PRIVACY NOTICE
Surrey Hills Frame Studio, trading name of Lamaron Limited (Company number: 15636815)
1. Who we are
Surrey Hills Frame Studio is the trading name of Lamaron Limited, which is the controller responsible for your personal data.
This Privacy Notice explains how we collect, use, store and share personal data when you visit our website, contact us, make an enquiry, arrange an appointment or use our picture framing services.
If you have any questions about this Privacy Notice or how we use your personal data, please contact us at: privacy@surreyhillsframe.studio
We keep this Privacy Notice under review and may update it from time to time. The latest version will always be available on our website.
2. The information we collect
Depending on how you interact with us, we may collect the following personal data.
Contact and identity information
Your name, email address, telephone number and postal address.
Enquiry and appointment information
Information you provide when you contact us, discuss your framing requirements, request a quotation or arrange an appointment, together with records of our communications with you.
Order and service information
Information relating to the framing services you ask us to provide, including details of your order, specifications, quotations, collection or delivery arrangements and communications concerning your order.
Information relating to items entrusted to us
Information about an item you provide to us for framing, including its description, value, condition and, where appropriate, photographs or other images.
Payment and financial information
Information necessary to process payments and maintain appropriate financial and accounting records. Where payment is processed by a third-party payment provider, we do not generally receive or retain your full payment card details.
Marketing information
Your marketing preferences and records of whether you have consented to receive marketing communications or have opted out of them.
Website and technical information
Information about your use of our website, which may include your IP address, browser type, device information and information collected through cookies, analytics, performance or similar technologies.
Special category data
Special category data is a particular type of personal data which the law gives additional protection because of its sensitive nature. It includes personal data revealing or concerning a person's racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data where it is used for the purpose of uniquely identifying a person, physical or mental health, sex life or sexual orientation. Information about criminal allegations, offences or convictions is not special category data, but is subject to separate legal protections.
We do not generally seek to collect special category data or criminal offence data. You should avoid providing us with such information unless it is genuinely necessary for the services we are providing. If we ever need to process special category data, we will only do so where we have both a lawful basis under the UK GDPR and an applicable additional condition for processing such data.
3. How we collect your information
We may collect personal data:
directly from you when you contact us, make an enquiry, request a quotation, arrange an appointment or place an order;
when you communicate with us by email, telephone or other means;
when you provide an item to us for framing;
when you make or arrange a payment;
when you use our website; and
from third parties where this is necessary to provide services to you or administer our business.
4. How we use your personal data and our lawful bases
We use your personal data only where we have a lawful basis to do so.
Responding to enquiries and arranging appointments
We use your contact details and information about your framing requirements to respond to enquiries, discuss your requirements, arrange appointments and prepare quotations. We rely on our legitimate interests in responding to enquiries and managing prospective customer relationships and, where applicable, on taking steps at your request before entering into a contract.
Providing framing services
We use your personal data and information relating to your item to provide the framing services you have requested, manage your order and communicate with you about the work, including arrangements for collection or delivery. Our lawful basis is the performance of our contract with you or, where applicable, taking steps at your request before entering into a contract as we have a legitimate interest in doing so.
Processing payments and maintaining financial records
We use information necessary to process payments and maintain appropriate invoices, accounting records and other financial records. Our lawful basis is performance of our contract with you and, where applicable, compliance with a legal obligation.
Administering our business
We may use personal data to maintain appropriate business records, deal with complaints and disputes, establish, exercise or defend legal claims, maintain the security of our website, systems and premises, and protect our legitimate business interests. Our lawful basis will generally be performance of our contract with you, furtherance of our legitimate interests or, where applicable, compliance with a legal obligation.
Photographs and images
We may photograph an item you have provided to us where reasonably necessary to record its condition, document the work or assist in providing the framing services. Where this is part of providing the framing service or protecting our legitimate business interests, our lawful basis will generally be performance of the contract and/or legitimate interests. We may also photograph completed framing for our portfolio, website, social media or other promotional purposes. Where this is appropriate, we may rely on our contractual right to do so, our legitimate interests in promoting our business, or on your consent where consent is required.
Marketing
Where you have given us permission to do so, we may use your email address to send you occasional marketing communications about our framing services, studio news and other updates which we think may be of interest to you. Our lawful basis for marketing based on consent is your consent. Where permitted by law, we may also contact existing customers about our own similar services where we can rely on the applicable existing-customer rules. In those circumstances, the lawful basis applicable to the underlying customer relationship may apply, subject to compliance with the Privacy and Electronic Communications Regulations (PECR).
Website operation and cookies
We use personal data and technical information where necessary to operate, secure and improve our website. We rely on legitimate interests, and where applicable another lawful basis permitted by law, for essential website functionality. Where we use non-essential cookies or analytics technologies for which consent is required, we will rely on your consent.
Sale or transfer of the business
If Lamaron Limited sells, transfers or reorganises all or part of its business, we may transfer relevant customer and prospective customer information to the purchaser or relevant successor as part of that transaction. Our lawful basis will generally be legitimate interests and, where applicable, compliance with a legal obligation.
Generally
Where we rely on legitimate interests, we will only process your personal data where those interests are not overridden by your interests, rights or freedoms. Where we rely on consent, you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before consent was withdrawn.
5. Marketing
We would like to be able to keep in touch with customers who are interested in Surrey Hills Frame Studio.
Where you have given us permission to do so, we may use your email address to send you occasional marketing communications about our framing services, studio news and other updates which we think may be of interest to you.
Where permitted by law, we may also contact existing customers about our own similar services where we can rely on the applicable rules relating to existing customer relationships.
You can opt out of marketing communications at any time by using the unsubscribe facility included in our emails, by responding to a communication with the word ‘unsubscribe’ or by contacting us at privacy@surreyhillsframe.studio
We will keep a record of your marketing preferences so that we can respect your decision not to receive marketing communications.
If you opt out of marketing, we may retain limited information on a suppression list so that we can ensure that we do not send you marketing communications in the future.
Electronic marketing is subject to the Privacy and Electronic Communications Regulations (PECR) as well as data protection law. We will comply with the requirements that apply to the type of marketing we undertake.
6. Photographs and images
Where you provide an item to us for framing, we may photograph it where reasonably necessary to record its condition, document the work or assist in providing the framing services.
We may also photograph completed framing for our portfolio, website, social media or other promotional purposes.
We will take particular care with personal and family photographs. We will not publish identifiable family photographs or similar personal images for promotional purposes without your express permission.
Where you provide an image or other material to us, you confirm that you are entitled to provide it to us for the purposes of the framing services and that our handling of it for those purposes does not knowingly infringe the rights of any third party.
Where we propose to use an image for a promotional purpose and a specific permission is required, we will seek that permission separately, unless such permission has already been obtained via our Terms of Business.
7. Who we share your personal data with
We do not sell your personal data.
We may share personal data where reasonably necessary with trusted third parties who help us operate our business or provide services to you. Depending on the circumstances, these may include:
website and hosting providers, including Squarespace;
email, IT and cloud service providers, including Microsoft;
payment service providers, including Square;
delivery or courier services where delivery has been requested;
suitably qualified specialist contractors or other service providers involved in providing the framing services;
professional advisers, insurers and other advisers where reasonably necessary; and
other organisations or authorities where disclosure is required or permitted by law.
We may disclose personal data where we are required or permitted to do so by law. This may include providing information to:
courts or tribunals;
the police or other law enforcement authorities;
government departments or agencies;
regulators and supervisory authorities;
HM Revenue & Customs or other tax authorities; or
other public authorities or bodies with a lawful right to request or receive the information.
We may also disclose personal data where reasonably necessary to establish, exercise or defend our legal rights or the legal rights of another person, including in connection with actual or prospective legal proceedings, obtaining legal advice, preventing or detecting crime, or protecting our business, property or other legitimate interests.
Where a third party processes personal data on our behalf, we will take appropriate steps to ensure that the processing is carried out in accordance with applicable data protection law.
8. Sale or transfer of the business
If Lamaron Limited sells, transfers or reorganises all or part of its business, we may transfer personal data relating to customers and prospective customers to the purchaser or relevant successor as part of that transaction.
Any such transfer will be carried out in accordance with applicable data protection law.
The information transferred may include customer and prospective customer contact details, order and transaction records, correspondence, and information reasonably required to enable the purchaser or successor to continue the business and provide services to existing and prospective customers.
The purchaser or successor will become responsible for the personal data transferred to it and will be required to comply with applicable data protection law.
9. International transfers
Some of the service providers we use may process personal data outside the United Kingdom.
Our principal service providers currently include Squarespace, Microsoft and Square. These providers may process or store personal data in countries outside the United Kingdom, including the United States.
Where our use of a service provider involves a restricted transfer of personal data outside the United Kingdom, we will ensure that the transfer is made in accordance with applicable UK data protection law and that an appropriate transfer mechanism and safeguards are in place.
Depending on the circumstances, this may include reliance on UK adequacy regulations, the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses, or another lawful transfer mechanism.
The particular providers and services we use may change from time to time. We will update this Privacy Notice where appropriate if changes materially affect how your personal data is processed or transferred.
10. How long we keep your personal data
We keep personal data only for as long as reasonably necessary for the purpose for which it was collected.
As a general guide, our normal retention periods are as follows.
Enquiries which do not result in an order
We will normally retain these for up to 12 months after our last communication with you.
Appointment and consultation records which do not form part of an order
We will normally retain these for up to 12 months after the appointment.
Customer and order records
We will retain these during our relationship with you and normally for up to 7 years after our last transaction.
Invoices, payment and accounting records
We will retain these for at least 7 years from the end of the relevant financial year, or for such longer period as applicable law requires.
Records relating to complaints, disputes or legal claims
We will retain these for as long as reasonably necessary to deal with the matter and, where appropriate, to establish, exercise or defend legal claims.
Marketing records and preferences
We will retain these until you withdraw your consent or opt out, subject to retaining limited information on a suppression list so that we can ensure that we do not send you further marketing communications.
Photographs taken solely for business or condition records
We will normally retain these for as long as the related customer or order records are retained, unless they are no longer required sooner.
Photographs used for promotional purposes
We will retain these for as long as reasonably necessary for the promotional purpose. If you ask us to remove a photograph and we are required or agree to do so, we will take appropriate steps to remove it from our active promotional use, subject to any copies that we are required to retain for legal or other legitimate purposes.
Generally
These periods are our normal retention periods rather than absolute rules. We may retain information for longer where necessary to comply with a legal obligation, establish, exercise or defend legal claims, deal with a complaint or dispute, or where another lawful reason requires or permits us to do so.
We may also retain limited information after you have asked us to delete your data where this is necessary to comply with a legal obligation or to maintain a suppression record so that we can respect a marketing opt-out.
When personal data is no longer required, we will securely delete it or anonymise it where appropriate.
11. Cookies and similar technologies
Our website is hosted on Squarespace. Our website may use cookies and similar technologies which are necessary for the operation, security and functionality of the website. We may also use analytics or other non-essential technologies to understand how visitors use our website and improve it. Where consent is required for a particular cookie or similar technology, we will obtain that consent before using it.
The cookies and similar technologies used on our website may change as we add, remove or modify website functionality. We will provide appropriate information about the technologies in use and, where required, provide a means of giving, refusing or withdrawing consent.
You can also control or restrict cookies through your browser settings.
Where third-party technologies are used, the relevant third party may also process information in accordance with its own privacy policy.
You can find more information about cookies here.
12. Your rights
Under data protection law, you may have the right to:
ask us for a copy of the personal data we hold about you;
ask us to correct inaccurate or incomplete personal data;
ask us to delete your personal data where there is no good reason for us to continue processing it;
ask us to restrict how we use your personal data in certain circumstances;
object to processing where we rely on legitimate interests as our lawful basis;
object at any time to the use of your personal data for direct marketing;
ask us to provide certain personal data to you or another organisation in a portable format where the right applies; and
withdraw your consent where we rely on consent as our lawful basis.
These rights are subject to certain exceptions and conditions under data protection law.
In particular, you have an absolute right to object to the processing of your personal data for direct marketing purposes.
You can exercise your rights by contacting us at: privacy@surreyhillsframe.studio
We may need to ask for information to verify your identity before dealing with a request.
We will normally respond to a valid request within one month, subject to any applicable extensions permitted by law.
13. Complaints
If you have concerns about how we have handled your personal data, we would encourage you to contact us first so that we have an opportunity to address your concerns.
You also have the right to complain to the Information Commissioner's Office (ICO), the UK's data protection supervisory authority.
Further information about making a complaint is available from the ICO's website.
14. Contact us
If you have any questions about this Privacy Notice, how we use your personal data, or wish to exercise any of your rights, please contact:
Lamaron Limited, Trading as Surrey Hills Frame Studio
Email: privacy@surreyhillsframe.studio
Postal address: Unit 6, Dunley Hill Court, Ranmore Common, Dorking, RH5 6SX