Privacy Policy

This privacy policy (“Privacy Policy”) applies to personal data that we collect from you as a customer

(“you” or “your”). It provides information on what data we collect, why we collect the data, how it is

used and the lawful basis on which your personal data is processed, and what your rights are under

the applicable data protection and privacy laws, including the General Data Protection Regulation

(“GDPR”).

  1. WHO ARE WE

We are Jay Saunders Photography, 10 Mayflower Way, Ongar, Essex, CM5 9AZ. We are the data

controller responsible for your personal data.

  1. WHAT DO WE COLLECT

We collect the following information from you:

• Personal information: This includes your name, address, e-mail address; phone number;

gender and date of birth; country, as well as the names, dates of birth, gender and other

details about your family members and other participants in a photography session, together

with and other information that you elect to provide to us.

• Payment Information: Information about your debit/credit card and bank account information

provided by you to our payment service providers, that we require for the purpose of

processing payment for our goods and services.

• Other Information: Personal details you choose to give when corresponding with us by

phone or e-mail or visit our studio.

In providing our services we create photographs which may identify you, your family members and

other participants and that may be considered personal data. Our photographs may be produced in

print and digital format. You are responsible for ensuring that all participants in a photograph sessions

have been provided with a copy of this privacy policy.

  1. HOW WE USE YOUR PERSONAL INFORMATION

We use your personal information in the following ways:

• to provide you with our services and to create and deliver the products you have requested and

contact you regarding your use of the services. Such use is necessary to respond to or implement

your request and for the performance of the contract between you and us.

• As necessary for certain legitimate business interests, which include the following:

o where we are asked to deal with any enquiries or complaints you make;

o to provide postal communications which we think will be of interest to you;

o if you ask us to delete your data or to be removed from our marketing lists and we are

required to fulfil your request, to keep basic data to identify you and prevent further

unwanted processing; and

o to (a) comply with legal obligations, (b) respond to requests from competent authorities;

(b) protect our operations; (c) protect our rights, safety or property, and/or that of our

affiliated businesses, you or others; and (d) enforce or defend legal rights, or prevent

damage.

• With your consent, we may use your photographs to promote and advertise our business,

including (a) in our studio and in our printed publications, presentations, promotional materials

(including leaflets, brochures, stickers, bookmarks, posters, factsheets, calendars); (b) on our

website and other digital advertising of our services; and (c) in social media forums such as

Instagram, Pinterest and Facebook.

• We may provide you with information about goods or services, events and other promotions we

feel may interest you. We will contact you by email only with your consent, if this was given at the

time you provided us with the personal data.

• We may use your personal data for other purposes which you have consented to at the time of

providing your data.

As used in this Privacy Policy, “legitimate interests” means our interests in conducting and managing

our business. When we process your personal data for our legitimate interests, we make sure to

consider and balance any potential impact on you, and your rights under data protection laws. Our

legitimate interests do not automatically override your interests. We will not use your personal data for

activities where our interests are overridden by the impact on you, unless we have your consent or

those activities are otherwise required or permitted to by law. You have the right to object at any time

to processing of your personal data that is based on our legitimate interests, on grounds relating to

your particular situation (for more information on your rights, please see “Your Data Protection Rights”

section below).

  1. DISCLOSURE OF YOUR INFORMATION

We share your personal data with third parties in the following situations:

• Service Providers: we sometimes engage selected third parties who act on our behalf to support

our operations, such as (i) card processing or payment services (see the section below headed

“Payment Information”), (ii) IT suppliers and contractors (e.g. data hosting providers or delivery

partners) as necessary to provide IT support and enable us to provide our goods/services, and

(iii) providers of specialist services, including retouching, printers, framers and book binders.

Pursuant to our instructions, these parties may access, process or store your personal data in the

course of performing their duties to us and solely in order to perform the services we have hired

them to provide.

• Business Transfers: if we sell our business or our company assets are acquired by a third party

personal data held by us about our customers may be one of the transferred assets.

• Administrative and Legal Reasons: if we need to disclose your personal data (i) to comply with

a legal obligation and/or judicial or regulatory proceedings, a court order or other legal process.

(ii) to enforce our Terms & Conditions or other applicable contract terms that you are subject to;

(iii) to protect us, our members or contractors against loss or damage. This may include (without

limit) exchanging information with the police, courts or law enforcement organisations.

  1. PAYMENT INFORMATION

Any credit/debit card payments and other payments you make will be processed by our third party

payment providers and the payment data you submit will be securely stored and encrypted by our

payment service providers using up to date industry standards. Please note that we do not ourselves

directly process or store the debit/credit card data that you submit.

We store and use this card or payment information for the purpose of processing any future payments

that you make for additional goods and services. We will store this data in accordance with our legal

obligations under applicable law and only for so long as legally permitted.

You may choose to opt out of us holding your card or payment data although this means that you will

need to re-supply us with card/payment details for the purpose of making any future purchases.

  1. DATA TRANSFERS

Your personal data will be transferred to and stored in countries other than the country in which the

information was originally collected, including the United States and other destinations outside the

European Economic Area (“EEA”) to our service providers for the purposes described above.

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Please note that the countries concerned may not provide the same legal standards for protection of

your personal data that you have in the United Kingdom or EEA. Where we transfer your personal

data to countries outside of the EEA we will take all steps to ensure that your personal data continue

to be protected. We will implement appropriate safeguards for the transfer of personal data to our

service providers in accordance with the applicable law, such as relying on our service providers’

Privacy Shield certification or implementing standard contractual clauses for data transfers. If you

would like to receive more information on the safeguards that we implement, including copies of

relevant data transfer contracts, please contact us as indicated below.

  1. DATA RETENTION

We will keep your personal data only for as long as is reasonably necessary for the purposes outlined

in this Privacy Policy, or for the duration required by any legal, regulatory, accounting or reporting

requirements, whichever is the longer. In particular, we retain your personal data for 6 years after your

photography session and we retain digital files of your photographs for 6. When you consent to

receive marketing communications, we will keep your data until you unsubscribe. Upon expiry of the

applicable retention period we will securely destroy your personal data in accordance with applicable

laws and regulations.

  1. YOUR DATA PROTECTION RIGHTS

Certain applicable data protection laws give you specific rights in relation to your personal data. In

particular, if the processing of your personal data is subject to the GDPR, you have the following

rights in relation to your personal data:

• Right of access: If you ask us, we will confirm whether we are processing your personal data

and, if so, provide you with a copy of that personal data along with certain other details. If you

require additional copies, we may need to charge a reasonable fee.

• Right to rectification: If your personal data is inaccurate or incomplete, you are entitled to ask

that we correct or complete it. If we shared your personal data with others, we will tell them about

the correction where possible. If you ask us, and where possible and lawful to do so, we will also

tell you with whom we shared your personal data so you can contact them directly.

• Right to erasure: You may ask us to delete or remove your personal data, such as where our

legal basis for the processing is your consent and you withdraw consent. If we shared your data

with others, we will tell them about the erasure where possible. If you ask us, and where possible

and lawful to do so, we will also tell you with whom we shared your personal data with so you can

contact them directly. We may continue processing personal data where this is necessary for a

legitimate interest in doing so, as described in this Privacy Policy.

• Right to restrict processing: You may ask us to restrict or ‘block’ the processing of your

personal data in certain circumstances, such as where you contest the accuracy of the data or

object to us processing it. We will tell you before we lift any restriction on processing. If we shared

your personal data with others, we will tell them about the restriction where possible. If you ask

us, and where possible and lawful to do so, we will also tell you with whom we shared your

personal data so you can contact them directly.

• Right to object: You may ask us at any time to stop processing your personal data, and we will

do so:

o If we are relying on a legitimate interest to process your personal data — unless we

demonstrate compelling legitimate grounds for the processing or

o If we are processing your personal data for direct marketing.

• Right to withdraw consent: If we rely on your consent to process your personal data, you have

the right to withdraw that consent at any time. This will not affect the lawfulness of processing of

your data before we received notice that you wished to withdraw your consent.

• Right to lodge a complaint with the data protection authority: If you have a concern about our

privacy practices, including the way we handled your personal data, you can report it to the UK

data protection authority (the Information Commissioner’s Office or ICO), or, as the case may be,

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any other competent data protection authority of an EU member state that is authorised to hear

those concerns (you may find EU Data Protection Authorities’ contact information here).

If you wish to exercise any of these rights please contact us as described in the “Contact” section

below. We may also need to ask you for further information to verify your identity before we can

respond to any request.

  1. CONTACT

Questions, comments or requests regarding this Privacy Policy should be addressed to

jay@jaysaundersphotography.co.uk.

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