Privacy — Pure Simple Photography

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PRIVACY NOTICE 
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Last Updated: September 2026

This Privacy Notice explains how Pure & Simple Ltd (trading as "Pure Simple Photography") collects, uses, stores, discloses, and protects your personal data. 
We are committed to protecting your privacy and handling your personal data transparently and securely in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

1. IMPORTANT INFORMATION AND WHO WE ARE

Pure & Simple Ltd is the data controller responsible for your personal data. 
• Company Name: Pure & Simple Ltd (Trading as "Pure Simple Photography")
• Company Registration Number: 07901739
• Registered Office Address: Pure & Simple, Enterprise Centre, 6 David Lane, 
  Basford, Nottingham, NG6 0JU
• Data Protection Contact Email: data@pureandsimple.company

2. THE DATA WE COLLECT ABOUT YOU

Personal data means any information about an individual from which that person can be identified. We may collect, use, store, and transfer different kinds of personal data about you, grouped as follows:

• Identity Data: First name, last name, date of birth (for age verification/model eligibility), and signature.
• Contact Data: Billing address, home address, email address, and telephone numbers.
• Visual Data: High-resolution digital photographs, video footage, and raw image files capturing your image, physical likeness, and characteristics.
• Financial Data: Bank account and payment card details (processed securely via our payment providers).
• Transaction Data: Details about payments to and from you, invoices, receipts, and details of photography services or products you have purchased from or provided to us.

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 a Contract: Where we need to perform the contract we are about to enter into or have entered into with you (e.g., fulfilling a commercial photography booking, delivering digital image files, or managing a Model Release Agreement).
• Legitimate Interests: Where it is necessary for our legitimate business 
  interests (or those of a third party) and your interests and fundamental rights do not override those interests. This includes displaying your image in our professional online portfolio (websites and social media) to promote our photography services, provided a valid Model Release Agreement has been executed.
• Compliance with a Legal Obligation: Where we need to comply with a legal or regulatory obligation (e.g., maintaining VAT records for HM Revenue & Customs).

4. DATA RETENTION: HOW LONG WILL WE KEEP YOUR DATA?

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

• Portfolio and Marketing Content: Where you have signed an irrevocable, perpetual Model Release Agreement, we will retain and display the photography/video content indefinitely in our professional portfolio, unless otherwise mutually agreed.
• Client Booking and Financial Records: We retain transaction, invoice, and contract data for a minimum of 6 years following the end of the financial year in which the transaction occurred, to comply with UK tax laws.
• Raw and Temporary Image Files: Temporary files or images not selected for final galleries are securely deleted in accordance with our internal storage policies.

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 unauthorized way, altered, or disclosed. We limit access to your personal data to those employees, contractors, and agents 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.

6. YOUR LEGAL RIGHTS (Including the Right to Erasure)

Pure & Simple Ltd is fully registered with the Information Commissioner's Office (ICO) under Data Protection Registration Number: [AWAITING ZA NUMBER FROM ICO]. 

Under certain circumstances, you have rights under UK data protection laws in relation to your personal data, including the right to request access, correction, restriction, or erasure of your data.

The "Right to be Forgotten" vs. Signed Contracts:

Please note that while the UK GDPR grants you a general "Right to Erasure" (the right to ask us to delete your personal data), this right is not absolute. If you have signed a legally binding, commercial Model Release Agreement granting Pure & Simple Ltd the irrevocable right to use your likeness in an online portfolio, our legal basis for processing your data is contractual performance and legitimate interests. In these circumstances, the signed contract generally overrides a standard erasure request to ensure business continuity. We review all deletion requests on a case-by-case basis.

If you wish to exercise any of your statutory rights, please contact us at 
data@pureandsimple.company. 

You also 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).