1. Identity and contact information
This Privacy Notice (“Notice”) is provided by Edward Mark Solly trading as Edward Solly Photography (“ESP”, “me”, or “I”), of 40 Roman Way, Maidstone, Kent. It covers your rights in relation to the Data Protection Act 1998 (“DPA”), the General Data Protection Regulation (“GDPR”) and the Privacy and Electronic Communications Regulations (“PECR”).
This Notice also explains how ESP complies with the DPA, GDPR and PECR as well.
ESP is both the controller and a processor of all personal data collected.
Date this Notice was created: 5th May 2018
Date this Notice was last modified: 24TH May 2018
2. Compliance declaration
Both ESP and this website, www.EdwardSollyPhotography.co.uk , comply with the DPA, GDPR and PECR. The GDPR comes into effect on the 25th of May 2018. This Notice is updated whenever changes are made to relevant data protection legislation.
3. Your rights under the GDPR
Under the GDPR, you have a number of different rights relating to your personal data and how it is processed. They are as follows:
· Right to be informed about the collection and use of your personal data.
· Right to access your personal data, and any supplementary information which constitutes personal data.
· Right to have your personal data rectified; this means you can ask me to correct your personal data if it changes, turns out to be inaccurate, or is incomplete.
· Right to have your personal data deleted; this means that you have the right to request the deletion or removal of your personal data. There are some circumstances when you do not have this right.
· Right to restrict me processing your personal data.
· Right to data portability.
· Right to object to me processing your personal data.
· Rights related to automated decision making including profiling.
Most of these Rights will apply to your personal data and how it is processed by ESP, but some (such as the right to data portability and rights related to automated decision making including profiling) are not relevant to this business at the time of writing.
4. The data I collect, how I use it and why
Cookies and website visitor tracking
When using this website, you have the choice to agree to or decline cookies. Cookies are small files installed on your browser device that allow websites like this, and many others, to find out more about your browsing behaviour. For ESP, the purpose of using cookies is to better understand visitor demographics to this site so that improvements can be made, as well as informing marketing and sales strategies in the future.
This website makes use of several cookies, most notably ones relating to Google Analytics and Facebook Pixel. I also make use of a plugin that enables me to defend against malicious attacks, which uses a cookie to understand whether you are a genuine user or a robot.
Client contact information
I use personal data, provided directly and voluntarily to me by clients, for two purposes. The first is to carry out my contractual obligations. This means that it’s information I need to do my job. This personal data includes: names, addresses, email addresses, phone numbers and further information which I need to complete your photography requirements.
The second purpose is for me to analyse and understand behaviour of my clients to assist me in relation to sales and marketing exercises. For example, to better understand where you heard about me and whether or not you choose to book me. This is a legitimate interest and a reasonable expectation that most people would have about a business. I collect personal data into and perform this analysis using simple spreadsheets.
Email addresses for gallery login
To deliver images to clients, I make use of a gallery and proofing service: Pixieset Media Inc. When clients share their galleries with friends and family, they will need to enter their email address to gain access to Pixieset, with the email address acting as a login. This allows users to create favourite lists, leave comments and also share images effectively. This is also necessary for the ordering of prints. For further information about how Pixieset collects and processes personal data please visit the Pixieset website.
From time to time, I make use of mailing lists to help market my business. As of May 2018, I have deleted all personal data relating to mailing lists that are no longer relevant and precede GDPR coming into force. New mailing lists created from this point will be populated with personal data collected from you on the basis of explicit consent for this single purpose.
More detailed information
If you want to contact me with questions about your personal data, wish to exercise any of your rights, or ask me further detailed questions, please use the contact form at the bottom of this page.
5. Sharing information with third parties
Other than those third parties mentioned in this Notice and listed below, ESP shall not pass your personal data to any third party.
Your personal data may, subject to my obligations to comply with data protection legislation, be shared with the following third parties:
· Pixieset Media Inc., as further described above;
· Tave.com, CRM software for contract and invoice management;
· ‘Second photographers’ or ‘Associate photographers’ who join me on wedding shoots and need information to be able to do their job;
· Having taken precautions to maintain the security of such personal data, I may in certain circumstances share personal data with the ICO, and other legal, regulatory and law enforcement bodies;
· In anonymised form, I may share personal data with:
o Any third party, in relation to the sale of some or all of my business, or its assets, or as part of any business restructuring or reorganisation. I will take steps with the aim of ensuring that your rights continue to be protected if your personal data is transferred in accordance with this clause; and
o Data aggregators and platform providers as part of an analysis of user metrics or sales performance (including but not limited to Google and Facebook).
In certain circumstances I may also share your personal data with third party media businesses for the purposes of marketing my offerings, improving my services, and running a profitable business. These third party businesses may include, wedding magazines/publications, wedding websites, social media sites, or other outlets, with the aim of raising public awareness of my business.
6. Security, storage and data retention
ESP stores your personal data in the EEA and ESP retains full details of your personal data for as long as it takes to complete your photography requirements. I will delete your personal data two years after completion of your photography requirements. If you would like me to delete your personal data before this time, you have the right to request me to do so.
7. Your consent
By using this site and/or engaging me on my Terms and Conditions, you agree to be bound by this Notice.
8. Your right to withdraw consent
You have the right to withdraw your consent to be bound by this Notice at any time. If you wish to do so, please use the contact form at the bottom of this page. You also have the right, as set out above, to withdraw your consent to my processing your personal data.
9. Your right to lodge a complaint
As well as the right to withdraw consent and exercise any of the above rights mentioned under ‘Your rights under the GDPR’, you also have the right to raise a complaint with a regulatory body. In the United Kingdom, this is the Information Commissioner’s Office (ICO). If you have concerns about the way your data is being processed by an organisation, you can find out more here.