Privacy Policy

We respect your privacy and are determined to protect your personal data. The purpose of this privacy notice is to inform you as to how we use and look after your personal data when you visit our website www.panelagency.com regardless of where you visit it from.  We’ll also tell you about your privacy rights and how the data protection law protects you.

This privacy notice aims to give you information on how we collect and process your personal data through use of our website and any interactions with us offline (for example if you purchase our products either onsite at an event, or by contacting our Studio), including any data you may provide through this website when you purchase our products, sign-up to our newsletter, or complete any online forms.

This website is not intended for children and we do not knowingly collect data relating to children.

You must read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data.  This privacy notice supplements the other notices and is not intended to override them.

1. Personal Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified.  You can find out more about personal data from the Information Commissioners Office.

We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:
Identity Data - Title, First Name, Last Name, Username.
Contact Data - Billing Address, Delivery Address, Email, Telephone Numbers.
Profile Data - Order History, Username, Passwords.
Technical Data - Referring websites, IP address, Browser Type.
Marketing Data - Communication / Opt-in Status.
Financial Data - Debit or Credit Card Details.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose.  Aggregated Data may be derived from your personal data, but is not considered personal data in law as this data does not directly or indirectly reveal your identity.  For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data.  Nor do we collect any information about criminal convictions and offences.

Third-party links outside of our control

This website 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 statements.

When you leave our website, we encourage you to read the privacy notice of each website you visit.

If you fail to provide personal data

Where we need to collect your personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the goods you are trying to order).  In this case, we may reluctantly have to cancel your order, but we will notify you if this is the case at the time.

2. How We Collect Your Personal Data

We collect personal data from you in the following ways:

Website Purchases

By ordering through the website you will provide your billing contact details – your name, billing address, phone number and email address.  You have the option to supply a different delivery address and specify a different contact name at that delivery address.  The payment data you provide when making an online purchase through our website is processed externally by SagePay who provide the payment gateway for this site.  Further information on how SagePay process and use your data can be viewed at https://www.sagepay.co.uk/policies.

Offline Purchases

Any purchase not completed through the website is classified as an offline purchase for the purposes of this document. For example, if you should purchase our products through one of our onsite photo centres at events, or by way of contacting our Studio by telephone or via email, or via one of our advance online booking forms. We will collect the same personal data from you as we collect with an online purchase. Offline purchases are processed on our debit/credit card terminal. Any paperwork created when processing the order is only kept whilst the order is being processed internally and is then destroyed. We also destroy payment slips from the card terminal once the payment is authorised.

Newsletter Subscription / Online Account / Online Forms

You may also provide your personal data including name, email address and phone number when setting up an account online, subscribing to our newsletter or using our online photo request form.

Automated Technologies or Interactions

As you interact with the website, we may automatically collect amo Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies (visit our cookie policy).

We receive Technical Data from various third parties such as analytics providers (Google Analytics). This anonymous data is used to improve website usability, identify and resolve technical issues and assist customers experiencing technical issues. We do not pass on data attained from analytics providers to third parties.

3. How We Use Your Personal Data

We will only use your personal data when the law allows us to.  Most commonly, we will use your personal data in the following circumstances.

Performance of Contract

This means processing your data where it is necessary for the performance of a contract to which you are a party, or to take steps at your request before entering into such a contract.

Legitimate Interest

This means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the most secure experience.  We make sure we consider and balance any potential impact on you (both positive and negative) and your rights, before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Comply with a legal or regulatory obligation

This means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email.  You have the right to withdraw consent to marketing communications at any time by unsubscribing from our email marketing list or contacting our Data Protection Office offline at contactus@jeromerussell.co.uk.

Purposes For Which We Will Use Your Personal Data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, with the legal bases we rely on to do so.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer	Identity Contact	Performance of a contract with you
To process and deliver your order Manage payments, fees and charges Collect and recover money owed to us	Identity Contact Financial	Performance of a contract with you Necessary for our legitimate interests, to recover debts due to us
To manage our relationship with you including: Notifying you about changes to our terms or privacy policy Asking you to leave a review	Identity Contact Profile Marketing	Performance of a contract with you Necessary for our legitimate interests Necessary to comply with a legal obligation
To administer and protect our business and this website including: troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data	Identity Contact Technical	Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise Necessary to comply with a legal obligations
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	Identity Contact Profile Marketing Technical	Necessary for our legitimate interests, to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	Technical Profile	Necessary for our legitimate interests, to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy
To make suggestions and recommendations to you about goods or services that may be of interest to you	Identity Contact Profile Marketing	Necessary for our legitimate interests, to develop our products/services and grow our business

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following data control mechanisms relating to our marketing and promotional activity

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

You will receive marketing communications from us if you have requested information from us, or if you subscribe to our marketing list - until you have opted out of receiving that marketing communication.

Opting out

You can ask us to stop sending you marketing communications at any time by visiting the website and unsubscribing www.panelagency.com.  You will only be added to our newsletter if you opt in during the checkout, create an account or subscribe to our marketing list on the website.

You can subsequently request to be removed from the newsletter list at any time by unsubscribing at www.panelagency.com. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of purchasing through the website.

Third-party marketing

We do not supply your personal data to 3rd parties for marketing purposes.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies.  If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.  For more information about the cookies we use, please see www.panelagency.com/cookie-policy/.

Change of purpose

We will only use your personal data for the 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact our Data Protection Officer, whose details appear at the end of this notice. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

4. Who We Share Your Personal Data With

We may have to share your personal data with the parties set out below. The lawful basis by which these parties have access to your data is outlined in the table under the above section “Purposes for which we will use your personal data”:

• Application and website development and hosting
• Online and Offline Payment Providers
• Professional advisers - legal and accountancy services.
• HM Revenue & Customs, regulators and other authorities

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

5. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach, including encrypting passwords, and will notify you and any applicable regulator of a breach where we are legally required to do so.

6. Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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.

By law we have to keep basic information about our customers including contact, identity, financial and transactional data for six years after they cease being customers for tax purposes. In some circumstances you can ask us to delete your data. Please see Your legal rights below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

7. Data Retention

Unless subject to an exemption under the data protection laws, you have the following rights with respect to your personal data:

• The right to request a copy of the personal data which we hold about you;
• The right to request that we correct any personal data if it is found to be inaccurate or out of date;
• The right to request your personal data is erased where it is no longer necessary to retain such data;
• The right to withdraw your consent to the processing at any time, where consent was the lawful basis for processing your data;
• The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller
• The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
• The right to object to our processing of personal data, where applicable i.e. where processing is based on our legitimate interests

If you wish to exercise any of the rights set out above, please contact our Data Protection Officer, contact details below.

No fee required – with some exceptions

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable admin fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We will acknowledge receipt of all legitimate requests within 48 hours, notifying you that it may take up to one month to provide a relevant response, after investigation. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

8. Changes to this notice and your duty to inform us of changes

This version was updated in May 2018.

Please keep us informed if your personal data changes during your relationship with us. It is important that the personal data we hold about you is accurate and current.

Queries, requests or concerns

To exercise all relevant rights, queries or complaints in relation to this policy, or any other data protection matter between you and us, please in the first instance contact our Data Protection Officer via the details below:

If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031 231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England, UK.