This Privacy Notice explains how RA Creative Limited (“RA”, “we”, “us” or “our”) collects, uses and protects personal information through our websites, business activities and services. StudioPackshots is a trading brand of RA Creative Limited.

1. Who we are

1.1 RA Creative Limited is responsible for personal information where it determines why and how that information is used.

1.2 Where RA processes personal information solely on behalf of a Client, RA may instead act as processor and the Client will normally be the controller.

1.3 RA Creative Limited is registered in England and Wales under company number 01940817. Registered office: 7 Poplars Court, Lenton Lane, Nottingham, England, NG7 2RR.

2. Information we may collect

2.1 Depending on your relationship with us, we may collect names, organisations, job titles, contact details, addresses, enquiry and correspondence information, quotation and project information, order and transaction information, invoice and payment information, website usage and technical information, cookie information and marketing preferences.

2.2 StudioPackshots may also process information associated with products, photography requirements, models, image approvals, delivery/return arrangements and delivered images.

2.3 We do not intentionally request special category personal data through our general website enquiry forms.

3. How we obtain information

3.1 We may obtain information directly from you, from your organisation, through website forms, email and telephone communications, quotations and Orders, meetings, business partners or suppliers, publicly available business sources, and through our websites and permitted analytics technologies.

4. How we use information

4.1 We may use personal information to respond to enquiries, prepare quotations, provide and administer Services, manage projects and customer relationships, provide hosting/support, deliver photography and digital assets, issue and reconcile invoices, recover debts, maintain records, operate and secure our systems and websites, comply with legal obligations, establish or defend claims, improve our business and undertake lawful business-to-business marketing.

5. Lawful bases

5.1 Depending on the purpose, we may rely on: (a) contract, where processing is necessary to enter into or perform a contract with you; (b) legal obligation, where we are required to process information by law; (c) legitimate interests, where necessary for our or a third party’s legitimate business interests and those interests are not overridden by your rights and interests; or (d) consent, where consent is the appropriate lawful basis.

5.2 Our legitimate interests may include operating and improving our business and services, managing business relationships, responding to business enquiries, protecting our systems and legal rights, preventing misuse, recovering debts and carrying out relevant business-to-business marketing where permitted by law.

5.3 Where we rely on consent, you may withdraw it at any time. Withdrawal does not affect processing carried out lawfully before withdrawal.

6. Business marketing

6.1 We may contact existing and prospective business customers about relevant RA Creative or StudioPackshots services where permitted by applicable law.

6.2 You have the right to object at any time to the use of your personal information for direct marketing. You may unsubscribe or ask us to stop marketing communications at any time. This does not prevent necessary service, contractual, invoice or administrative communications.

7. Client systems

7.1 When providing digital, ecommerce, hosting, support or development services, RA may access personal information held in a Client’s website, application, database or systems.

7.2 Where RA processes that information solely on the Client’s instructions, the Client will normally be controller and RA processor. RA’s General Data Processing Addendum or a separately agreed DPA may apply.

8. Service providers

8.1 We use third-party service providers to operate our business. These currently include services provided by Google for business communications, file storage and website analytics, Xero for accounting and invoicing, Stripe for card and supported digital-wallet payments, and SiteGround for website hosting.

8.2 We may also disclose information where reasonably necessary to banks and payment providers, professional advisers, insurers, technology and hosting providers, debt recovery providers, authorities and other suppliers supporting our business or Services.

8.3 We disclose personal information only where permitted or required by applicable law.

9. Payments

9.1 Payments may be processed by banks or third-party payment providers. RA does not necessarily receive or retain complete payment-card information where payment is processed by a third-party provider.

10. Cookies and analytics

10.1 Our websites use cookies and similar technologies as described in our Cookie Policy.

10.2 We currently use Google Analytics 4. Analytics technologies requiring consent are subject to our cookie controls.

11. International transfers

11.1 Some of our service providers may process personal information outside the United Kingdom. Where Data Protection Law requires safeguards for an international transfer, we use or rely on an applicable lawful transfer mechanism or other permitted basis. You may contact us for further information about applicable safeguards.

12. Retention

12.1 We keep personal information for no longer than is reasonably necessary for the purpose for which it is held, taking account of contractual, legal, accounting, tax, operational and claims requirements.

12.2 Retention periods vary according to the type of information and why we hold it. In deciding how long to retain information, we consider the continuing business need for it, applicable legal or regulatory requirements, limitation periods, and whether it is needed to establish, exercise or defend legal claims.

12.3 Project files and photography may be retained where there is a continuing legitimate business reason, including maintaining project records, responding to replacement-file requests or supporting future work. Information will not be retained solely because it might conceivably be useful at some unspecified future time.

13. Security

13.1 We use reasonable technical and organisational measures designed to protect personal information. No internet-connected system can be guaranteed to be completely secure.

14. Your rights

14.1 Depending on the circumstances and the lawful basis being used, you may have rights including access, rectification, erasure, restriction, data portability and objection. These rights are not absolute and exemptions may apply.

14.2 You have the right to object at any time to processing for direct marketing. You may also have a right to object to other processing based on legitimate interests.

14.3 Where processing is based on consent, you may withdraw that consent at any time. We do not normally charge a fee for exercising data protection rights except where permitted by law.

15. Requests and complaints

15.1 Privacy enquiries and requests may be sent to [email protected] or by post to our registered office.

15.2 We may need to verify identity before responding.

15.3 If you are unhappy with how we have handled your personal information, you may complain to us. You also have the right to complain to the Information Commissioner’s Office.

16. Third-party information supplied to RA

16.1 Where a Client, supplier or other third party provides us with personal information about another person, we expect that information to have been obtained and disclosed lawfully. Where RA acts only as Processor, the relevant Controller remains responsible for its Controller obligations.

17. Contractual effect

17.1 This Privacy Notice describes how RA handles personal information and does not create contractual rights beyond those provided by applicable law.

18. Changes

18.1 We may update this Privacy Notice from time to time to reflect changes in our processing, services, suppliers or legal requirements. The current version will be published on our website.