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Privacy Policy

This Privacy Policy applies to personal data collected through the Website https://www.asda-photo.co.uk (the “Website”). Photo-Me Retail (“PMR”), with registered office at 3B Blenheim Road Longmead Industrial Estate Epsom Surrey KT19 9AP and registered with the register of legal entities under the number 735438 is the Controller for the processing of your personal data for the purposes of executing your order and managing the website, as further described below. PMR will collect your Personal data in accordance with this Privacy Policy and applicable laws, notably with the General Data Protection Regulation (Regulation (EU) 2016/679). The following terms “Personal data”, “Processing”, “Controller”, “Processor”, “Data protection authority” take the definitions given by article 4 of the General Data Protection Regulation (Regulation (EU) 2016/679).

1. Which personal data is collected?

Information collected about you via the website
PMR collects information about your computer hardware and software and uses cookies. The main categories of personal data processed are: your IP address, browser type, domain names, access times and referring Web site addresses.

Information collected about you when you register or order a product on the Website
When you register for an account on the Website or when you decide to order without creating an account, PMR collects personal data about you in order to execute your order. The main categories of collected data processed are: name, email, phone number, home & delivery addresses and the digital media you upload to the Website.

If you have an account, other personal data will be processed. The main categories of data processed are: the information you provided for your order (photos, product, price, date of the order), name, email, phone number, home & delivery addresses, delivery process & preferences, history of purchases, projects (un-ordered gifts), photos in storage, account passwords & contact preferences.

Information collected about you indirectly
When you personalise a product, whether you have an account or not, the Website allows you to upload photos from a personal storage (PC, laptop, smart phone, tablet, external hard drives, local networks and cloud storage), from your social network accounts or online profile (Facebook, Instagram, Flickr, Dropbox, Google Photos, My Photos).

Uploading a photo by any of these means on the Website gives PMR access to personal data about you. The main categories of collected data are: digital images. A digital image is a file which contains, at least, image data and may also include associated metadata, eg. camera details, editing software, copyright notices, GPS data and colour profiles. Common formats that we deal with include JPEG, HEIF, WEBP, SVG, PDF and PSDs. We store the unaltered file that you upload for as long as is required (based on usage/customer intent) - it is up to you to ensure that you remove any metadata or details that you do not wish to share before uploading the file.

2. What are the purposes for processing and what is the legal basis?

Your personal data will be processed for the following purposes and in accordance with the legal basis set out below.

Purposes Legal basis
Processing your order and the delivery of the products purchased by you, including the management of electronic pictures provided, and providing you with information about the storage, the printing and the shipping of media & personalised gifts.
Contacting you for order status changes and for Customer Service issues
The need to execute the purchase contract with you
Creating your personal account The need to perform the contract with you for the access and the use of the website
Managing and providing the Website (please see our cookie policy) Our legitimate interest to provide a Website
Performing statistics on the use of the Website (please see our cookie policy) to improve the quality of our website Your consent
Allowing you to participate in interactive features of our service, when you choose to do so Our legitimate interest to improve the quality of our website and of our products and services and to better communicate with you concerning our services and products

3. Who are the recipients of your data?

Your data will be used by authorised employees of PMR when necessary for carrying out the above listed purposes.

If you agree to receive direct marketing communication from ASDA, your personal information will be communicated to our business partner ASDA. ASDA is the Controller of the processing of your personal data for direct marketing purposes. If you want more information about the way ASDA processes your data, please see their privacy policy available here: https://www.asda.com/privacy/

Your payment data is securely processed by Payment Sense, please see their privacy policy available here: https://www.paymentsense.co.uk/legal/privacy/

PMR transmits your personal data to LiveLink Technology Limited which is PMR’s Processor and is authorized to process your personal data on behalf of PMR and according to PMR’s instructions. Data provided to LiveLink Technology Limited may be disclosed to other businesses for provision of services in the purchase contract. LiveLink Technology Limited requires all such third-parties to treat personal information as confidential and to comply with General Data Protection Regulation (GDPR) and consumer legislation in place at any given time. Please see their privacy policy available here: http://www.livelinktechnology.net/about/privacy-policy

PMR also discloses some of your personal information to its delivery services when it is necessary to ensure the good delivery of your purchased products.

PMR may disclose information it collects about you if required by applicable law or to comply with a court order or an order from a public authority.

Any disclosure will be done in accordance with applicable data protection laws, and with the General Data Protection Regulation (Regulation (EU) 2016/679) to ensure the protection of your personal data.

4. How long will your personal data be retained?

Personal data, order data & financial transaction data will be kept for 7 years.

Digital image data will be kept for the following:

  • Digital media and associated data uploaded to the website will be stored on the LiveLink Technology Ltd servers for up to 60 days whether an order is placed or not.
  • Images are not retrievable once uploaded to the website, except for printing – and all images will be automatically deleted.
  • Images will be retrievable once uploaded to the ‘My Albums’ section of your account on the Asda-photo.co.uk website for as long as customers sign into their account at least every 60 days. After 60 days images will be deleted after a notification email has been issued to the account holder.

  • 5. Transfers outside of the European Economic Area

    PMR & its data processor do not transfer personal data outside of the E.E.A.

    6. Security

    PMR will implement appropriate technical and organizational measures alongside LiveLink Technology to ensure an appropriate level of security regarding the risk incurred and protect your personal data against unauthorized access, disclosure, alteration or destruction.

    7. What are your rights? How can you exercise them?

    Under applicable Data Protection Law, notably the General Data Protection Regulation (“GDPR”) you have a number of rights with regard to your personal data. Those rights are as follows:

    Right to Access – You can ask to see the personal information PMR holds about you. In connection with a request, we may request specific information about you to enable us to confirm your identity and right access, as well as search for and provide you with the personal information PMR holds about you. In the event we cannot provide you with access to your personal information (for instance, personal information may have been destroyed, erased or made anonymous), we will inform you of the reasons why.

    Correction or Deletion of Personal Information – PMR works to ensure that personal information in its possession is accurate, current and complete. If you think that the personal information PMR holds on you is incorrect, inaccurate, incomplete or outdated, you may request the revision or correction of that information. If it is determined that personal information is inaccurate, incomplete or outdated, we will revise it.

    Withdrawal of Consent – If you have provided consent for the processing of your data, you have the right to withdraw that consent at any time which will not affect the lawfulness of the processing before your consent was withdrawn.

    Objection to processing – You have the right to object to the processing of your personal data including profiling, on grounds relating to your particular situation as provided by Data Protection law.

    When profiling is related to direct marketing you always have a right to object to the profiling.

    Limitation to processing – You have the right to obtain from us restriction of processing in certain instances as provided by data protection law.

    Right to data portability – You have the right to receive the personal data, which you have provided to us, in a structured, commonly used and machine-readable format when the processing is based on your consent or on a contract. You also have the right to ask us to transmit it to another data controller of your choice.

    Complaints – You have the right to lodge a complaint to the Data Protection Authority in the country where you live or work, if you believe that PMR has not complied with the requirements of the GDPR with regard to your personal data

    If you wish to exercise one of your rights, please send a request in this regard via email to: DataProtection@photo-me.com

    8. Cookies

    PMR uses a number of different cookies.

    A cookie is a small text file that may be placed on your device when you visit the Website. When you next visit the Website the cookie allows us to distinguish you from other users.

    Cookies can be Persistent cookies that remain on your device until deleted manually or automatically, or Session cookies that remain on your device until you close your browser.

    Cookies we use and why we use them

    Essential cookies
    Essential cookies are technical cookies that are required for the operation of our sites. Without essential cookies our sites can’t operate properly. Essential cookies include, for example, cookies that enable you to log into secure areas.

    Performance cookies
    Performance cookies allow us to recognise and count the number of visitors to our sites and to see how visitors move around them. This helps us to improve the way our sites work by enabling us to tailor our sites to the way visitors use them. The information we collect from performance cookies is aggregated which means that we cannot identify you from it.

    Experience cookies
    Experience cookies allow our sites to remember the choices you make. Our sites use experience cookies to provide you with enhanced and personalised features. For example, we use information collected through what are known as “web-analytic” cookies to compare the choices you make to those of our other customers so that we can learn from those choices.
    Information collected by experience cookies cannot track your browsing activity when you leave our sites to browse other sites.

    Marketing cookies
    Marketing cookies record your visits to our sites, the pages you have visited and the links you have followed. We use this information to make our sites and the advertising displayed on them more relevant to your interests. For example sometimes we use marketing cookies to limit the number of times that you see an advert. Sometimes we share information about your browsing activity, which we have collected from cookies, with our advertising partners. They may use this information to advertise products, which may interest you, on other sites.

    Your right to refuse cookies and what happens if you refuse them
    You can refuse cookies by activating the relevant setting on your browser. However, if you do so you may not be able to access all or parts of our sites. If you carry on using our sites and do not change your browser settings we will assume you consent to us using cookies as described above.