# PRIVACY NOTICE

**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 applicable UK data protection law, including 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.

**Legal name:** Pure & Simple Ltd
**Trading name:** Pure Simple Photography
**Company registration number:** 07901739
**Registered office:**
Enterprise Centre
6 David Lane
Basford
Nottingham
NG6 0JU
United Kingdom

**Data protection contact:** [data@pureandsimple.company](mailto:data@pureandsimple.company)
**General/customer support:** [support@pureandsimple.company](mailto:support@pureandsimple.company)
**Telephone:** +44 115 987 5773

Pure & Simple Ltd is registered with the Information Commissioner's Office where required by law.

**ICO registration reference:** [ZC258555]

## 2. THE PERSONAL DATA WE COLLECT

Personal data means information relating to an identified or identifiable individual.

Depending on how you interact with us, we may collect the following categories of personal data.

### Identity Data

This may include:

* first name;
* last name;
* date of birth where necessary for age verification or photography/model eligibility; and
* signature.

### Contact Data

This may include:

* email address;
* telephone number;
* billing address;
* delivery address; and
* other contact details you provide.

### Visual and Photography Data

Where relevant to our photography services, this may include:

* photographs;
* video footage;
* raw image files;
* edited image files;
* your physical likeness and appearance; and
* other information contained within photographic or video material.

Photographs and video may constitute personal data where an individual can be identified.

### Financial and Transaction Data

This may include:

* details of payments made to or from you;
* invoices;
* receipts;
* order details;
* products or services purchased; and
* information required to process or reconcile payments.

Payment-card transactions are processed through third-party payment providers, including **Stripe**, and we do not intend to store complete payment-card details ourselves.

### Technical Data

When you use our website, we may collect technical information such as:

* IP address;
* browser type and version;
* operating system;
* device information;
* website usage information; and
* information collected through cookies and similar technologies.

The specific technologies used on our website are described in our Cookie Policy.

## 3. HOW WE COLLECT YOUR PERSONAL DATA

We may collect personal data when you:

* visit or use our website;
* contact us by email, telephone or contact form;
* request information or a quotation;
* purchase a product or service;
* make or receive a payment;
* enter into a photography agreement;
* sign a Model Release Agreement;
* provide photographs or other material to us;
* communicate with us about an order;
* interact with us through social media; or
* otherwise provide information to us voluntarily.

We may also receive information from service providers involved in fulfilling your order or providing our services.

## 4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data where we have a lawful basis to do so.

Depending on the circumstances, we may use your information to:

* respond to enquiries;
* provide quotations;
* arrange and provide photography services;
* enter into and perform contracts;
* process and fulfil orders;
* provide digital downloads;
* produce and deliver photographic products;
* arrange delivery through third-party couriers;
* process payments;
* communicate with you about your order or service;
* maintain financial, accounting and tax records;
* deal with complaints and enquiries;
* prevent fraud and misuse;
* protect our website, systems, business and property;
* maintain and improve our website and services;
* send marketing communications where legally permitted;
* display photographs for portfolio or promotional purposes where we have an appropriate lawful basis and any required contractual permission; and
* comply with legal and regulatory obligations.

## 5. OUR LAWFUL BASES FOR PROCESSING

We may rely on one or more of the following lawful bases.

### Performance of a contract

We may process personal data where it is necessary to enter into or perform a contract with you.

Examples include:

* processing a photography booking;
* fulfilling an order;
* providing digital image files;
* producing photographic products;
* arranging delivery; and
* administering a relevant photography or Model Release Agreement.

### Legal obligation

We may process personal data where necessary to comply with legal obligations, including accounting, taxation, financial and regulatory requirements.

### Legitimate interests

We may process personal data where necessary for our legitimate interests, provided those interests are not overridden by your rights and freedoms.

Our legitimate interests may include:

* operating and administering our business;
* protecting our business and property;
* preventing fraud;
* maintaining appropriate records;
* improving our services and website;
* responding to enquiries;
* defending or establishing legal claims; and
* promoting our photography services where an appropriate lawful basis applies.

Where we rely on legitimate interests, we will consider the impact of the processing on your rights and interests.

### Consent

Where consent is the appropriate lawful basis, we will ask for your consent before processing your information.

Where processing is based on consent, you may withdraw that consent at any time.

Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

## 6. PHOTOGRAPHS, PORTFOLIO AND PROMOTIONAL USE

Our business involves displaying photographic work as part of our professional portfolio and promotional activities.

Where photographs identify an individual, their use may involve processing personal data.

Where appropriate, we may enter into a separate **Model Release Agreement**, photography agreement or other contract covering the use of photographs or video.

The terms of such an agreement may specify how and where images may be used, including for portfolio, website, social-media or promotional purposes.

A Model Release Agreement and UK data protection rights are separate legal matters. The existence of a signed agreement does not automatically remove an individual's statutory data protection rights.

Any request concerning the use, deletion or restriction of personal data will therefore be considered in accordance with the applicable law, the relevant contract and the circumstances of the request.

Where consent is the applicable lawful basis, we will provide an appropriate mechanism for withdrawing consent.

## 7. WHO WE MAY SHARE YOUR PERSONAL DATA WITH

We do not sell your personal data.

Where necessary to operate our business or fulfil our contractual and legal obligations, we may share relevant personal data with trusted third-party service providers, including:

* **Stripe and other payment service providers** for payment processing;
* website hosting and technology providers;
* email and communications providers;
* printing and photographic laboratories;
* delivery and courier companies;
* cloud storage and backup providers;
* accountants and professional advisers;
* IT and security providers;
* fraud-prevention providers; and
* other contractors or service providers necessary to provide our services.

We only provide third parties with information that is reasonably necessary for the relevant purpose.

Where a third party processes personal data on our behalf, we take appropriate steps to require appropriate confidentiality and security protections.

## 8. INTERNATIONAL TRANSFERS

Some of the service providers we use may process personal data outside the United Kingdom.

Where personal data is transferred outside the UK, we will take the steps required by applicable data protection law to ensure that appropriate safeguards are in place.

Depending on the circumstances, these safeguards may include an adequacy decision, appropriate contractual safeguards or another legally recognised transfer mechanism.

## 9. DATA SECURITY

We take appropriate technical and organisational measures to protect personal data against accidental loss, destruction, alteration, unauthorised disclosure or unauthorised access.

Access to personal data is restricted to employees, contractors and service providers who have a legitimate business need to access it.

Where appropriate, we use security measures such as access controls, authentication, encryption and secure systems.

No internet transmission or electronic storage system can be guaranteed to be completely secure.

## 10. DATA RETENTION

We retain personal data only for as long as reasonably necessary for the purposes for which it was collected, including where necessary to satisfy legal, regulatory, tax, accounting, contractual or reporting requirements.

Different types of information may therefore be retained for different periods.

### Client, booking and financial records

Transaction, invoice, contract and financial records may be retained for at least **6 years following the end of the relevant financial year**, or for such longer period as may be required for legal, tax, accounting or dispute-resolution purposes.

### Portfolio and marketing material

Where a valid agreement permits continuing use of photographs or video for portfolio or promotional purposes, relevant material may be retained for as long as reasonably necessary for those purposes, subject to the terms of the relevant agreement and applicable data protection law.

### Raw and temporary files

Temporary files and images that are no longer required for the agreed service or legitimate business purposes will be securely deleted in accordance with our internal retention procedures, subject to any legal or contractual requirement to retain them.

## 11. YOUR DATA PROTECTION RIGHTS

Subject to applicable legal conditions and exemptions, you may have rights including:

* the right to be informed about how your personal data is used;
* the right to access personal data we hold about you;
* the right to have inaccurate personal data corrected;
* the right to request erasure;
* the right to request restriction of processing;
* the right to object to certain processing;
* the right to data portability in applicable circumstances; and
* rights relating to automated decision-making and profiling where applicable.

These rights are not absolute and may be subject to legal conditions and exemptions.

For example, a request for erasure does not necessarily mean that all personal data must be deleted if we have a lawful reason to retain or continue processing it.

## 12. HOW TO EXERCISE YOUR RIGHTS

To exercise your data protection rights, please contact:

**[data@pureandsimple.company](mailto:data@pureandsimple.company)**

You may also contact us at:

**[support@pureandsimple.company](mailto:support@pureandsimple.company)**

Please provide enough information for us to identify you and understand the nature of your request.

We may need to verify your identity before responding.

We will respond within the period required by applicable data protection law.

## 13. MARKETING

Where we send direct marketing communications, we will comply with applicable data protection and electronic marketing laws.

You can unsubscribe from marketing communications at any time.

Unsubscribing from marketing communications will not normally prevent us from sending essential communications relating to an existing order, booking, contract or service.

## 14. COOKIES AND SIMILAR TECHNOLOGIES

Our website may use cookies and similar technologies.

Some technologies may be strictly necessary for the website to function. Other technologies may be used for purposes such as analytics, performance, embedded content or marketing.

Where consent is legally required, we will obtain consent before using the relevant technology.

Further information is provided in our Cookie Policy.

## 15. CHILDREN'S DATA

Our website and photography services are not specifically directed at children.

Where we knowingly process information relating to a child, we will take appropriate measures having regard to the nature and circumstances of the processing.

Where photography involves children or young people, appropriate parental or guardian arrangements may apply.

## 16. THIRD-PARTY WEBSITES

Our website may contain links to third-party websites or services.

We are not responsible for the privacy practices of those third parties.

You should review the relevant third party's privacy notice before providing personal information to them.

## 17. CHANGES TO THIS PRIVACY NOTICE

We may update this Privacy Notice from time to time to reflect changes to our business, technology, services or legal obligations.

The latest version will be published on our website together with its effective date.

## 18. CONTACT AND COMPLAINTS

If you have questions or concerns about how we process your personal data, please contact:

**Pure & Simple Ltd**
Enterprise Centre
6 David Lane
Basford
Nottingham
NG6 0JU
United Kingdom

**Data protection:** [data@pureandsimple.company](mailto:data@pureandsimple.company)
**Customer support:** [support@pureandsimple.company](mailto:support@pureandsimple.company)
**Telephone:** +44 115 987 5773

If you are unhappy with how we have handled your personal data, please contact us first so that we have an opportunity to investigate and resolve your concern.

You also have the right to complain to the **Information Commissioner's Office (ICO)**.

**ICO website:** https://ico.org.uk/

**ICO telephone:** 0303 123 1113

**ICO postal address:**
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

**ICO registration reference:** [ZC258555]

**Last updated: September 2026**