PRIVACY POLICY
INTRODUCTION
1.1 Welcome to David James Page Event Photography’s privacy policy.
David James Page Event 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 (regardless of where you visit it
from) and tell you about your privacy rights and how the law protects you when you
become a client, or in some cases where you simply become the subject of a
photograph.
1.2 David James Page Event Photography is the controller and responsible for your
personal data (collectively referred to as “David James Page Event Photography”, “we”,
“us” or “our” in this privacy policy).
1.3. We have appointed a data privacy manager who is responsible for overseeing
questions in relation to this privacy policy. If you have any questions about this privacy
policy, including any requests to exercise your legal rights, please contact the data privacy
manager using the details set out below:
Full name of manager: David James Page
Email address: davidjamespage@mac.com
Postal address: David James Page 27 Lavington Road, Beddington, Sutton, Surrey, CR0
4PQ Telephone number: 07941 657429
1.4 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.
1.5 This privacy policy is provided in a layered format so you can click through to the
specific areas set out below. Please also use the Glossary to understand the meaning of
some of the terms used in this privacy policy.
• IMPORTANT INFORMATION
• THE DATA WE COLLECT ABOUT YOU
• HOW IS YOUR PERSONAL DATA IS COLLECTED?
• HOW WE USE YOUR PERSONAL DATA
• MARKETING
• COOKIES
• DISCLOSURES OF YOUR PERSONAL DATA
• INTERNATIONAL TRANSFERS
• DATA SECURITY
• DATA RETENTION
• YOUR LEGAL RIGHTS
• GLOSSARY2. IMPORTANT INFORMATION
2.1 This privacy policy aims to give you information on how David James Page Event
Photography collects and processes your personal data based on different types of
interaction.
2.2 It is important that you read this privacy policy together with any other privacy policy or
fair processing policy we may provide on specific occasions when we are collecting or
processing personal data about you so that you are fully aware of how and why we are
using your data. This privacy policy supplements other notices and privacy policies and is
not intended to override them.
2.3 We keep our privacy policy under regular review. This is the first version and was
created in July 2024.
2.4 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.
2.5 This website may include links to third-party websites, plug-ins 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.
3. THE DATA WE COLLECT ABOUT YOU
3.1 Personal data, or personal information, means any information about an individual
from which that person can be identified. It does not include data where the identity has
been removed (anonymous data) or data about corporate entities, like a company.
3.2 We may collect, use, store and transfer different kinds of personal data about you
which we have grouped together as follows:
a) Identity Data includes first name, maiden name, last name, marital status, title, date of
birth and gender.
b) Contact Data includes billing address, delivery address, email address and telephone
numbers.
c) Transaction Data includes details about payments to and from you and other details of
products and services you have purchased from us.
d) Technical Data includes internet protocol (IP) address, browser type and version, time
zone setting and location, browser plug-in types and versions, operating system and
platform, and other technology on the devices you use to access this website.
e) Usage Data includes information about how you use our website, products and
services.
f) Marketing and Communications Data – preferences in receiving marketing from you and
third parties and the way it’s received.
3.3 Aggregated Data. We also collect, use and share Aggregated Data such as statistical
or demographic data for any purpose. Aggregated Data could be derived from your personal
data but is not considered personal data in law as this data will not directly or
indirectly reveal your identity.
3.4 Special Categories. 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.
3.5 Photographs and other images. Unless you feature in an image as a paid model, or
you are part of a large group of people, we will seek your consent to an ‘image release
form’ for you or your child, which will specify how that image will be used.
3.6 Data not provided. 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 services). In this case, we may have to cancel a product or
service you have with us, but we will notify you if this is the case at the time.
4. HOW IS YOUR PERSONAL DATA COLLECTED?
4.1 We use different methods to collect data from and about you including through:
a) Direct interactions. You may give us your Identity, Contact by filling in forms or by
corresponding with us by web-chat, post, phone, email or otherwise. This includes
personal data you provide when you:
i) apply for our products or services;
ii) feature in a photograph or other image;
iii) subscriptions to publications or other forms of marketing;
iv) give us feedback or contact us.
b) Automated technologies or interactions. As you interact with our website, we will
automatically collect Technical Data about your equipment, browsing actions and patterns.
We collect this personal data by using cookies, server logs and other similar technologies.
We may also receive Technical Data about you if you visit other websites employing our
cookies. Please see section titled ‘cookies’ under ‘HOW WE USE YOUR PERSONAL
DATA’ for further details.
c) Third parties or publicly available sources. We will receive personal data about you
from various third parties and public sources as set out below:
i) Technical Data from analytics providers, such as Google based outside the EU;
ii) Contact and Transaction Data from providers of technical, payment and delivery
services;
iii) Identity and Contact Data from publicly available sources, such as Companies House
and social media accounts, like LinkedIn.
5. HOW WE USE YOUR PERSONAL DATA
5.1 We will only use your personal data when the law allows us to. Most commonly, we will
use your personal data where we need to perform the contract we are about to enter into
or have entered into with you, where it is necessary for our legitimate interests
(or those of a third party) or where we need to comply with a legal obligation. The meaning of
Lawful Basis is further defined in the glossary.
• 5.2 Generally, we do not rely on consent as a legal basis for processing your
personal data although we will get your consent before sending third party direct
marketing communications to you via email or text message. You have the right to
withdraw consent to marketing at any time by contacting us.
• 5.3 We have set out below, in a 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 register you as a new customer
(a) Identity
(b) Contact Performance of a contract with you
To process and deliver your order including:
(a) Taking of photographs and other image media
(b) Manage payments, fees and charges
(c) Collect and recover money owed to us
(a) Identity
(b) Contact
(d) Transaction
(e) Marketing and Communications
(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:
Notifying you about changes to our terms or privacy policy
(a) Identity
(b) Contact
(d) Marketing and Communications
(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 products and services)
To enable you to partake in a prize draw competition or complete a survey
(a) Identity
(b)Contact
(c) Profile(
d) Usage
(e) Marketing and Communications
(a) Performance of a contract with you
(b)
Necessary for our legitimate interests (to study how customers use our products, services, to develop them and grow our business)
5.4 We will only use your personal data for the purposes for which we collected it, unless
we reasonably consider that we need to use it for another reason and that reason is
compatible with the original purpose. If you wish to get an explanation as to how the
processing for the new purpose is compatible with the original purpose, please contact us.
6. MARKETING
6.1 We strive to provide you with choices regarding certain personal data uses, particularly
around marketing and advertising. We have established the following personal data control
mechanisms:
a) Promotional offers from us. We may use your Identity, Contact, Technical, Usage
and Profile Data to form a view on what we think you may want or need, or what may be of
interest to you. This is how we decide which products, services and offers may be relevant
for you (we call this marketing). You will receive marketing communications from us if you
have requested information from us or purchased goods or services from us and you have
To administer and protect our business and this 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 and in the context of a business reorganisation or
group restructuring exercise)
(b)Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the
effectiveness of the advertising we serve to you
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
Necessary for our legitimate interests (to study how customers use our products/services,
to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer
relationships andexperiences
(a) Technical
(b) Usage
Necessary for our legitimate interests (to define types of customers for our products and
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
(d) Usage
(e) Profile(
f) Marketing and Communications Necessary for our legitimate interests (to develop our
products/services and grow our business)not opted out of receiving that marketing.
The methods of communication may include phone calls from time to time, targeted adverts
on social media and other websites (this is dictated by cookies, which we cover in section 7)
and material delivered by post.
b) Third-party marketing. We will get your express opt-in consent before we share your
personal data with any third party for marketing purposes.
c) Opting out. You can ask us or third parties to stop sending you marketing messages at
any time by following the opt-out links on any marketing message sent to you, or by
contacting us at any time. Where you opt out of receiving these marketing messages, this
will not apply to personal data provided to us as a result of purchases or other
transactions.
7. COOKIES
7.1 Our website uses cookies to distinguish you from other users of our website. This
helps us to provide you with a good experience when you browse our website and also
allows us to improve our site.
7.2 A cookie is a small file of letters and numbers that we store on your browser or the
hard drive of your computer if you agree. Cookies contain information that is transferred to
your computer’s hard drive. We use the following cookies:
a) Analytical, tracking or performance cookies. These allow us to recognise and count
the number of visitors and to see how visitors move around our website or our client’s
website when they are using it. This helps us to improve the way website works, for
example, by ensuring that users are finding what they are looking for easily. Tracking
cookies
b) Functionality cookies. These are used to recognise you when you return to our
website. This enables us to personalise our content for you, greet you by name and
remember your preferences (for example, your choice of language or region).
c) Targeted cookies. These are used to show you targeted adverts on third party websites.
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service. Other possible values indicate opt-out, inflight request or an error
retrieving a Client ID from AMP Client ID service 30 seconds to one year
7.3 You can block cookies by activating the setting on your browser that allows you to
refuse the setting of all or some cookies. However, if you use your browser settings to
block all cookies (including essential cookies) you may not be able to access all or parts of
our website.
8. DISCLOSURES OF YOUR PERSONAL DATA
8.1 We may share your personal data with the parties set out below for the purposes set
out in the table ‘Purposes for which we will use your personal data’ above:
a) External Third Parties as set out in the Glossary;
b) Specific third parties listed in the table Purposes for which we will use your personal
data; and
c) 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.
8.2. We require all third parties to respect the security of your personal data and to treat it
in accordance with the law. We do not allow our third-party service providers to use your
personal data for their own purposes and only permit them to process your personal data
for specified purposes and in accordance with our instructions.
9. INTERNATIONAL TRANSFERS
9.1 Your personal data may be stored or transferred to countries outside the EEA for the
purposes described in this policy and pursuant to providing the services to you. When we
store or transfer your personal data outside the EEA, we will do so in accordance with
applicable law and we will ensure a similar degree of protection is afforded to it by
implementing the appropriate safeguards listed below. Transfers of personal data will only
be made:
a) to a country recognised by the European Commission as providing an adequate level
of protection; or
b) to a country which does not offer adequate protection but whose transfer has been
governed by the standard contractual clauses of the UK GDPR or by implementing other
appropriate cross-border transfer solutions to provide adequate protection.
By using our services, you understand that your personal data may be transferred to our
facilities and those third parties with whom we share it as described in this policy under
‘Third Parties’ in the glossary.
10. DATA SECURITY
10.1 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
Contains campaign related information for the user. If you have linked your
Google Analytics and Google Ads accounts, Google Ads website conversion
tags will read this cookie unless you opt-out. Learn more.
90 days process your personal data on our instructions and they are subject to a duty of
confidentiality.
10.2 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.
10.3 Data is stored on local hard drives at the address specified at the top of this policy,
and in a secure warehouse. Data is also stored on secure cloud software, such as Dropbox.
11. DATA RETENTION
11.1 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.
11.2 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.
11.3 By law we must keep basic information about our customers (including Contact,
Identity, and Transaction Data) for six years after they cease being customers for tax
purposes.
12. YOUR LEGAL RIGHTS
12.1 Under certain circumstances, you have rights under data protection laws in relation to
your personal data as follows (please check the Glossary for further information on each
right):
a) Request access to your personal data.
b) Request correction of your personal data.
C) Request erasure of your personal data.
d) Object to processing of your personal data.
e) Request restriction of processing your personal data.
f) Request transfer of your personal data.
g) Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us.
12.2 Fees. 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 clearlyunfounded, repetitive or excessive. Alternatively, we could refuse to comply with your
request in these circumstances.
12.3 Specific Information. 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.
12.4 Response time. We try to respond to all legitimate requests within one month.
Occasionally it could take us longer than a month if your request is particularly complex or
you have made a number of requests. In this case, we will notify you and keep you
updated.
13. GLOSSARY
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our
business to enable us to give you the best service or product and the best and most
secure experience. We make sure we consider and balance any potential impact on you
(both positive and negative) 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.
Performance of Contract means processing your data where it is necessary for the
performance of a contract to which you are a party or to take steps at your request before
entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary
for compliance with a legal obligation that we are subject to.
THIRD PARTIES
In addition to any third parties specifically mentioned throughout this document, External
Third Parties can be summarised as follows:
a) Service providers acting as processors based in the UK who provide IT and system
administration services, such as Dropbox, which is based in the US or Pinnacle Media
or Manipal Pre media based in India and Capture One which is based in Denmark.
b) Professional advisers, acting as processors, including lawyers, bankers, auditors and
insurers based in the UK, who provide consultancy, banking, legal, insurance and
accounting services.
c) HM Revenue & Customs, regulators and other authorities acting as processors or joint
controllers based in the United Kingdom who require reporting of processing activities in
certain circumstances.YOUR LEGAL RIGHTS
You have the right to:
a) 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.
b) 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.
c) 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.
d) 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.
e) 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:
i) If you want us to establish the data’s accuracy;
ii) where our use of the data is unlawful but you do not want us to erase it;
iii) where you need us to hold the data even if we no longer require it as you need it ti
establish, exercise or defend claims; or
iii) you have objected to our use your data but we need to verify wether we have overriding
legitimate grounds to use it.
f) 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.
g) 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.