Privacy Notice

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Last updated: September 2026

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Traits Photography respects your privacy and is committed to protecting your personal information and photographs.

This notice explains what information I collect, why I collect it, how it is stored and used, how long it may be retained, and your rights in relation to your personal data.

 

1. Who is responsible for your information?

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Traits Photography is operated by Keith Emmerson as a sole trader.

For the purposes of UK data protection law, Keith Emmerson trading as Traits Photography is the data controller for the personal information covered by this notice.

If you have any questions about this notice or how your information is handled, you can contact:

Traits Photography
Keith Emmerson
Email: Keith@traits.photo
Website: traits.photo

 

2. Information I may collect

 

Depending on your enquiry, booking or photography session, I may collect and process information including:

• Your name

• Email address and telephone number

• Business or company name

• Information you provide during enquiries, questionnaires or consultations

• Booking, session and location information

• Contracts, model releases and records of consent

• Payment and transaction information

• Photographs and other images taken during your session

• Correspondence between you and Traits Photography

• Information reasonably necessary to provide the photography service

I only collect information that is reasonably required to manage your enquiry, provide photography services, deliver your images and operate Traits Photography.

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3. Photographs

 

Photographs in which an individual can be identified may constitute personal data.

Images taken during a photography session may be captured, transferred, backed up, professionally edited, exported and stored as part of providing the photography service.

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Original image files and working backups are primarily stored locally on physical hard drives controlled by Traits Photography.

Final photographs may be uploaded to PicDrop for the purpose of providing a private online client gallery, allowing clients to view, select and download their photographs.

Where you have separately agreed that photographs may be used by Traits Photography for promotional purposes, selected images may also be used in places such as:

• The Traits Photography website and online portfolio

• Traits Photography social media accounts

• Printed portfolios and promotional materials

• Business listings and professional profiles

• Photography competitions, exhibitions or professional accreditation, where appropriate

 

Where this use relies upon your consent, you can withdraw that consent by contacting Traits Photography.

 

Withdrawal of consent does not affect processing that took place lawfully before consent was withdrawn. I will take reasonable steps to stop future use of the affected images where that use is under my control.

 

4. Why I use your personal information

 

Your information may be used to:

• Respond to enquiries

• Arrange and manage photography sessions

• Communicate with you before and after a session

• Fulfil photography agreements and provide requested services

• Edit, manage and deliver photographs

• Maintain appropriate business, accounting and transaction records

• Deal with questions, complaints or legal matters

• Protect and back up photography work

• Use photographs for portfolio, promotional or marketing purposes where an appropriate lawful basis applies

I will not use your personal information for purposes incompatible with those described in this notice without informing you where required.

 

5. Lawful bases for processing

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Under UK data protection law, Traits Photography must have a lawful basis for processing personal information.

Depending on the circumstances, I may rely on:

Contract – where processing is necessary to provide a photography service you have requested or to take steps before entering into an agreement with you.

Legal obligation – where information must be retained or processed to meet legal, tax or accounting requirements.

Legitimate interests – where processing is reasonably necessary for operating and protecting Traits Photography, provided those interests do not override your rights and interests.

Consent – where you have specifically agreed to a particular use of your information or photographs, such as agreed portfolio or promotional use where consent is the lawful basis relied upon.

Where processing is based on consent, you may withdraw that consent at any time by contacting me.

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6. How information and photographs are stored

 

I take reasonable steps to protect personal information and photographs against accidental loss, unauthorised access, alteration or disclosure.

Original photographs and backups
RAW image files, edited photographs and working backups are primarily stored locally on physical hard drives controlled by Traits Photography.

Client galleries
Selected photographs may be uploaded to PicDrop to provide private online galleries for viewing, selection and delivery. Access controls, including gallery access restrictions where appropriate, may be used to limit access to client photographs.

Email and cloud storage
Google services, including Gmail and Google Drive, may be used for business correspondence, client information, documents and secure cloud storage.

Access to these systems and physical storage devices is restricted and reasonable security measures are used to protect the information held.

 

7. Third-party service providers

 

Traits Photography uses selected third-party services where necessary to operate the business and provide photography services.

These currently include:

PicDrop GmbH – used to host and deliver private client photography galleries.

Google – Gmail and Google Drive are used for business communications, documents and cloud storage.

These providers may process personal information on behalf of Traits Photography in accordance with their own contractual and data-protection arrangements.

Traits Photography does not sell client personal information.

Information may also be disclosed where required by law or where reasonably necessary to establish, exercise or defend legal claims.

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8. International processing

 

Some technology providers used by Traits Photography may process or store information outside the United Kingdom.

Where this occurs, appropriate safeguards required by applicable UK data-protection law will be relied upon where necessary.

PicDrop states that its servers are located in Germany. Other service providers, including Google, may process information internationally.

 

9. How long information and photographs are kept

 

Traits Photography does not keep personal information for longer than is reasonably necessary for the purposes for which it was collected.

Photographs

Original RAW files, edited photographs and local backups will normally be retained for a minimum of two years following the photography session.

After this period, photographs may be retained for longer where there is a continuing legitimate business reason to do so, but their continued retention will be reviewed periodically.

Clients should maintain their own copies of delivered photographs. Retention by Traits Photography should not be considered a permanent backup service, and I cannot guarantee that photographs will remain available after the stated retention period.

Photographs selected for the Traits Photography portfolio or promotional use may be retained for longer where there is an appropriate lawful basis for doing so.

Online galleries

Client galleries hosted through PicDrop may be removed before the locally stored photographs are deleted. Clients will be given a reasonable opportunity to download their final images following delivery.

Business records

Contracts, invoices, transaction records and other business information may be retained for longer where necessary to comply with tax, accounting, legal or regulatory requirements.

Enquiries and correspondence

Enquiry and correspondence information will be retained only for as long as reasonably necessary for the enquiry, client relationship or associated business requirements.

 

10. Website, Cookies and Analytics

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The Traits Photography website is hosted using Wix.

 

Like most websites, the site may use cookies and similar technologies. These are small files or technologies that can store or access information on your device when you visit the website.

Some cookies and similar technologies are necessary for the website to operate correctly, including functions relating to security, website performance and user preferences.

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Other technologies may be used, with your consent where required, to understand how visitors use the website, measure website performance or support marketing activities.

 

Traits Photography may use website analytics services, including Google Analytics. If Google Analytics or another non-essential analytics service is enabled, information such as how visitors reach and use the website, pages viewed, approximate location and information about the visitor's device or browser may be processed.

 

Where consent is required, non-essential cookies and similar technologies will not be used until you have made your choice through the website's cookie controls.

 

You can accept, reject or manage non-essential cookies through the cookie controls provided on the website and can change your preferences where those controls allow.

 

Further information about the specific cookies and similar technologies currently used, their purposes, providers and retention periods can be found in the Traits Photography Cookie Notice.

 

11. Your rights

 

Depending on the circumstances, UK data-protection law may give you rights relating to your personal information, including the right to:

• Ask what personal information I hold about you

• Request a copy of your personal information

• Ask for inaccurate information to be corrected

• Request deletion of your personal information in certain circumstances

• Ask for processing to be restricted in certain circumstances

• Object to certain types of processing

• Request transfer of certain information where applicable

• Withdraw consent at any time where processing is based on consent

These rights are not absolute and may depend on the circumstances and the lawful basis on which information is being processed.

To exercise any of these rights, please contact Traits Photography using the details above.

12. Complaints

If you have concerns about how your personal information is being handled, please contact me first so I have the opportunity to resolve the issue.

You also have the right to raise a concern with the UK Information Commissioner's Office (ICO).

Further information is available from the ICO.

13. Changes to this notice

This privacy notice may be updated occasionally to reflect changes to the way Traits Photography operates, the services used or applicable data-protection requirements.

The latest version will be made available through Traits Photography website (www.traits.photo).