Privacy Policy

Background

Supaphoto Ltd appreciates that your privacy is important to you and that it is important to you how your personal data is used and shared online. We respect and value the privacy of everyone who enters this website, www.freshpath.co.uk (“Our Site”) and will only gather and utilise personal data in ways that are described below and in a way that is consistent with our obligations and your rights under the law.

Please read this Privacy Policy and make sure that you understand all its contents. Your acceptance of Our Privacy Policy is deemed to have been given upon your first use of Our Site and you will be obliged to read and accept this Privacy Policy when registering for an Account. If you do not accept and agree with this Privacy Policy, you must leave Our Site straightaway.

1. Interpretation

1. In this Policy, the following expressions have the following definitions:

2. About Us

1. Our Site is owned and operated by Supaphoto Ltd, a limited company registered in England, whose registered address is 113 Valley Drive Brighton BN1 5LG,  United Kingdom. United Kingdom and whose main trading address is 113 Valley Drive Brighton BN1 5LG. United Kingdom

    

2. Our Data Protection Officer is P Epifanoff and can be contacted by email at info@freshpath.co.uk or by post at Supaphoto Ltd. Supaphoto Ltd. 113 Valley Drive Brighton BN1 5LG,  United Kingdom.
   

    

3. What Does This Policy Cover?

This Policy applies solely to your usage of Our Site. Our Site may include links to third party websites. We do not have independent control over how your data is collated, stored, or utilised by third party websites and We advise you to read the privacy policies of any such websites before giving any personal data to them.

4. Your Rights

1. As a data subject, you have certain  legal rights under the GDPR as specified below, which this Policy and Our use of personal data have been designed to uphold:

   1. The right to be informed about our collection and use of personal information and data;

   2. The right of access to any personal  information or data we hold about you (see section 12);

   3. The right to correction if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 14);

   4. The right to be forgotten – i.e. the right to request Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 14);

   5. The right to restrict (i.e. prevent) the use or processing of your personal data;

   6. The right to data portability (being transmitted a copy of your personal data to re-use with a third party organisation);

   7. The right to object to Us utilising your personal data for specific means; and as a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:

   8. Rights with respect to automated decisions and profiling.

2. If you have any reason for complaint about Our use of your personal information, please write to Us using the contact details provided in section 14 and We will do Our utmost to resolve the issue for you. If We are not in a position to help, you also have the right to file a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.

3. For additional information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.

    

5. What Data Do We Collect?

Subject  to your use of Our Site, We may gather some or all of the following personal and non-personal data (please also see section 13 on Our use of Cookies and similar technologies and Our Cookie Policy:

1. name

2. date of birth

3. gender

4. business/company name

5. job title

6. profession

7. contact information such as email addresses and telephone numbers

8. demographic information such as post code, preferences, and interests

9. financial information such as credit / debit card numbers

10. IP address

11. web browser type and version

12. operating system

13. a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to

     

6. How Do We Use Your Data?

1. All personal data is processed and stored securely, for a period of time no longer than is required considering the reason(s) for which it was first collected. We will comply with Our obligations and protect your rights under the Data Protection Act 1998 or GDPR at all times. For more details on security see section 7.

2. Our use of your personal data will without exception have a lawful basis, either because it is required for Is in performing our obligations under a contract with you, because you have accepted Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following objectives:

    

   1. Providing and administering your Account;

   2. Giving you access to Our Site and managing that access;

   3. Personalising your user experience on Our Site;

   4. Supplying Our products and/or services to you (please note that We require your personal data in order to contract with you);

   5. Customising and tailoring our products and/or services for you;

   6. Responding to emails from you;

   7. Supplying you with electronic messages that you have opted into (you may unsubscribe or opt-out at any time through the link clearly laid out at the bottom of such messages;

   8. Market research and analysis;

   9. Examining your use of Our Site (and collecting feedback) to allow Us to regularly improve Our Site and your user experience

       

3. With your permission and/or where allowed by law, We may also utilise your data for marketing which may involve contacting you by email and/or telephone and/or text message and/or post with information, news and offers on our products and/or services. We will not send you any unwarranted marketing correspondence or ‘spam’ and will take all reasonable steps to protect completely your rights and comply with our obligations under the Data Protection Act 1998 or GDPR and the Privacy and Electronic Communications
   (EC Directive) Regulations 2003.

    

4. Third parties whose content is included on Our Site may utilise third party Cookies, as specified below in section 13. Please read section 13 for more information on controlling Cookies. Please note that We do not control the activities of such third parties, nor the information they collect and use and advise you to check the privacy policies of any such third parties.

    

5. You have the right to rescind your consent to Us using your personal data at any time, and to communicate your wish to Us that that We delete it.

    

6. We do not keep your personal data for any longer than is required in light of the purpose(s) for which it was first collected. Data will therefore be stored for the following periods (or its retention will be determined on the following bases):

   1. Data will be stored on an continuous basis for active customers to enable us to service our customer’s needs. At any time our customers can contact us and request us to discontinue holding data at which point we will ensure data is deleted within 1 month of request. Contact data for businesses that have yet to purchase goods or services but that are in continuing contact with Us will be retained for the purpose of contact and at every point of email contact the option for contacts to remove themselves from future correspondence will be patently available.

       

7. The Storage of your Data?

1. We only store your personal data for as long as We require to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.

2. Your data will only be stored in the UK

3. Your data will only be stored within the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein).

4. Some or all of your data may be stored outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the Data Protection Act 1998 or GDPR

5. Data security is of great significance to Us, and to protect your data We have taken the requisite measures to safeguard and secure data collected through Our Site.

6. Steps We take to secure and safeguard your data include:

    

   1. If you post a comment to a blog post published on this website some personal information will be retained within this website’s database. This is currently the only instance where personal data will be stored on this site. This data is currently stored in an identifiable way; a limitation of the content management system that this website has been designed on (WordPress). In the near future we seek to modify the storage of this data to a pseudonymous fashion meaning that the data would require extra processing using a separately stored ‘key’ before it could be utilised to identify an individual. Pseudonymisation is a recent obligation imposed by the GDPR which many web application developers are currently working to implement in full. We are committed to maintaining it as a high priority and will implement it on this website as soon as we are able to.

       

   2. Standard Web Hosting is based on a shared hosting on dedicated web servers located in one of two data centres located in the UK. Hosting: We man these data centres 24/7 and ensure security, from the physical controls stopping unauthorised access within the data centre to the system teams securing the network and platforms.
      
      

       

8. Do We Share Your Data?

1. Subject to section 8.2, We will not share any of your data with any third parties for any means whatsoever.

2. In certain situations, We may be legally required to share certain information held by Us, which may include your personal data; for instance, where We are a party to legal proceedings, where We are complying with legal obligations, a court order, or a governmental authority

3. We may sometimes contract with third parties to provide products and services to you on our behalf. These may include payment services, consignment of goods, search engine facilities, advertising, and marketing. In some cases, the third parties may need access to some or all of your data. Where any of your data is needed for such a purpose, We will take all reasonable steps to ensure that your data will be processed and stored safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.

4. We may gather statistics about the use of Our Site including data on traffic, usage patterns, visitor statistics, sales, and other information. All such data will be anonymised and will not comprise any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may occasionally share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and utilised within the bounds of the law.

5. The third party data processors used by Us and specified below are located or we may sometimes use third party data processors that are situated outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where We transfer any personal data outside the EEA, We will take all reasonable steps to ensure that your data is handled as safely and securely as it would be within the UK and under the Data Protection Act 1998 or GDPR including:

   1. Google

   2. Campaign Monitor

6. In certain instances, We may be legally obliged to share certain data held by Us, which may include your personal data, for instance, where We are party to legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.

    

9. What Happens If Our Business Changes Ownership?

1. We may, from time to time, increase or decrease Our business and this may involve the sale and/or the transfer of ownership or control of all or part of Our business. Any personal data that you have supplied will, where it is relevant to any part of Our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be entitled to use that data only for the same purposes for which it was originally collected by Us.

2. In the event that any of your data is to be transferred in such a way, you will not be informed in advance of the changes. When contacted you will not, however be given the choice to have your data deleted or withheld from the new owner or controller.

    

10. How Can You Retain Control Over Your Data?

Further to your rights under the GDPR 4, when or when you provide personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We intend to give you strong controls on Our use of your data for direct marketing purposes (including the possibility to opt-out of receiving correspondence from Us which you may do by unsubscribing using the links given in Our emails and at the point of providing your details and by managing your Account).

1. In addition, you may  want to sign up to one or more of the preference services working in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may enable you to prevent the receipt of unsolicited marketing. Please note, however, that these services will not stop you from receiving marketing communications that you have agreed in advance to receiving.

    

11. Your Right to Withhold Data

1. You may access specific areas of our Site without supplying any data at all. However, to utilise all features and functions on Our Site you may need to submit or permit the collection of certain data.

2. You may control Our use of Cookies. For more information, see section 13 and Our Cookie Policy.

    

12. Gaining Access To Your Data?

You have the right to request a copy of any of your personal data stored by Us (where such data is held). Under the GDPR, no fee can be demanded in exchange and accordingly We will provide any and all information in response to your request free of charge. Please contact us for more information at info@freshpath.co.uk, or using the contact details below in section 14. Alternatively, please refer to Our Data Protection Policy

13. Cookies on this Site

1. Our Site may store and access certain first party Cookies on your computer, smartphone or device. First party Cookies are those placed directly by Us and are used only by Us. We deploy Cookies to facilitate and ameliorate your experience of Our Site and to supply and improve Our products and/or services. We have carefully selected these Cookies and have taken steps to ensure that your privacy and personal data is safeguarded and respected at all times.

2. By using Our Site you may also retain certain third party Cookies on your computer, smartphone or device. Third party Cookies are those placed by websites, businesses, and/or parties other than Us. Third party Cookies are utilised on Our Site for Google, Campaign Monitor. For more details, please refer to section 6 and to section 13.6 below. These Cookies are not intrinsic to the working of Our Site and your user experience of Our Site will not be diminished by withholding consent to them.

3. All Cookies utilised by and on Our Site are used in accordance with current Cookie Law.

4. Before Cookies are stored on your computer or device, you will be shown a prompt or banner at the bottom of the site requesting your consent to those Cookies. By giving your consent to the placing of Cookies you are allowing Us to design the best possible experience and service to you. You may, if you wish, refuse consent to the placing of Cookies; however certain features of Our Site may not function fully or as desired. You will be given the chance to allow only first party Cookies and prevent third party Cookies.

5. Certain features of Our Site require Cookies to function. Cookie Law  specifies that these Cookies are “strictly necessary”. These Cookies are listed below in section 13.6. Your consent will not be requested to place these Cookies, but it is still important that you know of their existence. You may still prevent these Cookies by updating your internet browser’s settings as specified below in section 13.10, but please note that Our Site may not function correctly if you do so. We have taken great care to ensure that your privacy is not at risk by accepting them.

6. These listed first party Cookies may be stored on your computer or device:

7. Please note that third parties (including, for instance, advertising networks and providers of external services like web traffic analysis services) may also utilise cookies, over which we have no control. There is a high probability that these cookies are analytical/performance cookies or targeting cookies.
   
   You block cookies by updating the setting on your browser that enables you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including strictly necessary cookies) you may lose access to all or parts of our site.
   
   Except for strictly necessary cookies which are specified in the table above and will remain for 1 year, all cookies will expire after the session.

8. Our Site uses analytics services created and supplied by Google Analytics. Website analytics relates to a set of tools used to collect and analyse anonymous usage information, allowing Us to better appreciate how Our Site is utilised. This consequently allow Us to enhance Our Site and the products and/or services provided. You do not have to consent to Our use of these Cookies; however, though Our use of them does not offer any risk to your privacy or your safe use of Our Site, it does allow Us to regularly improve Our Site, making it a better and more enhanced experience for you.

    

9. The analytics service(s) used by Our Site use(s) Cookies to gather the required information.

10. The analytics service(s) used by Our Site use(s) the following Cookies:

11. In addition to the controls that We furnish, you can elect to enable or disable Cookies in your internet browser. Most internet browsers also allow you to select whether you wish to disable all cookies or simply third party Cookies. By default, the majority of internet browsers accept Cookies but this can be modified. For additional details, please check the help menu in your internet browser or the documentation that was provided with your device.

12. You can select to remove Cookies from your computer or device at any time, however you may lose any data that allows you to visit Our Site more expediently and efficiently including, but not limited to, login and personalisation settings.

13. We strongly suggest that you keep your internet browser and operating system up-to-date and that you check the help and guidance included by the developer of your internet browser and manufacturer of your computer or device if you are unsure about modifying your privacy settings.

     

14. Contact
If you have any questions about Our Site or this Privacy Policy, please write to Us via email at info@freshpath.co.uk  by post at Supaphoto Ltd. 113 Valley Drive Brighton BN1 5LG,  United Kingdom. Please make sure that your query can easily be understood, especially if it is a request for information about the data We have stored about you (as under section 12, above).

15. Modifications to Our Privacy Policy
We may modify this Privacy Policy from time to time (for instance, if the law changes). Any modifications will be immediately posted on Our Site and you will be assumed to have accepted the terms of the Privacy Policy on your first use of Our Site following the changes. We recommend that you read this page at regular intervals to keep up-to-date.