1.1 We are committed to safeguarding the privacy of our website visitors and service users.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.
1.5 In this policy, “we”, “us” and “our” refer to Breaking Your Mould Ltd T/A Beatrice & Bertrum. For more information about us, see Section 13.
2. HOW WE USE YOUR PERSONAL DATA
2.1 In this Section 2 we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
2.2 We may process data about your use of our website and services (“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 our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
2.3 We may process (“account data“).The account data may include your name and email address. The source of the account data is you. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is legitimate interests, namely providing you with information and images you request from us.
2.4 We may process information that you post for publication on our website or through our services (“publication data“). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is our legitimate interests, namely the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.5 We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant services to you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
2.6 We may process your contact details. This data may include: your name, company name, address, email, phone number, event date, venue details, venue contact, type of event, number of guests, event timings. The source of this data is by the participant (you). This data may be processed for sending requested information to the participant. The legal basis for this processing is our legitimate interests, namely sharing of information and/or photos.
2.9 We may process any of your personal data identified in this policy 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.
2.10 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
2.11 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of 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.
2.12 Please do not supply any other person’s personal data to us, unless we prompt you to do so.
3. PROVIDING YOUR PERSONAL DATA TO OTHERS
3.1 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, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
3.2 Your photographs will be held in a database which will be stored on the servers of our hosting services providers identified at www.smugmug.com/about/privacy
3.3 In addition to the specific disclosures of personal data set out in this Section 3, 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.
4. INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA
4.1 In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
4.2 The hosting facilities for parts of our website are situated in the UK and USA. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which you can obtain from www.smugmug.com/about/privacy
4.3 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.
5. RETAINING AND DELETING PERSONAL DATA
5.1 This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
5.2 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.
5.3 Online galleries are hosted on smugmug.com until either Breaking Your Mould Ltd stops trading or if the client who booked Breaking Your Mould Ltd wishes for their gallery to be deleted.
5.4 We use an externally hosted third party to manage and administer your account.
6. YOUR RIGHTS
6.1 In this Section 6, we have listed the rights that you have under data protection law.
6.2 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;
(c) the right to erasure – you can ask us to erase your personal data;
(d) the right to restrict processing – you can ask use 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.
6.3 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/.
6.4 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.
7. ABOUT COOKIES
7.1 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.
7.2 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.
7.3 Cookies do not typically 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.
8. COOKIES USED BY OUR SERVICE PROVIDERS
9. MANAGING COOKIES
9.1 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);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies(Internet Explorer);
9.2 Blocking all cookies will have a negative impact upon the usability of many websites.
9.3 If you block cookies, you will not be able to use all the features on our website.
10. WILL MY PERSONAL DATA BE KEPT SECURE?
Yes. We use an externally hosted third party to manage and administer your account. This company is called Light Blue Software and is registered in England and Wales. Light Blue Software take extensive precautions to secure every aspect of Light Blue’s online services, including (but not limited to): encrypting all communications between the Light Blue desktop and mobile apps and their servers; encrypting data at rest on their servers; securing their servers according to industry best practices.
11. WHERE DOES LIGHT BLUE SOFTWARE STORE MY PERSONAL DATA?
12.1 We may update this policy from time to time by publishing a new version on our website.
12.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
13 OUR DETAILS
13.2 We are registered in England and Wales under registration number 9711517 and our registered office is at: The Exuberance, Pin Mill, Suffolk IP9 1JW
13.3 Our principal place of business is at: Harkstead Hall Barns, Lings Lane, Harkstead, Suffolk IP9 1DB
13.4 You can contact us:
(a) by post, to the registered postal address given above
(b) using our website contact form
(c) by telephone, on the contact number published on our website
(d) by email, using the email address published on our website
14. DATA PROTECTION OFFICER
For more information about data control please contact:
Telephone: 07813 457 817