PRIVACY POLICY

Swagger Productions Ltd (“Company”, “we”, “us”, “our”) is committed to protecting personal data and complying with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

This Privacy Policy explains how we collect, use and protect personal information in the course of providing corporate photography and visual production services.

1. WHO WE ARE

Swagger Productions Ltd is a corporate photography and visual services provider operating in the United Kingdom and internationally.

For the purposes of UK GDPR, Swagger Productions Ltd is the Data Controller of personal data collected directly by us.

Where we process personal data on behalf of a corporate client (e.g., employee imagery), we may act as a Data Processor.

2. DATA WE MAY COLLECT

We may collect and process the following categories of personal data:

Business Contact Information

• Name
• Job title
• Company name
• Business email address
• Business telephone number

Client Account Information

• Billing address
• VAT details
• Payment records
• Contractual correspondence

Visual Content Data

• Photographic images of identifiable individuals
• Video footage where applicable
• Metadata associated with visual assets

Website Data

• IP address
• Browser type
• Device information
• Usage data via analytics tools

We do not intentionally collect sensitive personal data unless explicitly required and agreed within a project scope.

3. HOW WE COLLECT DATA

We collect personal data:

• When you contact us
• When entering into a contract
• During project delivery
• Via our website contact forms
• Through cookies and analytics tools
• Via third-party referral or introduction

4. LAWFUL BASIS FOR PROCESSING

We process personal data under the following lawful bases:

Contractual Necessity

To perform services agreed with a Client.

Legitimate Interest

To manage business relationships, marketing and operational communication.

Legal Obligation

To comply with tax, accounting and regulatory requirements.

Consent

Where required (e.g., direct marketing communications).

5. USE OF PHOTOGRAPHIC IMAGES

For corporate commissions:

• The Client is responsible for informing employees or participants that photography is taking place.
• Where required, the Client is responsible for obtaining appropriate internal permissions or releases.
• We process imagery in accordance with contractual agreements.

We do not sell personal data or imagery to third parties.

Portfolio usage is governed by contractual licence terms.

6. DATA SHARING

We may share personal data with:

• Professional advisers (accountants, legal advisers)
• IT and cloud storage providers
• Secure file transfer platforms
• Payment processing providers

All third parties are required to handle data securely and lawfully.

We do not sell personal data.

7. INTERNATIONAL TRANSFERS

Where projects involve international production or cloud storage providers, data may be processed outside the UK.

In such cases, we ensure appropriate safeguards are in place in accordance with UK GDPR.

8. DATA RETENTION

We retain:

• Contractual and financial records for statutory accounting periods
• Client correspondence as required for business operations
• Final delivered visual assets for up to two (2) years unless otherwise agreed

Data is not retained longer than necessary.

9. DATA SECURITY

We implement appropriate technical and organisational measures, including:

• Encrypted storage systems
• Secure cloud platforms
• Controlled access to production files
• Password-protected systems
• Secure file transfer methods

No system is entirely secure; however, we take reasonable steps to protect data integrity.

10. YOUR RIGHTS

Under UK GDPR, individuals have the right to:

• Access their personal data
• Request correction
• Request erasure (where applicable)
• Restrict processing
• Object to processing
• Request data portability

Requests may be submitted via the contact details below.

We may require identity verification before fulfilling requests.

11. COOKIES

Our website may use cookies to improve user experience and analyse traffic.

Users can manage cookie preferences through browser settings.

Separate Cookie Policy documentation may apply where required.

12. COMPLAINTS

If you believe your data has been handled improperly, you may contact:

Information Commissioner’s Office (ICO)
www.ico.org.uk

We encourage contacting us first to resolve concerns.

13. CONTACT

Data Protection Contact
Swagger Productions Ltd
Email: HQ@swagger.productions