WHO IS RESPONSIBLE FOR YOUR INFORMATION?
Adept Imagery is the trading name of James Robinson, a sole trader.
For data-protection purposes, James Robinson trading as Adept Imagery is the controller of the personal information described in this policy.
Contact details:
Adept Imagery
James Robinson
Lynwood, Shinehill Lane, South Littleton, Evesham, WR11 8TP
Email: James@adeptimagery.co.uk
Telephone: 07853 338332
If you have a question about this policy or how your information is used, contact James using the details above.
WHAT INFORMATION DO I COLLECT?
The information collected depends on how you interact with Adept Imagery.
WEBSITE ENQUIRIES
This can include your name and your partner’s name.
It can include your email address and, if supplied, your telephone number.
It can include your wedding date, venue and ceremony time.
It can include the collection or amount of coverage you are considering.
It can include information you choose to provide about the wedding.
It can include how you found Adept Imagery.
It can include the page used to submit the form.
It can include campaign or Google Ads information available when the form is submitted.
It can include the date and time of submission.
It can include technical and security information needed to operate and protect the form.
BOOKED CLIENTS
This can include contact, correspondence and billing details.
It can include contract, booking-payment, balance-payment and invoice records.
It can include the wedding date, timetable, locations and access information.
It can include names and relationships used to plan family photographs.
It can include emergency contact details.
It can include questionnaire answers, meeting notes and client instructions.
It can include album choices, print orders, delivery addresses and design approvals.
It can include photographs made as part of the contracted service.
WEDDING GUESTS, SUPPLIERS AND OTHER PEOPLE PHOTOGRAPHED
Wedding galleries naturally contain guests, suppliers and other people attending or working at the event. Photographs may also include children and may reveal information through the context of the wedding, such as family relationships, religion, disability or sexual orientation.
I do not use facial recognition or process photographs to identify biometric characteristics.
LIMITED SAFETY AND ACCESSIBILITY INFORMATION
I do not routinely collect medical information. Occasionally, a couple may verbally provide a minimum amount of information that directly affects safety or accessibility, such as an instruction not to use flash near a guest with photosensitive epilepsy or a note that a guest uses a wheelchair.
The person may be identified by a first name or relationship to the couple. The information is handwritten on the wedding-day sheet, is not entered into a digital system and is shredded after the wedding. I use it only to manage the immediate safety or accessibility requirement.
GALLERY VISITORS AND PRINT CUSTOMERS
Pic-Time requires a gallery visitor to provide an email address before accessing a gallery. I may be able to see that address if the visitor interacts with the gallery, for example by favouriting photographs. I do not export or use gallery-visitor details for my own marketing.
If somebody orders a print or product, the information can also include their name, delivery address, order details, selected photographs and payment information. Adept Imagery does not receive or store the complete card number.
WEBSITE USE
Depending on your cookie choices, the website may collect your IP address and approximate location.
It may collect information about your browser, device and operating system.
It may collect information about the pages you view and the actions you take.
It may collect your referral source and campaign information.
It may collect your cookie preferences and enquiry-conversion information.
The Cookie Policy explains the technologies currently in use.
WHERE DOES THE INFORMATION COME FROM?
Most information comes directly from you through the website form, email, WhatsApp Business, telephone, Zoom or WhatsApp video calls, questionnaires, meetings, contracts, galleries and orders. Video calls are not recorded.
Some information may be supplied by your partner, venue, wedding planner or another person involved in organising the wedding. Family names, group details and practical guest information are normally provided by the couple.
Technical website information may be collected by the website host, Google Analytics, Google Ads, CookieYes and security services, subject to your cookie choices where required.
WHY DO I USE THE INFORMATION, AND WHAT IS THE LAWFUL BASIS?
TO ANSWER ENQUIRIES AND PREPARE A BOOKING
I use enquiry details to check availability, understand the service requested, answer questions and provide relevant pricing or a quote.
Lawful basis: taking steps at your request before entering into a contract and legitimate interests in operating the business and responding to genuine enquiries.
TO PROVIDE THE CONTRACTED PHOTOGRAPHY SERVICE
I use client, timetable, venue, family, correspondence and payment information to plan and photograph the wedding, communicate with you, deliver the gallery, produce requested products and manage the agreement.
Lawful basis: performance of a contract and taking steps connected with that contract.
TO PHOTOGRAPH THE WEDDING AND DELIVER A COMPLETE GALLERY
Wedding guests and suppliers may appear in photographs made as part of the service requested by the couple.
Lawful basis: legitimate interests in providing a complete professional record of the wedding and performing the contracted service for the clients. Those interests are balanced against the reasonable expectations and rights of the people attending.
If you are a guest with a particular concern about being photographed, speak to me or the couple so the request can be considered practically.
TO USE SELECTED PHOTOGRAPHS FOR PROMOTION
The client agreement permits Adept Imagery to use selected photographs for promotional purposes unless the clients request otherwise in writing. This can include the Adept Imagery website, social media, advertising, directories, competitions, sample albums, blog or Real Wedding features and professional accreditation submissions.
Lawful basis: legitimate interests in showing the style and standard of my work, maintaining a professional portfolio and promoting the business. Promotional use is considered separately from copyright ownership and is subject to the rights of identifiable people.
Photographs containing children are not used for promotion by default. If I want to publish one, I normally email the child’s parent and retain their written permission.
Clients can opt out in writing before publication. Anybody shown in a photograph can also object to further promotional use. I will consider the circumstances, stop future use and remove the photograph from websites and accounts under my control where appropriate, unless there is a compelling lawful reason to retain a particular use.
Removal cannot guarantee that an image disappears from search-engine caches, archives, downloads, printed material, shares or copies already republished by somebody else.
TO SHARE PHOTOGRAPHS WITH VENUES AND SUPPLIERS
Supplier sharing is not assumed under the general promotional clause. During the pre-wedding meeting, I ask the couple whether photographs may be supplied to their venue and wedding suppliers. Their answer is recorded in their VSCO Studio Manager customer file.
The couple’s recorded permission controls whether sharing takes place. For the couple’s instruction, I rely on consent. For identifiable people appearing in the selected photographs, I rely on legitimate interests in limited professional collaboration and promotion, balanced against their rights and reasonable expectations.
The couple can refuse or withdraw permission for future sharing. A later change does not make earlier lawful sharing unlawful and cannot retrieve copies already supplied. An independent venue or supplier is responsible for its own later use, so any removal request concerning its copy must also be made to that organisation.
TO OPERATE AND SECURE GALLERIES
Gallery-access emails help protect the gallery, operate favourites and allow orders to be linked to the correct visitor.
Lawful basis: legitimate interests in operating a secure and functional client gallery and performance of a contract where a visitor places an order.
TO SEND PIC-TIME GALLERY MARKETING
Marketing is separate from gallery access. The Pic-Time marketing box is optional and unticked by default. Only visitors who actively opt in receive automated gallery-related marketing emails. They can unsubscribe through the email or the available Pic-Time controls.
Lawful basis: consent. I do not use gallery visitors’ details for separate manual marketing.
TO MAINTAIN BUSINESS, ACCOUNTING AND LEGAL RECORDS
I keep contracts, essential instructions, invoices, payments, correspondence and relevant transaction information to administer the business, establish or defend legal claims and meet tax or other legal obligations.
Lawful basis: legal obligation and legitimate interests in keeping accurate business records and protecting legal rights.
TO PROTECT THE WEBSITE AND COMMUNICATIONS
Technical data and anti-spam or security services may be used to keep the website secure, prevent misuse and diagnose faults.
Lawful basis: legitimate interests in protecting the website, customers and business systems.
TO MEASURE WEBSITE PERFORMANCE AND ENQUIRIES
Where you accept the relevant cookies, Google Analytics helps me understand how visitors find and use the site. Google Ads conversion tracking measures whether an advertisement results in an enquiry. Enhanced conversions may send Google a securely hashed version of information such as an email address for conversion matching.
Google Ads is used for enquiry measurement, not remarketing audiences or personalised advertising.
Lawful basis: consent. You can reject or withdraw consent through CookieYes.
YOUR RIGHT TO OBJECT
You have the right to object where I rely on legitimate interests, including promotional use of identifiable photographs. I will consider the reasons for your objection and stop the relevant use unless there are compelling legitimate grounds to continue or the information is needed for legal claims.
The right to object to direct marketing is absolute. If you object to direct marketing, that use will stop.
To object, email [james@adeptimagery.co.uk](mailto:james@adeptimagery.co.uk) and identify the photograph, message or processing you are concerned about.
DO YOU HAVE TO PROVIDE THE INFORMATION?
You do not have to submit an enquiry. If you want to book, I need enough information to identify the clients, understand the wedding, prepare the contract, take payment and provide the service.
If necessary information is not supplied, I may be unable to confirm availability, enter into the agreement or complete a requested product.
WHO RECEIVES THE INFORMATION?
Information is shared only where needed for the service, business administration or legal obligations.
WEBSITE HOSTING AND MAINTENANCE
The website is maintained by The Curious using UK-hosted WordPress infrastructure. This can involve website logs and enquiry-form submissions.
BUSINESS EMAIL
Google Workspace and Gmail process enquiries, correspondence and attachments.
CLIENT MANAGEMENT
VSCO Studio Manager contains client details, contracts, questionnaires, permissions and correspondence.
ONLINE GALLERIES AND SHOP
Pic-Time processes photographs, gallery-access emails, favourites, orders and delivery details.
PHOTOGRAPHY BACKUP
Backblaze backs up active and archived photography files while the connected backup drives are available.
PAYMENTS
Square processes payment, transaction and fraud-prevention information.
ACCOUNTING
SRC Accountants and Xero process invoices, payments and accounting records.
PRINT FULFILMENT
Digitalab receives the order details, selected photographs, customer name and delivery address needed to produce and deliver an order.
ALBUM PRODUCTION
nPhoto receives selected photographs only. Albums are delivered to me before being sent to the client.
POSTAGE
Royal Mail Click & Drop receives the client’s first name and postal address.
CALLS AND MESSAGING
WhatsApp Business, its Google Drive backup and Zoom can process contact details, conversations and meeting information. Calls are not recorded.
WEBSITE MEASUREMENT
Google Analytics and Google Ads can process device, website-use, campaign and conversion information where the relevant cookies have been accepted.
COOKIE MANAGEMENT
CookieYes processes cookie choices and the consent record.
SOCIAL PUBLISHING AND EMBEDDED MEDIA
Facebook, Instagram and Google Business Profile may receive selected photographs and associated post information.
SECOND PHOTOGRAPHERS
Second photographers are used rarely. When one is required, they normally receive only the couple’s first names, the date and the locations needed to perform the work.
With the couple’s specific permission, selected photographs may be supplied to the wedding venue or suppliers. Those recipients become responsible for their own use of the copies they receive.
Information may also be shared with professional advisers, insurers, courts, regulators, law-enforcement bodies or public authorities where necessary or legally required.
I do not sell personal information.
INTERNATIONAL TRANSFERS
The website is hosted in the United Kingdom, but several technology providers operate internationally. Google, Pic-Time, Backblaze, Square, Meta, Zoom, Xero and other providers may process or support information outside the United Kingdom. nPhoto operates in Poland.
Where UK personal information is transferred internationally, I rely on the provider’s applicable UK transfer arrangements, such as a UK adequacy regulation, the UK International Data Transfer Agreement, the UK Addendum to approved contractual clauses or another lawful safeguard.
You can contact me for more information about the safeguard relevant to a particular provider.
HOW LONG IS INFORMATION KEPT?
I keep information only for as long as it is needed for the purpose described, to meet legal obligations or to establish and defend legal claims.
WEBSITE ENQUIRY FORM
Website enquiry forms are deleted from WordPress after four weeks, whether or not the enquirer books.
ENQUIRIES THAT DO NOT BECOME BOOKINGS
The information is deleted from the client-management system and Gmail after approximately four weeks, unless an active conversation, dispute or legal reason requires it to be kept for longer.
BOOKED-CLIENT OPERATIONAL FILE
The file is closed and unnecessary information is deleted when every deliverable has been completed. This normally happens no later than 12 months after the wedding where unclaimed deliverables have been forfeited under the contract.
CONTRACTS, ESSENTIAL CLIENT INSTRUCTIONS AND RELEVANT CORRESPONDENCE
These records are retained for six years after the services end where they are needed for business records or legal claims.
INVOICES, PAYMENTS AND TAX RECORDS
These are retained for at least five years after the 31 January Self Assessment submission deadline for the relevant tax year, or longer where HMRC requires it.
TELEPHONE NUMBERS AND WHATSAPP CONVERSATIONS
These are deleted as part of the client close-down process after all deliverables have been completed. A deleted conversation may remain temporarily in the rolling encrypted Google Drive backup until it is replaced.
WEDDING-DAY OPERATIONAL INFORMATION
Emergency contacts and other short-term operational details are normally deleted within three months of gallery delivery unless they are needed for an outstanding matter. The handwritten safety and accessibility sheet is shredded after the wedding.
ONLINE GALLERY
The online gallery is normally available for 24 months from delivery, unless the client agreement or gallery states otherwise.
GALLERY VISITOR AND ORDER INFORMATION
This is kept for the operation of the gallery and for the period needed to administer an order, accounting record, complaint or legal obligation.
UNDELIVERED RAW FILES, WORKING FILES AND TEMPORARY JPEG EXPORTS
These are deleted once all final delivery items have been received or at the 12-month contractual deadline for unclaimed deliverables.
SOURCE RAW FILES UNDERLYING THE DELIVERED GALLERY
These may be retained indefinitely on offline archive drives for archival, copyright, portfolio and legal purposes. RAW files are not supplied to clients, and retention is not a guarantee that a replacement copy will always be available.
BACKBLAZE COPIES
Active and connected drives are backed up. Archive drives are backed up only while connected, and deleted information can remain until backup cycles are replaced.
ALBUM AND PRINT ORDER RECORDS
These are normally retained for six years where needed for accounting, customer service or legal claims.
PROMOTIONAL OPT-OUTS OR OBJECTIONS
A minimal do-not-publish marker is retained for as long as the relevant photographs are held or may be used, so the restriction is not accidentally forgotten.
SUPPLIER-SHARING PERMISSION
This is retained while photographs may still be supplied and afterwards for up to six years where needed to demonstrate the instruction given.
COOKIE PREFERENCES
The current CookieYes preference record lasts one year unless replaced or deleted sooner.
GOOGLE ANALYTICS DATA
User-level and event-level information is retained for two months under the current property setting. This does not necessarily remove historical aggregated reporting data.
HOW IS INFORMATION PROTECTED?
My computer and phone are protected by biometrics. Business accounts use unique passwords, normally at least 30 characters, through a password manager. Two-step verification is enabled on business and payment accounts where available. Backups are encrypted and access to client systems is limited to me.
No internet or storage system can be guaranteed completely secure. If a personal-data breach creates a legal duty to notify the ICO or affected people, I will follow the applicable reporting requirements.
YOUR OTHER INFORMATION RIGHTS
Depending on the circumstances, you may have the right to ask for access to your personal information.
You may have the right to ask for inaccurate information to be corrected.
You may have the right to ask for information to be deleted.
You may have the right to ask for processing to be restricted.
You may have the right to object to processing based on legitimate interests or direct marketing.
You may have the right to receive certain information in a portable format.
You may have the right to withdraw consent where processing relies on consent.
You may have the right to complain about how your information has been used.
These rights are not absolute and can depend on why the information is held. I may need to verify your identity before acting on a request.
To make a request, email James@adeptimagery.co.uk.
COMPLAINTS
Please contact me first if you have a concern so I can try to resolve it.
You can also complain to the Information Commissioner’s Office:
Information Commissioner’s Office
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Telephone: 0303 123 1113
Website: https://ico.org.uk/make-a-complaint/
CHANGES TO THIS POLICY
I will review this policy when the website, services, providers or legal requirements change. The latest version and its update date will remain on this page.
