Roz & Kirsty Photography Limited (“we”, “us”, “our”) respects your privacy and is committed to protecting your personal data.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us as the data controller. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
2. THE DATA WE COLLECT ABOUT YOU
We may collect, use, store and transfer different kinds of personal data about you as follows:
- Your Identity Data includes your first name, last name, title and images/photos of you.
- Your Child’s Identity Data includes the first name, last name, age, school class and images/photos of your child or children.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Financial Data includes bank account and payment card details.
- Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, other technology on the devices you use to access our website and information about how you use our website.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data (where used for identification purposes)). Nor do we collect any information about criminal convictions and offences.
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
- Information you give us. You may give us your Identity Data, Your Child’s Identity Data, Contact Data and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise.
- Information we receive from other sources. We may receive personal data about you from various third parties and public sources including:
- Your Identity Data, Your Child’s Identity Data and Contact Data from your child’s school.
- Technical Data from analytics providers such as Google based outside the EU; and
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as ShootProof, GotPhoto and Calotype based inside and/or outside the EU.
5. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where you have consented before the processing.
- Where we need to perform a contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
6. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To provide our products and services to you, including to:
|To provide our products and services to your child’s school, including to provide copies of your child’s photos to your child’s school||Identity||Necessary for ours and a third party’s legitimate interests (for running our business and for the school’s record-keeping purposes)|
|To process and deliver your order including managing payments and collecting money owed to us||Identity
|To manage our relationship with you including:
Marketing and Communications
|To administer and protect our business and our website (including troubleshooting, data analysis and system testing)||Identity
|Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)|
|To deliver relevant website content and advertising to you and to measure or understand the effectiveness of the advertising we serve to you||Identity
Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you, including sending you examples of products bearing your child’s photo we think might interest you, or sending you marketing that you have requested||Identity
Marketing and Communications
Change of Purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
7. DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data with the parties set out below for the purposes set out in the table above:
- Your child’s school – we will share photos of your child with your child’s school for the school’s record-keeping purposes.
- Other parents at your child’s school – we will share group photos of your child with other parents at your child’s school where you have provided your consent for your child to feature in such group photo (such as a class or team photo).
- Our third party service providers, including editors, assistants and photographers; and ShootProof, GotPhoto and Calotype, who we use to create our online galleries where photos of your children can be viewed and from which you can directly purchase such photos. Please note that such third party service providers have their own websites, terms and conditions and privacy policies for which we are not responsible. We encourage you to read the terms and conditions and privacy policies of such third parties before accessing and using their websites and services.
- Social media platforms – we may share your personal data with social media platforms for our marketing purposes. We will get your express opt-in consent before we do so.
- Professional advisers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue and Customs, regulators and other authorities based in the UK who require reporting of processing activities in certain circumstances.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
8. INTERNATIONAL TRANSFERS
We may transfer your personal data outside the European Economic Area (“EEA”) for the purposes set out in the table above. Whenever we transfer your personal data outside of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
9. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
10. DATA RETENTION
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Details of typical retention periods for different types of your personal data are set out in the table below:
|Type of Personal Data||Retention Period|
|Your Identity Data||6 years|
|Your Child’s Identity Data||Images – 6 years
Other data – 6 years
|Contact Data||6 years|
|Transaction Data||6 years|
|Financial Data||6 years|
|Technical Data||Please see our Cookies Policy|
|Marketing and Communication Data||2 years from last contact|
11. YOUR LEGAL RIGHTS
Under certain circumstances you have the following rights under data protection laws in relation to your personal data.
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- if you want us to establish the data’s accuracy;
- where our use of the data is unlawful but you do not want us to erase it;
- where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
- you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
You can also ask us or third parties to stop sending you marketing messages at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase or other transactions.
You can exercise any of these rights at any time by contacting us using the details set out below.
12. CONTACTING US AND COMPLAINTS
- Company details: Roz & Kirsty Photography Limited (company number: 11198599)
- Email address: firstname.lastname@example.org
- Postal address: 15 Langland Court Road, Swansea SA3 4TB
You also have the right to make a complaint at any time to the Information Commissioner’s Office (“ICO”), the UK supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.