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
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.
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:
We call this data ‘Technical Data’.
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:
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:
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 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)|
We do not disclose, give, sell or transfer any personal information about our visitors or customers, unless:
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:
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
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.
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:
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.