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This sample document is for example use only. It contains placeholder fields which are customized to each client’s specific activation and requirements.

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WHO WE ARE

[THIS PHOTOBOOTH / THIS TECHNOLOGY./ THIS WEBSITE / INSERT LINK TO PHOTOBOOTH / INSERT LINK TO VIRTUAL-VID] is operated by Noonah Marketing Limited (we or us).

We are a private limited company registered in England and Wales under company number 7619471, and have our registered office and main trading address at Underwood Cottage, Bar Road, Baslow DE45 1SF United Kingdom. For details on how to contact us, please see our Contact Us page https://noonah.com/contact-us/ 

Noonah Marketing Limited is the data processor in relation to any personal data you provide to us through this [WEBSITE / SERVICE]. This means that we will only handle your personal data in accordance with the strict instructions of [[ HIRER ]], the data controller, and subject to the terms of our contract with them.

[[HIRER]], as data controller is responsible for your personal data. Please refer to their privacy policy at [[ HIRER’S PRIVACY POLICY ]] for details about how your personal data will be processed, and what instructions they have given us in relation to processing your personal data. We are not responsible for [[ HIRER ]]’s, use of your personal data or for any actions they may take in relation to it. You are advised to check the terms of their privacy policy before you submit any content to our website.

The purpose of this privacy statement is to inform you about how we, as data processor, will deal with your personal data when you [USE OUR SERVICE / VISIT OUR WEBSITE (regardless of where you visit it from)]. It gives you information on how we will collect and process your personal data through your use of our service, including any data you may provide to:

register as a user;

view or share a photo / video you have created on website, in a video booth or kiosk, or post any other material on our website (such as images, graphics, text or other content);

view a photo / video someone else has made;

participate in discussion boards or other social media functions or interactive services on our website;

use the services on our website, for example to upload content from an external device, or edit content where you have been given the appropriate access to enable you to do so; or

share content to third party social media platforms through our website.

THIRD PARTY LINKS

Our website may include links to third party websites (including social media platforms), plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third party websites, and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Introduction

Welcome to [HIRER] privacy policy.

We respect your privacy and are committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you come into contact with the company.

 

  • Purpose of this privacy policy

 

This privacy policy aims to give you information on how we collect and process your personal data during and after your relationship with us, in accordance with the General Data Protection Regulations (GDPR).

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

 

  • Controller

 

[HIRER] is the controller and is responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy policy).

 

  • Processor

 

We enlist the services of Noonah Marketing Limited to collect and process your personal data on our behalf. The collection and processing carried out by Noonah Marketing Limited is detailed in this privacy policy.

 

  • Contact details

 

If you have any questions about this privacy policy, please contact [HIRER CONTACT DETAILS]

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

 

  • Changes to the privacy policy and your duty to inform us of changes

 

We keep our privacy policy under regular review.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

 

  • The data we collect about you

 

Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

During our relationship with you, we may (or may instruct our Processor to) collect, use, store and transfer different kinds of personal data about you, including:

Identity data: includes first name, last name, title, date of birth, gender and photographs, username or similar identifier, social media tokens provided to us by a social media site, and may include a photograph or video of you or other content such as text or comments (if you have provided these to us via the website, a video booth or kiosk, or via an upload from an external device).

Contact data: includes email address, your postal address and telephone numbers.

Profile data: includes usernames and use of social media sites.

Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

Usage Data includes information about how you use our website.

Aggregate Data We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data, but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy statement.

Marketing data: includes your preference in receiving marketing from us and your communication preferences.

We do not collect any special categories of personal data about you nor do we collect any information about criminal convictions and offences.

Please note that if you:

post content on our website that includes a third party’s personal data (for example if they can be identified in a video posted by you);

provide us with a third party’s email address or sms number, so that we can send them a link to content you have provided that you would like to share with them,

then you are solely responsible for obtaining the consent of that third party to their personal data being provided to us in this way.

 

  • If you fail to provide personal data

 

If you fail to provide your personal data, we will be unable to provide you with our services or marketing material. 

 

  • How is your personal data collected?

 

We enlist the services of our data processor to collect your personal data. Your data is collected via your direct interaction with a service provided on our behalf, such as:

Your use and interaction with a photobooth or other electronic equipment which takes your photograph;

Your use and interaction with interactive digital media, which may take your photograph and/or collect your identity, contact and marketing data.

Some services may permit the sharing of your identity data (photographs) to social media or microsites. Where this service is available, you will be asked to input your email address and/or telephone number for this service to be provided. 

Direct interactions. You may give us your Identity and Contact Data by supplying them via a website or a video booth / kiosk at an event organised by [[ HIRER ]], or by uploading them to our website from an external device. Alternatively, you may have provided this information to us by registering on our website, or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

create and upload photos or videos on our website;

use a video booth / kiosk or upload content from an external device;

search for a video or photograph on our website;

contact us for user support, for example if you have a query about our service, or cannot find the video you are looking for;

register to use our website;

visit our website in order to view or share a video (whether the video is one you created, one which you have been invited to view, or which you have browsed via a gallery).

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy https://noonah.com/cookies-policy/ for further details.

Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:

Technical Data from the following parties:

analytics providers such as Google based outside the EU.

 

  • How we use your personal data

 

We will only use your personal data when the law allows us to, and we act at all times only the instructions of the data controller. Most commonly, we will use your personal data in the following circumstances:

To provide you with the services you require when you use our website, for example to enable you to register on our website, to find and view a video or photo, or to share it with a third party;

Where we have obtained your consent to process your personal data in order to provide you with a service or marketing material;

Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;

Where we need to comply with a legal or regulatory obligation.

 

  • Purposes for which we will use your personal data

 

We have set out below all of the ways we envisage using your personal data, along with the lawful reason on which we rely. 

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. 

 

Type of data Processing activity Retention period Lawful basis 
Personal Data [[PERSONAL DATA WILL BE SPECIFIC TO HIRER REQUIREMENTS ]] [[ DATA RETENTION DURATION TO BE SPECIFIED BY THE HIRER]] days Consent 
Media [[ MEDIA TYPE WILL BE SPECIFIC TO YOUR ACTIVATION ]] [[ MEDIA RETENTION DURATION TO BE SPECIFIED BY THE HIRER]] days Consent, legitimate aim (to promote our business and brand)

 

 

  • Withdraw consent

 

Where we are processing your personal data solely on the basis of your consent, you are entitled to withdraw your consent to that processing at any time by contacting us on the details provided above.

 

  • Disclosures of your personal data

 

We may share your personal data with the parties set out below for the purposes set out above.

Our provider of hosting services, currently 

Virtual-Vid – Memset Limited https://www.memset.com/about-us/datacentre/ as your personal data will be stored on their UK server. 

Virtual Photo Booth – Webhosting UK COM Ltd, a company registered in England and Wales under Companies House registration number 6471390. as your personal data will be stored on their UK server. 

[[ HIRER ]], as they are the data controller in relation to your personal information, and we only handle your personal information on their behalf and as instructed by them. Where you make use of the services on our website (for example, if you are attending an event or venue and your submit video, photographs or other content for that company’s secured area of our website), any content you contribute may be shared with the company in question, its employees and agents, and with any other individuals who have participated in the same secured area of the website. 

Please note that [[ HIRER ]], may feature the content you contribute in a public gallery on their website. Please refer to their privacy policy for further details.

If you have submitted content to our website, and have provided us with one or more email addresses or sms numbers of third parties with whom you would like us to share that content, we will use those email addresses and sms numbers to send the third parties in question a link to the content to enable them to view it.

If you have submitted content to our website, and you have decided to share that content with your social media networks, or [[ HIRER ]], decides to share it with its social networks, that content will be made available to the social networks in question.

We may offer an RSS feed and API on our website, which [[ HIRER ]], can use to pull in content such as photos and videos to populate their own online galleries or slideshows. Please refer to their privacy policy for further details.

External third parties, including third party IT and technical support providers, customer relationship management systems and marketing and design companies.

Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owner may use your personal data in the same way as set out in this privacy policy.   

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specific purposes and in accordance with our instructions. 

International transfers

We do not envisage transferring your data outside of the European Economic Area (EEA). However, if the need arises, we will ensure that a similar degree of protection is afforded to your personal data. Please contact us if you would like further information in relation to such transfers

 

  • Data security

 

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

  • Data retention

We will only retain your personal data for as long as we are required to do so by [[ HIRER ]], in accordance with their instructions:

We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.

To determine the appropriate period for personal data, we consider the amount, nature and sensitivity of the personal data, potential risk of harm from unauthorised use or disclosure, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory and other requirements.

  • Your legal rights

Under certain circumstances you have rights under data protection laws in relation to your personal data.

Request access to your personal data. This enables you to receive a copy of the personal data we hold about you.

Request correction of the personal data that we hold about you. 

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us to continue to process it. However, we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. 

Request restriction of processing of your personal data.

Request transfer of your personal data to you or a third party

Withdraw consent at any time where we are relying on your consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdrew your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

  • COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see https://noonah.com/cookies-policy/ 

FURTHER INFORMATION

If you have any questions about how we process your personal data on behalf of [[ HIRER ]], or about this privacy statement more generally, please contact us at https://noonah.com/contact-us/ 

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