Rhian White Photography Privacy Policy 2018

1. Introduction

1.1 I am committed to safeguarding the privacy of Rhian White Photography website visitors and service users.

1.2 This policy applies where I am acting as a data controller with respect to the personal data of Rhian White Photography; in other words, where I determine the purposes and means of the processing of that personal data.

1.3 I use cookies on my website. Insofar as those cookies are not strictly necessary for the provision of Rhian White Photography website and services, I will ask you to consent to my use of cookies when you first visit my website.

1.4 My website incorporates privacy controls which affect how I will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information. You can access the privacy controls via https://www.rhianwhitephotography.co.uk/privacy-policy.

1.5 In this policy, "I" , "my" and “myself” refer to Rhian White.

2. Credit

2.1 This document was created using a template from SEQ Legal (https://seqlegal.com).

3. How I use your personal data

3.1 In this Section 3 I have set out:

(a) the general categories of personal data that I may process;

(b) in the case of personal data that I did not obtain directly from you, the source and specific categories of that data;

(d) the legal bases of the processing.

3.2 I may process data about your use of my website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is my analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is consent OR my legitimate interests, namely monitoring and improving my website and services.

3.3 I may process your account data ("account data"). The account data may include your name and email address. The source of the account data is you. The account data may be processed for the purposes of operating my website, providing my services, ensuring the security of my website and services, maintaining back-ups of my databases and communicating with you. The legal basis for this processing is consent OR my legitimate interests, namely the proper administration of my website and business OR the performance of a contract between you and myself and/or taking steps, at your request, to enter into such a contract.

3.4 I may process your information included in your personal profile on my website ("profile data"). The profile data may include your name, address, telephone number, email address. The profile data may be processed for the performance of a contract between you and myself and/or taking steps, at your request, to enter into such a contract. The legal basis for this processing is consent OR legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at you request, to enter into such a contract.

3.5 I may process your personal data that are provided in the course of the use of our services ("service data"). The service data may include your name, email address, telephone number and postal address. The source of the service data is you. The service data may be processed providing our services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent OR my legitimate interests, namely the proper administration of my website and business OR the performance of a contract between you and myself and/or taking steps, at your request, to enter into such a contract.

3.6 I may process information contained in any enquiry you submit to us regarding goods and/or services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.

3.7 I may process information relating to our customer relationships, including customer contact information ("customer relationship data"). The customer relationship data may include your name, your contact details, and information contained in communications between us. The source of the customer relationship data is you.The customer relationship data may be processed for the purposes of managing my relationships with customers, communicating with customers, keeping records of those communications and promoting my products and services to customers. The legal basis for this processing is consent OR my legitimate interests, namely the proper management of our customer relationships.

3.8 I may process information relating to transactions, including purchases of goods and services, that you enter into with myself and/or through my website ("transaction data"). The transaction data may include your contact details and the transaction details. I do not keep your card details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and myself and/or taking steps, at your request, to enter into such a contract and my legitimate interests, namely the proper administration of my website and business.

3.9 I may process information that you provide to myself for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.

3.10 I may process information contained in or relating to any communication that you send to me ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. My website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is my legitimate interests, namely the proper administration of my website and business and communications with users.

3.11 I may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is my legitimate interests, namely the protection and assertion of my legal rights, your legal rights and the legal rights of others.

3.12 In addition to the specific purposes for which I may process your personal data set out in this Section 3, I may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

3.16 Please do not supply any other person's personal data to me, unless I prompt you to do so.

4. Providing your personal data to others

4.1 Newsletter subscriber names and email addresses are stored in my Mailchimp account.

4.2 I will disclose your name and postal address to my print/book suppliers insofar as reasonably necessary for to fulfill an order you have placed with me. My book supplier generally also requires a telephone number.

4.3 Financial transactions relating to my website and services are OR may be handled by my payment services providers, Paypal and Stripe. I will share transaction data with my payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers' privacy policies and practices at:
https://www.paypal.com/en/webapps/mpp/ua/privacy-full
https://stripe.com/gb/privacy

4.4 In addition to the specific disclosures of personal data set out in this Section 3, I may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

5. Retaining and deleting personal data

5.1 This Section 5 sets out my data retention policies and procedure, which are designed to help ensure that I comply with my legal obligations in relation to the retention and deletion of personal data.

5.2 Personal data that I process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

5.3 I will retain your personal data as follows:

(a) Name, email address and any other personal data you have provided me will be retained for a minimum period of 3 years following when you contact me, and for a maximum period of 5 years following when you contact me.

5.4 Notwithstanding the other provisions of this Section 6, I may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

6. Amendments

6.1 I may update this policy from time to time by publishing a new version on my website.

6.2 You should check this page to ensure you are happy with any changes to this policy.

7. Your rights

7.1 In this Section 8, I have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in my summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

7.2 Your principal rights under data protection law are:

(a) the right to access;

(b) the right to rectification;

(d) the right to restrict processing;

(e) the right to object to processing;

(f) the right to data portability;

(g) the right to complain to a supervisory authority; and

(h) the right to withdraw consent.

7.3 You have the right to confirmation as to whether or not I process your personal data and, where I do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, I will supply to you a copy of your personal data.

7.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

7.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

7.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; I no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, I may continue to store your personal data. However, I will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

7.7 You have the right to object to my processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in myself; or the purposes of the legitimate interests pursued by myself or by a third party. If you make such an objection, I will cease to process the personal information unless I can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

7.8 You have the right to object to my processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, I will cease to process your personal data for this purpose.

7.9 You have the right to object to my processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

7.10 To the extent that the legal basis for my processing of your personal data is:

(a) consent; or

(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,

and such processing is carried out by automated means, you have the right to receive your personal data from me in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

7.11 If you consider that y processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

7.12 To the extent that the legal basis for my processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

7.13 You may exercise any of your rights in relation to your personal data by written notice to myself.

8. About cookies

8.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

8.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

8.3 Cookies do not typically contain any information that personally identifies a user. Personal information that I store about you will not be linked to the information stored in and obtained from cookies.

9. Cookies that I use

9.1 I use cookies for the following purposes:

(a) authentication - I use cookies to identify you when you visit my website and as you navigate my website (cookies used for this purpose are: identify cookies);

(b) security - we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect my website and services generally (cookies used for this purpose are: identify cookies);

(e) advertising - I use cookies to help us to display advertisements that will be relevant to you (cookies used for this purpose are: identify cookies);

(f) analysis - I use cookies to help me to analyse the use and performance of my website and services (cookies used for this purpose are: identify cookies); and

(g) cookie consent - I use cookies to store your preferences in relation to the use of cookies more generally (cookies used for this purpose are: identify cookies).

10. Cookies used by our service providers

10.1 My service providers use cookies and those cookies may be stored on your computer when you visit our website.

10.2 I use Google Analytics to analyse the use of my website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to my website is used to create reports about the use of my website. Google's privacy policy is available at: https://www.google.com/policies/privacy/.[ The relevant cookies are: identify cookies.

10.3 I use Squarespace to host my website. This service uses cookies to “obtain information about your visitors for Squarespace Analytics by using Analytics Cookies.” You can view the privacy policy of this service provider at https://www.squarespace.com/privacy/. The relevant cookies are: identify cookies. For the complete list of Cookies Squarespace collects see here: https://support.squarespace.com/hc/en-us/articles/360001264507

11. Managing cookies

11.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);

(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e) https://support.apple.com/kb/PH21411 (Safari); and

(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

11.2 Blocking all cookies will have a negative impact upon the usability of many websites.

11.3 If you block cookies, you may not be able to use all the features on my website.

12. My details

12.1 This website is owned and operated by Rhian White.

12.2 I am registered in England and Wales under registration number 06151502, and my registered office is at 25a Compton Road, Brighton, BN15AL.

12.3 My principal place of business is at 25a Compton Road, Brighton, BN15AL.

12.4 You can contact me:

(a) by post, to [the postal address given above;

(b) using my website contact form;

(d) by email, using the email address published on our website from time to time.

13. Data protection officer

13.1 My data protection officer's contact details are: Rhian White, hello@rhianwhitephotography.co.uk, 07810 516120.