Privacy Policy

Introduction

sparkpassage-base Ltd ("we", "our", or "us") is committed to protecting and respecting your privacy. This policy explains how we collect, use, and safeguard personal information when you interact with our photography services or visit our website.

We operate under the laws of England and Wales and comply with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. Your privacy matters to us, and we take our responsibilities regarding your personal data seriously.

Information We Collect

We may collect and process the following categories of personal information:

Information You Provide Directly

• Contact details including your name, email address, and postal address
• Information provided when enquiring about or booking our services
• Photographs and visual materials created during sessions
• Payment and billing information necessary to process transactions
• Correspondence and communications you send to us
• Preferences and requirements you share regarding your photography project

Information Collected Automatically

• Technical data such as IP address, browser type, and operating system
• Usage data including pages visited and time spent on our website
• Cookie data as detailed in our separate Cookies Policy

How We Use Your Information

We process your personal data for the following purposes:

• To provide photography services you have requested
• To respond to enquiries and communicate about bookings
• To process payments and maintain financial records
• To deliver and provide access to your photographs
• To improve our services and website functionality
• To comply with legal obligations and protect our legitimate interests
• To send service updates and, where you have opted in, marketing communications

Legal Basis for Processing

We rely on the following legal grounds to process your personal information:

• Contract: Processing necessary to fulfil our contractual obligations to you
• Legitimate interests: Where processing is necessary for our legitimate business interests, provided these do not override your rights
• Consent: Where you have given explicit consent, particularly for marketing communications and certain uses of photographs
• Legal obligation: Where we must comply with legal requirements

Photographs and Image Rights

Photographs created during sessions constitute personal data and are treated with particular care. The specific terms regarding photograph usage, including any portfolio or promotional use, are addressed in individual client agreements signed before each project.

We will never use your photographs for purposes beyond what has been agreed without obtaining additional consent. Requests to remove images from any promotional materials will be honoured promptly.

Data Sharing and Third Parties

We may share your personal information with:

• Professional printing and framing services when you order physical products
• Payment processors to complete transactions securely
• Cloud storage providers for secure file delivery and backup
• Professional advisers including accountants and legal counsel
• Law enforcement or regulatory bodies when required by law

We do not sell your personal information to third parties. Any service providers we work with are contractually bound to process your data only as instructed and maintain appropriate security measures.

Data Retention

We retain personal information only for as long as necessary to fulfil the purposes for which it was collected:

• Client project files and photographs: Minimum two years from delivery
• Financial records: Seven years as required for tax purposes
• Email correspondence: Three years from last contact
• Marketing consent records: Until consent is withdrawn

Upon request, we can provide more specific information about retention periods applicable to your data.

Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include:

• Encrypted file transfer and storage systems
• Password-protected client galleries
• Regular security assessments of our systems
• Limited access to personal data on a need-to-know basis
• Secure backup procedures

Your Rights

Under data protection legislation, you have the right to:

• Request access to your personal data
• Request correction of inaccurate data
• Request erasure of your data in certain circumstances
• Object to processing based on legitimate interests
• Request restriction of processing
• Request data portability
• Withdraw consent where processing is based on consent

To exercise any of these rights, please contact us at the details provided below. We will respond to requests within one month.

International Transfers

Your personal data is primarily processed within the United Kingdom. Where data is transferred outside the UK, we ensure appropriate safeguards are in place, such as standard contractual clauses approved by the Information Commissioner's Office.

Changes to This Policy

We may update this privacy policy periodically to reflect changes in our practices or legal requirements. Material changes will be communicated through our website or direct notification where appropriate. We encourage you to review this policy regularly.

Contact and Complaints

For questions about this privacy policy or to exercise your data rights, contact us at:

If you are dissatisfied with our response to any privacy concern, you have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk.