This Privacy Policy explains how Antonin Puleo Photography (“we,” “us,” or “our”), collects, uses, discloses, and protects your personal data when you visit and use our website.

We are committed to protecting your privacy and handling your personal data in an open and transparent manner, in accordance with the General Data Protection Regulation (GDPR) (EU) 2016/679 and Belgian data protection laws.

1. Who We Are

Website Name: Antonin Puleo Photography

Website URL: https://antoninpuleo.com

Owner/Data Controller: Antonin Puleo

2. Data We Collect

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

2.1 Information You Provide to Us

When you use our contact form, you may provide us with:

• Name: To address you personally.
• Email Address: To respond to your inquiry.
• Message: Any personal information you choose to include in your message.

2.2 Information Collected Automatically

When you visit our WordPress website, certain information may be collected automatically:

• Log Data: Our servers automatically record information that your browser sends whenever you visit our site. This may include your IP address, browser type, browser version, the pages of our site that you visit, the time and date of your visit, the time spent on those pages, and other statistics.
• Cookies: We use cookies to enhance your browsing experience. Please see Section 9 for more details on our use of cookies.
• Google Analytics: We use Google Analytics to understand how visitors use our website. This service collects information such as your IP address, pages visited, time spent on pages, and referring websites. This data is aggregated and anonymized where possible.
• Google reCAPTCHA: We use Google reCAPTCHA on our contact form to protect against spam and abuse. reCAPTCHA collects hardware and software information, such as device and application data, and sends it to Google for analysis. This information is used for providing, maintaining, and improving reCAPTCHA and for general security purposes, but not for personalised advertising by Google.

2.3 Photographic Images

Our portfolio pages feature photographs, some of which are portraits of individuals. Where individuals are identifiable, and depending on the context and agreements, these images may constitute personal data. We ensure that we have the necessary legal basis (e.g., explicit consent or legitimate interest, as applicable) for the processing and display of such images. If you are a subject in one of our photographs and have concerns, please contact us using the details provided in Section 15.

3. How We Use Your Data

We use the collected data for various purposes:

• To Respond to Inquiries: To communicate with you and respond to your messages sent via the contact form.
• To Maintain and Improve Our Website: To monitor and analyse the usage of our website (including through Google Analytics) to improve its functionality, content, and user experience.
• To Ensure Security: To protect our website from spam and malicious activity using Google reCAPTCHA.
• For Legal and Regulatory Compliance: To comply with legal obligations and respond to lawful requests from public authorities.
• To Showcase Photography: To display our photographic work on portfolio pages.

4. Legal Basis for Processing (GDPR)

We process your personal data based on the following legal grounds as set out in the GDPR:

• Consent: Where you have given explicit consent for us to process your personal data for a specific purpose (e.g., by submitting our contact form, or for certain types of cookies if a cookie consent banner is used).
• Legitimate Interests: Where processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms (e.g., website security, analytics for website improvement, displaying our portfolio with appropriate legal basis for images).
• Compliance with a Legal Obligation: Where processing is necessary for compliance with a legal obligation to which we are subject.

5. Data Retention

We will retain your personal data only for as long as is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as for tax, accounting, or other legal requirements).

• Contact Form Submissions: We will retain contact form submissions for a reasonable period to handle your inquiry and any follow-up correspondence.
• Log Data: Log data is typically retained for a short period for security and analytical purposes.
• Google Analytics Data: Google Analytics data is retained according to Google’s data retention policies, which you can typically configure. We retain this data for a maximum of 26 months to understand long-term trends.
• Photographic Images: Images displayed in our portfolio will be retained as long as they serve the purpose for which they were collected and displayed, in accordance with any contractual agreements or consents.

6. Data Sharing

We do not sell, trade, or otherwise transfer your personal data to outside parties, except in the following limited circumstances:

• Service Providers: We may share your data with trusted third-party service providers who assist us in operating our website, conducting our business, or serving you, provided that those parties agree to keep this information confidential and comply with GDPR. This includes services like web hosting, analytics (e.g., Google Analytics), and security (e.g., Google reCAPTCHA).
• Legal Requirements: We may disclose your personal data when required to do so by law or in response to valid requests by public authorities (e.g., a court or government agency).
• Business Transfers: In the event of a merger, acquisition, or asset sale, your personal data may be transferred to the acquiring entity.

7. Your Data Protection Rights (GDPR)

As a data subject under GDPR, you have the following rights concerning your personal data:

• The right to be informed: You have the right to be provided with clear, transparent, and easily understandable information about how we use your personal data and your rights. This is why we provide you with the information in this Privacy Policy.
• The right of access: You have the right to obtain confirmation as to whether or not personal data concerning you is being processed, and, where that is the case, access to the personal data.
• The right to rectification: You have the right to request that we correct any inaccurate or incomplete personal data we hold about you.
• The right to erasure (“right to be forgotten”): In certain circumstances, you have the right to request the deletion or removal of your personal data where there is no compelling reason for its continued processing.
• The right to restrict processing: In certain circumstances, you have the right to “block” or suppress further use of your personal data.
• The right to object to processing: You have the right to object to certain types of processing, including processing for direct marketing purposes.
• The right to data portability: You have the right to obtain and reuse your personal data for your own purposes across different services.
• The right to withdraw consent: If we are relying on your consent to process your personal data, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing based on consent before its withdrawal.
• The right to lodge a complaint: You have the right to lodge a complaint with a supervisory authority, particularly in the EU member state of your habitual residence, place of work, or place of the alleged infringement if you believe our processing of your personal data violates GDPR. In Belgium, this is the Data Protection Authority (GBA/APD).

To exercise any of these rights, please contact us using the details provided in Section 15.

8. Google Analytics

We use Google Analytics to collect information about how visitors use our website. Google Analytics uses cookies to collect anonymous information such as your IP address (anonymized), the pages you visit, the time you spend on our website, and how you arrived at our website. This information helps us to understand visitor behaviour and improve our website’s performance and content.

You can opt-out of Google Analytics without affecting how you visit our site. For more information on opting out of Google Analytics across all websites you use, visit the Google Analytics Opt-out Browser Add-on page.

9. Google reCAPTCHA

Our contact form uses Google reCAPTCHA to protect our site from spam and abuse. Google reCAPTCHA is subject to the Google Privacy Policy and Terms of Use. The reCAPTCHA service works by assessing information about your device and application, and sending that data to Google.

10. Cookies

Our website uses cookies to improve your experience. Cookies are small text files placed on your device. We use them for:

• Essential functionality: To make our WordPress site work correctly.
• Analytics: To understand how visitors use our site (e.g., Google Analytics).
• Security: Related to our WordPress setup and reCAPTCHA.

You can control and manage cookies in your browser settings. Most browsers allow you to block or delete cookies. However, please note that if you disable cookies, some features of our site may not function properly.

11. Third-Party Links

Our website may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

12. Security Measures

We implement appropriate technical and organisational measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access. However, please remember that no method of transmission over the Internet or method of electronic storage is 100% secure.

13. International Data Transfers

As our website uses services that may involve international data transfers (e.g., Google Analytics and reCAPTCHA), we ensure that such transfers comply with GDPR by relying on appropriate safeguards, such as Standard Contractual Clauses or other approved mechanisms.

14. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the “Last Updated” date at the top of this Privacy Policy. We encourage you to review this Privacy Policy periodically for any changes.

15. Contact Us

If you have any questions about this Privacy Policy, your data, or would like to exercise any of your data protection rights, please contact us via our contact page.