ELODIE PICTURES LIMITED – PRIVACY NOTICE

This privacy notice describes how Elodie Pictures Limited (Elodie or we/us) uses personal data relating to our customers, newsletter subscribers and other people who contact us (you). It also contains information about our use of cookies on our website.

We may update this notice from time to time. It was last updated on 29 October 2020.
This notice is set out in the following sections. 

1. The quick read (a summary) 
2. Who we are (including our contact details) 
3. Use of data about our customers (and our legal basis under data protection law) 
4. Use of data about other contacts (and our legal basis under data protection law) 
5. Google analytics and cookies 
6. Sharing your data 
7. International data transfers 
8. Retaining your information 
9. Your data protection rights


1. THE QUICK READ
Controller: Elodie Pictures Limited is the controller for use of your personal data as described in this notice, meaning we decide how and why your personal data is used. You can contact us at: hello@elodiepictures.com.
Use of customer data: If you are a customer of ours, we will collect and hold your personal data to perform our contract with you, including creating your film and managing our relationship with you. This includes your name and contact details, and the content of photos and videos which you provide to us for inclusion in your film.
Content featuring other people: Before providing us with content featuring other people, you must consider whether the other person would be comfortable for you to send it to us for the film.
Publication of films: With your consent, we may publish your film (or extracts) on our website and within social media to assist with publicity for our business.
Retention of customer data: We generally retain content you provide us for six months, and the final film and other customer information for six years.
Newsletter subscribers: If you wish to subscribe to your newsletter, we will collect your name and email address.
Contacting us: We may hold your details if you contact us, for example over our website or social media.
Google Analytics: We may use Google Analytics on our website for the purposes of website analysis.
Our service providers: Our service providers, including technology providers, may hold your data on our behalf (as processors) in providing their services to us. We remain responsible for how they use your data on our behalf.
Sharing your data: We do not generally share your data with other parties, except in exceptional circumstances, such as where required by law or in order to protect our legal rights.
International data transfers: We do not generally transfer your data outside the UK, except to the extent our service providers have data centres outside the UK.
Your rights: You have rights in relation to our use of your data, including the right to access a copy of the data we hold about you and, in certain circumstances, to object to our use of your data or request that we erase your data.

2. WHO WE ARE
Elodie Pictures Limited is a company registered in England and Wales, with company number 12604026, and registered office at Kemp House, 160 City Road, London, EC1V 2NX. For the purposes of data protection law, we act as a controller in our use of your personal data, meaning that we decide how and why we use your data.
You may contact us with any queries or concerns about our use of your personal data, and to exercise your data protection rights using the following contact details.
• Email: hello@elodiepictures.com
• Telephone: 07393 031586

3. USE OF DATA ABOUT OUR CUSTOMERS
3.1 Creation of a film for you
If you are a customer of ours, we will collect and hold your personal data in order to create your film and provide you with our services, and to manage our relationship with you.
The personal data we collect includes:
• Name
• Address, email address and telephone number
• Details of payments you have made
• Content of photos and videos which you provide to us
• Additional information about your photos and videos which you provide to assist us in selecting appropriate content for the film (for example information about people or photos which are particularly significant for you). It is optional for you to provide us with this information.
• Logs of access to our systems when you download your film and other materials we provide to you (where relevant)
• Other personal data within communications between you and us
Our legal basis under data protection law for using your personal data is that it is necessary for the performance of our contract with you (or to take steps at your request prior to entering into a contract with you). We may not be able to provide you with our services if you do not provide us with relevant information.
We will not use your details to send you our newsletter or other direct marketing communications without seeking additional consent from you to do so. However, we may contact you for the purposes of customer care, including to provide updates on creation of your film, and to check you are happy with our service.
3.2 Other people featuring in your content
The content you provide to us for us to create your film may include information about other people (such as friends or family members who feature in your photos). You may also provide us with additional information about them to assist us in selecting appropriate content for the film. Our legal basis for using this information is our legitimate interests in creating the film for you.
Before providing us with such content or information, please consider whether the other person would be comfortable for you to send it to us for the film (and, if in doubt, please check with them and direct them to this privacy notice). If you have any reason to think another person would not be comfortable, you should not provide such content or information to us.
3.3 Sensitive data
We may need to obtain explicit consent before we use any content you provide which reveals sensitive information about you or any other person (such as information relating to health).
3.4 Use of your film for our publicity
If you give us your consent, we may publish your film (or extracts from it or a social media version of it) on our website or within social media posts, to assist with publicity for our business. Please also consider the wishes of other people who feature in the film; before giving your consent, you should also check that they are comfortable with us publishing it, or you may otherwise request that we blur people’s faces. Please note that we would not seek to include images of people outside your family within any social media version of the film.
You may withdraw your consent at any time by contacting us using the contact details at section 2 above. If you withdraw your consent, we will use our best endeavours to remove content from our website and other social media. However, it may not always be possible to remove all occurrences from social media, and we do not have full control over how other parties may have accessed and used the film whilst it was published.
3.5 Other use of your data
Your personal data may also be used by us:
• to maintain appropriate records of our business communications and relationships (in our legitimate interests); and
• to protect or enforce legal rights, or for other purposes permitted or required by law, including data protection law (in our legitimate interests, or as needed to comply with a legal obligation).

4. USE OF DATA ABOUT OTHER CONTACTS
4.1 Subscribing to our newsletter
We request your name and email address if you want to sign up for our newsletter (which includes special offers, information about our services, and other news). This information is used to send you our newsletter by email.
Our legal basis is for sending you our newsletter is consent (which we will request from you at the time you subscribe). You can unsubscribe from our newsletter at any time, by sending us an email using the contact details at section 2 above.
4.2 Other contact with us (including over our website and social media)
You may provide us with information if you get in contact with us (for example over our website, by email or phone, or over social media), or if you connect with, follow or interact with us on social media, or comment on our social media posts.
Personal data which we hold or access includes:
• Name or social media username
• Contact details (as relevant to your contact with us)
• Other information associated with your social media account (such as within your profile)
• Information you communicate to us
We use such information for the purposes of handling your enquiry or communication, keeping records of the communication, and as may be relevant to the circumstances or our relationship with you. Our legal basis for using your personal data is our legitimate interests in carrying out these activities.
4.3 Other use of your data
Your personal data may also be used by us:
• to maintain appropriate records of our business communications and relationships (in our legitimate interests); and
• to protect or enforce legal rights, or for other purposes permitted or required by law, including data protection law (in our legitimate interests, or as needed to comply with a legal obligation).

5. GOOGLE ANALYTICS AND COOKIES
We may use Google Analytics on our website to collect standard internet log information and details of visitor behaviour patterns, such as session duration, pages per session and bounce rate, as well as source of the traffic. We do this to understand our site better and to improve it. We do not seek to identify anyone during this process.
Except to the extent they are strictly necessary for the operation of our website or delivery of our services, cookies will only be used if we obtain your consent. You will be given options when you first visit our website. You can remove cookies at any time using the privacy settings of your web browser.

6. SHARING YOUR DATA
6.1 Our service providers
Our service providers may handle your data, such as our data centre and technology service providers (such as Dropbox), and providers of mailing services (such as Mailchimp). They act as processors on our behalf, meaning that we remain primarily responsible for how they use your data on our behalf in line with the purposes and legitimate interests identified in section Error! Reference source not found. above.
6.2 Other parties
We may also share your data, where relevant, with the following parties:
• legal authorities or regulatory bodies
• our legal or other professional advisers
• prospective or actual purchasers of our company or business
• other parties where we are otherwise required or permitted by law to do so (including by data protection law).
Our legal basis for such data sharing is, as appropriate, our (or the recipient’s) legitimate interests in the relevant activity, or compliance with a legal obligation.

7. INTERNATIONAL DATA TRANSFERS
We do not generally transfer your data outside the UK except where our service providers have data centres or systems outside the UK (which includes Dropbox with data centres outside the UK). If the laws of the country of transfer are not deemed to provide adequate protection for personal data, we shall take steps to check with our providers that there are other safeguards in place to protection your data protection rights.

8. RETAINING YOUR INFORMATION
We will retain your personal data for as long as we need it for the relevant purposes specified above, in accordance with our records retention procedures. For customers:
a) we generally retain the content you have provided to us for six months following completion of our services; and
b) we generally retain your contact details, the film we create for you, and details of payments and communications, for six years following completion of our services.
Our retention periods may be changed in appropriate circumstances, for example we may need to retain your details for longer if there is a dispute in relation to our services. Please contact us (using the contact details at section 2 above) for further information about our retention periods and procedures.

9. YOUR DATA PROTECTION RIGHTS
In accordance with data protection laws, you have certain rights in relation to our use of your personal data. These rights include the following:
• to obtain a copy of the personal data we hold about you, together with other information about how we process it (known as a subject access request)
• to withdraw any consent which you have given relating to the use of your data
• to request rectification of inaccurate or incomplete data, and, in some circumstances, to request us to erase or restrict our use of your data, or otherwise to object to our processing of your data for direct marketing purposes or for reasons relating to your particular situation
• where our use of your data is based on your consent or necessity for our contract with you (described as the ‘legal basis’ in the relevant sections above), to exercise a right to data portability, in order to transfer sets of data provided by you and held electronically to another organisation • not to be subject to a decision based solely on automated processing, which significantly affects you, unless additional legal requirements are met (although we do not make any such decisions as at the date of this notice)
Please contact us (see section 2 above) to send us requests to exercise these rights (specifying what you are requesting), or if you would like further information about these and other rights which you have. Note that there are certain limitations and exemptions to these rights which we may apply depending on the circumstances.
You may also make a complaint about how we handle your data to the UK Information Commissioner’s Office. Please visit ico.org.uk for further information about how to do this (and further guidance on your rights). You may also take legal action in court to enforce your rights.