1. Definitions and interpretation

In this Policy, the following terms shall have the following meanings:

“Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 13, below;

“Personal data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the General Data Protection Regulation 2016/679 (“GDPR”); and

“We/Us/Our” means the Directors of Mitchell-Armstrong Limited and authorised partners (company address: 94 Cambridge Road, Great Shelford, Cambridge CB22 5JS).

2. About us

2.1 We own and operate this Site.

2.2 Our Data Protection Officer is Claire Armstrong, contactable via email at info@mitchell-armstrong.com or by post at the address given above.

3. What this policy covers

This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

4. Your rights

4.1 As a data subject, you have the following rights under the GDPR, which this Policy and our use of personal data have been designed to uphold:

4.1.1 The right to be informed about our collection and use of personal data;

4.1.2 The right of access to the personal data we hold about you (see section 12);

4.1.3 The right to rectification if any personal data we hold about you is inaccurate or incomplete (please contact us using the details in section 14);

4.1.4 The right to be forgotten – i.e. the right to ask us to delete any personal data we hold about you (we only hold your personal data for a limited time, as explained in section 6 but if you would like us to delete it sooner, please contact us using the details in section 14);

4.1.5 The right to restrict (i.e. prevent) the processing of your personal data;

4.1.6 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);

4.1.7 The right to object to us using your personal data for particular purposes; and

4.1.8 Rights with respect to automated decision making and profiling.

4.2 If you have any cause for complaint about our use of your personal data, please contact us using the details provided in section 14 and we will do our best to solve the problem for you. If we are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.

4.3 For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens’ Advice Bureau.

5. Data collected by us

Depending upon your use of our Site, we may collect some or all of the following personal and non-personal data (please also see section 13 on our use of Cookies and similar technologies):

5.1 Name;

5.2 Address;

5.3 Contact information such as email addresses and telephone numbers;

5.4 Demographic information such as post code, preferences, and interests;

5.5 IP address;

5.6 Web browser type and version; and

5.7 Operating system.

6. How your data is used

6.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 7, below.

6.2 Our use of your personal data will always have a lawful basis, either because it is necessary for our performance of a contract with you, because you have consented to our use of your personal data (e.g. by subscribing to emails), or because it is in our legitimate interests. Specifically, we may use your data for the following purposes:

6.2.1 Providing and managing your access to our Site;

6.2.2 Personalising and tailoring your experience on our Site;

6.2.3 Supplying our services to you (please note that we require your personal data in order to enter into a contract with you);

6.2.4 Replying to emails from you;

6.2.5 Supplying you with emails that you have opted into (you may unsubscribe using the link at the bottom of each email or you may opt-out at any time by emailing us directly);

6.2.6 Analysing your use of our Site to enable us to continually improve our Site and your user experience.

6.3 With your permission and/or where permitted by law, we may also use your data for marketing purposes which may include contacting you by email with information, news and offers on our services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.

6.4 Third parties whose content appears on our Site may use third party Cookies, as detailed below in section 13. Please refer to section 13 for more information on controlling Cookies. Please note that we do not control the activities of such third parties, nor the data they collect and use, and we advise you to check the privacy policies of any such third parties.

6.5 You have the right to withdraw your consent to us using your personal data at any time, and to request that we delete it.

6.6 We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected.

7. Data processing

7.1 Type of data being processed:

Mitchell-Armstrong Limited provides photography services to clients as directed by the client. Electronic and hard copy images are provided for the purposes of marketing or print sales on behalf of the client.

7.2 Categories of data subject whose data will be processed:

Mitchell-Armstrong Limited captures photographic images of subjects as per instruction by the client.

7.3 Purpose of processing:

Mitchell-Armstrong captures images, as described above. These images remain the property of the client. The client can dictate whether Mitchell-Armstrong is eligible to house published photography (that used for promotional literature or website) within MA Ltd advertising spaces.

With the sale of photography, purchasers’ details are requested through the payment gateway, through Stripe. All email and personal data relating to purchase of photography (excluding payment card data), is securely stored on fulfilment of order, for Mitchell-Armstrong's accounting purposes.

7.4 Duration of processing:

Mitchell-Armstrong captures images, as described above, and these are kept electronically, off line, for up to one year, after which, and on an annual basis, images are deleted or as agreed with the client with their own privacy policy.

Mitchell-Armstrong Limited may act as commissioned photographers for clients, where images are captured in line with the client’s own privacy policy and agreement with parents/customers.

Captured images will be held on Our Site in accordance with instructions from the client. Once the image gallery for sale is ‘closed’ the images will be removed from Our Site and then remain the intellectual property of the client – unless otherwise stated or agreed by the customer.

Mitchell-Armstrong Limited may act as commissioned photographers for clients, where images are captured in line with the client’s own privacy policy and agreement with parents/customers.

8. How your data is stored

8.1 We only keep your personal data for as long as we need to in order to use it as described above in section 6, and/or for as long as we have your permission to keep it.

8.2 Data security is very important to us, and to protect your data we have taken suitable measures to safeguard and secure data collected through our Site.

9. When and how your data is shared

9.1 We may sometimes contract with other third parties to supply services to you on our behalf. These may include search engine facilities and sub-contractors. In some cases, these third parties may require access to some or all of your data. Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under the law.

9.2 We may compile statistics about the use of our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.

9.3 We may sometimes use third party data processors that are located outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where we transfer any personal data outside the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR.

9.4 In certain circumstances, we may be legally required to share certain data held by us, which may include your personal data, for example, where we are involved in legal proceedings, where we are complying with legal requirements, a court order, or a governmental authority.

10. If our business changes hands

10.1 We may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of our business. Any personal data that you have provided will, where it is relevant to any part of our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use that data only for the same purposes for which it was originally collected by us.

10.2 In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes.

11. How you can control your data

11.1 In addition to your rights under the GDPR, set out in section 4, when you submit personal data to us via email or via our Site, you may be given options to restrict our use of your data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails, at the point of providing your details and by contacting us).

11.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

12. Your right to withhold information

12.1 You may access certain areas of our Site without providing any data at all. However, to use all features and functions available on our Site you may be required to submit or allow for the collection of certain data.

12.2 You may restrict our use of Cookies. You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party Cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device. You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access our Site more quickly and efficiently.

13. How you can access your data

You have the right to ask for a copy of any of your personal data held by us (where such data is held). Please contact us for more details using the contact details below.

14. Our use of Cookies

14.1 Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of our Site and to provide and improve our services. All Cookies used by and on our Site are used in accordance with current Cookie Law.

14.2 Before Cookies are placed on your computer or device, you will be shown a pop-up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of our Site may not function fully or as intended.

14.3 Certain features of our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.

14.4 Our Site uses Squarespace Analytics. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how our Site is used. This, in turn, enables us to improve our Site and the services offered through it. You do not have to allow us to use these Cookies, however whilst our use of them does not pose any risk to your privacy or your safe use of our Site, it does enable us to continually improve our Site, making it a better and more useful experience for you.

14.5 From time to time, we run campaigns to reach our existing client audiences on Facebook. Facebook makes use of a pixel code, which sits on our Site and acts similarly to a cookie, in that it gives us information on how people coming from Facebook to our Site, are using our Site. Any data that passes through the Facebook pixel is “hashed” locally on the browser before it goes to the Facebook servers for matching. This hashing process turns your data into short encrypted messages that cannot be tampered with. They use these hashes to match pixel events with people on Facebook. Then Facebook deletes all matched and unmatched hashes immediately after the matching process ends. They do not collect or store any personally identifiable information on their servers. Facebook’s privacy policy is available at: https://www.facebook.com/about/privacy.

14.6 In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

14.7 You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access our Site more quickly and efficiently.

14.8 It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

15. Contacting us

If you have any questions about our Site or this Privacy Policy, please contact us by email info@mitchell-armstrong.com, by telephone on 07875 008510 or by post at 94 Cambridge Road, Great Shelford, Cambridge CB22 5JS. Please ensure that your query is clear, particularly if it is a request for information about the data we hold about you.

16. Changes to our Privacy Policy

We may change this Privacy Policy from time to time (for example, if the law changes). Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.