Privacy Policy
This privacy policy (“Privacy Policy”) applies to personal data that we collect from you as a customer
(“you” or “your”). It provides information on what data we collect, why we collect the data, how it is used
and the lawful basis on which your personal data is processed, and what your rights are under the
applicable data protection and privacy laws, including the General Data Protection Regulation
(“GDPR”).
1. WHO ARE WE
We are Lanta Photography by Sarah McNulty. We are the data controller responsible for your personal data.
2. WHAT DO WE COLLECT
We collect and process the following information provided by you in the course of your initial enquiry
and the formation, operation and conclusion of our contract for photography services:
● Personal information: This includes your name, address, e-mail address; phone number;
gender and date of birth; country and any other information that you elect to provide to us for the purposes of the photography services.
● Payment Information: Information about your debit/credit card and bank account information
provided by you to our payment service providers, that we require for the purpose of processing payment for our goods and services.
● Other Information: Personal details you choose to give when corresponding with us by
phone or e-mail or in-person.
Personal data will be processed in order to perform our contract with you, fulfil legal obligations and for
legitimate interests, as described below.
3. HOW WE USE YOUR PERSONAL INFORMATION
We use your personal information in the following ways:
● to provide you with our services and to create and deliver the products you have requested and
contact you regarding your use of the services. Such use is necessary to respond to or implement your request and for the performance of the contract between you and us.
● as necessary for certain legitimate business interests, which include the following:
o where we are asked to deal with any enquiries or complaints you make;
o to provide postal communications which we think will be of interest to you;
o if you ask us to delete your data or to be removed from our marketing lists and we are
required to fulfil your request, to keep basic data to identify you and prevent further unwanted processing; and
2
ACTIVE/95110669.3
o to (a) comply with legal obligations, (b) respond to requests from competent authorities; (b)
protect our operations; (c) protect our rights, safety or property, and/or that of our affiliated
businesses, you or others; and (d) enforce or defend legal rights, or prevent damage.
●
(a) in our printed publications, presentations, promotional materials (including leaflets, brochures,
stickers, bookmarks, posters, factsheets, calendars); (b) on our website and other digital advertising
of our services; and (c) in social media forums such as Instagram, Pinterest and Facebook.
● We may provide you with information about goods or services, events and other promotions we feel
may interest you. We will contact you by email only with your consent, if this was given at the time
you provided us with the personal data.
We may use your personal data for other reasons compatible with the purposes of the data processing
outlined in this Privacy Policy. There may be other occasions where personal data is processed for
unrelated purposes which will be explained at that time upon notice to you. If required, we will ask for
your consent to any such further processing.
As used in this Privacy Policy, “legitimate interests” means our interests in conducting and managing
and fulfilling our obligations under our contract with you. This Privacy Notice describes
when we process personal data for those legitimate interests, what these interests are and your rights.
When we process your personal data for our legitimate interests, we make sure to consider and balance
any potential impact on you, and your rights under data protection laws. Our legitimate interests do not
automatically override your interests. We will not use your personal data for activities where our
interests are overridden by the impact on you, unless we have your consent or those activities are
otherwise required or permitted to by law. You have the right to object at any time to processing of your
personal data that is based on our legitimate interests, on grounds relating to your particular situation
(for more information on your rights, please see “Your Data Protection Rights” section below).
You acknowledge and agree that where provision of personal data is necessary to ensure compliance
with legal obligations or to perform our contract with you, failure to provide relevant personal data for
the above mentioned purposes may prevent us providing our goods and services to you.
4. DISCLOSURE OF YOUR INFORMATION
We share your personal data with third parties in the following situations:
● Service Providers: we sometimes engage selected third parties who act on our behalf to support
our operations, such as (i) card processing or payment services (see the section below headed
“Payment Information”), (ii) IT suppliers and contractors (e.g. data hosting providers or delivery
partners) as necessary to provide IT support and enable us to provide our goods/services, and (iii)
providers of specialist services, including retouching, printers, framers and book binders. Pursuant
to our instructions, these parties may access, process or store your personal data in the course of
performing their duties to us and solely in order to perform the services we have hired them to
provide.
● Business Transfers: if we sell our business or our company assets are acquired by a third party
personal data held by us about our customers may be one of the transferred assets.
● Administrative and Legal Reasons: if we need to disclose your personal data (i) to comply with
a legal obligation and/or judicial or regulatory proceedings, a court order or other legal process. (ii)
to enforce our Terms & Conditions or other applicable contract terms that you are subject to; (iii) to
protect us, our members or contractors against loss or damage. This may include (without limit)
exchanging information with the police, courts or law enforcement organisations.
5. PAYMENT INFORMATION
Any credit/debit card payments and other payments you make will be processed by our third party
payment providers and the payment data you submit will be securely stored and encrypted by our
3
ACTIVE/95110669.3
payment service providers using up to date industry standards. Please note that we do not ourselves
directly process or store the debit/credit card data that you submit.
6. DATA RETENTION
Personal data will not be held for longer than necessary with regard to the purposes of the data
processing outlined in this Privacy Policy, subject to any retention periods provided by applicable laws
and regulations. We apply criteria to determine the appropriate periods for retaining personal data
depending on its purpose, nature, and sensitivity. We Collect the minimum possible data in order to provide our services and store it only for the purposes and period necessary to fulfil the usage outlined in this Privacy Policy.
When you consent to receive marketing communications, we will keep your data until you let us know either via email, contact form or telephone via our website that you no longer wish to receive marketing communications by us.
8. YOUR DATA PROTECTION RIGHTS
Certain applicable data protection laws give you specific rights in relation to your personal data. In
particular, you have the following rights in relation to your personal data:
● Right of access: If you ask us, we will confirm whether we are processing your personal data and,
if so, provide you with a copy of that personal data along with certain other details.
● Right to rectification: If your personal data is inaccurate or incomplete, you are entitled to ask that
we correct or complete it. If we shared your personal data with others, we will tell them about the
correction where possible.
● Right to erasure: You may ask us to delete or remove your personal data, such as where our legal
basis for the processing is your consent and you withdraw consent. We may continue processing
personal data where this is necessary for a legitimate interest in doing so, as described in this
Privacy Policy.
● Right to restrict processing: You may ask us to restrict or ‘block’ the processing of your personal
data in certain circumstances, such as where you contest the accuracy of the data or object to us
processing it. We will tell you before we lift any restriction on processing.
● Right to object: You may ask us at any time to stop processing your personal data on grounds
relating to your particular situation, and we will do so:
4
ACTIVE/95110669.3
o If we are relying on a legitimate interest to process your personal data — unless we demonstrate
compelling legitimate grounds for the processing or
o If we are processing your personal data for direct marketing.
● Right to withdraw consent: If we rely on your consent to process your personal data, you have
the right to withdraw that consent at any time. This will not affect the lawfulness of processing of
your data before we received notice that you wished to withdraw your consent.
● Right to lodge a complaint with the data protection authority: If you have a concern about our
privacy practices, including the way we handled your personal data, you can report it to the UK data
protection authority (the Information Commissioner’s Office or ICO) using the following link.
https://ico.org.uk/make-a-complaint
If you wish to exercise any of these rights please contact us as described in the “Contact” section below.
We may also need to ask you for further information to verify your identity before we can respond to
any request.
9. CONTACT
Questions, comments or requests regarding this Privacy Policy should be addressed to Sarah McNulty
info@lantaphotography.co.uk
