Privacy policy

1. Introduction

1.1 We are committed to safeguarding the privacy of our website visitors, individual customers and customer personnel.

1.2 This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.

1.3 We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website, we will ask you to consent to our use of cookies when you first visit our website.

1.4 In this policy, "we", "us" and "our" refer to Jack Eames Photography Ltd. For more information about us, see Section 14.

2. The personal data that we collect

2.1 In this Section 3 we have set out the general categories of personal data that we process and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data.

2.2 We may process data enabling us to get in touch with you ("contact data"). The contact data may include your name, email address, telephone number, postal address and/or social media account identifiers. The source of the contact data is you and/or your employer.

2.3 We may process information relating to transactions, including purchases of goods and/or services, that you enter into with us ("transaction data"). The transaction data may include your name, your contact details and the transaction details. The source of the transaction data is you.

2.4 We may process information contained in or relating to any communication that you send to us or that we send to you ("communication data"). The communication data may include the communication content and metadata associated with the communication.

2.5 We may process data about your use of our website and services, and interact with our direct marketing ("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 Squarespace Analytics and Mailchimp.

3. Purposes of processing and legal bases

3.1 In this Section 4, we have set out the purposes for which we may process personal data and the legal bases of the processing.

3.2 Operations - We may process your personal data for the purposes of operating our website, processing and fulfilment of orders, providing our services, supplying our goods, generating invoices, bills and other payment-related documentation, and credit control. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, services and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

3.3 Relationships and communications - We may process contact data, transaction data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post, fax and/or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our service users, individual customers and customer personnel, the maintenance of relationships, and the proper administration of our website, services and business.

3.4 Direct marketing - We may process contact data and/or transaction data for the purposes of creating, targeting and sending direct marketing communications by email, post and making contact by telephone for marketing-related purposes. The legal basis for this processing is our legitimate interests, namely promoting our business and communicating marketing messages and offers to our service users.

3.5 Research and analysis - We may process usage data and/or transaction data for the purposes of researching and analysing the use of our website and services, as well as researching and analysing other interactions with our business. The legal basis for this processing is our legitimate interests, namely monitoring, supporting, improving and securing our website, services and business generally.

3.6 Record keeping - We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.

3.7 Security - We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.

3.8 Insurance and risk management - We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

3.9 Legal claims - We may process your personal data 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 our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

3.10 Legal compliance and vital interests - We may also process 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.

4. Providing your personal data to others

4.1 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.

4.2 Your personal data held in our website database will be stored on the servers of our hosting services providers identified at www.squarespace.com.

4.3 Your personal data stored for the purpose of direct digital marketing will be stored on the servers of our marketing service provider identified at www.mailchimp.com.

4.4 Your personal data stored for the purposes of managing our relationships and communicating with you will be stored on the servers of our CRM software provided by Daylite CRM (www.marketcircle.com) and our email client provided by GSuite (www.gsuite.google.com).

4.5 In addition to the specific disclosures of personal data set out in this Section 5, we 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. International transfers of your personal data

5.1 In this Section 6, we provide information about the circumstances in which your personal data may be transferred to countries outside the United Kingdom and the European Economic Area (EEA).

5.2 The hosting facilities for our website are situated in the United States. The competent data protection authorities have made an "adequacy decision" with respect to the data protection laws of the United States. Transfers to the United States will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the competent data protection authorities, a copy of which you can obtain from www.squarespace.com/privacy.

5.3 The hosting facilities for our direct digital marketing service are situated in the United States. The competent data protection authorities have made an "adequacy decision" with respect to the data protection laws of the United States. Transfers to the United States will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the competent data protection authorities, a copy of which can be obtained from www.mailchimp.com/legal/privacy.

5.4 The hosting facilities for our CRM software are situated in Canada. The competent data protection authorities have made an "adequacy decision" with respect to the data protection laws of Canada. Transfers to Canada will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the competent data protection authorities, a copy of which can be obtained from www.marketcircle.com/privacy.

5.5 The hosting facilities for our email client service are situated in the United States. The competent data protection authorities have made an "adequacy decision" with respect to the data protection laws of the United States. Transfers to the United States will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the competent data protection authorities, a copy of which can be obtained from www.policies.google.com/privacy.

5.4 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

6. Retaining and deleting personal data

6.1 This Section 7 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. This will be regularly reviewed on an individual basis.

6.3 We will retain your personal data as follows:

(a) Contact data will be retained until it is deemed to no longer be necessary or until a request is made to remove the data;

(b) Transaction data will be retained for a minimum period of 7 following the date of the transaction;

(d) Communication data will be retained until it is deemed to no longer be necessary or until a request is made to remove the data;

(e) Usage data for our website will be retained for up to 2 years following the date of collection, depending on the type of data. See Squarespace’s policy for storing usage data here: https://support.squarespace.com/hc/en-us/articles/360001264507#toc-analytics-and-performance-cookies

(f) Usage data for our direct digital marketing campaigns will be retained for up to 2 years following the date of collection.

6.4 Notwithstanding the other provisions of this Section 7, we 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.

7. Your rights

7.1 In this Section 8, we have listed the rights that you have under data protection law.

7.2 Your principal rights under data protection law are:

(a) the right to access - you can ask for copies of your personal data;

(b) the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;

(d) the right to restrict processing - you can ask us to restrict the processing of your personal data;

(e) the right to object to processing - you can object to the processing of your personal data;

(f) the right to data portability - you can ask that we transfer your personal data to another organisation or to you;

(g) the right to complain to a supervisory authority - you can complain about our processing of your personal data; and

(h) the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.

7.3 These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.

7.4 You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.

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 may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.

9. Cookies used by our service providers

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

9.2 We use Google Analytics. Google Analytics gathers information about the use of our website by means of cookies. The information gathered is used to create reports about the use of our website. You can find out more about Google's use of information by visiting https://www.google.com/policies/privacy/partners/ and you can review Google's privacy policy at https://policies.google.com/privacy.

9.3 We use Squarespace to host our website and provide website analysis through Squarespace Analytics. The information gathered is used to support function and navigation of the website as well as to create reports about the use of our website. You can view the privacy policy of this service provider at www.squarespace.com/privacy. The relevant cookies used by Squarespace are listed here: https://support.squarespace.com/hc/en-us/articles/360001264507

9.4 We use Mailchimp to send our direct digital marketing campaigns and provide campaign analysis through Mailchimp reports. The information gathered is used to analyse the use and performance of our digital marketing campaigns. You can view the privacy policy of this service provider at www.mailchimp.com/legal/privacy. The relevant cookies used my Mailchimp are listed here: https://mailchimp.com/legal/cookies/#Cookies_served_through_the_Service.

10. Managing cookies

10.1 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 (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/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari); and

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

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

10.3 If you block cookies, you will not be able to use all the features on our website.

11. Amendments

11.1 We may update this policy from time to time by publishing a new version on our website.

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

12. Our details

12.1 Our website (www.jackeames.com) is owned and operated by Jack Eames Photography Ltd.

12.2 We are registered in England and Wales under registration number 08316055 and our registered office is at 201 Haverstock Hill, London, NW3 4QG.

12.3 Our principal place of business is at White Rabbit Studios, First Floor, The Arches, 471-473 Dereham Place, London, EC2A 3HJ

12.4 You can contact us:

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

(b) by telephone, on the contact number published on our website; or