1. INTRODUCTION
This privacy notice provides you with details of how I collect and process your personal data through your use of our site www.kirstybowen.com including any information you may provide through my site when you purchase my services or sign up to my newsletter. Kirsty Bowen is the data controller and I am responsible for your personal data (referred to as “I”, “me” or “my” in this privacy notice). This policy complies with the DPA (Data Protection Act 1998) and the GDPR (General Data Protection Regulation) which came into effect from May 2018.

2. DATA I COLLECT ABOUT YOU
Personal Data: Personal data means any information capable of identifying an individual. It does not include anonymised data. I may process certain types of personal data about you as follows:

• Identity Data may include your first name, last name, username, marital status, title and gender.
• Contact Data may include your billing address, delivery address, email address and telephone numbers.
• Financial Data may include your bank account and payment card details.

• Transaction Data may include details about payments between me and other details of purchases made by you.
• Technical Data may include your IP addresses, browser type, time zone and location, operating system and platform and other technology on the devices you use to access my site.
• Profile Data may include your username and password, purchases or orders, your preferences, feedback and survey responses.
• Usage Data may include information about how you use our website, products and services.
• Marketing and Communications Data may include your preferences in receiving marketing communications from me and my third parties and your communication preferences.

Sensitive Data: I 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, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data.

Contractual Commitments: Where I am required to collect personal data by law, or under the terms of the contract between me and you. If you do not provide me with that data when requested, I may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide me with the requested data, I may have to cancel a product or service you have ordered but if I do, I will notify you at the time.

3. HOW I COLLECT YOUR PERSONAL DATA
I collect data about you through a variety of different methods including:

Direct Interactions: You may provide data by filling in forms on my site or by communicating with me by phone, email or otherwise, including when you:

• Order my Products Or Services;
• Create An Account On my Site;
• Request Resources Or Marketing Be Sent To You
• Send me Your Feedback

Automated Technologies Or Interactions: As you use my site, I may automatically collect Technical Data about your equipment, browsing actions and usage patterns. I collect this data by using cookies, server logs and web analytics. I may also receive Technical Data about you if you visit other websites that use my cookies. My web analytics are provided by Google Analytics which uses cookies to track visitor usage. The software will save a cookie to your device in order to track and monitor your engagement and usage of the website, but will not store, save or collect personal information. You can read Google’s privacy policy for further information.

4. HOW I USE YOUR PERSONAL DATA
I will only use your personal data when legally permitted. The most common uses of your personal data are:

• Where I need to perform the contract between me
• Where it is necessary for my legitimate interests and your interests and fundamental rights do not override those interests
• Where I need to comply with a legal or regulatory obligation.

Marketing Communications: You will receive marketing communications from me if you have requested information from me or purchased goods or services from me; or if you provided me with your details and ticked the box at the point of entry of your details for me to send you marketing communications. You can ask me or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by emailing me at hello@kirstybowen.com at any time. Where you opt out of receiving marketing communications, this will not apply to personal data provided to me as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

5. DISCLOSURES OF YOUR PERSONAL DATA
I may have to share your personal data with the parties set out below for the purposes set out in paragraph 4 above:

• Service providers who provide IT and system administration services
• Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.

I require all third parties to whom I transfer your data to respect the security of your personal data and to treat it in accordance with the law. I only allow such third parties to process your personal data for specified purposes and in accordance with my instructions. I currently share or store data with the following third parties:

• Client Management System (CMS) By Dubsado
• Client Photo Galleries By PicTime
• Schools Photo Galleries by GotPhotos

6. INTERNATIONAL TRANSFERS
I share your personal data within my business which sometimes involves transferring your data outside the European Economic Area. 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 I transfer your personal data out of the EEA, I do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:

I will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or Where I use certain service providers, I 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 Where I use providers based in the United States, I may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

If none of the above safeguards is available, I may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time. Please email me at hello@kirstybowen.com if you want further information on the specific mechanism used by me when transferring your personal data out of the EEA.

7. DATA SECURITY
I have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, I limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. I have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where I are legally required to do so.

8. DATA RETENTION
I will only retain your personal data for as long as necessary to fulfil the purposes I collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, I consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which I process your personal data and whether I can achieve those purposes through other means, and the applicable legal requirements. By law I have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes. In some circumstances you can ask me to delete your data: see below for further information. In some circumstances I may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case I may use this information indefinitely without further notice to you.

9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

If you wish to exercise any of the rights set out above, please email me at hello@kirstybowen.com You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, I may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.

10. CHANGES TO THIS PRIVACY POLICY
Kirsty Bowen Photography has the discretion to update this privacy policy at any time. I encourage you to frequently check this page for any changes to stay informed about how I are helping to protect the personal information I collect. You acknowledge and agree that it is your responsibility to review this privacy policy periodically and become aware of modifications.

11. YOUR ACCEPTANCE OF THESE TERMS
By using my website and services, you signify your acceptance of this policy. If you do not agree to this policy, please do not use our services. Your continued use of my site following the posting of changes to this policy will be deemed your acceptance of those changes.

12. CONTACTING ME
If you have any questions about my website or this Privacy Policy, please contact me by email at hello@kirstybowen.com Please ensure that your query is clear, particularly if it is a request for information about the data I hold about you.