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Cookies & Privacy Policy

Effective Date: 1 January 2021

1.
Introduction
1.1
We are committed to safeguarding the privacy of our website visitors, individual customers and corporate customer personnel.
1.2
This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.
1.3
In this policy, “we”, “us” and “our” refer to Arif Rampuri trading as Showtime Photo Booth. For more information about our business, see Section 16.
2.
The personal data that we collect
2.1
In this Section 2 we have set out the general categories of personal data that we process and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data.
2.2
We may process information relating to our prospective customers and customer relationships (“customer data“). The customer data may include your name, the name of your business or employer, your job title or role, your contact details and information contained in or relating to communications between us and you, or between us and your employer. The source of the customer data is you and/or your employer.
2.3
Although we process personal data contained in photographs, videos and other content created through our services and metadata associated with such photographs, videos and content, we usually do so as a processor acting on behalf of one of our customers, and accordingly this policy does not in general apply to such personal data. However, in limited circumstances, notably where we use photographs, videos and other content for the purposes of promoting our business, we will act as a controller with respect to that data. For the purposes of this policy, where we are acting as a controller, such data is referred to as “content data“.
2.4
We may process information relating to transactions, including purchases of services, that you enter into with us and/or through our website (“transaction data“). The transaction data may include your name, your contact details, your payment card details (or other payment details) and the transaction details. The source of the transaction data is you and/or our payment services providers.
2.5
We may process data about your use of our 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 our analytics tracking system.
3.
Purposes of processing and legal bases
3.1
In this Section 3, we have set out the purposes for which we may process personal data and the legal bases of the processing.
3.2
Operations – We may process customer data and/or transaction data for the purposes of operating our website, the processing and fulfilment of orders, providing our services, generating invoices, bills and other payment-related documentation, and credit control. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, services and business.
3.3
Relationships and communications – We may process customer data and/or transaction data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post and/or telephone, providing support and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors, service users, individual customers and customer personnel, the maintenance of our relationships, enabling the use of our services, and the proper administration of our website, services and business.
3.4
Publications – We may process content data for the purposes of publishing such data on our website and elsewhere through our services, and on our partners’ websites and services, but only where we have your agreement or the agreement of the relevant customer to such publication. The legal basis for this processing is our legitimate interests, namely the publication of content in the ordinary course of our operations.
3.5
Direct marketing – We may process customer data and/or transaction data for the purposes of creating, targeting and sending direct marketing communications by email, SMS and/or post and making contact by telephone for marketing-related purposes. The legal basis for this processing is consent.
3.6
Research and analysis – We may process usage data and/or transaction data for the purposes of researching and analysing the use of our website and services, as well as researching and analysing other interactions with our business. The legal basis for this processing is our legitimate interests, namely monitoring, supporting, improving and securing our website, services and business generally.
3.7
Record keeping – We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.
3.8
Security – We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.
3.9
Insurance and risk management – We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
3.10
Legal claims – We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
3.11
Legal compliance and vital interests – We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.
4.
Providing your personal data to others
4.1
Your personal data held in our website database will be stored on the servers of our hosting services providers in the UK (currently DOWO Digital Ltd).
4.2
We use third party service providers to store and transfer content data.  Currently, we use Dropbox, Inc, SmugMug, Inc, dslrBooth, Curator and WeTransfer B.V. for these purposes. Content data will be stored by these service providers in the UK, the European Economic Area and/or the United States. Transfers from the UK or EEA to the USA will be protected by contractual clauses approved by the competent data protection authorities.
4.3
We will disclose customer data to our subcontractors insofar as reasonably necessary for the purpose of enabling them to provide services to our customers.
4.4
Financial transactions relating to our services are handled by our payment services providers, Network Merchants Limited. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find out more about how they handle personal data at https://www.nmi.com/eu/privacy-policy.
4.5
We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.
4.6
In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We 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.
5.
Location of data processing
5.1
Except as specified elsewhere in this policy, we and our service providers will store and process personal data only within the UK.
6.
Retaining and deleting personal data
6.1
This Section 6 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
6.2
Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
6.3
We will retain your personal data as follows:
(a)
customer data will be retained for a minimum period of 6 years following the date of termination of the relevant customer relationship and for a maximum period of 7 years following that date;
(b)
transaction data will be retained for a minimum period of 6 years following the date of the transaction, and for a maximum period of 7 years following that date; and
(c)
usage data will be retained for 36 months following the date of collection.
6.4
Content data will usually be deleted within the period of 30 days following the end of the event at which that content data was generated. However, if you grant to us, or one of your guests or our customers grants to us, a licence to publish content data or other personal data, we may continue to retain and publish that data in accordance with the applicable licence terms, subject to your data subject rights. If we cease to publish such personal data after the end of the relevant retention period specified in this Section 6, that personal data will be retained for a minimum period of 6 years and a maximum period of 7 years following the date that publication ceases.
6.5
Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
7.
Your rights
7.1
In this Section 7, we have listed the rights that you have under data protection law.
7.2
Your principal rights under data protection law are:
(a)
the right to access – you can ask for copies of your personal data;
(b)
the right to rectification – you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
(c)
the right to erasure – you can ask us to erase your personal data;
(d)
the right to restrict processing – you can ask us to restrict the processing of your personal data;
(e)
the right to object to processing – you can object to the processing of your personal data;
(f)
the right to data portability – you can ask that we transfer your personal data to another organisation or to you;
(g)
the right to complain to a supervisory authority – you can complain about our processing of your personal data; and
(h)
the right to withdraw consent – to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
7.3
These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://edpb.europa.eu/our-work-tools/general-guidance/gdpr-guidelines-recommendations-best-practices_en and https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
7.4
You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.
8.
Third party websites
8.1
Our website may include hyperlinks to, and details of, third party websites.
8.2
In general we have no control over, and are not responsible for, the privacy policies and practices of third parties.
9.
Updating information
9.1
Please let us know if the personal information that we hold about you needs to be corrected or updated.
10.
Acting as a data processor
10.1
In respect of personal data comprised in photographs, videos and other content that we create, store and/or transmit on behalf of a customer, we do not usually act as a data controller; instead, we act as a data processor.
10.2
Insofar as we act as a data processor rather than a data controller, this policy shall not apply. Our legal obligations as a data processor are instead set out in the contract between us and the relevant data controller.
11.
About cookies
11.1
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.
11.2
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.
11.3
Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
12.
Cookies that we use
12.1
We use session cookies to enable the website to keep track of your movement from page to page and store your selections so you do not get asked repeatedly for the same information. These cookies allow you to proceed through many pages of the website quickly and easily without having to authenticate or reprocess each new area you visit.
12.2
We also use persistent cookies (up to one year) to verify details of your logged-in status and to customise views of our interfaces.
12.3
More information about how WordPress (the software that powers our website) uses cookies can be found at cookies can be found at https://wordpress.org/support/article/cookies/.
13.
Cookies used by our service providers
13.1
We use Google Analytics. Google Analytics gathers information about the use of our website by means of cookies. The information gathered is used to create reports about the use of our website. You can find out more about Google’s use of information by visiting https://www.google.com/policies/privacy/partners/ and you can review Google’s privacy policy at https://policies.google.com/privacy.
13.2
We use ShareThis to allow you to share website pages via social media. You can view the privacy policy of this service provider at https://sharethis.com/privacy/.
14.
Managing cookies
14.1
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/answer/95647 (Chrome);
(b)
https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop (Firefox);
(c)
https://help.opera.com/en/latest/security-and-privacy/ (Opera);
(d)
https://support.microsoft.com/en-gb/windows/delete-and-manage-cookies-168dab11-0753-043d-7c16-ede5947fc64d (Internet Explorer);
(e)
https://support.apple.com/en-gb/guide/safari/sfri11471/mac (Safari); and
(f)
https://support.microsoft.com/en-gb/windows/microsoft-edge-browsing-data-and-privacy-bb8174ba-9d73-dcf2-9b4a-c582b4e640dd (Edge).
14.2
Blocking all cookies will have a negative impact upon the usability of many websites.
15.
Amendments
15.1
We may update this policy from time to time by publishing a new version on our website.
16.
Our details
16.1
This website is owned and operated by Arif Rampuri trading as Showtime Photo Booth.
16.2
Our principal place of business is at 43-51 New North Road, London N1 6LW.
16.3
You can contact us:
(a)
by post, to the postal address given above;
(b)
using our website contact form; or
(c)
by email, using the email address published on our website.
17.
Data protection registration
17.1
We are registered as a data controller with the UK Information Commissioner’s Office.
17.2
Our data protection registration number is ZB223976