I am committed to safeguarding the privacy of my website visitors and clients.
This policy applies where I am acting as a data controller with respect to the personal data of my website visitors and clients; in other words, where I determine the purposes and means of the processing of that personal data.
In this policy, “I”, “me” and “my” refer to me, Sarah Debnam, and my data processors. For more information on this please contact me via email- email@example.com
How I use your personal data
In this section I have set out:
(a) the general categories of personal data that I may process;
(b) in the case of personal data that I did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which I may process personal data; and
(d) the legal bases of the processing.
I may process data about your use of my 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 Google Analytics and Facebook Pixel. 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 consent OR my legitimate interests, namely monitoring and improving my website and services OR establishing what my website and service users wish to see more of.
I may process your personal data that are provided in the course of the use of my services (“service data“). The service data may include your name, address, and email address. The source of the service data is given directly by you via email, Facebook or telephone. The service data may be processed for the purposes of operating my website, providing my services, ensuring the security of my website and services, maintaining back-ups of my databases and communicating with you. The legal basis for this processing is consent OR my legitimate interests, namely the proper administration of my website and business.
I may process information contained in or relating to any communication that you send to me (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. My website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is my legitimate interests, namely the proper administration of my website, business and communications with users.
I 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 my legitimate interests, namely the proper protection of my business against risks.
In addition to the specific purposes for which I may process your personal data set out in this section, I may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which I am subject, or in order to protect your vital interests or the vital interests of another natural person.
Please do not supply any other person’s personal data to us, unless I prompt you to do so.
Providing your personal data to others
I may disclose your personal data to my 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.
In addition to the specific disclosures of personal data set out in this section, I may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which I are subject, or in order to protect your vital interests or the vital interests of another natural person. I 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.
I will never sell your personal data, or pass it on to anyone other than my data processors and only where absolutely necessary to carry out services (Eg, post prints to your address).
Retaining and deleting personal data
This section sets out my data retention policies and procedure, which are designed to help ensure that I comply with my legal obligations in relation to the retention and deletion of personal data.
Personal data that I process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
I will retain your personal data as follows:
(a) Personal data will be retained for as long as reasonable, this includes photographs which will be retained and used for the purpose of creating prints/ art work, marketing my services, entering competitions, educational workshops and for my portfolio of art work. This will be for as long as I hold permission from you. This will be discussed and agreed BEFORE any photographic work is carried out.
In some cases it is not possible for me to specify in advance the periods for which your personal data will be retained. In such cases, I will determine the period of retention based on the following criteria:
(a) the period of retention of personal data will be determined based on necessity.
Notwithstanding the other provisions of this section, I may retain your personal data where such retention is necessary for compliance with a legal obligation to which I are subject, or in order to protect your vital interests or the vital interests of another natural person.
Security of personal data
I will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
I will store all your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.
You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and I cannot guarantee the security of data sent over the internet.
I may update this policy from time to time by publishing a new version on my website.
You should check this page occasionally to ensure you are happy with any changes to this policy.
In this Section, I have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in my summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
You have the right to confirmation as to whether or not I process your personal data and, where I do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, I will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can access data I hold about you by emailing me at firstname.lastname@example.org.
You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they are collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; I no longer need the personal data for the purposes of my processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, I may continue to store your personal data. However, I will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
You have the right to object to my processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by me or by a third party. If you make such an objection, I will cease to process the personal information unless I can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
You have the right to object to my processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, I will cease to process your personal data for this purpose.
You have the right to object to my processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
To the extent that the legal basis for my processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from me in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
If you consider that my processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
To the extent that the legal basis for my processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
You may exercise any of your rights in relation to your personal data via email at email@example.com
Please let me know if the personal information that I hold about you needs to be corrected or updated.
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.
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.
Cookies do not typically contain any information that personally identifies a user, but personal information that I store about you may be linked to the information stored in and obtained from cookies.
Cookies that I use
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/ansIr/95647?hl=en (Chrome);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
Blocking all cookies will have a negative impact upon the usability of many Websites.
If you block cookies, you will not be able to use all the features on my website.
This Website is owned and operated by Sarah Debnam.
You can contact us:
(a) By email to- firstname.lastname@example.org
(b) Using my Website contact form
(c) By telephone, on 07793 866349