Kittle Photographic: Privacy Notice

KITTLE PHOTOGRAPHIC is committed to protecting and respecting your privacy.

Introduction

This Privacy Notice together with our Terms of Use and any other documents referred to in it sets out how KITTLE PHOTOGRAPHIC LTD uses and protects any Personal Data that you provide us or we collect about you.

Your privacy is of the utmost importance to us. Please read the following privacy notice carefully to understand our views and practices regarding your Personal Data and how we will treat it.

Whenever we process your Personal Data, we are legally obliged to use it in accordance with the laws concerning the protection of Personal Data.

Who we are

KITTLE PHOTOGRAPHIC LIMITED is a company incorporated and registered in England and Wales with company number 04072260 whose registered office address is PO Box 5693, Chelmsford, Essex, CM3 8JE, England. (“Kittle Photographic”)

We provide one of the most comprehensive ranges of traditional and contemporary school photography services in the UK.

For the purposes of the Data Protection Act 2018, the UK General Data Protection Regulation and any other applicable data protection and privacy laws and regulations (“Data Protection Legislation”), Kittle Photographic will be the ‘data controller’ for all Personal Data we determine the means and purpose of processing and has registered with the Information Commissioners Office under registration number Z8800450.

By “Personal Data” we refer to information collected or held by Kittle Photographic, that identifies and relates to you as an individual.

Who this privacy notice applies to

This privacy notice applies to you if:

• You visit our website
• You enquire about our products and/or services
• You purchase our products
• We take a photograph of you
• We contact you to promote our products and/or services

Information we collect, how we use it, how long we keep it and our lawful bases are set out in the table below

Type of Individual	Type of Personal Data	Purpose of Processing	Lawful Basis	Retention Period
Customers (purchasers)	Your name Postal address Invoicing details/address Information regarding the services you request Supplementary information you provide us about yourself when contacting us Email address Telephone numbers (including mobile)	To ship orders requested to your address To process the services you request To ensure our records are complete and accurate To provide the specific services agreed by you	Contract	7 years following your last purchase
People making enquiries	Your name Information regarding the services you request Supplementary information you provide us about yourself when contacting us; Email address Telephone numbers (including mobile)	To give you information that you request from us and to improve our services To notify you about changes to our services To undertake sales analysis and management of the business	Legitimate interests	2 years from the date of last meaningful contact
Representatives of the schools at which we provide our services	Your name Job title Information regarding the services you request Supplementary information you provide us about yourself when contacting us Email address Work telephone number Name and address of the school you represent	To make arrangements for the photoshoot in the school	Legitimate interests	6 years from the date of last meaningful contact
Representatives of the schools at which we provide our services	Your name Job title Information regarding the services you request Supplementary information you provide us about yourself when contacting us Email address Work telephone number Name and address of the school you represent	Provide you with information about our services that we offer via promotional communications Keep you up to date with features on our website	Consent	Until you withdraw consent. You can withdraw consent at any time by emailing [email protected]
People attending our premises	CCTV footage	Provide you with information about our services that we offer via promotional communications	Legitimate interests	Footage is kept for 30 days
Individuals being photographed	First name Last name Admission number (an ID number) Class or form	To enable us to identify which photograph relates to which individual	Legitimate interests	We keep names and admin numbers on school archive for 5 years
Individuals being photographed	Photos	To provide our photography services	Legitimate interests	5 years from the date of the photoshoot following which the photos are archived for a further 5 years
Website visitors	Internet protocol (IP) address used to connect your computer to the Internet, your browser type and version, time zone setting, operating system and platform, browser plug-in types and version, the full URL clickstream to, through and from our website, page response times, download errors, length of visits to certain pages, page interaction (such as scrolling, clicks and mouse-overs) and methods used to browse away from the page. We use cookies to collect this information.	To allow us to operate the Website efficiently Troubleshooting, testing or statistical analysis as appropriate To analyse your use of our website to improve your experience and develop new services To keep the Website secure	Consent	Varies per cookie. See our Cookie Policy.

What we don’t collect

Card payment details taken via the website are processed and managed via Sage Pay. Further details regarding Sage Pay can be found at www.sagepay.com

Protecting your Personal Data

We are committed to ensuring that your Personal Data is secure and we have procedures in place to try and prevent any unauthorised access or disclosures and to safeguard and keep secure the Personal Data that we collect online.

All the Personal Data collected by us and stored electronically is currently held on a secure server in the UK only. Where required, this information is encrypted for additional security. We use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our buildings and files, and we authorise access to Personal Data only for those employees who require it to fulfil their job responsibilities.

However, you should be aware that providing information over the internet can never be guaranteed as being completely safe and if you choose to send such information to us via the internet, you do so at your own risk.

Data protection officer

To ensure we continue to monitor our obligations under Data Protection Legislation, Kittle Photographic has appointed a data protection officer (DPO). If you wish to contact the DPO regarding any specific elements of Kittle Photographic’s data handling, please send your enquiries for attention of the DPO to [email protected].

Transfer of data outside of the UK

We shall not transfer any Personal Data to any country outside of the UK or the European Economic Area unless we ensure that such Personal Data is subject to an adequate level of protection and appropriate legal safeguards, in accordance with Data Protection Legislation. In particular, we will ensure that:

• Your Personal Data is only processed in a country which has adequacy status or
• We use an International Data Transfer Agreement (IDTA) approved by the ICO, together with supplementary measures, where necessary

This will ensure that your Personal Data will be afforded the same level of protection as it has in the UK international-data-transfer-agreement.pdf (ico.org.uk)

Sharing your information with others

Please be assured that we will not share your Personal Data for any other reason unless we are required by law or permitted to do so under this privacy notice. The main circumstances in which we will be permitted or required to disclose this is by law will be by court order, to government bodies and law enforcement agencies. However, sometimes we may share your Personal Data with third parties in the following ways:

• We may use carefully selected sub-processors to help us collect, store or manage your Personal Data. This will always be managed under the terms of a written data processing agreement, ensuring that the processors act under our strict instructions and they are not permitted to use your Personal Data for their own purposes.
• Analytics and search engine providers that assist us in the improvement and optimisation of our website; and
• If Kittle Photographic is acquired by a third party, in which case Personal Data held by it about its customers will be one of the transferred assets. We process your Personal Data for this purpose because we have a legitimate interest to ensure our business can be continued by the buyer. If you object to our use of your Personal Data in this way, the relevant seller or buyer of our business may not be able to provide services to you.

Your rights

You have rights in relation to any Personal Data that we hold about you, including a right of access. If you wish to access your Personal Data you may make a formal subject access request by contacting Kittle Photographic using the contact details below.

The information you request must relate to you. If you request Personal Data relating to another person, you must have authority to act on their behalf. Kittle Photographic will require confirmation of your ID before processing your request.. If you are unable to prove your ID, Kittle Photographic reserves the right to refuse your request for access to Personal Data.

Other rights you have in relation to your Personal Data are:

• The right to rectify any inaccuracies in the information we hold
• The right to erasure of information in specific circumstances
• The right to request transfer of your information to another controller
• The right to object to processing in specified circumstances
• The right to restrict processing of your Personal Data

You also have rights in relation to automated decision-making. However, we do not use automated decision-making.

If you have provided us with consent to process your Personal Data, you have the right to withdraw this consent at any time. We are committed to ensuring that your wishes are respected and upon notification that you wish to withdraw your consent, Kittle Photographic will immediately cease processing the Personal Data in question.

If you wish to exercise any of your rights, please send your request to Kittle photographic by emailing [email protected] or telephoning us on 01245 401313 We will process your request within one month.

Changes to this privacy notice

We may change this privacy Notice at any time to ensure it always accurately reflects the way we collect, use and safeguard your Personal Data.

Please check this notice from time to time to ensure you are aware of any updates we may have made to our Personal Data handling practices. The date of the changes will be listed in the 'Last updated' section below. We will endeavour to notify all of our current clients of any updates to this notice via email and we will post the relevant announcement on our website homepage.

We recommend that you print a copy of this page for your reference.

Cookies

Our website uses cookies to help us recognise different users of our website and to provide users of our website with a good experience when using it. Please see our Cookies Policy for further information.

How can you make a complaint?

Please note that if you are not satisfied with the processing of your Personal Data as set out in this privacy notice, please contact us at [email protected].

You have the right to issue a complaint directly with the Information Commissioners Office, the data protection supervisory authority for England and Wales (https://ico.org.uk/concerns/).

Contacting us

Please contact us at [email protected] if you have any questions, comments or requests regarding this Privacy Notice.

Last updated July 2023