Privacy Policy 2026

Effective Date: 01.04.2023
Last Updated: 16.01.2026
Data Controller: Swagger Productions Ltd, trading as Jo Hanley Photography
Contact Email: studio@johanley.com

1. OVERVIEW

This Privacy & Cookie Policy explains how we collect, use, disclose, and safeguard your personal data when you visit our website:
https://www.johanley.com

It also explains your rights under the UK GDPR, EU GDPR, and applicable data protection laws, including how we use cookies.

2. WHAT WE COLLECT

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

  • Contact details (e.g. name, email address, phone number) when you complete forms, subscribe to services, or correspond with us
  • Account or registration information (if applicable)
  • Transaction data, including services requested, purchases, or billing information
  • Technical data, including IP address, browser type, operating system, device identifiers, and pages viewed
  • Usage data, such as time spent on site, click paths, and interaction with page features
  • Survey or feedback responses, if you choose to provide them
  • Any other information you voluntarily submit

3. LEGAL BASIS FOR PROCESSING

Under GDPR, we rely on one or more of the following lawful bases to process your data:

  • Consent (e.g. marketing communications or non-essential cookies)
  • Contract (e.g. to fulfil services you have requested)
  • Legal obligation (e.g. retention of financial records)
  • Legitimate interests (e.g. improving site performance or securing our systems)

You have the right to withdraw your consent at any time.

4. HOW WE USE YOUR DATA

We may use your personal data to:

  • Provide, personalise, and improve our services and website
  • Respond to enquiries or provide client support
  • Process transactions and administer projects
  • Send marketing communications where legally permitted
  • Conduct surveys or research (participation is optional)
  • Monitor website performance and security

We do not sell your data to third parties.

5. MARKETING AND COMMUNICATION

  • If you are a current client, we may contact you about similar services on the basis of legitimate interest.
  • If you are a new client, we will only contact you by email or SMS where you have actively opted in.
  • You can unsubscribe or opt out at any time by contacting us or using the unsubscribe link included in any marketing communication.

6. INTERNATIONAL TRANSFERS

Some of our service providers or suppliers may be located outside the UK or EEA. Where personal data is transferred internationally, we ensure:

  • Appropriate safeguards are in place (such as Standard Contractual Clauses)
  • Your data is handled securely and in accordance with this policy

7. DATA SECURITY

We take data protection seriously. Personal data is stored on secure servers and protected using appropriate encryption and access controls.

However, transmission of information over the internet is not entirely secure. Any data you transmit to us is at your own risk.

If you receive login credentials for restricted areas of the website, you are responsible for keeping them confidential.

8. YOUR RIGHTS

Under GDPR, you have the right to:

  • Access your personal data
  • Rectify inaccurate or incomplete data
  • Request erasure of your data (“right to be forgotten”)
  • Restrict or object to processing
  • Request data portability
  • Withdraw consent at any time (where consent is the legal basis)
  • Lodge a complaint with the Information Commissioner’s Office (ICO)

To exercise any of these rights, contact us at studio@johanley.com.

9. DATA RETENTION

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, including legal, accounting, or tax obligations.

If you request deletion of your data, we will comply unless we are legally required to retain it.

10. COOKIES

Cookies are small files stored on your device to help our website function, analyse usage, and improve user experience.

Types of Cookies We Use

  • Essential cookies – Required for site functionality (e.g. navigation, security)
  • Analytics cookies – Help us understand website usage (e.g. Google Analytics)
  • Marketing cookies – Track behaviour for advertising or social media integration

Your Consent

When you visit our site, you will be asked to consent to the use of non-essential cookies. You can accept, reject, or customise settings via the cookie banner.

You may also manage or delete cookies at any time through your browser settings.

11. THIRD-PARTY LINKS

Our website may include links to third-party websites or services. These operate under their own privacy policies, and we are not responsible for their content or data handling practices.

12. ACCESS TO YOUR DATA

You may request access to the personal data we hold about you by emailing studio@johanley.com.
We will respond within 30 days. Requests are provided free of charge unless they are manifestly unfounded or excessive.

13. CHANGES TO THIS POLICY

We may update this Privacy & Cookie Policy periodically. The latest version will always be published on this page, with the “Last Updated” date revised accordingly. If changes are significant, we may notify you by email where appropriate.

CONTACT US

If you have any questions, concerns, or requests regarding your personal data or this policy, please contact:

Jo Hanley Photography
Email: studio@johanley.com

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VAT Registration Number GB457489930
Part of the Swagger Productions Group.
SWAGGER PRODUCTIONS ltd.
EDINBURGH – Scotland.

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