Privacy Policy

Introduction

1.1 We are committed to safeguarding the privacy of our website visitors.

1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors; in other words, where we determine the purposes and means of the processing of that personal data.

1.3 We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website.

1.4 In this policy, “we”, “us” and “our” refer to Magniv Photomagnets. (For more information about us, see Section 13).

1.5 This document was created using a template from SEQ Legal (https://seqlegal.com).

**How we use your personal data **

2.1 In this section we have set out:

(a) the general categories of personal data that we may process;

(b) the purposes for which we may process personal data; and

2.2 We do not process your personal data that are provided in the course of the use of our website (“service data“).

2.3 We may process information that you post for publication on our website (comments and reviews) (“publication data“). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is the consent when submitting a publication.

2.4 We may process information contained in any enquiry you submit to us regarding goods and/or services through the contact forms (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent through submitting of a form.

2.5 We may process information relating to our customer relationships, including customer contact information (“customer relationship data“). The customer relationship data may include your name, your email, your phone number, your address, your company, your proposed venue, your proposed function date, your proposed number of guests, your proposed number of hours and information contained in communications between us and you. The source of the customer relationship data is through our contact forms. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is consent through submitting of a form.

2.6 We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication through our contact forms. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our and your legitimate interests, namely the proper administration of our website, ability to provide our services and to communicate with users.

2.7 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

2.8 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

2.9 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject to and in order to protect your vital interests or the vital interests of another person.

2.10 Please do not supply any other person’s personal data to us, unless we prompt you to do so.

Providing your personal data to others

3.1 We may disclose your personal data to any member of our group of outsourced-companies, insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.

3.2 We may disclose your personal data to our insurers and/or professional advisers, insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

3.3 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

International transfers of your personal data 4.1 In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).

4.2 We have an office in Spain. The European Commission has made an “adequacy decision” with respect to the data protection laws of this country. Transfers to Spain will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted and approved by us.

4.3 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

**Retaining and deleting personal data **

5.1 This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

5.3 We will retain your personal data for a minimum period of 1 year following the date of submission, up to a maximum of 5 years from the date of your event.

5.4 Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

Amendments 6.1 We may update this policy from time to time by publishing a new version on our website.

6.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

6.3 We may notify you of changes to this policy by email.

**Your rights **

7.1 In this Section 7, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

7.2 Your principal rights under data protection law are:

(a) the right to access;

(b) the right to rectification;

(d) the right to restrict processing;

(e) the right to object to processing;

(f) the right to data portability;

(g) the right to complain to a supervisory authority; and

(h) the right to withdraw consent.

7.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

7.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

7.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

7.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

7.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

7.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

7.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

7.10 To the extent that the legal basis for our processing of your personal data is:

(a) consent; or

(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

7.11 If you consider that our processing of your personal information infringes data protection laws, please let us know and we will be happy to oblige.

7.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

7.13 You may exercise any of your rights in relation to your personal data by written notice to us.

**About cookies **

8.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

8.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

8.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

Cookies that we use 9.1 We use cookies for security – we use cookies as an element of the security measures used to protect us from spam, including preventing fraudulent use of our contact forms, and to protect our website and services generally (cookies used for this purpose are the CAPTCHA verification at the end of forms). 9.2 We also use cookies for marketing purposes to send targeted advertising and track user behaviour.

**Managing cookies ** 10.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);

(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e) https://support.apple.com/kb/PH21411 (Safari); and

(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

10.2 Blocking all cookies will have a negative impact upon the usability of many websites.

10.3 If you block cookies, you will not be able to use all the features on our website.

Our details 11.1 This website is owned and operated by MAGNIV Photomagnets Ltd.

11.2 You can contact us:

(a) by using our website contact form;

(b) by email, using hello@magniv.co.uk

Below are the additional privacy provisions (“Additional Provisions”) relating specifically to the MAGNIV Photo Distribution Service (“Photo Distribution Service”). These Additional Provisions form an integral part of our existing Privacy Policy and apply where we act as a data controller with respect to the personal data processed in connection with the Photo Distribution Service. In the event of any conflict between these Additional Provisions and our base Privacy Policy, these Additional Provisions shall apply with respect to the Photo Distribution Service.

Additional Provisions - MAGNIV Photo Sharing Services

1. Introduction

1.1 Purpose and Scope.
These Additional Provisions set out how MAGNIV Photomagnets Ltd (“MAGNIV”, “we”, “us” or “our”) collects, uses, stores, and shares personal data in connection with the Photo Distribution Service. This service enables guests to receive event photographs by using facial recognition technology that matches a guest’s uploaded selfie with event photos. In addition, the service integrates third-party services such as Amazon Rekognition, Google OAuth, and WhatsApp.

1.2 Relation to the Base Privacy Policy.
These provisions supplement our existing Privacy Policy. All references to “we”, “us” and “our” in these Additional Provisions have the same meaning as in the base Privacy Policy. Where applicable, the legal bases, retention practices, and your rights described in our base Privacy Policy continue to apply.

2. Additional Categories of Personal Data Processed

2.1 Biometric and Facial Data.
For the purposes of providing the Photo Distribution Service, we process biometric data in the form of facial images. This includes:

Selfie Images: Guests who register to receive photos must upload a clear selfie.
Event Photographs: Photographs uploaded by event hosts or their designated contributors are processed to detect and match facial features.

2.2 Contact and Authentication Data.
In addition to biometric data, the service may process:

Contact details (such as phone numbers and email addresses) provided by guests to facilitate photo delivery (e.g. via WhatsApp).
Authentication data obtained through Google OAuth to confirm guest identities.

2.3 Metadata and Usage Information.
We may also collect metadata associated with image uploads and the use of third-party services (e.g. IP addresses, timestamps, and device information) to help ensure the security and smooth operation of the Photo Distribution Service.

3. How We Use Your Personal Data for the Photo Distribution Service

3.1 Facial Recognition and Matching.
We use Amazon Rekognition to compare uploaded selfies with event photographs. The sole purpose of this processing is to accurately identify guests in event photos so that we can deliver relevant images to them.

3.2 Service Provision and Communication.
Your personal data is used to:

Authenticate users through Google OAuth.
Distribute matched photos via WhatsApp or other chosen communication channels.
Manage and administer the Photo Distribution Service, including troubleshooting and improving our service.

3.3 Legal Bases for Processing.
The processing of personal data for the Photo Distribution Service is carried out on one or more of the following legal bases:

Consent: By uploading a selfie and registering for the service, you explicitly consent to the processing of your biometric and contact data.
Contractual Necessity: Processing is necessary for the performance of the service you have requested.
Legitimate Interests: We process personal data to ensure the effective and secure operation of the service, provided such interests do not override your rights and freedoms.
Legal Obligation: Where required, processing may also be necessary for compliance with applicable legal obligations.

4. Sharing and Disclosure of Personal Data

4.1 Third-Party Service Providers.
In connection with the Photo Distribution Service, we share personal data with the following third-party service providers:

Amazon Rekognition: For facial recognition and matching purposes.
Google OAuth: For authentication and identity verification.
WhatsApp (and similar messaging platforms): For the purpose of photo delivery.

Each third party is contractually obligated to protect your data and process it only for the purposes specified by us. We recommend reviewing the privacy policies of these third parties for further information.

4.2 Other Disclosures.
In line with our base Privacy Policy, your personal data may also be disclosed:

To our group companies or outsourced partners as reasonably necessary for providing the service.
For compliance with a legal obligation, or to protect your vital interests or those of another natural person.
In connection with any legal claims, disputes, or proceedings.

5. International Transfers

5.1 Transfers Outside the EEA.
Personal data processed in relation to the Photo Distribution Service may be transferred to, and maintained on, servers located outside the European Economic Area (EEA). In such cases, we ensure that appropriate safeguards are in place in accordance with applicable law (for example, standard contractual clauses or other legally approved transfer mechanisms).

5.2 Third-Party Transfers.
When personal data is transferred to third-party providers such as Amazon, Google, or WhatsApp, such transfers will be subject to the terms and data protection practices of those providers.

6. Data Retention for the Photo Distribution Service

6.1 Retention Period.
Personal data collected specifically for the Photo Distribution Service (including selfies, event photographs, and related metadata) will be retained only for as long as necessary to provide the service or until you request deletion, subject to any legal or regulatory obligations.

6.2 Deletion and Anonymisation.
Once the purpose for processing is fulfilled, we will either securely delete or anonymise your data. In particular, biometric data used for facial recognition will not be retained longer than necessary for the operational requirements of the service.

7. Your Rights in Relation to Photo Distribution Service Data

7.1 Access and Correction.
You have the right to request access to the personal data we process in relation to the Photo Distribution Service, including the biometric and contact information. You may also request that any inaccurate or incomplete data be rectified.

7.2 Erasure and Restriction.
Subject to applicable law and where no overriding legal obligation exists, you have the right to request deletion or restriction of the processing of your personal data collected for this service.

7.3 Data Portability.
Where applicable, you have the right to obtain your personal data in a structured, commonly used, and machine-readable format and to transfer that data to another controller.

7.4 Withdrawal of Consent.
If your processing is based on consent, you have the right to withdraw your consent at any time. Please note that withdrawal will not affect the lawfulness of processing prior to the withdrawal.

7.5 Exercising Your Rights.
Any requests to exercise your rights should be submitted in writing using the contact details provided in Section 11 (“Our Details”) below. We will respond in accordance with applicable data protection laws.

8. Cookies and Similar Technologies

8.1 Cookies in the Photo Distribution Service.
In addition to the cookies described in our base Privacy Policy, the Photo Distribution Service may use cookies or similar technologies to facilitate authentication (via Google OAuth) and to enhance the performance and security of the service.

8.2 Managing Cookies.
The methods for managing these cookies are the same as those outlined in our base Privacy Policy. Blocking these cookies may affect your ability to use certain features of the Photo Distribution Service.

9. Amendments to These Additional Provisions

9.1 Updates.
We may update these Additional Provisions from time to time by publishing a revised version on our website. Any changes will be effective upon posting and, where appropriate, you will be notified by email.

9.2 Continued Use.
Your continued use of the Photo Distribution Service after any changes constitutes your acceptance of the revised Additional Provisions.

10. Our Details

10.1 Contacting Us.
For any queries or concerns regarding these Additional Provisions or your personal data processed in connection with the Photo Distribution Service, please contact us by one of the following means:

Via our website contact form
Email: hello@magniv.co.uk

By using the MAGNIV Photo Distribution Service, you acknowledge that you have read, understood, and agree to the processing of your personal data as described in these Additional Provisions, in conjunction with our base Privacy Policy.

If you have any further questions or require clarification regarding any aspect of our data processing practices for the Photo Distribution Service, please do not hesitate to contact us.