Privacy Policy

Last updated 14 September 2026

This Privacy Policy explains how First Audiobooks Limited ("First Audiobooks", "FAB", "we", "us" or "our") collects and uses personal data in connection with firstaudiobooks.com, Author Accounts, audiobook production, the First Audiobooks Store, customer purchases, digital fulfilment and related services.

First Audiobooks Limited is incorporated in Gibraltar under Company No. 124089 and has its registered office at Suite 4.3.02, Eurotowers, Gibraltar GX11 1AA. Contact: info@firstaudiobooks.com.

For personal data for which FAB determines the purposes and means of processing, FAB is the data controller. Some service providers, payment resellers and commerce platforms may also act as independent controllers for parts of their own services.

1. Scope

This Policy applies to visitors to the Website, Authors and their representatives, Store Customers, people whose voices or other personal data are supplied for a Project, and people who contact us.
It should be read with our Terms & Conditions and any just-in-time notice presented when specific data is collected, such as a voice-cloning consent or optional marketing consent.

2. Personal data we collect

Account and contact data

  • name, email address, country/region and contact details;
  • password and authentication data (stored using appropriate security controls rather than as readable plain text);
  • author name, pen name, company/publisher name and Account preferences;
  • records of acceptance of Terms, privacy notices and Project approvals.

Project and manuscript data

  • manuscripts, book titles, descriptions, genre and metadata;
  • character descriptions, production notes, pronunciation instructions, casting choices and revision requests;
  • cover art, illustrations, audio references, uploaded music or sound effects;
  • voice recordings and related voice data supplied for authorised voice cloning;
  • generated chapters, production files, quality-control records and final Audiobook masters.

Transaction, royalty and fulfilment data

  • order and transaction identifiers, amount, currency, tax status, payment status and timestamps;
  • billing details supplied by the payment/commerce provider where needed for support, accounting or legal compliance;
  • Store sales, refunds, chargebacks, royalty statements and Author payout details;
  • customer email address, purchased title, delivery status, download or library-access information and support history.

We do not intentionally receive or store complete payment-card numbers on our own systems. Sensitive card data is handled by the applicable payment provider.

Technical and usage data

  • IP address, browser, device and operating-system information;
  • security logs, login history, diagnostic data and error records;
  • pages visited, feature usage and cookie or similar identifiers where those technologies are enabled.

Communications and preferences

  • support messages, emails and Account messages;
  • feedback and survey responses;
  • marketing preferences and records of consent or opt-out.

3. Personal data contained in manuscripts and other Content

A manuscript may itself contain information about identifiable living people, including sensitive information. Authors should not submit personal data about real people unless it is reasonably necessary for the Project and they have a lawful basis to do so.
If an Author supplies another person's voice recording, likeness or other personal data, the Author is responsible for providing any required privacy notice and obtaining any required consent or other lawful authority before submission.
Voice data can be particularly sensitive. Where voice data is treated as biometric or special-category data under applicable law, we will process it only where an appropriate legal condition is available, which may include the explicit consent of the voice owner.

4. How we use personal data

Provide the Services: to create and manage Accounts; receive manuscripts; produce the Free Chapter and full Audiobook; manage approvals and revisions; deliver master files; operate the Store; fulfil purchases; calculate royalties; and provide support.

Payments and accounting: to reconcile transactions, refunds and chargebacks, maintain records, pay Author royalties and meet accounting or tax obligations.

Security and fraud prevention: to authenticate users, protect Accounts and systems, detect abuse, prevent unauthorised access and investigate suspicious activity.

Rights and compliance: to confirm rights and voice consents where appropriate, respond to copyright complaints, enforce our Terms, comply with legal obligations and respond to lawful requests.

Service improvement: to diagnose faults, understand how features are used, improve workflows and quality, and plan new functionality, using aggregated or de-identified data where reasonably practicable.

Communications: to send service messages, transaction confirmations, Account alerts, policy updates and responses to enquiries.

Marketing: to send promotional communications only where permitted by law and, where required, with consent. Marketing consent is separate from acceptance of our Terms and can be withdrawn at any time.

5. Legal bases for processing

Where the GDPR, UK GDPR or similar laws require a legal basis, we rely on one or more of the following:

  • Contract: processing necessary to create and administer an Account, provide a Free Chapter, produce and deliver an Audiobook, operate Store purchases, fulfil orders and account for royalties.
  • Legitimate interests: protecting our systems and users, preventing fraud, maintaining project and approval records, improving services, resolving disputes, defending legal claims and operating a commercially viable Store, where those interests are not overridden by the individual's rights.
  • Consent: optional marketing, optional non-essential cookies where required, and specific uses of voice or other sensitive data where consent is the appropriate legal basis.
  • Legal obligation: accounting, tax, regulatory, consumer-protection, law-enforcement and other obligations imposed by applicable law.
  • Legal claims / substantial public interest / other permitted conditions: where required for special-category data or legal proceedings and permitted by applicable law.

We do not rely on a general statement of "consent to this Privacy Policy" as the legal basis for all processing. Different activities rely on the legal bases described above.

6. Who we share personal data with

We do not sell personal data for money. We share data only where reasonably necessary for the purposes described in this Policy, including with:

Midsummer LTD / Midsummerr: AI-assisted audiobook production and back-office processing, which may involve manuscripts, character information, production instructions, voice data and generated audio.

BookFunnel LLC: digital audiobook hosting, fulfilment, reader libraries, delivery links, technical support, watermarking and fraud/abuse prevention for Store distribution.

Shopify and related Shopify services: e-commerce hosting, checkout, order administration, fraud prevention, Store analytics and customer-facing commerce services where enabled.

Paddle: where used as reseller/merchant of record, for checkout, payment processing, invoicing, tax handling, refunds, chargebacks, order support and related compliance. Paddle may act as an independent controller for buyer/payment data.

DigitalOcean and other infrastructure providers: hosting, storage, network and security infrastructure.

Email, support, analytics and security providers: only to the extent those services are enabled and necessary to operate, communicate, diagnose or secure the Services.

Professional advisers, insurers and authorities: where reasonably necessary to obtain advice, protect legal rights, comply with law or respond to valid legal process.

Business successors: if FAB is reorganised, sold, merged or transfers a relevant business or asset, subject to appropriate confidentiality and data-protection safeguards.

7. BookFunnel and digital fulfilment

When BookFunnel is used to deliver an Audiobook, FAB may provide the customer's email address, title purchased, relevant metadata and the digital Audiobook file as necessary for fulfilment, technical support and fraud/abuse prevention.
BookFunnel's published author/publisher terms provide for processing of names, email addresses, IP addresses, usernames, usage data and cookie identifiers and for international transfers, including to the United States, using contractual transfer mechanisms for EEA/UK data where applicable.
A purchased Audiobook may remain available in a customer's BookFunnel reader library for re-download. Deleting an Audiobook from FAB's current catalogue does not necessarily erase a copy already associated with a purchaser's BookFunnel library.

8. Shopify and Store privacy

Where the Store is hosted or operated through Shopify, Shopify may collect and process customer data to provide checkout, fraud prevention, order management and other commerce services. Information submitted to the Store may therefore be shared with Shopify and other service providers, including providers located in other countries.
If FAB enables Shopify features that use additional customer data for advertising, targeted marketing or Shopify Network Intelligence/Enhanced Services, we will use the available privacy controls and provide any additional notices or opt-out links required by applicable law.
Where required by Shopify's then-current terms for enabled features, the Store Privacy Policy will include or link to Shopify's Consumer Privacy Policy and applicable opt-out mechanism.

9. Paddle and payment privacy

Where Paddle is used as merchant of record/reseller, the buyer contracts with Paddle for the checkout transaction and Paddle collects buyer data for payment processing, invoicing, fraud prevention, tax and order support under Paddle's own privacy terms.
Paddle may pass buyer data to FAB where necessary for fulfilment, order processing, fraud prevention and product support. We will not use data received from Paddle for unrelated marketing unless the buyer has separately consented or another lawful basis applies.
FAB may receive transaction identifiers, product/order information, buyer contact details, location or tax-related information, refund/chargeback status and other information reasonably necessary to provide the purchased service and support the buyer.

10. International transfers

FAB is based in Gibraltar and uses providers operating internationally. Personal data may therefore be processed outside the country in which the individual is located, including in the United States and other countries where providers operate.
Where EEA or UK personal data is transferred to a country that is not recognised as providing adequate protection, we will rely on an available lawful transfer mechanism where required, such as the EU Standard Contractual Clauses, the UK International Data Transfer Addendum or Agreement, or another approved safeguard.
BookFunnel states that its EEA author/publisher processing uses the Controller-to-Processor Standard Contractual Clauses and that its UK processing incorporates the UK International Data Transfer Addendum. Other providers maintain their own transfer mechanisms and privacy arrangements.

11. Retention

We keep personal data only for as long as reasonably necessary for the purpose for which it was collected, legal obligations and legitimate business needs. Our intended retention approach is:

Account and contract records: for the life of the Account and thereafter for the period reasonably needed for support, disputes, legal claims and statutory record-keeping.

Financial and transaction records: for the period required by applicable accounting, tax and anti-fraud laws.

Manuscripts and working production files: ordinarily for up to 12 months after final delivery unless a longer period is needed for an active dispute, requested revision, continuing production or another lawful purpose.

Final Store masters and metadata: for as long as the Audiobook is listed and thereafter as reasonably necessary to honour prior purchases, account for royalties and maintain legal records.

Voice samples / voice data: only as long as reasonably necessary to create and use the authorised voice for the relevant Project(s), subject to provider technical retention and legal requirements; access will be removed or data deleted when no longer required where reasonably practicable.

Support and approval records: for as long as reasonably necessary to administer the Project and establish what was approved or agreed.

Security logs: for a limited period appropriate to security, fraud prevention and incident investigation.

12. Cookies and similar technologies

The public FAB website is intended to use only strictly necessary cookies by default where practicable. Necessary cookies may be used for security, login, Account sessions, checkout and other functions that cannot operate without them.
If optional analytics, functionality, advertising or targeting cookies are enabled, we will provide the notices and consent controls required by applicable law before using them where consent is required.
Shopify, Paddle, BookFunnel and other Third-Party Providers may set or use their own cookies or similar technologies when a user interacts with their checkout, delivery or embedded services. Their own privacy/cookie notices apply to those technologies.
Users can also control cookies through browser settings, although disabling necessary cookies may prevent login, checkout or other features from functioning.

13. Security

We use reasonable administrative, technical and organisational measures designed to protect personal data, including access controls, authentication, encrypted connections, restricted administrative access and reputable hosting/service providers.
No internet or storage system is completely secure. We cannot guarantee absolute security, but we will investigate suspected incidents and make notifications to affected individuals and regulators where required by law.

14. Your rights

Depending on the law that applies to you, you may have rights to:

  • access personal data and obtain a copy;
  • correct inaccurate or incomplete data;
  • request deletion where no legal reason requires continued retention;
  • restrict processing in specified circumstances;
  • object to processing based on legitimate interests;
  • receive certain data in a portable format;
  • withdraw consent at any time where processing is based on consent, without affecting prior lawful processing;
  • opt out of direct marketing;
  • complain to a competent data-protection supervisory authority.

To exercise a right, contact info@firstaudiobooks.com or DataRep using the details below. We may request reasonable evidence of identity and may retain limited information about the request where necessary to demonstrate compliance.

15. US state privacy choices

Where an applicable US state privacy law gives a consumer additional rights, including rights to know, correct, delete or opt out of certain sale/sharing or targeted advertising, we will honour those rights to the extent the law applies to FAB.
FAB does not sell personal information for money. If a Shopify or other advertising feature that constitutes "sharing" or targeted advertising under an applicable law is enabled, we will provide the required opt-out mechanism and notice.

16. DataRep – EU/EEA and UK representative

FAB has appointed DataRep as its data-protection representative for individuals in the EU/EEA and the United Kingdom, as applicable. You may contact DataRep about FAB's processing of your personal data by:

  • email: firstaudiobooks@datarep.com
  • online form: https://www.datarep.com/firstaudiobooks
  • post: using the DataRep address most convenient to you in the table below.

When writing by post, mark the correspondence for "DataRep" and clearly refer to First Audiobooks Limited so that the enquiry is routed correctly. DataRep may require evidence of identity before personal data is disclosed or rights are exercised.

Country Address
Austria DataRep, City Tower, Brückenkopfgasse 1/6. Stock, Graz, 8020, Austria
Belgium DataRep, Rue des Colonies 11, Brussels, 1000
Bulgaria DataRep, 132 Mimi Balkanska Str., Sofia, 1540, Bulgaria
Croatia DataRep, Ground & 9th Floor, Hoto Tower, Savska cesta 32, Zagreb, 10000, Croatia
Cyprus DataRep, Victory House, 205 Archbishop Makarios Avenue, Limassol, 3030, Cyprus
Czech Republic DataRep, Platan Office, 28. Října 205/45, Floor 3&4, Ostrava, 70200, Czech Republic
Denmark DataRep, Lautruphøj 1-3, Ballerup, 2750, Denmark
Estonia DataRep, 2nd Floor, Tornimae 5, Tallinn, 10145, Estonia
Finland DataRep, Luna House, 5.krs, Mannerheimintie 12 B, Helsinki, 00100, Finland
France DataRep, 72 rue de Lessard, Rouen, 76100, France
Germany DataRep, 3rd and 4th floor, Altmarkt 10 B/D, Dresden, 01067, Germany
Greece DataRep, Ippodamias Sq. 8, 4th floor, Piraeus, Attica, Greece
Hungary DataRep, President Centre, Kálmán Imre utca 1, Budapest, 1054, Hungary
Iceland DataRep, Kalkofnsvegur 2, 3rd Floor, 101 Reykjavík, Iceland
Ireland DataRep, The Cube, Monahan Road, Cork, T12 H1XY, Republic of Ireland
Italy DataRep, Viale Giorgio Ribotta 11, Piano 1, Rome, Lazio, 00144, Italy
Latvia DataRep, Viale Giorgio Ribotta 11, Piano 1, Rome, Lazio, 00144, Italy
Liechtenstein DataRep, City Tower, Brückenkopfgasse 1/6. Stock, Graz, 8020, Austria
Lithuania DataRep, 44A Gedimino Avenue, 01110 Vilnius, Lithuania
Luxembourg DataRep, BPM 335368, Banzelt 4 A, 6921, Roodt-sur-Syre, Luxembourg
Malta DataRep, Tower Business Centre, 2nd floor, Tower Street, Swatar, BKR4013, Malta
Netherlands DataRep, Tower Business Centre, 2nd floor, Tower Street, Swatar, BKR4013, Malta
Norway DataRep, C.J. Hambros Plass 2c, Oslo, 0164, Norway
Poland DataRep, Budynek Fronton ul Kamienna 21, Krakow, 31-403, Poland
Portugal DataRep, Torre de Monsanto, Rua Afonso Praça 30, 7th floor, Algès, Lisbon, 1495-061, Portugal
Romania DataRep, 15 Piaţa Charles de Gaulle, nr. 1-T, Bucureşti, Sectorul 1, 011857,Romania
Slovakia DataRep, Apollo Business Centre II, Block E / 9th floor, 4D Prievozska, Bratislava, 821 09, Slovakia
Slovenia DataRep, Trg. Republike 3, Floor 3, Ljubljana, 1000, Slovenia
Spain DataRep, Calle de Manzanares 4, Madrid, 28005, Spain
Sweden DataRep, S:t Johannesgatan 2, 4th floor, Malmo, SE – 211 46, Sweden
Switzerland DataRep, Leutschenbachstrasse 95, ZURICH, 8050, Switzerland
United Kingdom DataRep, 107-111 Fleet Street, London, EC4A 2AB, United Kingdom

17. Children

Author production Accounts are for adults aged 18 or over. We do not knowingly invite children to create Author Accounts or provide voice-cloning material.
If we learn that personal data was submitted by a child in circumstances where parental or guardian consent was legally required and not obtained, we will take appropriate steps to delete or restrict it, subject to legal obligations.

18. Changes to this Policy

We may update this Policy for operational, legal or regulatory reasons. The current version will be posted on the Website with a revised date. Where a material change affects an ongoing service and notice is required by law, we will provide appropriate notice.
Where processing relies on consent, a change to this Policy does not itself create consent for a materially different use that requires fresh consent.

19. Contact and complaints

First Audiobooks Limited
Suite 4.3.02, Eurotowers
Gibraltar GX11 1AA
Email: info@firstaudiobooks.com

EU/EEA/UK representative: DataRep
Email: firstaudiobooks@datarep.com
Web form: https://www.datarep.com/firstaudiobooks

You may also complain to the data-protection supervisory authority that is competent for you. We would appreciate the opportunity to address your concern first, but you are not required to contact us before exercising any statutory right to complain.

Last updated: 14 September 2026

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