We are the controller and responsible for your personal data. As organisers and producers of Photo London, we operate both the website with URL www.candlestar.co.uk and the website with URL www.photolondon.org (together “ Our Websites”).
|We, us, our||Candlestar Limited Registered No. 04858030
|Our Data Protection Office||Jakub Wawrzacz
0784 134 2980 / 0207 759 1170
|Personal data||Any information relating to an identified or identifiable individual|
It is important that the personal data we hold about you is accurate and current, so please keep us informed if your personal data changes during your relationship with us.
Personal data we collect about you
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data which includes first name, last name, username or similar identifier, title, date of birth
- Contact Data includes billing address, delivery address, email address and telephone numbers
- Financial Data includes bank account and payment card details
- Profile Data includes your username and password, purchases or orders made by you
- Marketing and Communications Data includes your preferences in receiving marketing information from us and our third party agents and your communication preferences
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone, setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.
- Any other information which you provide to us.
We do not collect any special categories of personal data (which include sensitive personal information such as details about your race, ethnicity, religious beliefs, political affiliation and sexual orientation).
How your personal data is collected
We collect most of this information from you directly, for example, Identity Data, Contact Data, Financial Data and Transaction Data when you fill in forms, correspond with us by email, phone, post or otherwise when you:
- subscribe to services or create an account on our website
- purchase products and/or services from us
- subscribe to our publications, such as our e-newsletter
- request marketing, promotional material or information to be sent to you
- enter a competition, promotion or survey; or
- give us some feedback.
However, we may also collect information from
- publicly accessible sources, such as Companies House
- providers of technical, payment and delivery services, such as PayPal or DHL
- analytics providers [such as Google, based outside the EU]
- a third party with your consent (e.g. your bank).
How and why we use your personal information
Under Data Protection Law, we can only use your personal data if we have proper reason for doing so, eg:
- to comply with our legal and regulatory obligations
- for the performance of our contract with you or to take steps at your request before entering into a contract
- for our legitimate interests or those of a third party; or
- you have given consent
A legitimate interest is when we have a business or commercial reason to use your information, provided this is not overridden by your own rights and interests.
The table below explains what we use (process) your personal data for and our reasons for doing so:
|What we use your personal data for||Type of Data||Our reasons|
|To register you as a new customer||Identity
|Performance of a contract with you|
|To provide our products and services to you including:
|For the performance of our contract with you or to take steps at your request before entering into a contract
Necessary for our legitimate interests (to recover debts due to us)
|To manage our relationship with you which will include:
Marketing & Communications
|For the performance of our contract with you
Necessary to comply with a legal obligation
For our legitimate interests or those of a third party (to give customers necessary information to enable them to use our products/services, to obtain customer feedback and learn how customers use our products and services)
|Promoting our services and those of selected third parties to:
Marketing & Communications
|For our legitimate interests or those of a third party (to develop our products and services, and grow our business)|
|To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
To ensure business policies are adhered to, e.g. policies covering security and internet use
To ensure the confidentiality of commercially sensitive information
|For our legitimate interests or those of a third party (for running our business and network security).
To comply with our legal and regulatory obligations
|To professional advisers and to external auditors for the audit of our accounts||Identity
|To comply with our legal and regulatory obligations|
We will only use your data for purposes for which we collected it, unless we reasonably consider that we need to use it for another reason, and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will inform you and explain the legal basis which allows us to do so.
We may use your personal data to send you updates (by email, telephone or post) about our events, courses and exhibitions that might be of interest to you and/or information about our services, including our e-newsletter, which may contain exclusive offers and promotions.
We have a legitimate interest in processing your personal data for promotional purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal data with the utmost respect and never share it with other organisations for marketing purposes unless we have your express prior consent to do so.
You have the right to opt-out of receiving promotional communications at any time by contacting us by email to firstname.lastname@example.org.
We may ask you to confirm or update your marketing preferences if you purchase products or services from us, or subscribe to our e-newsletter, or request updates or information about our products and services in the future, or if there are changes in the law or the structure of our business.
Who we share your personal data with
In addition to the disclosures reasonably necessary for the purposes identified elsewhere above, we may disclose your personal information to the extent that we are required to do so by law, in connection with any legal proceedings or prospective legal proceedings, and in order to establish, exercise or defend our legal rights.
We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal data with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
Where your personal data is held
Information may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above (see ‘Who we share your personal data with’).
Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal data when this occurs, see below: ‘Transferring your personal data out of the EEA’.
How long your personal data will be kept
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
For example, if we have collected your personal data because you are a customer of our products or services, by law we have to keep basic information about you (including Contact, Identity, Financial and certain Transaction Data for six years after you cease being a customer for tax purposes).
To determine the appropriate retention period for personal data, we 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 we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. We will conduct regular reviews of the personal data we are holding and delete any data we no longer require.
Transferring your personal data out of the EEA
To deliver services to you, it is sometimes necessary for us to share your personal data outside the European Economic Area (EEA), eg:
with your and our service providers located outside the EEA;
if you are based outside the EEA;
These transfers are subject to special rules under European and UK data protection law.
If you would like further information, please contact us (see ‘How to contact us’ below).
You have the following rights, which you can exercise free of charge:
|Access||The right to be provided with a copy of your personal data (the right of access)|
|Rectification||The right to require us to correct any mistakes in your personal data|
|To be forgotten||The right to require us to delete your personal data in certain situations|
|Restriction of processing||The right to require us to restrict processing of your personal data in certain circumstances, e.g. if you contest the accuracy of the data|
|Data portability||The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party in certain situations|
|To object||The right to object:
|Not to be subject to automated individual decision-making||The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you|
For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.
- If you would like to exercise any of those rights, please:
- email, call or write to our data protection manager—see below: ‘How to contact us’; and
- let us have enough information to identify you (e.g. your full name, address and client reference number);
- let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
- let us know what right you want to exercise and the information to which your request relates.
Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Updating this statement
Our Websites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy policies.
How to contact us
- by email to email@example.com
- by post to Candlestar Limited, Somerset House, Strand, London, WC2R 1LA
- by phone to the Office Manager: 0207 759 1170
How to complain
We hope that we can resolve any query or concern you may raise about our use of your information. You have the right to make a complaint at any time to the Information Commissioner’s Officer (ICO), the UK Supervisory Authority for data protection issues: https://ico.org.uk/. We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.