Privacy Policy

Privacy Policy

Data protection is of a particularly high priority for Sonja Lee Photography. The use of the Sonja Lee Photography website is possible without any indication of personal data; however, if a data subject wants to use special enterprise services via our website, processing of personal data could become necessary. If the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain consent from the data subject.

The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject, shall always be in line with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection regulations applicable to Sonja Lee Photography (United Kingdom).

By means of this data protection declaration, our enterprise would like to inform the general public of the nature, scope, and purpose of the personal data we collect, use, and process. Furthermore, data subjects are informed, by means of this data protection declaration, of the rights to which they are entitled.

As the controller, Sonja Lee Photography has implemented numerous technical and organisational measures to ensure the most complete protection of personal data processed through this website. However, Internet-based data transmissions may, in principle, have security gaps, so absolute protection may not be guaranteed. For this reason, every data subject is free to transfer personal data to us via alternative means, e.g. by telephone.

1. Definitions

The data protection declaration for Sonja Lee Photography is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration should be legible and understandable for the general public, as well as our customers and business partners. To ensure this, we would like to first explain the terminology used.

In this data protection declaration, we use, inter alia, the following terms:

a) Personal data

Personal data means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

b) Data subject

Data subject is any identified or identifiable natural person whose personal data is processed by the controller responsible for the processing.

c) Processing

Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment or combination, restriction, erasure, or destruction.

d) Restriction of processing

Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.

e) Profiling

Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location, or movements.

f) Pseudonymisation

Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

g) Controller or controller responsible for the processing

Controller or controller responsible for the processing is 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; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

h) Processor

Processor is a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller.

i) Recipient

Recipient is a natural or legal person, public authority, agency, or another body to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.

j) Third party

Third party is a natural or legal person, public authority, agency, or body other than the data subject, controller, processor, and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

k) Consent

Consent of the data subject is any freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

2. Name and Address of the Controller

Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member States of the European Union, and other provisions related to data protection is:

Sonja Lee Photography
43 Minden Way
Tidworth, Wiltshire
SP9 7GX
United Kingdom

3. Collection of General Data and Information

The website of Sonja Lee Photography collects a series of general data and information when a data subject or automated system calls up the website. This general data and information are stored in the server log files.

This may include:

  1. The browser types and versions used;
  2. The operating system used by the accessing system;
  3. The website from which an accessing system reaches our website (so-called referrers);
  4. The sub-websites;
  5. The date and time of access to the Internet site;
  6. An Internet Protocol address (IP address);
  7. The Internet service provider of the accessing system; and
  8. Any other similar data and information that may be used in the event of attacks on our information technology systems.

When using these general data and information, Sonja Lee Photography does not draw any conclusions about the data subject. Rather, this information is needed to:

  1. Deliver the content of our website correctly;
  2. Optimise the content of our website as well as its advertising;
  3. Ensure the long-term viability of our information technology systems and website technology; and
  4. Provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack.

Therefore, Sonja Lee Photography analyses anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise and ensuring an optimal level of protection for the personal data we process.

The anonymous data of the server log files are stored separately from all personal data provided by a data subject.

4. Subscription to Our Newsletters

On the website of Sonja Lee Photography, users are given the opportunity to subscribe to our newsletter. The input mask used for this purpose determines what personal data are transmitted, as well as when the newsletter is ordered from the controller.

Sonja Lee Photography informs its customers and business partners regularly by means of a newsletter about enterprise offers. The enterprise’s newsletter may only be received by the data subject if:

  1. The data subject has a valid e-mail address; and
  2. The data subject registers for the newsletter via the website.

In this case, a confirmation e-mail will be sent to the e-mail address registered by a data subject for the first time for newsletter shipping, for legal reasons, in the double opt-in procedure. This confirmation e-mail is used to prove whether the owner of the e-mail address, as the data subject, is authorised to receive the newsletter.

If the data subject chooses to opt in to the newsletter subscription via an alternative means (through events, e-mail, or through this policy), the double opt-in system will not be used, as the e-mail address will be added manually.

During registration for the newsletter, we also store the IP address of the computer system assigned by the Internet service provider (ISP) and used by the data subject at the time of registration, as well as the date and time of registration.

The collection of this data is necessary in order to understand the possible misuse of the e-mail address of a data subject at a later date, and it therefore serves the aim of the legal protection of the controller.

The personal data collected as part of registration for the newsletter will only be used to send our newsletter. In addition, subscribers to the newsletter may be informed by e-mail where this is necessary for the operation of the newsletter service or a registration in question, as could be the case in the event of modifications to the newsletter offer or a change in technical circumstances.

There will be no transfer of personal data collected by the newsletter service to third parties.

The subscription to our newsletter may be terminated by the data subject at any time. Consent to the storage of personal data given by the data subject for the purpose of newsletter delivery may be revoked at any time. For the purpose of revocation of consent, a corresponding link is found in each newsletter.

It is also possible to unsubscribe from the newsletter at any time directly on the website of the controller or to communicate this to the controller in another way.

5. Newsletter Tracking

The newsletter of Sonja Lee Photography contains so-called tracking pixels. A tracking pixel is a miniature graphic embedded in e-mails sent in HTML format to enable log file recording and analysis.

This allows a statistical analysis of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, Sonja Lee Photography may see if and when an e-mail was opened by a data subject and which links in the e-mail were accessed by data subjects.

Such personal data collected through tracking pixels contained in the newsletters are stored and analysed by the controller in order to optimise the delivery of the newsletter and to adapt the content of future newsletters more closely to the interests of the data subject.

These personal data will not be passed on to third parties.

Data subjects are at any time entitled to revoke the respective separate declaration of consent issued by means of the double opt-in procedure. After a revocation, these personal data will be deleted by the controller.

Sonja Lee Photography automatically regards a withdrawal from receipt of the newsletter as a revocation.

6. Contact Possibility via the Website

The Sonja Lee Photography website contains information that enables a quick electronic contact with our enterprise, as well as direct communication with us, which also includes electronic mail (e-mail address).

If a data subject contacts the controller by e-mail or via a contact form, the personal data transmitted by the data subject are automatically stored.

Such personal data transmitted voluntarily by a data subject to the data controller are stored for the purpose of processing or contacting the data subject.

There is no transfer of this personal data to third parties.

7. Comments Function in the Blog on the Website

Sonja Lee Photography offers users the possibility to leave individual comments on individual blog contributions on a blog on the website of the controller.

A blog is a web-based, publicly accessible portal through which one or more people, called bloggers or web bloggers, may post articles or write down thoughts in so-called blog posts. Blog posts may usually be commented on by third parties.

If a data subject leaves a comment on the blog published on this website, the comments made by the data subject are also stored and published, as well as information on the date of the commentary and on the username (pseudonym) chosen by the data subject.

In addition, the IP address assigned by the Internet service provider (ISP) to the data subject is also logged.

This storage of the IP address takes place for security reasons and in case the data subject violates the rights of third parties or posts illegal content through a given comment.

The storage of these personal data is therefore in the own interest of the data controller, so that the controller can defend itself in the event of an infringement.

This collected personal data will not be passed to third parties unless such a transfer is required by law or serves the aim of the defence of the data controller.

8. Subscription to Comments in the Blog on the Website

The comments made in the blog of Sonja Lee Photography may be subscribed to by third parties.

In particular, there is the possibility that a commenter subscribes to the comments following their comments on a particular blog post.

If a data subject decides to subscribe to this option, the controller will send an automatic confirmation e-mail to check the double opt-in procedure and confirm whether the owner of the specified e-mail address decided in favour of this option.

The option to subscribe to comments may be terminated at any time.

9. Routine Erasure and Blocking of Personal Data

The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject.

If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.

10. Rights of the Data Subject

a) Right of Confirmation

Each data subject shall have the right granted by the European legislator to obtain from the controller confirmation as to whether or not personal data concerning them are being processed.

If a data subject wishes to exercise this right, they may contact the controller at any time.

b) Right of Access

Each data subject shall have the right granted by the European legislator to obtain from the controller free information about their personal data stored at any time and a copy of this information.

Furthermore, the data subject has the right to obtain information regarding:

  • The purposes of the processing;
  • The categories of personal data concerned;
  • The recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
  • Where possible, the envisaged period for which the personal data will be stored or, if not possible, the criteria used to determine that period;
  • The existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;
  • The existence of the right to lodge a complaint with a supervisory authority;
  • Where the personal data are not collected from the data subject, any available information as to their source;
  • The existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.

Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organisation. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.

If a data subject wishes to exercise this right of access, they may contact the controller at any time.

c) Right to Rectification

Each data subject shall have the right granted by the European legislator to obtain from the controller, without undue delay, the rectification of inaccurate personal data concerning them.

Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

If a data subject wishes to exercise this right to rectification, they may contact the controller at any time.

d) Right to Erasure (Right to Be Forgotten)

Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning them without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:

  • The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
  • The data subject withdraws consent on which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.
  • The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.
  • The personal data have been unlawfully processed.
  • The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
  • The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.

If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by Sonja Lee Photography, they may contact the controller at any time.

An employee of Sonja Lee Photography shall promptly ensure that the erasure request is complied with, subject to any applicable legal requirements.

Where the controller has made personal data public and is obliged pursuant to Article 17(1) to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required.

An employee of Sonja Lee Photography will arrange the necessary measures in individual cases.

e) Right of Restriction of Processing

Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:

  • The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
  • The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use.
  • The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise, or defence of legal claims.
  • The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification of whether the legitimate grounds of the controller override those of the data subject.

If one of the aforementioned conditions is met, and a data subject wishes to request restriction of the processing of personal data stored by Sonja Lee Photography, they may contact the controller at any time.

An employee of Sonja Lee Photography will arrange the restriction of processing.

f) Right to Data Portability

Each data subject shall have the right granted by the European legislator to receive the personal data concerning them, which was provided to a controller, in a structured, commonly used, and machine-readable format.

They shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Furthermore, in exercising their right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.

In order to assert the right to data portability, the data subject may contact the controller at any time.

g) Right to Object

Each data subject shall have the right granted by the European legislator to object, on grounds relating to their particular situation, at any time, to processing of personal data concerning them, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.

Sonja Lee Photography shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the data subject, or for the establishment, exercise, or defence of legal claims.

If Sonja Lee Photography processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning them for such marketing. This applies to profiling to the extent that it is related to such direct marketing.

If the data subject objects to Sonja Lee Photography processing their personal data for direct marketing purposes, Sonja Lee Photography will no longer process the personal data for these purposes.

In addition, the data subject has the right, on grounds relating to their particular situation, to object to processing of personal data concerning them by Sonja Lee Photography for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

In order to exercise the right to object, the data subject may contact the controller.

In addition, the data subject is free, in the context of the use of information society services and notwithstanding Directive 2002/58/EC, to use their right to object by automated means using technical specifications.

h) Automated Individual Decision-Making, Including Profiling

Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them, as long as the decision:

  1. Is not necessary for entering into, or the performance of, a contract between the data subject and a data controller;
  2. Is not authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests; or
  3. Is not based on the data subject’s explicit consent.

If the decision:

  1. Is necessary for entering into, or the performance of, a contract between the data subject and a data controller; or
  2. Is based on the data subject’s explicit consent,

Sonja Lee Photography shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, including at least the right to obtain human intervention on the part of the controller, to express their point of view, and to contest the decision.

If the data subject wishes to exercise rights concerning automated individual decision-making, they may contact the controller at any time.

i) Right to Withdraw Data Protection Consent

Each data subject shall have the right granted by the European legislator to withdraw their consent to processing of their personal data at any time.

If the data subject wishes to exercise the right to withdraw consent, they may contact the controller at any time.

11. Data Protection Provisions About the Application and Use of Google Analytics (with Anonymisation Function)

On this website, the controller has integrated the component of Google Analytics (with the anonymiser function).

Google Analytics is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behaviour of visitors to websites.

A web analysis service collects, inter alia, data about the website from which a person has come (the so-called referrer), which sub-pages were visited, or how often and for what duration a sub-page was viewed.

Web analytics are mainly used for the optimisation of a website and in order to carry out a cost-benefit analysis of Internet advertising.

The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.

For web analytics through Google Analytics, the controller uses the application _gat._anonymizeIp. By means of this application, the IP address of the Internet connection of the data subject is abridged by Google and anonymised when accessing our websites from a Member State of the European Union or another Contracting State to the Agreement on the European Economic Area.

The purpose of the Google Analytics component is to analyse traffic on our website.

Google uses the collected data and information, inter alia, to evaluate the use of our website and to provide online reports which show the activities on our websites, and to provide other services concerning the use of our Internet site for us.

Google Analytics places a cookie on the information technology system of the data subject. The definition of cookies is explained above.

With the setting of the cookie, Google is enabled to analyse the use of our website. With each call-up to one of the individual pages of this Internet site, which is operated by the controller and into which a Google Analytics component was integrated, the Internet browser on the information technology system of the data subject will automatically submit data through the Google Analytics component for the purpose of online advertising and the settlement of commissions to Google.

During the course of this technical procedure, the enterprise Google gains knowledge of personal information, such as the IP address of the data subject, which serves Google, inter alia, to understand the origin of visitors and clicks and subsequently create commission settlements.

The cookie is used to store personal information, such as the access time, the location from which the access was made, and the frequency of visits to our website by the data subject.

With each visit to our Internet site, such personal data, including the IP address of the Internet access used by the data subject, will be transmitted to Google in the United States of America.

These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.

The data subject may, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies.

Such an adjustment to the Internet browser used would also prevent Google Analytics from setting a cookie on the information technology system of the data subject.

In addition, cookies already in use by Google Analytics may be deleted at any time via a web browser or other software programs.

The data subject also has the possibility of objecting to the collection of data generated by Google Analytics relating to the use of this website, as well as the processing of this data by Google.

For this purpose, the data subject must download and install a browser add-on under the following link:

Google Analytics Opt-out Browser Add-on

This browser add-on tells Google Analytics through JavaScript that any data and information about visits to Internet pages may not be transmitted to Google Analytics.

The installation of the browser add-on is considered an objection by Google. If the information technology system of the data subject is later deleted, formatted, or newly installed, the data subject must reinstall the browser add-on to disable Google Analytics.

If the browser add-on was uninstalled by the data subject or any other person attributable to their sphere of competence, or is disabled, it is possible to execute the reinstallation or reactivation of the browser add-on.

Further information and the applicable data protection provisions of Google may be retrieved under:

Google Privacy Policy

Google Analytics Terms of Service

Google Analytics

Legal Basis for Processing

Article 6(1)(a) GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose.

If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1)(b) GDPR.

The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services.

If our company is subject to a legal obligation by which processing of personal data is required, such as for the fulfilment of tax obligations, the processing is based on Article 6(1)(c) GDPR.

In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured in our company and their name, age, health insurance data, or other vital information would have to be passed on to a doctor, hospital, or other third party. Then the processing would be based on Article 6(1)(d) GDPR.

Finally, processing operations could be based on Article 6(1)(f) GDPR. This legal basis is used for processing operations which are not covered by any of the aforementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. The legislator considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47, Sentence 2 GDPR).

12. The Legitimate Interests Pursued by the Controller or by a Third Party

Where the processing of personal data is based on Article 6(1)(f) GDPR, our legitimate interest is to carry out our business in favour of the well-being of all our employees and shareholders.

13. Period for Which the Personal Data Will Be Stored

The criteria used to determine the period of storage of personal data is the respective statutory retention period.

After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfilment of the contract or the initiation of a contract.

14. Provision of Personal Data as a Statutory or Contractual Requirement; Requirement Necessary to Enter into a Contract; Obligation of the Data Subject to Provide the Personal Data; Possible Consequences of Failure to Provide Such Data

We clarify that the provision of personal data is partly required by law, e.g. tax regulations, or can also result from contractual provisions, e.g. information on the contractual partner.

Sometimes it may be necessary to conclude a contract that the data subject provides us with personal data which must subsequently be processed by us.

The data subject is, for example, obliged to provide us with personal data when our company enters into a contract with them.

The non-provision of the personal data would have the consequence that the contract with the data subject could not be concluded.

Before personal data is provided by the data subject, the data subject must contact the controller. The controller will clarify to the data subject whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data, and the consequences of non-provision of the personal data.

15. Existence of Automated Decision-Making

As a responsible company, we do not use automatic decision-making or profiling.