This privacy notice describes how Lubomir Jiponov Photography Ltd. will collect and use your personal data.
Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as: “any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.
1. Who is processing your data?
Lubomir Jiponov Photography Ltd., UIC 204481210, with headquarters 9, Manush voivoda Str., Fl. 1, ap. 2, Sofia, Bulgaria, is your data controller. The company represented by me, Lubomir Jiponov – a professional photographer who works in Sofia, Bulgaria and Europe. You can contact me at +359 888 381 318 or by email: firstname.lastname@example.org
1.1. Why does Lubomir Jiponov Photography Ltd. need to collect and store personal data?
In order to be able to provide the professional photography services of your choosing, we need to collect your personal data in order to identify and contact you. According to the GDPR, photographs are also considered personal data. We need to process your photographs in order to provide you with the services you have ordered.
In any event, we are committed to ensuring that the information I collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy. In terms of being contacted for marketing purposes Lubomir Jiponov Photography Ltd. would contact you for additional consent.
1.2. The personal data we would like to collect from you is:
|Personal data type:||Source:|
|Name and surname||Data subject|
|Personal identification number (PIN)||Data subject|
|E-mail address||Data subject|
|Phone number||Data subject|
|Your photos||Created by me|
|Metadata (e.g., IP address, device information)||Automatically generated (by cookies)|
|Website usage data (e.g., time spent on site, number of clicks)||Automatically generated (by cookies)|
1.3. The personal data we collect will be used for the following purposes:
• Answering queries submitted by phone or email.
• Feedback and communication with current and future clients.
• Provision of the professional photographic services you have ordered.
• Collecting information about visitors’ engagement with the website.
• Sending newsletters and marketing messages.
1.4. Our legal basis for processing for the personal data:
• Performance of a contract to which the data subject is party;
• Taking steps at the request of the data subject prior to entering into a contract;
• Legitimate interests of the controller;
• Your consent
1.5. Any legitimate interests pursued by Lubomir Jiponov Photography Ltd. are as follows:
• Communication with current and future clients.
• Advertising Lubomir Jiponov’s photographic services by posting photographs online on social media, professional portfolio, at websites such as www.lubomirjiponovphotography.com, or by participating in photography competitions and other.
• Website development and increasing website visitor engagement.
• Direct marketing.
By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified.
Consent is required for Lubomir Jiponov Photography Ltd. to process both types of personal data, but it must be explicitly given. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used.
You may withdraw consent at any time by sending an email at: email@example.com
3.1. The following third parties will receive your personal data for the following purpose(s) as part of the processing activities:
|Third Party||Type of personal data||Purpose|
|Photo studios||Photographs||Performance of services according to our contract, e.g. photo printing, making photo albums.|
|Assistent(s)||Contact data; Photographs||Assistance in the provision of photographic services.|
|Google Inc.||Metadata; Website usage data||Website development and increasing website visitor engagement.|
|MailChimp||Name and surname; email;||Sending newsletters and marketing emails.|
4. Retention period
Lubomir Jiponov Photography Ltd. will process personal data from the moment you wish to enter into a contract and provide your contact details, until the completion of the purpose for which the data were collected, or until withdrawal of your consent.
5. Your rights as a data subject
At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
• Right of access – you have the right to request a copy of the information that we hold about you.
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
• Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
• Right of portability – you have the right to have the data we hold about you transferred to another organisation.
• Right to object – you have the right to object to certain types of processing such as direct marketing.
• Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
• Right to judicial review: in the event that Lubomir Jiponov Photography Ltd. refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 6 below.
In the event that you wish to make a complaint about how your personal data is being processed by Lubomir Jiponov Photography Ltd., or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Lubomir Jiponov Photography Ltd.’s data protection representatives.
The details for each of these contacts are:
|Supervisory authority contact details||GDPR Owner contact details|
|Contact Name:||Commission for Personal Data Protection||Lubomir Jiponov|
|Address line:||2 Prof. Tsvetan Lazarov Blvd., 1592 Sofia Bulgaria||1 Hristo Smirnensky Blvd., 1164 Sofia Bulgaria|
|Telephone:||02/91-53-518||+359 888 381 318|
7. Additional information
Under what circumstances will Lubomir Jiponov Photography Ltd. contact me?
Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.
Can I find out the personal data that the organisation holds about me?
Lubomir Jiponov Photography Ltd. at your request, can confirm what information we hold about you and how it is processed. If Lubomir Jiponov Photography Ltd. does hold personal data about you, you can request the following information:
• Identity and the contact details of the person or organisation that has determined how and why to process your data. In some cases, this will be a representative in the EU.
• The purpose of the processing as well as the legal basis for processing.
• If the processing is based on the legitimate interests of Lubomir Jiponov Photography Ltd. or a third party, information about those interests.
• The categories of personal data collected, stored and processed.
• Recipient(s) or categories of recipients that the data is/will be disclosed to.
• If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.
• How long the data will be stored.
• Details of your rights to correct, erase, restrict or object to such processing.
• Information about your right to withdraw consent at any time.
• How to lodge a complaint with the supervisory authority.
• Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
• The source of personal data if it wasn’t collected directly from you.
• Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
What forms of ID will I need to provide in order to access this?
Lubomir Jiponov Photography Ltd. accepts the following forms of ID when information on your personal data is requested: ID card, driving licence.
Current version March 2020