1.1 We are committed to safeguarding the privacy of our website visitors and our clients and customers.
1.2 This policy applies where we are acting as a data controller with respect to their personal data; 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 Eason Media Ltd, trading as Flight Artworks and Gary Eason Photography, and operating the website flightartworks.com (this site), with a blog at aerialcombat.co.uk.
2.1 This document was adapted from a template from SEQ Legal https://seqlegal.com
3. How we use your personal data
3.1 In this Section 3 we have set out:
(a) the general categories of personal data that we may process;
(b) the purposes for which we may process personal data;
(c) the legal bases of the processing.
3.2 We may process data about your use of our website and services ("usage data"). These 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 use. Sources of the usage data are PhotoDeck, Google Analytics and Facebook tracking. These data may be processed to analyse the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
3.3 We may process your account data ("account data"), the name and email address you supply if you create an account on our website, to operate the website, ensure its security, maintain back-ups of our databases and communicate with you. The legal basis for this processing is the performance of a contract between you and us, to provide the functionality of your account.
3.4 We may process information that you post for publication on our websites or blogs ("publication data"). The data may be processed for the purposes of enabling such publication and administering our business. The legal basis for this processing is our legitimate interests, namely the proper administration of our websites and business.
3.5 We may process information contained in any enquiry you submit to us regarding goods and/or services ("enquiry data"). This may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis 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.
3.6 We may process information relating to our customer relationships, including contact information ("relationship data"). These data may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer. The source of the data is you or your employer. The data may be processed for the purposes of managing our relationships with customers, communicating with them, keeping records of those communications and promoting our products and services. The legal basis for this processing is our legitimate interests, namely the proper management of our customer relationships.
3.7 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our websites ("transaction data"). The transaction data may include your contact details and the transaction details. These may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis 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 and our legitimate interests, namely the proper administration of our website and business.
3.8 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is our legitimate interests in promoting our products and services.
3.9 We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our websites will generate the metadata associated with communications made using the websites' contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our websites and business, and communications with users.
3.10 We may also process information from you to inform our picture captions and blog articles. The legal basis for this processing is the data protection exemption for journalistic, artistic, literary or academic purposes. However, it is our policy to be open and honest and to tell you when we wish to publish any information we have obtained from you.
3.11 We may process any of your personal data identified in this policy 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.
3.12 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
3.13 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary to comply with a legal obligation to which we are subject, or to protect your vital interests or the vital interests of another natural person.
3.14 Please do not supply any other person's personal data to us, unless we prompt you to do so. If you do need to provide a friend's address, please ensure you have their authorisation to do so.
4. Providing your personal data to others
4.1 We may disclose your personal data to our suppliers or subcontractors insofar as reasonably necessary to fulfil your orders of goods or services.
4.2 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, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4.3 Financial transactions relating to our website and services are handled by our payment services providers, Stripe and PayPal. We will share transaction data with them 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. We do not store your card numbers. You can find information about the payment services providers' privacy policies and practices at https://stripe.com/gb/privacy (Stripe) and https://www.paypal.com/uk/webapps/mpp/ua/privacy-prev (PayPal).
4.5 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, or for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
5. International transfers of your personal data
5.1 In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
5.2 The hosting facilities for our website are situated in a secure environment in OVH data centres in France, with an encrypted backup in Ireland - both within the EEA.
5.3 Email correspondence and some file storage is handled by Google, based in the USA and protected by the EU-US Privacy Shield. You can read more about this at: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/eu-us-privacy-shield_en
5.6 You acknowledge that personal data that you submit for publication through our website or blogs may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
6. Retaining and deleting personal data
6.1 This Section 6 sets out our data retention policies and procedure, 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 shall not be kept for longer than is necessary for that purpose.
6.3 We will retain your personal data as follows:
(a) Relationship and transaction data will be retained for a maximum period of seven years, to comply with the legal requirements of HMRC.
(b) Correspondence data may be retained indefinitely based on our assessment - for example, because of an ongoing dialogue with regular clients, or the likelihood of a repeat commission.
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.
7.1 We may update this policy from time to time by publishing a new version on our website.
7.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
7.3 We may notify you of significant changes to this policy by email, if you have consented to such communications.
8. Your rights
8.1 In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
8.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
8.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. If you have chosen to create an account on our website, you can access your personal data yourself by visiting your Profile at https://www.flightartworks.com/client and using the "Download my data" link. The data will be collected into a ZIP archive in a machine-readable format (JSON), as required by the General Data Protection Regulation. A link to download this will be e-mailed you once it is ready.
8.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
8.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
8.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
8.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
8.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
8.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
8.10 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
8.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
8.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
8.13 You may exercise any of your rights in relation to your personal data by written notice to us, in addition to the other methods specified in this Section 8.
10. Our details
10.1 This website and our blogs are owned and operated by Eason Media Ltd.
10.2 We are registered in England under company number 7248731. Our registered address is
14 Scarletts Road,
which is also our principal place of business.
10.3 You can contact us:
(a) by post, to the postal address given above;
(b) using our website contact form at https://www.flightartworks.com/contact;
(c) by telephone, on the number published on the same contact page; or
(d) by email, using the address firstname.lastname@example.org.