own iPad, it instead opens your own email app with the message already filled in, and you send it yourself from your own account. The App does not send it, and the Library’s account is not used. Your email provider’s own privacy policy applies to that message.

Google API Services: the App’s use and transfer of information received from Google APIs follows the Google API Services User Data Policy, including its Limited Use requirements.

4. Sharing

We do not sell, trade, rent or otherwise share your personal information with third parties. Emails from the Club’s iPads pass through Google’s Gmail service, which processes them on the Club’s behalf. Google may store and process data outside the UK under appropriate safeguards.

5. How long we keep it

• Emails sent from a library iPad: kept in the Library’s email account and handled by library staff under the Club’s data protection policy.

• On the library iPad itself: the App keeps a copy of each email for up to about a week to confirm it was delivered. Messages that could not be delivered are kept until they can be sent. Library staff receive a periodic delivery report listing the subject and recipient of each email sent.

• Newsletter subscribers: your details are kept until you unsubscribe or ask us to delete them.

• On your own iPad: the App keeps nothing. The message stays in your own email account.

6. Security

The Library’s email sign-in is stored in the iPad’s hardware-encrypted Keychain. All communication with Google and with the App’s data service uses encrypted (HTTPS/TLS) connections. The library’s iPads are locked to the App, and their settings are protected by an administrator PIN.

7. The Members Archive

The App includes a historical archive of past Club members, compiled from the Club’s records, published sources and public references. It includes names, dates, careers, Club roles, and where available portraits and biographies. Addresses are included only where they appear in publicly available nineteenth-century sources. Some content has been compiled with the help of AI tools and is reviewed by Club researchers.

UK data protection law applies to living individuals. To protect members who may still be living, the archive does not include members elected after 1950 unless their death is recorded. Original source records restricted by the London Metropolitan Archives for data protection are not shown to the public.

If you believe the archive includes information about you or a living relative, or contains an error, please use Report an error in the App or contact us (section 10). We will correct or remove it.

8. Your rights

Under UK data protection law you have the right to:

• access the personal information we hold about you;

• have it corrected;

• have it deleted;

• restrict or object to its use;

• withdraw your consent to the newsletter at any time.

To use any of these rights, contact us using the details in section 10. You also have the right to complain to the Information Commissioner’s Office (ico.org.uk).

9. Children

The App is intended for Club members, their guests and library visitors. It is not directed at children, and we do not knowingly collect information from anyone under 13.

10. Contact

• App developer: fsenterprisesmd@gmail.com

11. Changes to this policy

We will update this page when the App changes how it handles information, and change the “Effective date” above. Significant changes will also be noted in the App’s App Info tab.