PRIVACY NOTICE – ALEXA LOY for LEAP AND DIVE LTD  (art and photography)

 

INTRODUCTION  

 

Welcome to our privacy notice.

 

Alexa Loy respects your privacy and is committed to protecting your personal data. This

privacy notice will inform you as to how we look after your personal data when you visit our website

(regardless of where you visit it from) and tell you about your privacy rights and how the law protects

you. You can download a pdf version of the policy here [insert link].

  

1.  IMPORTANT INFORMATION AND WHO WE ARE  

 

PURPOSE OF THIS PRIVACY NOTICE  

 

This privacy notice aims to give you information on how we collect and process your personal data

through your use of this website, including any data you may provide through this website when you

sign up to our newsletter or take part in a competition.

 

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

 

It is important that you read this privacy notice together with any other privacy notice or fair

processing 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.

 

CONTROLLER  

 

Alexa Loy Photography is the controller and responsible for your personal data (collectively referred to

as “we”, “us” or “our” in this privacy notice).

 

We have appointed a data privacy manager who is responsible for overseeing questions in relation to

this privacy notice. If you have any questions about this privacy notice, including any requests to

exercise your legal rights, please contact the data privacy manager using the details set out below.

CONTACT DETAILS  

 

Our contact details are set out in table 1 below:

Full name of legal entity LEAP AND DIVE LTD

Name or title of data privacy

Manager : Alexa Loy Dent


Email address hello@alexa-loy.com


PRIVACY NOTICE – Alexa Loy LEAP and DIVE LTD

United Kingdom


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 chance to deal with your concerns before you approach the ICO so please contact us in the first

instance.

 

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES  

 

This version was last updated in Oct 2024.

  

It is important that the personal data we hold about you is accurate and current. Please keep us

informed if your personal data changes during your relationship with us.

 

THIRD-PARTY LINKS  

 

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 every website you visit.

 

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).

 

We may collect, use, store and transfer different kinds of personal data about you which we have

grouped together in table 2 below:

 

Identity Data includes first name, maiden name, last name, username or similar identifier,


marital status, title, date of birth and gender


Contact Data Includes billing address, mailing address, email address and telephone


numbers


Financial Data includes bank account and payment card details

Transaction Data includes details about payments to and from you and other details of


PRIVACY NOTICE – ALEXA LOY  for LEAP AND DIVE LTD


products and services you have purchased from us


Technical Data includes internet protocol (IP) address, your login data, browser type and

version, time zone setting and location, browser plug-in types and versions,

operating system and platform and other technology on the devices you

use to access this website


Profile Data includes your username and password, purchases or orders made by you,


your interests, preferences, feedback and survey responses


Usage Data includes information about how you use our website, products and services

Marketing and

Communications Data


includes your preferences in receiving marketing from us and our third

parties and your communication preferences


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.

  

IF YOU FAIL TO PROVIDE PERSONAL DATA  

Where we need to collect 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 goods or services). In this case, we

may have to cancel a product or service you have with us but we will notify you if this is the case at the

time.

 

3.  HOW IS YOUR PERSONAL DATA COLLECTED?  

 

We use different methods to collect data from and about you, as set out in table 3 below:

 

Direct interactions You may give us your Identity, Contact and

Financial Data by filling in forms or by

corresponding with us by post, phone, email or

otherwise. This includes personal data you

provide when you:

• make an enquiry regarding our services;


PRIVACY NOTICE – ALEXA LOY for LEAP AND DIVE LTD


• purchase our products or services;

• request marketing to be sent to you;

• enter a competition, promotion or survey; or

• give us some feedback.


Automated technologies or interactions As you interact with our website, we may

automatically collect Technical Data about your

equipment, browsing actions and patterns. We

collect this personal data by using cookies,

server logs and other similar technologies. We

may also receive Technical Data about you if you

visit other websites employing our cookies.

Please see our cookie policy [insert link] for

further details.


Third parties or publicly available sources. We may receive personal data about you from


various third parties as set out below:

• Technical Data from analytics providers such

as Google based outside the EU;

• Contact, Financial and Transaction Data

from providers of technical, payment and

delivery services such as QuickBooks, PayPal

and other financial institutions based inside

and outside the EU.


4.  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:

 

• Where we have your consent to do so.

• Where we need to perform the contract we are about to enter into or have entered into with you.

• 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.

• Where we need to comply with a legal or regulatory obligation.

See table 4 below to find out more about the types of lawful basis that we will rely on to process your

personal data. 

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA  

 

We have set out below in table 4 a description of all the ways we plan to use your personal data, and


PRIVACY NOTICE – ALEXA LOY for LEAP AND DIVE LTD

which of the legal bases we rely on to do so. We have also identified what our legitimate interests are

where appropriate.

 

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 us via email at hello@alexa-loy.com

or via the Contact page on our website if you need further details.

 

Purpose/Activity Type of data Lawful basis for processing including


basis of legitimate interest


To register you as a new

customer


(a) Identity

(b) Contact


Performance of a contract with you


To process and deliver your

order including:

(a) Manage payments, fees and

charges

(b) Collect and recover money

owed to us


(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and

Communications


(a) Performance of a contract with you

(b) Necessary for our legitimate

interests (to recover debts due to us)


To manage our relationship with

you which will include:

(a) Notifying you about changes

to our terms or privacy policy

(b) Asking you to leave a review

or take a survey


(a) Identity

(b) Contact

(c) Profile

(d) Marketing and

Communications


(a) Performance of a contract with you

(b) Necessary to comply with a legal

obligation

(c) Necessary for our legitimate interests

(to keep our records updated and to

study how customers use our

products/services)


To enable you to partake in a

prize draw, competition or

complete a survey


(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and

Communications


(a) Performance of a contract with you

(b) Necessary for our legitimate

interests (to study how customers use

our products/services, to develop them

and grow our business)


To administer and protect our

business and this website

(including troubleshooting, data

analysis, testing, system

maintenance, support, reporting


(a) Identity

(b) Contact

(c) Technical


(a) 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


PRIVACY NOTICE – ALEXA LOY for LEAP AND DIVE LTD

and hosting of data) group restructuring exercise)

(b) Necessary to comply with a legal

obligation


To deliver relevant website

content and advertisements to

you and measure or understand

the effectiveness of the

advertising we serve to you


(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and

Communications

(f) 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


(a) Technical

(b) Usage


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


(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile


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.

 

PROMOTIONAL OFFERS FROM US  

 

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 (we call this marketing).

 

You will receive marketing communications from us if you have requested information from us or

purchased goods or services from us or if you provided us with your details when you entered a

competition or registered for a promotion and, in each case, you have not opted out of receiving that


PRIVACY NOTICE – ALEXA LOY for LEAP AND DIVE LTD

marketing.

 

THIRD-PARTY MARKETING  

We will get your express opt-in consent before we share your personal data with any company for

marketing purposes.

 

OPTING OUT  

 

You can ask us or third parties to stop sending you marketing messages at any time by:

by following the opt-out links on any marketing message sent to you; or

by contacting us via email at hello@alexa-loy.com or via the Contact page on our website at any

time.

 

Where you opt out of receiving these marketing messages, this will not apply to personal data

provided to us as a result of a product/service purchase or other transactions.

 

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 our Cookie Policy, which is available here [insert link].

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 us via email at hello@alexa-loy.com or via the Contact page

on our website.

 

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.

 

5.  DISCLOSURES OF YOUR PERSONAL DATA  

 

We may have to share your personal data with the parties set out in table 5 below for the purposes set

out in the table in paragraph 4 above.

 

Third Party Purpose of disclosure Link to Third Party Privacy Policy


PRIVACY NOTICE – ALEXA LOY for LEAP AND DIVE LTD

ShootProof To store photographs https://www.shootproof.com/legal/priva


cy-policy


XODO SIGN To allow for electronic signatures


of documents


https://www.adobe.com/uk/privacy.html


QuickBooks To create invoices and log


transactions


https://quickbooks.intuit.com/uk/privacy

-policy/


Gmail and Google

Docs


For business related emails and

storage of business documents


https://policies.google.com/privacy?hl=e

n&gl=uk


We may have to share your personal data with third parties to whom we may choose to sell, transfer,

or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or

merge with them. If a change happens to our business, then the new owners may use your personal

data in the same way as set out in this privacy notice.

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.

 

6.  INTERNATIONAL TRANSFERS  

 

Some of our external third parties are based outside the European Economic Area (EEA) so their

processing of your personal data will involve a transfer of data outside the EEA.

 

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is

afforded to it by ensuring at least one of the following safeguards is implemented:

 

• 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 European Commission. For further details,

see European Commission: Adequacy of the protection of personal data in non-EU countries.

• Where we use certain service providers, we may use specific contracts approved by the European

Commission which give personal data the same protection it has in Europe. For further details, see

European Commission: Model contracts for the transfer of personal data to third countries.

• Where we use providers based in the US, we may transfer data to them if they are part of the

Privacy Shield which requires them to provide similar protection to personal data shared between

the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us via email at hello@alexa-loy.com or via the Contact page on our website if you want

further information.


PRIVACY NOTICE – ALEXA LOY for LEAP AND DIVE LTD

 

7.  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 and will notify you

and any applicable regulator of a breach where we are legally required to do so.

 

8.  DATA RETENTION  

 

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?  

 

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 Transaction Data) for six years after they cease being customers for tax purposes.

 

In some circumstances you can ask us to delete your data: see Request erasure 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.

 

9.  YOUR LEGAL RIGHTS  

 

Under certain circumstances, you have rights under data protection laws in relation to your personal

data. Please see below to find out more about these rights:

 

• Request access to your personal data (commonly known as a “data subject access request”). This

enables you to receive a copy of the personal data we hold about you and to check that we are

lawfully processing it.

• Request correction of your personal data that we hold about you. This enables you to have any

incomplete or inaccurate data we hold about you corrected, though we may need to verify the


PRIVACY NOTICE – ALEXA LOY for LEAP AND DIVE LTD

accuracy of the new data you provide to us.

• Request erasure of your personal data - this enables you to ask us to delete or remove personal

data where there is no good reason for us continuing to process it. You also have the right to ask

us to delete or remove your personal data where you have successfully exercised your right to

object to processing (see below), where we may have processed your information unlawfully or

where we are required to erase your personal data to comply with local law. Note, however, that

we may not always be able to comply with your request of erasure for specific legal reasons which

will be notified to you, if applicable, at the time of your request.

• Object to processing of your personal data where we are relying on a legitimate interest (or those

of a third party) and there is something about your particular situation which makes you want to

object to processing on this ground as you feel it impacts on your fundamental rights and

freedoms. You also have the right to object where we are processing your personal data for direct

marketing purposes. In some cases, we may demonstrate that we have compelling legitimate

grounds to process your information which override your rights and freedoms.

• Request restriction of processing your personal data - this enables you to ask us to suspend the

processing of your personal data in the following scenarios: (a) if you want us to establish the

data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c)

where you need us to hold the data even if we no longer require it as you need it to establish,

exercise or defend legal claims; or (d) you have objected to our use of your data but we need to

verify whether we have overriding legitimate grounds to use it.

• Request transfer of your personal data to you or to a third party. We will provide to you, or a third

party you have chosen, your personal data in a structured, commonly used, machine-readable

format. Note that this right only applies to automated information which you initially provided

consent for us to use or where we used the information to perform a contract with you

• Right to withdraw consent at any time where we are relying on consent to process your personal

data. However, this will not affect the lawfulness of any processing carried out before you

withdraw your consent. If you withdraw your consent, we may not be able to provide certain

products or services to you. We will advise you if this is the case at the time you withdraw your

consent.

If you wish to exercise any of the rights set out above, please contact us via email at hello@alexa-

loy.com or via the Contact page on our website.

 

NO FEE USUALLY REQUIRED  

 

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 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  


PRIVACY NOTICE – ALEXA LOY for LEAP AND DIVE LTD

 

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 try to respond to all legitimate requests within one month. 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.