We are serious about protecting your privacy and personal data by default and design, meaning that we have put in place tough systems and processes to protect your data across all touch points. We aim to comply with all relevant privacy laws across policy, process, training and documentation.
Who are we?
Our full details are:
Full name of legal entity: John Wright Photography Ltd
Name and title of DPO: John Wright
Email address: firstname.lastname@example.org
Postal address: Motel. Arch 406-408, Long Street, London, E2 8HG
Telephone number: 020 7190 9656
You have the right to make a complaint at any time to the Information Commissioner's Office(ICO), the UK supervisory authority for data processing 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.
What data we collect from you:
We will only collect basic information from you to allow us to provide the services to you and to inform you of new services which might be of interest to you. In particular we may collect the following information from you which is defined as 'personal data':
• Personal details (name, address, email, phone number);
• Business activities of the person whose details we are processing.
We also record details of any enquiries you make with us.
We do not collect any 'special categories' of personal data about you (this include 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.
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.
How we use your data:
We use your data to provide you with service from MOTEL, as is necessary for the performance of the contract between us.
With your permission, we will email you our newsletter approximately every six weeks. We may also check in by phone from time to time. Occasionally we may send a letter by post. We only email business email addresses and will only contact you if:
1) You have asked us to; or
2) We genuinely believe you have a legitimate need for our services and we deem this to represent a legitimate interest in line with the ICO's guidance.
If at any point you decide you would prefer us not to contact you, let us know and we won't.
We may also use your personal data for:
1) Administering any accounts;
2) Processing your bank/credit card details in order to obtain payment;
3) Market research;
4) Our own internal marketing; and
5) Credit reference checks (where appropriate).
We will only use your data where we're allowed to by law, e.g. carrying out an agreement we have with you, fulfilling a legal obligation, because we have a legitimate business interest or where you agree to it.
We do not use your data for automated decision making or profiling.
Who we share your data with:
We may have to share your personal data with certain third parties (see the list below for examples). Where your data is shared, 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.
1) Service providers, acting as processors, who provide technical, administrative or other specialised support required in the fulfilment of any business operations that we undertake to provide to you, in partnership with you, or on your behalf.
2) Professional advisers, acting as processors or joint controllers, including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services,
3) HM & Customs, regulators and other authorities, acting as processors or joint controllers, who require reporting or processing activities in certain circumstances.
We never share your data with third parties for marketing purposes.
We do not transfer your personal data outside the European Economic Area (EEA) unless under the circumstances outlined in point 1)
How we keep your data secure:
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.
How long we keep your data:
Unless you request otherwise, we will securely hold your data for a period of seven years following our last contact.After seven years we will securely delete your data.
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If you would like us to remove you from our database entirely, let us know and we shall remove the information you ask us to. If you would like to view any or all of the data we may hold on you, please ask us. We aim to comply with all data requests within 14 days. Occasionally it may take us longer 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.
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 further information in relation to your request to speed up our response.
This version was last updated in May 2018.