We may use Data Processors who act on our instruction in relation to the management of your data and they must adhere to all data protection laws and regulations. We will ensure that any Data Processors used only operate on our written instructions and comply with their obligations under the GDPR. You will be informed of any other Data Controllers who have access to your data and who may determine processing activities separately to us, or as a Joint Data Controller.
We will only send you emails about our services, i.e. direct marketing, with your express consent. You have the option not to give consent and to withdraw consent at any time. You may withdraw your consent for us to contact you by contacting us at firstname.lastname@example.org. Non-personally identifiable visitor information may be provided to third parties for marketing, advertising or other uses.
Social Media Platforms
Communication, engagement and actions taken through external social media platforms that this website and its owners participate on are subject to our terms and conditions as well as the privacy policies held with each social media platform respectively.
Users are advised to use social media platforms wisely and communicate and/or engage with them with due care and caution in regard to their own privacy and personal details. This website nor its owners will not ask for personal or sensitive information through social media platforms and encourage users wishing to discuss sensitive details to contact them through primary communication channels such as by telephone or email.
90° East uses social sharing buttons which help share web content directly from web pages to the social media platform in question. Users are advised that before using such social sharing buttons, that they do so at their own discretion, and should consider that the social media platform may track and save requests to share a web page, through the users’ social media platform account.
All payment made to 90° East are processed securely and details are not stored on our servers. Transactions by debit/credit card are processed using SSL technology.
You may be asked for your name, email address, mailing address, phone number and credit / debit card information in order to facilitate and validate payment to us.
We keep your personal information in accordance with our Data Retention Policy which reflects our needs to provide services to you as contracted and also as required to meet legal, statutory and regulatory obligations. The need to hold information is regularly reviewed and data will be disposed of when no longer required.
We take appropriate steps to ensure a safe processing of personal data, however, we cannot guarantee the security of data transmitted through our website or by email. Any transmission is at your own risk.
Our website is hosted by Squarespace.com. Any information that you supply to us may be stored and processed by our servers located in the US. Your data may be transferred in accordance with the relevant data protection laws.
Rights of Data Subjects
90° East recognises a data subjects rights and will uphold these in accordance with data protection laws. You are entitled to see the information held about you and you may ask us about any of the following:
- Subject Access Requests
Data subjects (i.e. individuals) have the right to access personal data that is held by submitting a subject access request (SAR) to 90° East. We will endeavour to respond quickly to any such requests, which legally require us to respond within one month of receiving the request and necessary information. A subject access request can be made by emailing us at email@example.com.
- Right to Rectification
Data subjects have the right to request that we amend or change personal information that is inaccurate or incorrect.
- Right to Erasure
Data subjects have the right to ask us to delete personal information from our systems without giving any reason and at any time. We will act on any such request without delay.
- Right to Restrict Processing
Data subjects have the right to rectification or erasure of personal data in the following circumstances:
Personal data is not accurate;
The processing of data is unlawful - data subjects may request that processing is restricted;
Data is required to exercise legal rights or defend legal claims;
Data is unlawful but there may be lawful grounds for processing, which override this right.
- Right to Data Portability
Data subjects have the right to obtain and request the transfer of their data to different service providers.
- Right to Object
Data subjects have the right to object to the processing of data at any time based on their particular situation. This includes objecting to profiling unless it is in the ‘public interest’ or exercised lawfully by an official authority. We will only process data under lawful grounds.
- Right not to be subject to decisions based on automated processing
We do not use any automated processing that results in any automated decision based on a data subject’s personal information.
Using your Rights
If you wish to invoke any of these rights, you should contact the person responsible for data protection by emailing us at firstname.lastname@example.org.
We will report any unlawful breach of data as required by the GDPR within 72 hours of the breach occurring, if it is considered that there is an actual, or possibility, that data within our control including the control of our data processors, has been compromised. If the breach is classified as ‘high risk’ we will notify all data subjects concerned using an appropriate means of communication. We will report any relevant breaches to the ICO, see below.
What are Cookies
Cookies are small files saved to the user’s computer hard drive that track, save and store information about the user’s interactions and usage of the website. This allows the website, through its server, to provide the user with a tailored experience when navigating the website. Session cookies may be used to validate your access to different parts of the website.
90° East uses tracking software provided by Google Analytics to monitor its visitors, and to better understand how they use the site. See above table. The software will save a cookie to the user’s hard drive in order to track and monitor engagement and usage of the website. The cookie will not store, save or collect personal information.
Cookies used by Google Analytics
The Cookies used by Google Analytics for statistical purposes are shown in this table below.
|_ga||Google Analytics||HTTP||Statistical data on how user uses the website||2 years|
|_gat||Google Analytics||HTTP||Google Analytics use to throttle request rate||Session|
|_gid||Google Analytics||HTTP||Registers unique ID for statistics on website use||Session|
Other Cookies may be used for marketing and other purposes.
Consent to Cookies
Information is also available at www.ec.europa.eu/ipg/basics/legal/cookies/index_en.html.
Questions and Queries
If you have any concerns about how we handle your data, you can contact the Data Controller by email to email@example.com.
Changes to this Policy
If you want to raise a concern about the use of your data, you can contact us by email to firstname.lastname@example.org. Alternatively, you can formally raise a concern or complaint to the Information Commissioner’s Office (ICO) directly on 0303 123 1113, or see the options for reporting issues on https://ico.org.uk/concerns.
Third Party Rights
Jurisdiction and Governing Law.
Copyright © 2019 Sarah Longworth Photography / 90° East.