Privacy policy.
Effective date: 6th October 2022
Introduction
Chohee Courtois Photography takes your privacy seriously. This privacy policy has been prepared in line with the EU’s General Data Protection Regulation (GDPR), which promotes fairness and transparency for all individuals in respect of their personal data. This privacy policy applies to all data we process, and by using Chohee Courtois Photography, using our website or providing your information to us, you consent to our collection and use of such data. Chohee Courtois Photography is the data controller and can be contacted at:
hello@choheecourtois.co.uk
267 Noel Road, London W3 0JP
Purpose
The purpose of this privacy policy is to inform the following:
The personal data we collect;
Use of collected data;
Who has access to the data collected;
Your rights; and
Our website’s cookie policy.
GDPR
For users in the European Union, we adhere to the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, known as the General Data Protection Regulation (the "GDPR"). For users in the United Kingdom, we adhere to the GDPR as enshrined in the Data Protection Act 2018.
We have not appointed a Data Protection Officer as we do not fall within the categories of controllers and processors required to appoint a Data Protection Officer under Article 37 of the GDPR.
Consent
By using Chohee Courtois Photography, using our website or providing your information to us, you agree that you consent to this privacy policy.
Legal Basis for Processing
We collect and process your personal data only when we have a legal basis for doing so under Article 6 of the GDPR.
We rely on the following legal basis to collect and process the personal data:
Processing of personal data is necessary for us or a third party to pursue a legitimate interest. Our legitimate interest is not overridden by your interests or fundamental rights and freedoms. Our legitimate interest(s) are: fulfilling our services, personalising the customer experience, communication, marketing and analytics.
Personal Data We Collect
Data Collected Automatically
When you visit and use our website, we may automatically collect and store the following information:
IP address;
Location;
Hardware and software details such as your browser, network and device;
Clicked links;
Content viewed;
Web pages visited prior to coming to this website;
Scrolling;
Searches; and
Timestamps.
Data Collected in a Non-Automatic Way
We may collect the following data when you perform certain actions:
First and last name;
Email address;
Phone number;
Address;
Payment information;
Photographs; and
Details relating to your enquiry (e.g. age, sex, job title, other participants in your photography session, who referred you, etc).
This data may be collected using the following methods:
Completing a form
Making a payment
Communication such as email, phone call or in person; and
Photography session
How We Use Personal Data
The data we collect automatically on our website is used for the following purposes:
Running the website;
Protecting and improving the website; and
Analytics.
The data we collect when you perform certain actions may be used for the following purposes:
Fulfilling our services;
Personalising customer experience;
Communication;
Marketing; and
Analytics.
Who We Share Personal Data With
Employees
We may disclose your data to any member of our organisation who reasonably needs access to the data to achieve the purposes set out in this privacy policy.
Third Parties
We may share your data with the following third parties:
Website hosting provider;
Website analytics provider;
Fonts provider;
Email marketing provider;
Email provider;
CRM system provider;
Payment provider;
Storage/back-up provider;
Online gallery provider; and
Photographic service provider (e.g. retouching, printing, framing, etc).
We may share the following data with third parties:
Any relevant data in course of performing their duties to us.
We may share the data with third parties for the following purposes:
Fulfilling our services;
Personalising customer experience;
Communication;
Marketing; and
Analytics.
Third parties will not be able to access your data beyond what is reasonably necessary to achieve the given purpose.
Other Disclosures
We will not sell or share your data with other third parties, except in the following cases:
If the law requires it;
If it is required for any legal proceeding;
To prove or protect our legal rights; and
To buyers or potential buyers of this company in the event that we seek to sell the company.
If you follow hyperlinks from our website to another website, please note that we are not responsible for and have no control over their privacy policies and practices.
How Long We Store Personal Data
We will keep your data and photographs until you request your data to be deleted. This is due to requests for replacement images being made several years after being taken.
How We Protect Your Personal Data
We implement widely accepted standards of technology and follow internal policies of best practices to protect your data. We ensure data is encrypted when in transit and storage, and access to the data is limited to a necessary number of individuals and third party services and is subject to confidentiality commitments. A strong password policy is used by all individuals with access to the data. When the data is shared with third party providers for the purposes described in this privacy policy we rely on their security policy and infrastructure to protect the data.
While we take all reasonable precautions to ensure that your data is secure, the Internet as a whole can be insecure at times and therefore we are unable to guarantee the security of the data beyond what is reasonably practical.
International Data Transfers
Your data may be transferred to countries outside the United Kingdom or the European Union such as the United States to our third party providers for the purposes described in this privacy policy.
When we transfer your data we will protect the data as described in this privacy policy and comply with applicable legal requirements for transferring personal data internationally.
If you are located in the United Kingdom or the European Union, we will only transfer your personal data if:
The country your personal data is being transferred to has been deemed to have adequate data protection by the European Commission or, if you are in the United Kingdom, by the United Kingdom adequacy regulations; or
We have implemented appropriate safeguards in respect of the transfer. For example, the recipient is a party to binding corporate rules, or we have entered into standard EU or United Kingdom data protection contractual clauses with the recipient.
Your Rights
Under the GDPR, you have the following rights:
Right to be informed;
Right of access;
Right to rectification;
Right to erasure;
Right to restrict processing;
Right to data portability; and
Right to object.
Children
We do not knowingly collect or use personal data from children under 16 years of age. If a child under 16 years of age has provided us with personal data their parent or guardian may contact us.
Other Participants Being Photographed in Your Photography Session
As a photography business, we create and manage photographs as per your booking. Depending on your photography session these photographs may include other participants in the session. If there are other people being photographed in your session you are responsible for ensuring that all participants have been provided with and consent to this privacy policy.
How to Access, Modify, Delete, or Challenge the Data Collected
If you would like to know if we have collected your personal data, how we have used your personal data, if we have disclosed your personal data and to who we disclosed your personal data, if you would like your data to be deleted or modified in any way, or if you would like to exercise any of your other rights under the GDPR, please contact us:
Chohee Courtois
hello@choheecourtois.co.uk
267 Noel Road, London W3 0JP
Website Cookie Policy
A cookie is a small file, stored on a user's hard drive by a website. Its purpose is to collect data relating to the user's browsing habits. You can choose to be notified each time a cookie is transmitted. You can also choose to disable cookies entirely in your internet browser, but this may decrease the quality of your user experience.
We use the following types of cookies on our website:
Functional cookies
Functional cookies are used to remember the selections you make on our website so that your selections are saved for your next visits;Analytical cookies
Analytical cookies allow us to improve the design and functionality of our website by collecting data on how you access our website, for example, data on the content you access, how long you stay on our website, etc;Targeting cookies
Targeting cookies collect data on how you use the website and your preferences. This allows us to personalise the information you see on our website for you; andThird Party Cookies
Third party cookies are created by a website other than ours. We may use third party cookies to achieve the following purposes:Securely serve the website to users; and
Monitor site traffic, activity, and other data to tailor marketing.
Modifications
This privacy policy may be amended from time to time in order to maintain compliance with the law and to reflect any changes to our data collection process. When we amend this privacy policy we will update the Effective Date at the top of this privacy policy. We recommend that you periodically review our privacy policy to ensure that you are notified of any updates. If necessary, we may notify you by email of changes to this privacy policy.
Complaints
If you have any complaints about how we process your personal data, please contact us through the contact methods listed below so that we can, where possible, resolve the issue. If you feel we have not addressed your concern in a satisfactory manner you may contact a supervisory authority. You also have the right to directly make a complaint to a supervisory authority. You can lodge a complaint with a supervisory authority by contacting the Information Commissioner's Office.
Contact Information
If you have any questions, concerns or complaints, please contact us:
Chohee Courtois
hello@choheecourtois.co.uk
267 Noel Road, London W3 0JP