PRIVACY & COOKIES
WHO ARE WE
Our website address is https://brosnanheadshots.com.
WHAT PERSONAL DATA WE COLLECT AND WHY WE COLLECT IT
When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.
An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.
PRIVACY
Thank you for visiting the www.headshotsuniversal.com site and reviewing our privacy policy. Our privacy policy is clear: We will not collect personal information about you when you visit our website unless you choose to provide that information to us.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
HOW WE COLLECT, USE AND DISCLOSE YOUR PERSONAL DATA
These websites are intended to showcase, and in the case of headshotsuniversal.com/shop also sell, the work of Headshots Universal and its products, as represented by us or the Affiliate Agencies.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
Among the types of Personal Data that this Application collects, by itself or through third parties, there are Cookies, usernames, email addresses, various types of Data, Usage Data, website, first name, and last name.
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.
Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools – by this Application or by the owners of third-party services used by this Application serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.
Users are responsible for any third-party Personal Data obtained, published or shared through this Application and confirm that they have the third party’s consent to provide the Data to the Owner.
MODE AND PLACE OF PROCESSING DATA
METHODS OF PROCESSING
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
Data processing is carried out using computers and/or IT-enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
LEGAL BASIS OF PROCESSING
The Owner may process Personal Data relating to Users if one of the following applies:
Users have given their consent for one or more specific purposes. Note: Under some legislations, the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
processing is necessary for compliance with a legal obligation to which the Owner is subject;
processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
PLACE
The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located.
Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.
RETENTION TIME
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
Therefore:
Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification, and the right to data portability cannot be enforced after the expiration of the retention period.
THE PURPOSES OF PROCESSING
The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Traffic optimization and distribution, Hosting and backend infrastructure, Registration, and authentication, Analytics, Displaying content from external platforms, User database management, Managing contacts and sending messages, Contacting the User, Managing support and contact requests, Content commenting, SPAM protection and Remarketing and behavioral targeting.
Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.
DETAILED INFORMATION ON THE PROCESSING OF PERSONAL DATA
Personal Data is collected for the following purposes and using the following services:
ANALYTICS
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
GOOGLE ANALYTICS (Google Inc.)
Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities, and to share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
Personal Data collected: Cookies and Usage Data.
Place of processing: US – Privacy Policy – Opt Out.
FACEBOOK ADS CONVERSION TRACKING (Facebook, Inc.)
Facebook Ads conversion tracking is an analytics service provided by Facebook, Inc. that connects data from the Facebook advertising network with actions performed on this Application.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy.
CONTACTING THE USER
MAILING LIST OR NEWSLETTER (this Application)
By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning this Application. Your email address might also be added to this list as a result of signing up to this Application or after making a purchase.
Personal Data collected: email address.
CONTACT FORM (this Application)
By filling in the contact form with their Data, the User authorizes this Application to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.
Personal Data collected: email address, first name, and last name.
CONTENT COMMENTING
Content commenting services allow Users to make and publish their comments on the contents of this Application.
Depending on the settings chosen by the Owner, Users may also leave anonymous comments. If there is an email address among the Personal Data provided by the User, it may be used to send notifications of comments on the same content. Users are responsible for the content of their own comments.
If a content commenting service provided by third parties is installed, it may still collect web traffic data for the pages where the comment service is installed, even when Users do not use the content commenting service.
COMMENT SYSTEM MANAGED DIRECTLY (this Application)
This Application has its own internal content comment system.
Personal Data collected: email address, username, and website.
DISPLAYING CONTENT FROM EXTERNAL PLATFORMS
This type of service allows you to view content hosted on external platforms directly from the pages of this Application and interact with them.
This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.
GOOGLE FONTS (Google Inc.)
Google Fonts is a typeface visualization service provided by Google Inc. that allows this Application to incorporate content of this kind on its pages.
Personal Data collected: Usage Data and various types of Data as specified in the privacy policy of the service.
Place of processing: US – Privacy Policy.
GOOGLE WIDGET(Google Inc.)
Google Maps is a maps visualization service provided by Google Inc. that allows this Application to incorporate content of this kind on its pages.
Personal Data collected: Cookies and Usage Data.
Place of processing: US – Privacy Policy.
GRAVATAR (Automattic Inc.)
Gravatar is an image visualization service provided by Automattic Inc. that allows this Application to incorporate content of this kind on its pages.
Please note that if Gravatar images are used for comment forms, the commenter’s email address or parts of it may be sent to Gravatar – even if the commenter has not signed up for that service.
Personal Data collected: email address and Usage Data.
Place of processing: US – Privacy Policy.
INSTAGRAM WIDGET (Instagram, Inc.)
Instagram is an image visualization service provided by Instagram, Inc. that allows this Application to incorporate content of this kind on its pages.
Personal Data collected: Cookies and Usage Data.
Place of processing: US – Privacy Policy.
SOUNDCLOUD WIDGET (SoundCloud Limited)
Soundcloud is an audio content delivery service provided by SoundCloud Limited that allows this Application to incorporate content of this kind on its pages.
Personal Data collected: Usage Data.
Place of processing: Germany – Privacy Policy.
SPOTIFY WIDGET (Spotify AB)
Spotify is an audio content delivery service provided by Spotify AB that allows this Application to incorporate content of this kind on its pages.
Personal Data collected: Cookies and Usage Data.
Place of processing: Sweden – Privacy Policy.
TYPEKIT (Adobe Systems Incorporated)
Typekit is a typeface visualization service provided by Adobe Systems Incorporated that allows this Application to incorporate content of this kind on its pages.
Personal Data collected: Usage Data and various types of Data as specified in the privacy policy of the service.
Place of processing: US – Privacy Policy.
VIMEO VIDEO (Vimeo, LLC)
Vimeo is a video content visualization service provided by Vimeo, LLC that allows this Application to incorporate content of this kind on its pages.
Personal Data collected: Cookies and Usage Data.
Place of processing: US – Privacy Policy.
YOUTUBE VIDEO WIDGET (Google Inc.)
YouTube is a video content visualization service provided by Google Inc. that allows this Application to incorporate content of this kind on its pages.
Personal Data collected: Cookies and Usage Data.
Place of processing: US – Privacy Policy.
HOSTING AND BACKEND INFRASTRUCTURE
This type of service has the purpose of hosting Data and files that enable this Application to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of this Application. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
GODADDY (Gadaddy, LLC.)
Godaddy is a hosting service provided by Godaddy, LLC.
Personal Data collected: various types of Data as specified in the privacy policy of the service.
Place of processing: US – Privacy Policy.
MANAGING CONTACTS AND SENDING MESSAGES
This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.
MAILCHIMP (The Rocket Science Group, LLC.)
MailChimp is an email address management and message sending service provided by The Rocket Science Group, LLC.
Personal Data collected: email address.
Place of processing: US – Privacy Policy.
MANAGING SUPPORT AND CONTACT REQUESTS
This type of service allows this Application to manage support and contact requests received via email or by other means, such as the contact form.
The Personal Data processed depends on the information provided by the User in the messages and the means used for communication (e.g. email address).
ZENDESK (Zendesk)
Zendesk is a support and contact request management service provided by Zendesk Inc.
Personal Data collected: various types of Data as specified in the privacy policy of the service.
Place of processing: US – Privacy Policy.
REMARKETING AND BEHAVIORAL TARGETING
This type of service allows this Application and its partners to inform, optimize, and serve advertising based on past use of this Application by the User.
This activity is performed by tracking Usage Data and by using Cookies, information that is transferred to the partners that manage the remarketing and behavioral targeting activity.
In addition to any opt-out offered by any of the services below, the User may opt-out of a third-party service’s use of cookies by visiting the Network Advertising Initiative opt-out page.
FACEBOOK CUSTOM AUDIENCE (Facebook, Inc.)
Facebook Custom Audience is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of this Application with the Facebook advertising network.
Personal Data collected: Cookies and email addresses.
Place of processing: United States – Privacy Policy – Opt Out.
FACEBOOK REMARKETING (Facebook, Inc.)
Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of this Application with the Facebook advertising network.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
SPAM PROTECTION
This type of service analyzes the traffic of this Application, potentially containing Users’ Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognized as SPAM.
AKISMET(Automattic Inc.)
Akismet is a SPAM protection service provided by Automattic Inc.
Personal Data collected: various types of Data as specified in the privacy policy of the service.
Place of processing: US – Privacy Policy.
TRAFFIC OPTIMIZATION AND DISTRIBUTION
This type of service allows this Application to distribute their content using servers located across different countries and to optimize their performance.
Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between this Application and the User’s browser.
Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information User are transferred.
CLOUDFLARE (Cloudflare)
Cloudflare is a traffic optimization and distribution service provided by CloudFlare Inc.
The way Cloudflare is integrated means that it filters all the traffic through this Application, i.e., communication between this Application and the User’s browser, while also allowing analytical data from this Application to be collected.
Personal Data collected: Cookies and various types of Data as specified in the privacy policy of the service.
Place of processing: US – Privacy Policy.
USER DATA MANAGEMENT
This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to this Application, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks’ profiles) and used to build private profiles that the Owner can display and use for improving this Application.
Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on this Application.
INTERCOM(Intercom Inc.)
Intercom is a User database management service provided by Intercom Inc. Intercom can also be used as a medium for communications, either through email or through messages within this Application.
Personal Data collected: Cookies, email address, Usage Data, and various types of Data as specified in the privacy policy of the service.
Place of processing: US – Privacy Policy.
MARKETING
We may use your Identity, Contact, Technical, Usage, and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services, and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased products or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
THE RIGHT OF THE USER
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following:
Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
Object to the processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing, and obtain a copy of the Data undergoing processing.
Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
DETAILS ABOUT THE RIGHT TO OBJECTION
Where Personal Data is processed for the public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
HOW TO EXERCISE RIGHTS
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.
OWNER AND DATA CONTROLLER
Michael Brosnan
Email: [email protected]
Phone: 07949007115
COOKIE POLICY
This Application uses Cookies. To learn more and for a detailed cookie notice, the User may consult the Cookie Policy.
Additional information about Data collection and processing
LEGAL ACTION
The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
ADDITIONAL INFORMATION ABOUT USER’S PERSONAL DATA
In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
SYSTEMS LOG AND MAINTENANCE
For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) use other Personal Data (such as the IP Address) for this purpose.
INFORMATION NOT CONTAINED IN THE PRIVACY POLICY
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
HOW “DO NOT TRACK” REQUESTS ARE HANDLED
This Application does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.
CHANGES TO PRIVACY POLICY
The Owner reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page and possibly within this Application and/or – as far as technically and legally feasible – sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. If a User objects to any of the changes to the Policy, the User must cease using this Application and can request that the Owner remove the Personal Data. Unless stated otherwise, the then-current privacy policy applies to all Personal Data the Owner has about Users.
DEFINITIONS AND LEGAL REFERENCES
PERSONAL DATA (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
USAGE DATA
Information collected automatically through this Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.
USER
The individual using this Application who, unless otherwise specified, coincides with the Data Subject.
DATA SUBJECT
The natural person to whom the Personal Data refers.
DATA PROCESSOR (or Data Supervisor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
DATA CONTROLLER (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.
THIS APPLICATION
The means by which the Personal Data of the User is collected and processed.
SERVICE
The service provided by this Application as described in the relative terms (if available) and on this site/application.
EUROPEAN UNION (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
COOKIES
If you leave a comment on our site you may opt-in to save your name, email address, and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.
If you have an account and you log in to this site, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.
When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.
If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.
EMBEDDED CONTENT FROM OTHER WEBSITES
Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.
COPYRIGHTS & TERMS OF USE
This material, including photographs, digital images, copyright, and trademarks, is owned by Michael Brosnan and protected by law.
PERMISSION STATEMENT
This material may not be used, reproduced, stored, or transmitted for commercial or non-commercial purposes without the express written permission of Michael Brosnan Photography.
DISCLAIMER
Information at this site is provided solely for the user’s information and, while thought to be accurate, is provided strictly “as is” and without warranty of any kind. Michael Brosnan and Headshots Universal, its agents, employees or contractors will not be liable to you for any damages, direct or indirect, or lost profits arising out of your use of information provided at this site, or information provided at any other site that can be accessed from this site.
LEGAL INFORMATION
This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).
This privacy policy relates solely to this Application, if not stated otherwise within this document.
Last Update: 18 March 2020
