FotoGoto.com

Data Protection Policy

(Rev 1.1 01/08/2023)

Address:    

1st Floor, The Old Printworks, Birley Street, Kirkham, Preston PR4 2AT

Email:

info@fotogoto.com

Personal Data Description

Processing reason

Legal Condition or Basis for processing

Customer’s (or prospective customer’s) name and email address.

Informing the Customer about specific products that we would like to offer them

Protection of the business from financial risk; provision of applicable discounts and benefits; keeping of mandatory financial records.

Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract

Art 6 (1) b)

Processing is necessary for compliance with a legal obligation to which the controller is subject (for example, contractual obligations, or financial and auditing regulations)

Art 6 (1) c)

Processing is necessary for the purposes of our legitimate interests -in providing services including customer service, protecting the business and maintaining and providing a secure environment

Art 6 (1) f)

Processing is necessary for the purposes of our legitimate interests - training development and quality purposes

Art 6 (1) f)

Personal appearance and behaviour (all customers and users of and other visitors to a facility)

Collection and monitoring of sporting event related images for the purpose of delivering digital and physical products related to event photography, as well as for the monitoring of staff when carrying out work duties; to facilitate in the management and support of staff, and for security / crime prevention purposes

Maintaining and providing a secure environment

Art 6 (1) f)

Processing is necessary for the purposes of our legitimate interests - protection and management of business risks and the legitimate interests of third parties

Art 6 (1) f)

Name, email address, gender, phone number, preferred method of contact and marketing preferences

For receiving promotions and marketing, including newsletters, bulletins and mailouts.

Consent – you have given consent to the processing of your personal data for one or more specific purpose

Art 6 (1) a)

Name, contact details, event details and services required

To pass to our preferred suppliers of event services for the Customer to contract with if they wish.

Consent – you have given consent to the processing of your personal data for one or more specific purpose

Art 6 (1) a)

Photograph, location, name

Publicity, competition result, promotion to be published in hard format or online or on social media

Consent – you have given consent to the processing of your personal data for one or more specific purpose

Art 6 (1) a)

Special Category Data                          

Processing

Legal Condition or Basis for processing – Article 9 condition required

Biometric data – facial measurements taken from images (participants and spectators at mass participation sports events) and/or from “selfie” photos taken by users and uploaded to our website.

Used to uniquely identify an individual, in order to deliver the services to them. Further information on this process is provided under "Facial Recognition" below.

Processing is necessary for the purposes of the legitimate interests pursued by FGT – to provide quick, safe and efficient product delivery

Art 6 (1) f)

Explicit consent will be requested Art 9 (2) a)

You may withdraw your consent to the processing of the personal data and Special Category Data in this section at any time. Please see s11.

Essential Cookies

For the full functional use of our websites we use essential cookies to
1. record the user's permission (if given) to allow cookies
2. record whether the user has seen the pop-up inviting them to take our customer survey

Performance Cookies

For Web statistic analysis – to track usage patterns and deliver customised content to our users

Data and from whom/where

Processing

Legal Condition or Basis for processing

Data

Name, Address, Contact details (telephone number(s)), date of birth, bank details, photographic images, marketing preferences, detail of event entry/ies

For the purposes of identifying customers and notifying them of offers or products

Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract

Art 6 (1) b)

Processing is necessary for the purposes of our legitimate interests - in providing services including customer service

Art 6 (1) f)

Data

How it is stored

Paper / hard copy personal data

In an appropriately secure manner and location with appropriately controlled access

Electronic personal data

On an appropriately secure server with appropriately controlled access or in a cloud storage facility within the UK managed by an approved third party contractor.

Biometric Data

Is indexed with AWS and stored in accordance with AWS's data privacy policy which can be found via: https://aws.amazon.com/compliance/data-privacy-faq/. FGT does not store any biometric data.

Data

Retention Principle

All personal data

Data is processed and stored only as long as it is needed for the purpose for which it was collected, subject to the following overriding principles:

1.where legal obligations require us to keep the information for longer or for a specified period

2.until the expiry of any limitation period in relation to potential claims against FGT

3.until the expiry of a reasonable period of time in relation to potential complaints or claims against FGT

4.

FGT has set out an internal protocol in relation to retention periods which takes account of the obligation to keep data only for as long as it is needed as well as all statutory or other legal obligations regarding the retention of such records.

1.   The right to be informed about who is controlling your data, how, and for what purpose they intend to process the data, with whom they may share the data, and for how long they will keep the data. Full information is at :

RIGHT TO BE INFORMED

All of these are summarised within this Privacy Notice and full details are available on the ICO website here:

RIGHT TO BE INFORMED

2.   The right of access – you have the right to receive confirmation that your data is being processed. You also have the right to access your personal data in order to verify the lawfulness of the processing.

You can contact us at info@fotogoto.com to request access to your data.

3.   The right to rectification – you can ask for inaccurate or incomplete personal data to be rectified.

If we decline to meet your request, we will explain why, and remind you of your right to complain to the Information Commissioner’s Office or ultimately seek a judicial remedy.

4.   The right to erasure or the right to be forgotten – you can ask for your personal data to be deleted or removed in specific circumstances.

We will only store and process data that is specifically required for genuine and proper business reasons and for the protection of our business from financial risk and only for the appropriate length of time.

5.   The right to restrict processing – you can ask us to “block” or suppress the processing of your personal data circumstances.

We will restrict processing of your personal data as requested unless we cannot do so for legal reasons

6.   The right to data portability – this allows you to obtain and re-use certain elements of your personal data for your own purposes across different services; it allows you to move copy or transfer your data easily from one IT environment to another in a safe and secure way, without hindering its usability.

If we are going to decline your request, we will within one month of the request explain to you why not and will inform you of your right to complain to the Information Commissioner’s Office, and your right to a judicial remedy.

7.   The right to object – you have the right to object to certain types of processing, or processing for specific reasons.

           i.       processing based on “legitimate interests” or “the performance of a task in the public interest/exercise of official authority (including profiling) on grounds relating to your particular situation;

 

          ii.       to direct marketing (including profiling);

         iii.       and to processing for purposes of scientific/historical research and statistics on grounds relating to your particular situation;

We will comply with your request to stop processing your data in accordance with the requirements and provisions set out here:

  i.       if you notify us of the grounds of objection specific to your situation we will stop processing the personal data unless:

a.   we can demonstrate compelling legitimate grounds for the processing, which override your interests, rights and freedoms; or

b.   the processing is for the establishment, exercise or defence of legal claims.

 ii.       We will, without delay and free of charge, stop processing personal data for direct marketing purposes as soon as we receive an objection.

iii.       if you notify us of the grounds of objection specific to your situation we will stop processing the personal data unless we are conducting research where the processing of personal data is necessary for the performance of a public interest task.

8.   Rights in relation to automated decision making and profiling – you have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects, or which similarly significantly affects you. 

We use or may use in the future automated decision making in the form of Facial Recognition Software for controlling access to our facilities and services. We may profile personal data and sometimes special category data for the purposes of marketing and promotion where individuals have opted into receiving this. You can ask for us to stop sending you marketing information by contacting photos@FGTadventure.com

Position:

Data Protection Officer

Date:

1^st August 2023

Due for Review by:

1^st August 2024