THE SOUTH BEACH PHOTO BOOTH CO PRIVACY POLICIES
THE PERSONAL DATA WE COLLECT ABOUT YOU
Personal data collected, used, stored and transferred by us may include:
- Identity Data including first name, last name
- Contact Data including home address, email address and telephone numbers
- Financial Data is never stored by SoBe and is always processed through third parties: Paypal, Stripe, and Quickbooks Online.
- Location Data including details of interaction, meetings
- Transaction Data including payments made for products and services you have purchased from us, minutes of meetings
- Photographic Data including CCTV and images captured from our photo technologies
- Technical Data including internet protocol (IP) address, 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 used to access the SoBe website. Information accessed via VNC during support sessions
- Profile and Usage Data including purchases made by you, feedback and survey responses, and how you use our website, products and services
- Marketing and Communications Data including your preferences in receiving marketing from us and your communication preferences
HOW DO WE COLLECT YOUR PERSONAL DATA?
Personal data is collected by us using the following methods:
- Direct interactions with employees and/or authorized representatives of SoBe, by post, phone, email, social media or otherwise when enquiring about a product or service offered by SoBe.
- Automated technologies or interactions with our website, by using the web inquiry form or any other automated means.
- Third parties or publicly available sources such as: Social Media, Blogs, Internet Searches, Online Advertising, CRM Systems, Suppliers and support ticket platforms.
HOW DO WE USE YOUR PERSONAL DATA?
We use your personal data in the following circumstances and relying on the following lawful basis for processing:
|Purpose / Activity||Type(s) of data||Lawful basis for processing|
|Initial Contact||Identity, Contact Information, Marketing & Comms||Consent, Performance of a contract|
|Supplying goods or services||Identity, Financial, Contact Information, Technical||Consent, Performance of a contract|
|Warranty / Returns||Identity, Financial, Contact Information, Technical||Consent, Performance of a contract, to comply with legal obligation|
|Continuation and re-engagement of client relations||Identity, Financial, Contact Information, Technical, Marketing & Comms||Consent, Legitimate Interest, Performance of a contract|
|Technical Support||Identity, Contact Information, remote login software access (Teamviewer/Anydesk)||Consent, Performance of a contract|
|Use of Data Analytics to improve our website, products and services, marketing and customer relationship experiences.||Technical, Location, Profile and Usage||Legitimate Interest|
|Transferring of information to third parties||Identity, Contact, Financial, Technical, Locations, Transaction, Personal Interest Photographic, Profile, Marketing & Comms||Legitimate Interest, Performance of a contract, Consent, to comply with legal obligation|
CHANGE OF PURPOSE
We will only use your personal data for the purposes stated above, unless we reasonably consider that we need to use it for another reason and it is compatible with the original purpose. Please contact us for an explanation as to how any new processing compatible with the original purpose.
If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
CHANGES TO OUR PRIVACY NOTICE
We keep our Privacy Notice under regular review and we will place any updates on this web page. This Privacy Notice was last updated on March 8th, 2021.
You will have the choice to opt-in to receiving other related marketing information and related products and services.
You can opt-out of receiving these types of communications at any time by contacting our Compliance team at email@example.com or by clicking on the relevant link in email communications you receive from us.
However please note that your personal information will not be passed to any third-party organization for marketing purposes.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. We also limit access to your personal data to only those SoBe staff, appointed representatives, advisers, business partners and suppliers 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.
WHAT ARE COOKIES?
Cookies are small pieces of text sent to your web browser by a website you visit. A cookie file is stored in your web browser and allows the Service or a third-party to recognize you and make your next visit easier and the Service more useful to you.
Cookies can be “persistent” or “session” cookies. Persistent cookies remain on your personal computer or mobile device when you go offline, while session cookies are deleted as soon as you close your web browser.
When you use and access the Service, we may place a number of cookies files in your web browser.
- To enable certain functions of the Service
- To provide analytics
We use both session and persistent cookies on the Service and we use different types of cookies to run the Service:
- Analytics cookies. We may use analytics cookies to track information how the Service is used so that we can make improvements. We may also use analytics cookies to test new advertisements, pages, features or new functionality of the Service to see how our users react to them.
In addition to our own cookies, we may also use various third-parties cookies to report usage statistics of the Service, deliver advertisements on and through the Service, and so on.
WHAT ARE YOUR CHOICES REGARDING COOKIES
Please note, however, that if you delete cookies or refuse to accept them, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages might not display properly.
- For the Chrome web browser, please visit this page from Google: https://support.google.com/accounts/answer/32050
- For the Internet Explorer web browser, please visit this page from Microsoft: http://support.microsoft.com/kb/278835
- For the Firefox web browser, please visit this page from Mozilla: https://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websitesstored
- For the Safari web browser, please visit this page from Apple: https://support.apple.com/kb/PH21411?locale=en_US
- For any other web browser, please visit your web browser’s official web pages.
WHERE CAN YOU FIND MORE INFORMATION ABOUT COOKIES
You can learn more about cookies and the following third-party websites:
- AllAboutCookies: http://www.allaboutcookies.org/
- Network Advertising Initiative: http://www.networkadvertising.org/
WEBSITE THIRD-PARTY LINKS
SoBe’s websites may include links to third-party websites, 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.
Who we disclose personal data to?
Your personal data may be shared with third parties for the following purposes:
|Type of recipient||Reason|
|External Suppliers & Contractors||Specialist IT system providers to facilitate the customer relationship management, to provide continuing advice, to inform you about relevant products and services, and to request feedback on customer service standards. It may also be necessary to share your personal; information with non-affiliated companies who perform support services on our behalf including those that provide professional, legal or accounting advice to SoBe.|
|Outsourced Support Provider||In order to provide out of hours technical support services in relation to our products and services we use third party suppliers and your data may be transferred to them for this
|Regulators||Sharing information may be necessary to fulfil our legal obligations as a regulated profession and otherwise cooperate with law enforcement, legal proceedings and regulatory authorities.|
|Others||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 them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.|
HOW LONG IS YOUR PERSONAL DATA RETAINED?
We only retain your personal data for as long as necessary. The table below outlines how long data is retained, and depends on the reason the personal data is used for:
|Purpose of processing||Retention Period|
|Purchase of goods / services contract||Indefinitely from the date of the original contract for legal obligations and defending potential legal claims.|
|Data relating to enquiries made that have not formed part of a formal contract obtained directly and from third parties.||Indefinitely in order for us to continue to contact the client between the period of initial enquiry to the point of forming a contract. However, the client may request their data be anonymized at any time.|
|Data relating to clients who have opted in for marketing||Indefinitely, or until such time client withdraws consent.|
|Data relating to existing customers||Indefinitely in order for us to continue to contact the client between the period of initial enquiry to the point of forming a contract. However, the client may request their data be anonymized at any time.|
Any categories of personal data not referenced specifically above, will be retained for as long as necessary taking into account the lawful basis for collecting the personal data initially, any ongoing obligations imposed on SoBe and the fundamental rights and freedoms of the data subject.
You have the right to:
- 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. This enables you to have any incomplete or inaccurate data corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete personal data where there is no good reason for us continuing to process it. You can also to ask us to delete your personal data where you have successfully objected to the processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to delete the data 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 (or those of a third party) 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. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you have any questions or complaints relating to how we use your personal data, or if you wish to exercise any of your rights regarding your personal data, please contact SoBe by emailing firstname.lastname@example.org or by writing to us. We will respond to you as soon as is possible. The length of time will depend on the type and complexity of the request, but you will receive a response no later than one month from the initial request.
When guests share their media from SoBe Booths software, what data do we collect for each direct sharing option?
- E-mail – E-mail Address and File Names
- Text – Phone Number and File Names
- Facebook -Username, File Names, Number of Friends, Name, Email Address, Gender, Age Range, Locale, Timezone (depending on profile settings)
- Twitter – Username, Number of Followers, File Names (depending on profile settings)
- Instagram – File Names, Username, Number of Followers (depending on profile settings)
Does SoBe Booths collect the names of my Facebook friends or Instagram or Twitter followers?
No. SoBe Booths does not collect the names or data of your Facebook friends or Instagram or Twitter Followers.
What other data does SoBe Booths Collect or Retain?
Some events include surveys of guests. For these events, the survey data will be collected, stored, and shared in accordance with other guest data from that event.
How is this data used?
- This data is accessed by our technical support team to help provide support.
- The data may be sent to the event coordinator or sponsors in individual or aggregate form.
- The data is aggregated for statistical reporting purposes.
What 3rd party services we use and what data they have access to.
Texts are sent through Twilio:
E-mails are sent through Sendgrid (unless we use a clients email server):
Unique URL data and media are stored and hosted on Amazon Web Services:
Photos are stored on SmugMug galleries:
Do we share this data with 3rd parties:
- The data from each event is available to the event coordinator for that individual event.
- The data from each event may be made available to sponsors of the event.
- Anonymous aggregate data may be shared publicly or with any 3rd party.
- SoBe Booths will not use any data collected from event guests for any direct marketing purposes.
- SoBe Booths will not sell any data collected from event guests.
Where are guests photos stored?
- Photos are stored and saved to a local hard drive when they are originally taken. They are deleted from this local storage within 1 week of the end of the event.
- Photos are saved to an online SmugMug Gallery. The gallery is private and used by our team for quality control. It is also shared with the event coordinator and sometimes event sponsors, unless otherwise specified.
- Photos are backed up to a local, password protected drive at the SoBe Booths office.
- Photos for Unique URLs are stored on our Amazon Web Services indefinitely.
Can I limit storage and data collection or sharing?
The event coordinator can decide to limit data collection and storage for a particular event.
Can I find out what data SoBe Booths has stored on me?
To find out what data SoBe Booths might have pertaining to you, please click here to contact email@example.com
Can I delete data that SoBe Booths has stored on me?
To have your personal data deleted please click here to contact firstname.lastname@example.org
SoBe Booths archives all photos from SoBe Booths events using Smugmug.com – Clients can request their photos to be removed or password protected at any time.
SoBe Booths reserves the right to use images (including but not limited to photos, GIFs and/or videos) from events for display, advertising, SoBe’s website and social media platforms, third party websites, magazine submissions and any other means of online or print marketing and promotion of SoBe Booths’ business. In connection with the marketing and promotion of the images, SoBe Booths may place its logo and/or trademarks on the images.Clients can request that media from their event not be used by SoBe Booths for marketing purposes.
PRIVACY SHIELD FRAMEWORK
In compliance with the Privacy Shield Principles, SoBe Booths commits to resolve complaints about our collection or use of your personal information. EU and Swiss
individuals with inquiries or complaints regarding our Privacy Shield policy should first contact SoBe Booths support at email@example.com
SoBe Booths has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning data transferred from the EU.
Information collected is subject to the investigatory and enforcement powers of the Federal Trade Commission.
Users of SouthBeachPhotoBoothCo.com have the possibility, under certain conditions, to invoke binding arbitration.
Onward Liability Transfer
Where relevant, we may transfer some of the personal information we have collected to third parties. For all third-party transfers, the data exchanged will be for limited and specified purposes. SoBe will enter into a contract agreement with any third party controller or agent in compliance with the Notice and Choice Principles and be liable for:
- Ascertaining that the third party is obligated to provide at least the same level of privacy protection as is required by the Principles
- Taking reasonable and appropriate steps to ensure that the agent effectively processes personal data transferred in a manner consistent with our obligations under the Principles
- Requiring the agent to notify us if it makes a determination that it can no longer meet its obligation to provide the same level of protection as is required by the Principles
- Taking reasonable and appropriate steps to stop and remediate unauthorized processing upon notice
- Providing a summary or a representative copy of the relevant privacy provisions of its contract with that agent to the Department upon request. SoBe is not obligated to require that the third party participate in the Privacy Shield, nor are we obligated to ensure that the third party participate in an independent recourse mechanism, however the third party is required to have an equivalent mechanism available. In the event of a dispute, the third party controller or agent is responsible for ceasing processing or taking other reasonable and appropriate steps to remediate.
To learn more about the Privacy Shield program and our participation please visit https://www.privacyshield.gov/list