Photo Concierge understands that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of everyone who visits our site and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and Our obligations under the law.
1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
means an account required to access and/or use certain areas and features of our site;
means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 12, below;
means this website www.photoconcierge.co.uk
“UK and EU Cookie Law”
means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015; and
means Photo Concierge
2. Information About Us
2.1 Our Site, www.photoconcierge.co.uk is owned and operated by Sue Oakford at PhotoConcierge whose main trading address is 43 Calbourne Road London SW12 8LW.
2.2 2.2 Our Data Protection Officer is Sue Oakford who can be contacted at firstname.lastname@example.org
3. Scope – What Does This Policy Cover?
4. What Data Do We Collect?
Data will only be collected if you voluntarily submit it and consent to us using it for the purposes set out in section 5.
5. How Do We Use Your Data?
5.1 All personal data is stored securely in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR). For more details on security see section 6, below.
5.2 We use your data to provide the best possible products and services to you. This includes:
5.2.1 Providing and managing your account
5.2.2 Providing and managing your access to our site
5.2.3 Personalising and tailoring your experience on our site
5.2.4 Supplying our products and services to you
5.2.5 Personalising and tailoring our products and services for you
5.2.6 Responding to communications from you
5.2.7 Supplying you with email Insert type of email e.g. newsletters, alerts etc. that you have subscribed to (you may unsubscribe or opt-out at any time by using the unsubscribe method)
5.2.8 Market research
5.2.9 Analysing your use of our site and gathering feedback to enable us to continually improve our Site and your user experience;
5.3 In some cases, the collection of data may be a statutory or contractual requirement, and We will be limited in the products and services We can provide you without your consent for Us to be able to use such data.
5.4 With your permission and/or where permitted by law, we may also use your data for marketing purposes which may include contacting you by email AND/OR telephone AND/OR post with information, news and offers on our products and services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.
5.5 Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:
a) you have given consent to the processing of your personal data for one or more specific purposes;
b) processing is necessary for the performance of a contract to which you are a party or to take steps at the request of you prior to entering into a contract;
c) processing is necessary for compliance with a legal obligation to which we are subject;
d) processing is necessary to protect the vital interests of you or of another natural person;
e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
f) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
6. How and Where Do We Store Your Data?
6.1 We only keep your data for as long as we need to use it as described above in section 5, and/or for as long as we have your permission to keep it. In any event, we will conduct periodical reviews to ascertain whether we need to keep your data. Your data will be deleted after 5 years if we no longer need it or deem it relevant to our business.
6.2 Some or all of your data may be stored or transferred outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein). You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store or transfer data outside the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA and under the GDPR. Such steps may include, but not be limited to, the use of legally binding contractual terms between Us and any third parties We engage and the use of the EU-approved Model Contractual Arrangements. If we intend at any time to transfer any of your data outside the EEA, we will always obtain your consent beforehand and ensure we have put in place the relevant safeguards to protect your data.6.2 Data security is of great importance to us, and to protect your data we will always put in place suitable security measures to safeguard and secure any data collected through our site.
6.3 Data security is of great importance to us, and to protect your data we will always put in place suitable security measures to safeguard and secure any data collected through our site.
6.4 Notwithstanding the security measures that we take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet.
7. Do We Share Your Data?
7.1 We may share your data with other companies in our Group. This includes Sue Oakford Photography which is part of PhotoConcierge.
7.2 We may compile statistics about the use of our site including data on traffic, usage patterns, user numbers, sales and other information. All such data will be anonymised and will not include any personally identifying information. We may from time to time share such data with third parties such as prospective investors, affiliates, partners and advertisers. Data will only be shared and used within the bounds of the law.
7.3 In certain circumstances we may be legally required to share certain data held by us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you to share your data in such circumstances and will comply as required with any legally binding request that is made of Us.
8. What Happens If Our Business Changes Hands?
8.2 In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes.
9. How Can You Control Your Data?
9.1 When you submit information via our site, you may be given options to restrict our use of your data. We aim to give you strong controls on our use of your data (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided at the point of providing your details.
9.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
10. Your Right to Withhold Information and Your Right to Withdraw Information After You Have Given it
10.2 You may withdraw your consent for us to use your personal data as set out section in 5 at any time by contacting us using the details set out in section 15, and we will delete your data from our systems. However, you acknowledge this may limit our ability to provide the best possible products and services to you.
11. How Can You Access Your Data?
You have the legal right to ask for a copy of any of your personal data held by us (where such data is held). Please contact us for more details at email@example.com
12. Cookie Consent Policy
12.1 What are Cookies?
12.3 Disabling Cookies
You can prevent the setting of cookies by adjusting the settings on your browser (see your browser Help for how to do this). Be aware that disabling cookies will affect the functionality of this and many other websites that you visit. Disabling cookies will usually result in also disabling certain functionality and features of this site. Therefore, it is recommended that you do not disable cookies.
12.4 The Cookies we set.
To provide you with a great experience on this site, we provide the functionality to set your preferences for how this site runs when you use it. To remember your preferences, we need to set cookies so that this information can be called upon whenever you interact with a page which is affected by your preferences.
12.5 Third Party Cookies
This site uses Google Analytics which is one of the most widespread and trusted analytics solutions on the web for helping us to understand how you use the site and ways that we can improve your experience. These cookies may track things such as how long you spend on the site and the pages that you visit so we can continue to produce engaging web content.
For more information on Google Analytics cookies, see the official Google Analytics page.
12.6 Targeting Cookies
Our website will: allow you to share pages with social networks such as Facebook (If available).
It also contains Facebook Pixels Code: A pixel refers to the code that is placed on your computer to trigger a cookie. We sometimes use this methodology to allow us to deliver more relevant messages to you.
12.7 More Information
By using our site, as per the Cookie Law, you are agreeing to these cookies being stored by your browser and their data being shared with the aforementioned services.
For more information on how Google uses your data, visit this page (link to Google Privacy page).
If you are still looking for more information on Cookies please contact us through one of our preferred contact methods
13. Your rights as a data subject
At any point whilst Andean Commodities is in possession of or processing your personal data, all data subjects have the following rights:
• Right of access – you have the right to request a copy of the information that we hold about you.
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
• Right to restriction of processing – where certain conditions apply you have a right to restrict the processing.
• Right of portability – you have the right to have the data we hold about you transferred to another organisation.
• Right to object – you have the right to object to certain types of processing such as direct marketing.
• Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.
If Andean Commodities refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge.
Andean Commodities at your request can confirm what information it holds about you and how it is processed.
You can request the following information:
• Identity and the contact details of the person or organisation that has determined how and why to process your data.
• Contact details of the data protection officer, where applicable.
• The purpose of the processing as well as the legal basis for processing.
• If the processing is based on the legitimate interests of Andean Commodities or a third party such as one of its clients, information about those interests.
• The categories of personal data collected, stored and processed.
• Recipient(s) or categories of recipients that the data is/will be disclosed to.
• How long the data will be stored.
• Details of your rights to correct, erase, restrict or object to such processing.
• Information about your right to withdraw consent at any time.
• How to lodge a complaint with the supervisory authority (Data Protection Regulator).
• Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
• The source of personal data if it wasn’t collected directly from you.
• Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
To access what personal data is held, identification will be required
Andean Commodities will accept the following forms of ID when information on your personal data is requested: a copy of your driving license, passport, birth certificate and a utility bill not older than three months or a national ID card. A minimum of one piece of photographic ID listed above and a supporting document is required. If we are dissatisfied with the quality, further information may be sought before personal data can be released.
All requests should be made to firstname.lastname@example.org.
In the event that you wish to make a complaint about how your personal data is being processed by us or its partners, you have the right to complain to Andean Commodities Managing Director – Eduardo Carmona.
14. Contacting Us