1.0 Introduction

1.1 Who We Are

This Privacy Policy (the "Policy") is issued by Sproul Photography ("we," "us," or "our") and sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

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Sproul Photography offers the following services: teaching photography online and in person, delivering talks and presentations to camera clubs and other organisations, hosting workshops in Tuscany and Venice, providing photography services for estate agents and other property showcasing, and offering drone photography services.

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We are committed to protecting your personal data and your right to privacy in compliance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

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1.2 The Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

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We may collect, use, store, and transfer various types of personal data about you. Based on our services, this data falls into the following categories:

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1.2.1 Identity and Contact Data: Includes first name, last name, title, billing address, delivery address, email address, and telephone numbers.

1.2.2 Financial and Transaction Data: Includes details about payments made to and from you and other details of products and services you have purchased, such as workshop fees or course enrolment records.

1.2.3 Technical and Usage Data: Includes Internet Protocol (IP) address, login data (if applicable), browser type and version, time zone setting and location, operating system, and information about how you use our website (pages viewed, duration of visit).

1.2.4 Profile and Marketing Data: Includes your preferences in receiving marketing emails from us, your communication preferences, and any feedback or survey responses you provide.

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1.3 Changes to the Policy

We regularly review our Policy. This version was last updated on 31/09/2025.

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2.0 How Is Your Personal Data Collected?

2.1 Direct Interactions

You may provide us with your Identity, Contact, and Financial Data by completing forms or by corresponding with us via post, phone, email, or other means. This includes personal data you provide when you:

1. Enquire about or purchase our online courses or in-person workshops (e.g., Tuscany or Venice).

2. Book a professional service, such as an estate agent or drone photography.

3. Subscribe to our mailing list or newsletter.

4. Give us feedback or contact us.

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2.2 Automated Technologies or Interactions

As you interact with our website, we will automatically collect Technical and Usage Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies and other similar technologies. See our Cookie Policy.

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2.3 Third Parties or Publicly Available Sources

We may receive personal data about you from various third parties, such as payment processors (for Financial Data).

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3.0 Purposes for Which We Will Use Your Personal Data

We will only use your personal data when permitted by law. Most commonly, we will use your personal data in the following circumstances:

3.1 Where we need to perform the contract we are about to enter into or have entered into with you (e.g., processing your workshop booking).

3.2 Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests (e.g., preventing fraud or improving our services).

3.3 Where we need to comply with a legal obligation (e.g., tax and accounting requirements).

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We rely on consent as a legal basis for processing your personal data for sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time.

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4.0 Disclosures of Your Personal Data

We may share your personal data with the parties listed below for the purposes outlined in Section 3.0.

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4.1 Payment Processors

We share your Financial and Transaction Data with providers like Stripe or bank merchant services to securely process payments for courses and workshops.

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4.2 Workshop Partners (Tuscany/Venice)

We share your Identity and Contact Data (such as name and dietary requirements) with third-party travel, accommodation, or local service providers in Italy to facilitate and book the in-person workshops you run.

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4.3 Technical and IT Service Providers

We share your Identity, Contact, Technical and Usage Data with website hosting providers, cloud storage services (for file management), and email marketing platforms (to send newsletters).

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4.4 Professional Advisers

We share relevant Financial and Transaction Data with professional advisers, including accountants, auditors, and lawyers, who provide services to Sproul Photography.

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4.5 Regulatory and Legal Authorities

We share data with HM Revenue & Customs (HMRC), regulators, and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.

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5.0 International Transfers

We share your personal data both inside and outside the UK/EEA.

5.1 Transfers within Adequate Jurisdictions

We transfer data to countries within the European Economic Area (EEA) (e.g., Italy for workshop bookings). The UK deems these jurisdictions to provide an adequate level of protection for personal data, so no specific safeguarding measures are required for these transfers.

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5.2 Transfers outside Adequate Jurisdictions

We may use some service providers (e.g., hosting, email marketing) whose servers are located outside the UK and EEA, in countries not deemed 'adequate' (e.g., the United States). In these cases, we ensure your personal data is protected by implementing at least one of the following safeguards:

5.2.1 We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK.

5.2.2 Where we use certain service providers, we may use specific contracts approved for use in the UK, which give personal data the same protection it has in the UK (known as UK Standard Contractual Clauses or SCCs).

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6.0 Data Retention

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

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6.1 Legal and Contractual Retention

We typically retain transaction data for a minimum period of six years after you cease to be a customer, in accordance with statutory obligations for UK tax purposes.

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6.2 Marketing and Inactive Data

Identity and Contact Data collected for marketing purposes are retained until you withdraw your consent. For all non-contractual data (such as general inquiries or website usage logs), we maintain a 24-month retention policy and securely delete data that has not been accessed for two consecutive years, unless a statutory obligation requires longer retention.

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7.0 Your Legal Rights

Under UK GDPR, you have rights in relation to your personal data. These include:

7.1 The Right to Access

The right to request a copy of the personal data we hold about you (a Subject Access Request).

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7.2 The Right to Rectification

The right to request that we correct any data we hold about you that is incomplete or inaccurate.

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7.3 The Right to Erasure (Right to be Forgotten)

The right to ask us to delete or remove personal data where there is no good reason for us to continue processing it.

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7.4 The Right to Object to Processing

The right to object to the processing of your personal data where we are relying on a legitimate interest.

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7.5 The Right to Restrict Processing

The right to ask us to suspend the processing of your personal data, for example, if you want us to establish its accuracy.

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7.6 The Right to Data Portability

The right to request the transfer of your personal data to you or to a third party.

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7.7 The Right to Withdraw Consent

The right to withdraw consent at any time where we are relying on consent to process your personal data (e.g., for marketing).

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8.0 Contact Details and Complaints

8.1 Contact Details

If you have any questions about this Policy or our privacy practices, please contact us at:

Email: martin@sproul.photography 

 

8.2 Right to Complain

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the opportunity to address your concerns before you approach the ICO, so please contact us in the first instance.