The un-official stuff. (The short version.)
Who we are
We are Malthouse Photography Ltd. I’m Mark Cornwell and my wife Sheila Cornwell and I run this little business. It’s just the two of us.
Our website address is: https://www.malthousephotography.co.uk
What personal data we collect and why we collect it
My basic rule of thumb is “how would I feel if my information was treated like that?” So whilst I do use contact details that you give me to send marketing information to you that’s done via individual emails and you can tell me to stop at any time and I shall. I don’t share your name and email details and the like with other people. My aim is to be a good guy.
If you send an email to me, or if you use the ‘contact’ page you may wonder what happens to your details. Actually, it is very simple. In both cases I see an email from you in my inbox. I will reply to that email as required. If you enquire about me doing a photo session or a wedding you go on my database and I will follow up with you as needed.
This website is in two sections:
- The website itself
- My client area
There’s one form on this website. That’s an email form which simply sends an email to my regular email account for me to reply to personally. There’s no email newsletter involved. There’s no fancy Google Analytics or Facebook “tracking pixel” to follow you around that I know of (see below for embedded content). I tried all that years ago, got bored of it and left it alone. Now there’s just my website and the link to email me!
The client area is a bit more special. I use a company called Zenfolio to look after my galleries. Any cookies that it sets are required for it to function. If you go into a gallery, so that I know who has looked at it (especially in case a couple ever asked who has had access to their images) it asks you for your name and email address. That’s stored by Zenfolio. If you choose to order something from my galleries that’s sorted out between Zenfolio and a photographic lab called OneVision Imaging. How they store details is a mystery to me but apparently it’s all GDPR compliant and the money comes to me from Zenfolio and the products get to you via OneVision Imaging. Voodoo magic.
Similarly if you pay me any money by signing a contract and paying a Booking Fee that’s sorted by a company called Stripe. I rely on them to do all the required financial stuff so that I don’t touch the money or your account. They do magic and we exchange money seamlessly.
Embedded content from other websites
Articles on this site may include embedded content (e.g. videos, images etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website. For example if you visit YouTube assume that if I’m embedding a YouTube video it is just as if you’ve watched it on YouTube.
Now I said there’s nothing I know about – you’ll spot that I have Instagram on my main page. I don’t believe it sets any cookies. I did some checks and it doesn’t look like it does.
At time of writing this I don’t have any YouTube or Vimeo embedded videos. If I end up putting some on there I don’t know what they will do by way of cookies. Honestly I try to turn them all off as they are a pain.
The official stuff. (The slightly longer version.)
What information is being collected?
I only get what you send me. Usually details like name/address/email address/phone number and of course things to do with your wedding – venue, date, how many people and so on.
Who is collecting it?
Me! Ok, not always me. If you sign in to my client area to view images a company called Zenfolio looks after that for me. If you actually order prints another company OneVision Imaging does the orders for me and therefore your details get into their systems and they’ve got their own privacy policies.
How is it collected?
There are a few places that you can get in to “my system”. You might phone me. You might email me. You might use my contact form. You might register to view a gallery. You might place an order. You might fill in a form on another website that then sends me information. In each case I only collect what you give me. That’s usually details of your wedding so that I can talk to you about potentially doing your wedding.
I put this all into my Customer Relationship Management system – something called Light Blue – and I use it to prompt me to do things like follow up with you, to send you contracts and so on. It actually reminds me to do things like check back if you’ve not chosen images for your albm. I can’t remember to do everything, after all!
Why is it being collected?
I keep data simply to help me to help you. If I didn’t have your phone number/name/address I couldn’t even contact you to talk about your big day in the first place.
How will it be used?
I’ve covered this in “how is it collected” above. Essentially I keep everything on my computer and my phone so that I can “do” your wedding. Without my Light Blue system I wouldn’t be able to do such a smooth job.
Who will it be shared with?
Nobody. Nearly. As I said in “who is collecting it” – if you enter an order on my client system that goes to Zenfolio and then to the company that does my printing for those orders, OneVision. They keep the data simply to fulfil the orders and so that I know who has gone into different galleries – that allows me to answer questions (that I do get) like “do you know if my aunt, a Mrs Smythe, has looked at our wedding at all?” I also keep names of people looking at galleries in case there are any problems with who is looking at galleries of images of school photography, for example.
What will be the effect of this on the individuals concerned?
Well other than me doing a smoother job on their weddings I can’t think of one!
Is the intended use likely to cause individuals to object or complain?
Not that I can see. If it were me I would expect my details to go into a system for any order I make. This is no different.
That’s the official stuff done.
(Well nearly – I have to put the “small print” in here too – that’s below!)
As I say I try not to share details that you give to me with anyone else. I hate it when it happens to me and I will not sell/give your information away. “But Mark, I’m only on your site because you contacted me!” If that is the case then I was provided with your email address by somewhere like a wedding fair that you attended and you said that you were happy to be contacted by suppliers. Or maybe you were at a networking event with me and handed me your card to contact you – in which case you’ve probably added me to your list too! Or maybe you filled in a form on one of the wedding “bid” type sites that ask me to quote you for your wedding.
If you do not want further contact with me please simply email me and I will take you off my list.
Oh and if you look at my testimonials page you’ll see stuff written by other couples. If you are kind enough to send me a thank-you card I am likely to scan it and put it up on that page and plaster it all over Facebook/Instagram/Twitter… it’s lovely when people thank me and I like to share that!
Warm Milk and Cookies
The only other time we gather your data is if you buy images from one of my galleries. The details there are used, again, for email marketing and… well for sending you what you’ve purchased. My galleries are looked after by company that specialises in galleries and my orders are looked after by another company that looks after printing products for me.
But I do not like cookies!
That’s fine by us. Google how to turn them off. Then turn them off. Our site will still function because… well it doesn’t use them unless you’re in the client area! 😀
Links to other sites
Where you do find links on this site they have been put there because we think they may have something of use to you.
Warm Milk and Cookies – again
The small print!
Ok, despite wanting to keep my privacy notice smooth and simple there are some legal niceties to cover. In order to do so I went and purchased a template from a lawyer called Suzanne Dibble who specialises in this stuff. I’ve filled in the template and paste it here in all its glory for you to… enjoy…
Website privacy notice
This privacy notice provides you with details of how we collect and process your personal data through your use of our site www.malthousephotography.co.uk
By providing us with your data, you warrant to us that you are over 13 years of age.
Malthouse Photography Ltd is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).
Our full details are:
Full name of legal entity: Malthouse Photography Ltd
Email address: email@example.com
Postal address: 4 Old Malthouse, Nottington, Weymouth, Dorset DT3 4BH
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at firstname.lastname@example.org
- WHAT DATA DO WE COLLECT ABOUT YOU, FOR WHAT PURPOSE AND ON WHAT GROUND WE PROCESS IT
Personal data means any information capable of identifying an individual. It does not include anonymised data.
We may process the following categories of personal data about you:
- Communication Data that includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
- Customer Data that includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address email address, phone number, contact details, purchase details and your card details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
- Technical Data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.
- Marketing Data that includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions such as competitions, prize draws and free give-aways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.
- We may use Customer Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).
We do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences.
Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.
We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at email@example.com . In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.
We may process your personal data without your knowledge or consent where this is required or permitted by law.
We do not carry out automated decision making or any type of automated profiling.
- HOW WE COLLECT YOUR PERSONAL DATA
We may receive data from third parties such as analytics providers such as Google based outside the EU, advertising networks such as Facebook based outside the EU, such as search information providers such as Google based outside the EU, providers of technical, payment and delivery services, such as data brokers or aggregators.
- MARKETING COMMUNICATIONS
Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).
Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However you can still opt out of receiving marketing emails from us at any time.
Before we share your personal data with any third party for their own marketing purposes we will get your express consent.
You can ask us or third parties to stop sending you marketing messages at any time by emailing us at firstname.lastname@example.org
If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations etc.
- DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below:
- Service providers who provide IT and system administration services.
- Professional advisers including lawyers, bankers, auditors and insurers
- Government bodies that require us to report processing activities.
- Third parties to whom we sell, transfer, or merge parts of our business or our assets.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
- INTERNATIONAL TRANSFERS
Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.
Many of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is in place:
- We will only transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data by; or
- Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
- If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
- DATA SECURITY
We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.
We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.
- DATA RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.
For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.
In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
- YOUR LEGAL RIGHTS
Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.
You can see more about these rights at: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
If you wish to exercise any of the rights set out above, please email us at email@example.com
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you.
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
- THIRD-PARTY LINKS
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.