Privacy Policy

The website https://thepeoplespicture.com/ (“Website”) is operated by Helen Marshall Limited trading as The People’s Picture (“we”, “us” or “our”), a company registered in England & Wales under company number 11423615, whose registered office is at 7, Wadeson Street, London, E2 9DR, and The People’s Picture, Inc. a company incorporated in Delaware with its registered office at 8 The Green Str. B, Dover, Delaware 19901. We collect, use and are responsible for certain personal information about you. When we do so we are regulated under the General Data Protection Regulation (“GDPR”) and the Data Protection Act 2018 (“DPA”) which apply in the European Union and the United Kingdom. Where we solely or jointly decide the purpose or means for the processing of the personal data that you provide when using our services, we are the “controller” of your personal data. Where we process the personal data that you provide when using our services on behalf of a third party who decides the purposes or means of that personal data, we are the “processor” of your personal data. We will comply our obligations as controller or processor of your personal data (as the case may be) pursuant to all applicable data protection laws, including the GDPR and the DPA.

This policy relates to your use of the Website and should be read together with our Website Terms of Use (https://thepeoplespicture.com/terms-conditions/) and our Contributor Terms and Conditions (https://thepeoplespicture.com/contributor-terms-conditions/). Throughout the Website we may link to other websites owned and operated by certain trusted third parties (e.g. to make additional information, products and services available to you). These other third-party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other third-party websites, please consult their privacy policies as appropriate.

We may collect personal information about you when you access the Website, subscribe to our mailing list (or a mailing list of our commissioning partners), contact us, send us feedback, submit information via the Website and/or participate in any of our photo mosaic projects. We collect this personal information from you either directly (such as when you submit information via the Website) or indirectly (such as your browsing activity while on the website (see Analytics section below).

Information provided by you

The personal information we collect about you depends on the activities carried via the Website. This information includes:

• Your name;
• Your address;
• Your phone number;
• Your email address;
• Your age;
• Your gender;
• Your birthplace; and/or
• Your social media handles,

(together, “Your Basic Information“).

You may also submit content to the Website and via social media (using specific hashtags and tagging) including:

• Photographs of you or that you have permission to grant us a licence to use; and/or
• Stories and other information that you would like us to publish,

(together, “Your Content”).

We do not intend to collect or use and we do not knowingly collect or use:

• any special categories of personal data (including details about your race, ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, genetic information or biometric information) (“Special Category Data”);
• any special categories of personal data (including details about your race, ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, genetic information or biometric information) (“Special Category Data”);
• any personal information about criminal convictions or offences (“Criminal Offence Data”); and/or
• any personal information relating to children (“Children’s Data”).

PLEASE DO NOT POST, UPLOAD OR OTHERWISE SUBMIT ANY OF YOUR CONTENT WHICH MAY CONTAIN SPECIAL CATEGORY DATA, CRIMINAL OFFENCE DATA OR CHILDREN’S DATA. IF YOU DO, YOU ACKNOWLEDGE AND AGREE THAT SUCH PERSONAL DATA HAS BEEN MANIFESTLY MADE PUBLIC BY YOU AND MAY BE MADE AVAILABLE AND/OR COMMUNICATED TO THE PUBLIC BY US AND/OR BY OUR COMMISSIONING PARTNERS AS PART OF A PHOTO MOSAIC PROJECT.

If a parent or guardian becomes aware that their child has provided us with information or may be receiving communications from us without consent of a parent or guardian, please contact us here. We will promptly address the situation and delete any information relating to a child as soon as practicable.

Analytics

Our Website uses cookies and other mechanisms to collect analytical information to help analyse how visitors use the Website. Such information includes:

• number of visitors to our Website;
• pages visited while at the Website and time spent per page;
• page interaction information, such as scrolling, clicks and browsing methods;
• websites where visitors have come from and where they go afterwards;
• page response times and any download errors; and/or
• other technical information relating to end user device, such as IP address or browser plug-in,

(together, the “Cookie Information”).

You can always choose to enable or disable cookies in your internet browser. By default, most internet browsers accept cookies but this can be changed. For further details, please consult the help menu in your internet browser. For further information about cookies, please see: www.allaboutcookies.org, and how to adjust your browser settings here: www.allaboutcookies.org/managecookies. We use Google Analytics on our Website for anonymous reporting of Website usage. If you would like to opt-out of Google Analytics monitoring your behaviour on our Website please use this link: (https://tools.google.com/dlpage/gaoptout/).

When we use your personal information we are required to have a legal basis for doing so. There are various different legal bases on which we may rely, depending on what personal information we process and why. The legal bases we may rely on include:

• consent: where you have given us clear consent for us to process your personal information for a specific purpose;
• contract: where our use of your personal information is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract;
• legal obligation: where our use of your personal information is necessary for us to comply with the law (not including contractual obligations); and/or
• legitimate interests: where our use of your personal information is necessary for our legitimate interests or the legitimate interests of a third party (unless there is a good reason to protect your personal information which overrides our legitimate interests).

When you visit our Website, whether to browse our content, to subscribe to our mailing list or to contribute to a photo mosaic project (our “Services”), or when you contact us in connection with our Services, we may use your personal information for the following purposes:

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We keep your information confidential but may disclose it to our partners, personnel, suppliers, subcontractors (including our cloud-based data processing, data analytics and payment service providers) and others insofar as it is reasonably necessary for the purposes set out in this privacy policy. This data sharing may involve the transfer of personal information outside the EEA (see International Data Transfers below)

Sharing information with third-party service providers

We may provide your personal information to the following third-party service providers:

• Payment-processing services such as PayPal or Intuit;
• Delivery couriers and postal services;
• Email marketing service providers such as Mailchimp;
• Event ticketing services;
• Marketing mailing houses;
• Social media platforms;
• Arts organisations, funders, sponsors, press, media or partners involved in our projects;
• Companies we subcontract to photograph, design, print or deliver our projects;
• Trained sub contracted arts assistants and interns and volunteers; and
• Software companies that we use to safely store and encrypt our data including Jot form, Drop box and Site Ground.

This list is not exhaustive and may change from time-to-time in line with our business processes. We will not pass your information on to third parties for marketing purposes unless you have provided your consent, in which case the advertisements that appear when you visit our Website may be targeted to provide you with more relevant advertising content and you may receive communications from third parties offering similar or related services to us. We require third parties to respect your personal information and to process it only in accordance with applicable law.

Sharing information with commissioning partners

If you choose to participate in a photo mosaic project, your Basic Information and Your Content will be a part of that project and, in accordance with our Contributor Terms and Conditions, will be shared with our commissioning partners for their use in connection with that photo mosaic project. The processing of your personal information by any commissioning partner is subject to their privacy policy.

Sharing information as part of a merger, acquisition or sale

If we are involved in a merger, acquisition or sale of all or a portion of our business or assets, the information we hold may be included as part of that merger, acquisition or sale, in which case you will be notified via email and/or a prominent notice on the Website of any changes affecting the use of your personal information. 

Legal requirement to share information

We may disclose your information to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies), in connection with any legal proceedings or prospective legal proceedings and in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).

Under the GDPR and the DPA, you have a number of important rights free of charge. In summary, those include rights to:

• fair processing of information and transparency over how we use your use personal information;
• access to your personal information and to certain other supplementary information that this privacy policy is already designed to address;
• require us to correct any mistakes in your information which we hold;
• require the erasure of personal information concerning you in certain situations;
• receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations;
• object at any time to processing of personal information concerning you for direct marketing;
• object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you;
• object in certain other situations to our continued processing of your personal information; and
• otherwise restrict our processing of your personal information in certain circumstances.

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (“ICO”) on individuals rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please:

• email, call or write to us;
• let us have enough information to identify you (e.g. your name and registration details);
• let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
• let us know the information to which your request relates.

You are under no statutory or contractual obligation to provide us with any personal information. However, if you do not provide the personal information necessary for the performance of our Services, we will not be able to provide you with our Services. If you are unhappy with the way that we are processing your personal information or would like to limit the processing of your personal information to a particular purpose, please email us here.

If you have previously consented to direct marketing but now would prefer not to receive direct marketing, you can follow the opt-out links on any marketing message sent to you or you can email us here.

We will take appropriate technical and organisational measures to ensure a level of security appropriate to the risk that could be encountered via the use of our Website and our Services. Except where otherwise described in this policy, we will limit access to your personal information to those employees, agents, contractors and third parties who need access. They will be subject to a duty of confidentiality. Confidentiality shall not apply to your personal information to the extent that it is: (a) made public by you; or (b) provided by you to us to be made public, such as for use in a photo mosaic project.

All information you provide to us is stored on our secure servers using a verified SSL (secure socket layer) system for transferring data. If you click on the small padlock symbol at the top of your browser’s screen, next to the web address, you will be taken to the site’s security certificate.

Whilst we make the security of our Website and your personal information a high priority, no security system can prevent all security breaches. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted to our site. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

In accordance with the requirements of the GDPR, the DPA and good commercial practice, we do not retain personal information in a form that permits identification of the person to whom it relates for any longer than is necessary.

After the purpose for which your personal information has been collected has been completed, we will either permanently delete it completely or remove all identifiers within it so that it is no longer personal data. We may use such anonymised data for research and/or business analysis purposes.

Where you have provided us with a photograph, image and/or story for use in an artwork or as part of a photo mosaic project, and you have expressly granted us a licence to use that photograph, image and/or story, it will remain as part of our artworks and archives and will be used in accordance with the terms of the licence.

Where we obtain your personal information in relation to the use or purchase of our Services, we are legally required to retain certain VAT and invoicing information for a minimum of 6 years.

If you contact us for a proposal or commission and you do not consent to marketing, we will keep your personal information for one year in anticipation that you wish to proceed with the proposal or commission.

Our servers are located in the EEA and the information that we collect directly from you will be stored on these servers.

We may also transfer your personal information to our third-party service providers, many of whom may be located outside of the EEA, operate from multiple locations including non-EEA based operations or engage sub-processors located outside the EEA.

Where your personal information is transferred outside of the EEA to a territory not subject to an adequacy decision by the European Commission, we will have data processing agreements or data sharing agreements in place with the relevant third parties which include standard contractual clauses approved by the European Commission, to ensure that appropriate safeguards are used to protect your personal information.

If you require more information about these safeguards, you can contact us here

We may update the terms of this policy from time to time. We will endeavour to notify you of any significant changes in the way we collect and process your personal information. We may do this by displaying a notice on the Website. This policy was last updated on 3 August 2020.

If you have any questions, comments or enquiries, please contact: 

HELEN MARSHALL LIMITED (Company No. 11423615)

The People’s Picture, 7, Wadeson Street, London, E2 9DR

The People’s Picture, Inc. 8 The Green Str. B, Dover, Delaware 19901

Email: admin@thepeoplespicture.com

Tel: 02087932769