Privacy Policy & Cookies

Picture Perfect Photography respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website, and tell you about your privacy rights and how the law protects you.

Our policy is clear:

We collect no information about you, other than information automatically collected and stored (see below) when you visit our website, unless you choose to provide that information to us.

Important information and who we are

This privacy policy aims to give you information on how Picture Perfect Photography collects and processes your personal data, including any data you may provide to us when you submit an enquiry through our website, purchase our services or take part in a photo shoot.

Controller

Collette Evans t/a Picture Perfect Photography is the controller and responsible for your personal data (collectively referred to as “we“, “us” or “our” in this privacy policy).

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the ‘Contact’ page of our website.

You 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 (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

We keep our privacy policy under regular review. 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.

Third-party links

This website may include links to third-party websites and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Information automatically collected and stored through our website

When you browse through any website, certain personal information about you may be collected. We automatically collect and temporarily store the following information about your visit:

The name of the domain you use to access the internet.
The date and time of your visit.
The pages that you visited.

We call this data ‘Technical Data’.

When you visit some pages on this website, your computer may be issued with a small file – a “cookie”. A cookie is a piece of information in the form of a very small text file that is placed on the hard drive of your computer. The information the cookie contains is set by the server (this website) and it can be used by that server whenever you visit this website. The server uses cookies to recognise your browser session if you visit multiple pages during your interaction with this website.

You can set your browser to refuse cookies or warn you before accepting them. However, some parts of this website may not function properly without accepting cookies.

Some parts of this website use Google Analytics which also place cookies on your computer. The information generated by these cookies about your use of this website will be transmitted to and stored by Google, For further information about cookies, please see www.allaboutcookies.org. We use this information for statistical purposes and to help us make our website more useful to visitors.

We have set out below the cookies that are in use on our website:

Cookie Name	Purpose and further information
Google analytics	To help us make sure that the website is working properly and fix any errors, and to help us personalise the website by remembering your preferences and settings.
Google task manager	To help us make sure that the website is working properly and fix any errors, and to help us personalise the website by remembering your preferences and settings.
Facebook pixel	To help us make sure that the website is working properly and fix any errors, and to help us personalise the website and advertisements by remembering your preferences and settings.

Personally provided information

You do not have to give us personal information to visit our website, however, all communications addressed to us (sent by email or by post) may be stored for reference purposes. If you purchase our services we will collect your personal data for reference and communication and to allow us to provide those services. This data may include:

Identity data, including first name, last name, date of birth and gender;
Contact data, including billing address, email address and telephone numbers;
Financial data, including bank account and payment card details;
Transaction data, including details about payments to and from you and other details of products and services you have purchased from us.

The data we collect may also include photographs containing your identity. We will request consent from our clients confirming that they allow us to use the images taken during their session to be used for our marketing materials, websites, leaflets etc.

Save for any such data comprised in any photographs that we hold, 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). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

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 our services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

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 we need to perform the contract for services that we are about to enter into or have entered into with you.
Where we need to comply with a legal obligation.
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. This means the interest of our business in conducting and managing our business to enable us to give you the best service. We make sure we consider and balance any potential impact on you and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Generally, we do not rely on consent as a legal basis for processing your personal data although if you are a customer we will get your consent to use your images for marketing purposes, as outlined above. If we have engaged you as a model to take your photograph and use the images, consent will not be the legal basis of processing, instead we will process your personal data in accordance with the contract.

We have set out below, in 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.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To provide our services to you, including:(a) Manage payments, fees and charges(b) Collect and recover money owed to us	(a) Identity(b) Contact(c) Financial(d) Transaction	(a) Performance of a contract with you(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:(a) Notifying you about changes to our terms or privacy policy(b) Asking you to leave a review or provide us with feedback	(a) Identity(b) Contact	(a) Performance of a contract with you(b) Necessary to comply with a legal obligation(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our services)
To engage you for modelling services (if you are a model)	(a) Identity(b) Contact(c) Financial(d) Transaction	(a) Performance of a contract with you(b) Necessary for our legitimate interests (to make use of the photographs taken)
To administer and protect our business and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity(b) Contact(c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud)(b) Necessary to comply with a legal obligation
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a) Technical	Necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop 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	(a) Identity(b) Contact(c) Technical	Necessary for our legitimate interests (to develop our services and grow our business)

Disclosure:

We do not disclose, give, sell or transfer any personal information about our visitors or customers, unless:

required by law or a regulatory body (such as HMRC);
to our service providers acting as processors based in the United States of America who provide software, IT and system administration services;
to our professional advisers, acting as processors, including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services; or
to third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

Some of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out 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. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
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.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

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.

Data Retention

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.

We keep basic information about our customers (including Contact, Identity and Transaction Data) for six years after they cease being customers for legal and tax purposes, and for such longer period as we may need to store the data in order to continue to provide our services to you.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your legal rights

Under certain circumstances, you have 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.
- 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.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is complex or there are other special circumstances which apply. In this case, we will notify you and keep you updated.

Thank you for reading about our privacy policy and cookies.