We are committed to safeguarding the privacy of our website visitors and customers; in this policy we explain how we will handle your personal data.
2. How we use your personal data
In this Section 2 we have set out:
- the general categories of personal data that we may process;
- the purposes for which we may process personal data; and
- the legal bases of the processing.
We may process data about your use of our website and services ("usage data"). The usage data 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 service use. The source of the usage data is Google Analytics. This usage data may be processed for the purposes of analysing 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.
We may process information that you post for publication on our website or through our services ("publication data"). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is consent.
We may process information contained in any enquiry you submit to us regarding products and/or services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and selling relevant products and/or services to you. The legal basis for this processing is consent.
We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website ("transaction data"). The transaction data may include your contact details, your card details and the transaction details. The transaction data 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 our interest in the proper administration of our website and business.
We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters.
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 website will generate the metadata associated with communications made using the website 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 website and business and communications with users.
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.
In addition to the specific purposes for which we may process your personal data set out in this Section 2, 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
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.
We may disclose transaction data to our subcontractors insofar as reasonably necessary to allow them to perform the services they provide to us.
Financial transactions relating to our website and services are handled by our payment services provider, Stripe. 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 the payment services providers' privacy policies and practices at https://stripe.com/gb/privacy.
In addition to the specific disclosures of personal data set out in this Section 3, 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. International transfers of your personal data
In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
The hosting facilities for our website are situated in Belgium, within the EEA. Our website is managed by Artlogic. Artlogic uses the latest cloud infrastructure to protect data. It is atomised and encrypted across a sophisticated cloud system that is fully resilient. The data is encrypted in transit using 256 bit TLS v1.1 or v1.2.
Our payment services provider Stripe has certified to the EU-US and Swiss-US Privacy Shield and has international data transfer compliance measures in place governing all of Stripe’s global entities’ processing of the personal data of EU individuals. These measures are based on the EU Standard Contractual Clauses.
Our cloud storage is provided by Google and Apple. Google’s certification under the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks includes G Suite and Google Cloud Platform. Google’s model contract clauses and current contractual commitments for G Suite and Google Cloud Platform fully meet the requirements under the Data Protection Directive to legally frame transfers of personal data from the EU to the rest of the world. Apple uses approved Model Contractual Clauses for the international transfer of personal information collected in the European Economic Area and Switzerland. Personal information regarding individuals who reside in a member state of the European Economic Area and Switzerland is controlled by Apple Distribution International in Ireland, and processed on its behalf by Apple Inc. iCloud secures information by encrypting it when it's in transit and storing it in iCloud in an encrypted format using a minimum of 128-bit AES encryption.
You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
5. Retaining and deleting personal data
This Section 5 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.
Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
We will retain and delete your personal data as follows:
- Usage data will be retained for 50 months, at the end of which period it will be deleted from our systems.
- Enquiry and correspondence data will be retained for 50 months, following the last date of enquiry or communication, at the end of which period it will be deleted from our systems.
- Transaction data will be retained indefinitely for historical records and to enable us to deal with any authenticity issues, complaints or legal claims you may raise in the future.
In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:
- the period of retention ofnotification data will be determined based on how long you do not opt out of receiving marketing communications from us. If you opt out from marketing, we will retain your data to enable us to stop including you in future direct marketing activities.
- Publication data will be retained for as long as our website is live, after which period it will be deleted from our systems.
Notwithstanding the other provisions of this Section 5, 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.
We may update this policy from time to time by publishing a new version on our website.
You should check this page occasionally to ensure you are happy with any changes to this policy.
7. Your rights
You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:
- the payment of a fee currently fixed at GBP 10; and
- the supply of appropriate evidence of your identity for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address.
We may withhold personal information that you request to the extent permitted by law.
You may instruct us at any time not to process your personal information for marketing purposes.
In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.
8. Third party websites
Our website includes hyperlinks to, and details of, third party websites. We have no control over, and are not responsible for, the privacy policies and practices of third parties.
9. Personal data of children
Our website and services are targeted at persons over the age of 13. If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
10. Updating information
Please let us know if the personal information that we hold about you needs to be corrected or updated.
11. About cookies
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.
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.
Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
12. Cookies that we use
13. Cookies used by our service providers
14. Managing cookies
Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
- https://support.google.com/chrome/answer/95647?hl=en (Chrome);
- https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
- http://www.opera.com/help/tutorials/security/cookies/ (Opera);
- https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
- https://support.apple.com/kb/PH21411 (Safari); and
- https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
Blocking all cookies will have a negative impact upon the usability of many websites. If you block cookies, you will not be able to use all the features on our website.
15. Our details
This website is owned and operated by Rock Paper Film Limited.
We are registered in England and Wales under registration number 10816464, and our registered office is at 15 Montpelier Terrace, Ilfracombe, Devon, EX34 9HR.
You can contact us:
- using our website contact form;
- by telephone, on the contact number published on our website from time to time; or
- by email, using the email address published on our website from time to time.