1.  Introduction

1. We are committed to safeguarding the privacy of our website users, our customers and our personnel.  In this policy we explain how we will handle your personal data.
2. We process ONLY the bare minimum of visitor data - just enough to keep the website running reliably and the business operational.  We do not engage in any direct tracking of visitors or use of your data for anything you haven't explicitly or implicitly consented to, signed up for, or given to us so that we can provide the services you have requested.
3. We will NEVER sell your data to third parties!  Ever!!
4. None of the data captured here makes you personally identifiable to us.  You will have to get in touch personally or link directly to us on social media before we have any chance of knowing who you are.
5. This policy applies to all Will Smith Photographer websites and services.

2.  How we use your personal data

1. In this section we have set out:
   1. the general categories of personal data that we may process;
   2. in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
   3. the purposes for which we may process personal data;
   4. the legal bases of the processing.
2. We use 'Google Analytics' for the purposes of analysing the use of our websites and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our websites and services.  Google processes usage data and provides us with broad usage data.  E.g. we do not have access to individually identifiable data points and cannot tie any individual actions to any individual visitor.
3. We may process your website account data (only if you have been given a Will Smith Photographer user account).  Only website administrators and a handful of long-term customers have accounts, and if you didn't enter a username and password to access special features of this website, this does not concern you. The account data may be processed for the purposes of operating our websites, providing our services, ensuring the security of our websites and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our websites and business.
4. We may process your personal data incorporated into communications and messages that you send to us in the course of the use of our services (known as "service data"). The service data may be processed for the purposes of providing our services to you, ensuring the security of our websites and services, maintaining back-ups of our databases and communicating with you.  For example:  If you send us a message, we will process that information solely in order to reply back to you and effectively provide the services that you have requested. The legal basis for this processing is our legitimate interests, namely the proper administration of our websites and business.
5. We may process information, images and other content that you intentionally provide for publication on our websites or through our services (known as "publication data"). The publication data may be processed for the purposes of enabling such publication and administering our websites and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our websites and business.
6. We may process information relating to transactions, including purchases of products or services, that you enter into with us and/or through our websites ("transaction data"). The transaction data may be processed for the purpose of supplying the purchased 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 our interest in the proper administration of our websites and business.
7. We may process information that you provide to us for the purpose of subscribing to our newsletters and other notifications ("newsletter data"). The newsletter data may be processed for the purposes of sending you the newsletters and other notifications, and analysing their use. The legal basis for this processing is consent.
8. We may process information contained in or relating to any communication that you send to us by email or any similar communications system ("message data"). The message data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The message 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, prospective customers and customers.
9. We may process any of your personal data identified in the other provisions of 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.
10. In addition to the specific purposes for which we may process your personal data set out in this section, we may also process any of your personal data where such processing 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.

3.  Providing your personal data to others

1. We will NEVER sell your data to third parties!  Ever!
2. If you order physical products from us that require shipping direct from our trusted manufacturers, we may provide them with the necessary information so that they can ship your products to you at the address you provided us.
3. If you request that we engage third party support to achieve the requested works, we may provide them only with the information they need to provide their quote, deliverables or services.  For example:  If you require a second photographer or support staff to be on site for a photoshoot, we may provide them with relevant dates, locations, timings and other information so they can fulfil their requirements to your satisfaction.
4. We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and managing legal disputes.
5. Financial transactions relating to our websites and services are handled by our payment services provider, PayPal. We will share transaction data with our payment services providers 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. You can find information about PayPal's privacy policies and practices at https://www.paypal.com/en/webapps/mpp/ua/privacy-full.
6. In addition to the specific disclosures of personal data set out in this section, we may also 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.

4.  Amendments

1. We may update this policy from time to time by publishing a new version on our website.
2. We may notify you of significant changes to this policy by email.

5.  Third party websites

1. Our websites includes hyperlinks to, and details of, third party websites.
2. We have no control over, and are not responsible for, the privacy policies and practices of third parties.

6.  Updating information

1. Please let us know if the personal information that we hold about you needs to be corrected or updated.

7.  Acting as a data processor

1. In respect of personal data which falls within the scope of any data processing contract that we have entered into, we do not act as a controller of that personal data; instead, we act as a processor of that personal data.
2. Insofar as we act as a processor rather than a controller, this policy shall not apply. Our legal obligations as a processor are instead set out in the contract between us and the relevant controller.  For example:  We use Google Analytics to keep our website running smoothly and let us know when web traffic is heavy  -  We had to accept their terms and conditions for this service and they control any data transmitted as part of the provision of the Google Analytics service.

8.  About cookies

1. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
2. Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
3. For example:
   
   1. Without persistent cookies, sites like Facebook would require you to log in for every visit, rather than being able to remember you.
   2. Without session cookies, sites like Facebook would require you to log in again for each and every single page you visited on the site.
4. Cookies do not typically contain any information that personally identifies a user.  They are tags that usually permit a specific web browser to be remembered on a repeat visit to a website.
5. Cookies are stored on your computer or device, via your chosen web browser.  They are not stored on our servers and we have no visibility of them whatsoever - we cannot provide them to you on request.  You can delete or disable your cookies at any time using your browser menus and settings on your device.  For more information, see "Managing cookies" below.

9.  Cookies that we use

1. We use cookies for the following purposes:
   1. Shopping cart - we use cookies to maintain the state of shopping carts as you store items, progress with any purchases and navigate our websites;
   2. Security - we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our websites and services generally;
   3. Analysis - we use cookies to help us to analyse the performance, usage and reliability of this website in order to provide the best possible service to visitors;
   4. Authentication (not applicable unless you have an account with us) - we use cookies to identify you when you log in to your account and keep your session alive as you navigate our websites;
   5. Personalisation - if you use any options to customise your experience with us, we use cookies to store information about your preferences and to personalise our websites for you.
   6. The 'cookie notice' at the bottom of the page - somewhat ironically whenever you click 'Accept' on a cookie notice (on any website), a cookie has to be stored so that your browser doesn't ask you the same question again every time you view a new page.

10.  Cookies used by our service providers

1. We use Google Analytics to analyse the use of our website and make improvements for our visitors. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our websites is used to create reports about the use of our website. Google's privacy policy is available at: https://www.google.com/policies/privacy/.

11.  Managing cookies

1. Most browsers allow you to refuse to accept cookies and to delete existing cookies. The methods for doing so vary from browser to browser, and from version to version. You can find out about blocking and deleting cookies via these links:
   1. https://support.google.com/chrome/answer/95647?hl=en (Chrome);
   2. https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
   3. http://www.opera.com/help/tutorials/security/cookies (Opera);
   4. https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
   5. https://support.apple.com/kb/PH21411 (Safari);
   6. https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
2. NOTE:  You can block all cookies and still get a very high level of service from this site.  However, if you login to an account or try to use the shopping cart, the website will forget who you are and what you were doing every time you tap a new link.