Privacy Policy

Early Chapter Ltd

Early Chapter Ltd is committed to protecting your privacy and handling personal data with care.

This Privacy Notice explains how we collect, use, store and protect personal information when you visit our website, enquire about our services, register for a photography day, book a family or mini session, access a gallery, place an order, or otherwise interact with Early Chapter.

It also explains how personal data may be used in connection with nursery photography days, graduation photography, parent/child mini sessions, private galleries and product ordering.

1. Who we are

Early Chapter Ltd is a company registered in England and Wales.

Company number: 17044549

Registered office: 167-169 Great Portland Street, 5th Floor, London, W1W 5PF

Email: hello@earlychapter.co.uk

Phone: 0333 050 5364

For privacy-related questions or requests about your personal data, please contact us using the details above.

2. When this Privacy Notice applies

This Privacy Notice applies when you:

·       visit our website

·       contact us by email, form, phone or another method

·       register a child for a photography day

·       book a family session, parent/child mini session, graduation mini session or other direct booking

·       access a private gallery connected to our services

·       place an order for prints, digital images or other products

·       attend a nursery photography day, graduation event or family mini session

·       give permission for photography or image use

·       sign up to receive updates or marketing communications

·       otherwise interact with Early Chapter

3. How our photography, gallery and ordering service works

We use third-party systems and service providers to help manage photography days, private galleries, customer ordering, payment processing, print fulfilment and related workflow.

Depending on how a photography day or session is organised, personal data may be provided:

  • directly by a parent, guardian or customer

  • by a nursery on behalf of families

  • through a registration form, booking form or gallery platform

  • through a combination of these routes

Where personal data is provided directly to us or through our registration, booking or ordering process, Early Chapter will usually act as the data controller for that information.

In some cases, where a nursery is sharing data, managing photography permissions or organising a photography day under its own arrangements, the nursery may also have its own data protection responsibilities. Where appropriate, Early Chapter may act as a processor for some information and as a controller for other information, depending on the arrangement and the purpose for which the data is used.

4. What information we collect

Depending on how you interact with us, we may collect and use the following information.

Parents, guardians and customers:

  • parent or guardian name

  • email address

  • phone number

  • billing and delivery address

  • booking details

  • deposit, session fee or payment information

  • order information

  • product choices and image selections

  • gallery access information

  • QR code or gallery code information

  • communication history

  • refund, complaint or customer service information

  • consent or permission preferences

  • information submitted through enquiry forms, registration forms, booking forms or consent forms

Children:

  • child’s name

  • nursery, class, group or room details where relevant

  • attendance or session information where relevant

  • sibling or group photograph information where relevant

  • photography permission status where relevant

  • photographs taken during a photography day, session or event

  • gallery reference, QR code or image reference information

  • limited notes needed to support the photography workflow, such as if a child should not be photographed or if a practical adjustment is needed

Nurseries and nursery contacts:

  • nursery name

  • nursery address

  • manager or staff contact details

  • booking and event information

  • photography day schedules

  • class, room or group lists where provided

  • permission or opt-out information where provided

  • commission, staff photo or agreed arrangement information where relevant

  • communication history

Website users:

  • information submitted through website forms

  • website usage information

  • IP address or device/browser information

  • cookie preferences

  • analytics information where cookies or analytics are enabled

We aim to collect only the information reasonably needed to provide our services, manage galleries and orders, communicate with customers and nurseries, and meet our legal and business responsibilities.

5. How we use personal information

We may use personal information to:

  • respond to enquiries

  • arrange and manage photography services

  • register children for photography days

  • manage family sessions, parent/child mini sessions, graduation sessions and other bookings

  • organise photography workflow on the day

  • prepare QR cards, private galleries and gallery access

  • create and manage private online galleries

  • process and fulfil orders

  • manage deposits, booking fees, voucher codes or redeemable credits where relevant

  • communicate about photography days, galleries, orders, delivery and customer queries

  • manage complaints, reprints, refunds or order issues where appropriate

  • support nursery photography day planning

  • manage agreed nursery arrangements, such as staff photos, commission or agreed benefits

  • keep business, tax and financial records

  • improve our services, website and customer experience

  • send service-related communications

  • send marketing communications where permitted

  • request separate permission to use selected images for our website, social media, portfolio or promotional materials

  • comply with legal and regulatory obligations

  • protect our business, customers, systems and legal rights

Where we provide sales or commission information to a nursery, we aim to avoid sharing unnecessary personal details about individual parent orders unless this is needed for the agreed arrangement, customer support, complaint handling or another valid reason.

6. Lawful basis for processing

We process personal data where we have a lawful basis to do so.

Depending on the circumstances, we may rely on:

Contract
We use personal data where needed to provide services, manage bookings, process orders, fulfil delivery, provide customer support, manage deposits or handle refunds and complaints connected to a purchase or booking.

Legitimate interests
We may rely on legitimate interests for reasonable business activities, such as responding to enquiries, organising photography days, managing private galleries, keeping records, improving our services, maintaining website security, communicating with nurseries and customers, and protecting our business.

Where we rely on legitimate interests, we consider the impact on individuals and balance our interests against their rights and expectations.

Consent
We rely on consent where required, including for optional marketing communications, non-essential cookies where applicable, and the use of child or family images in our own marketing, website, social media, brochures, portfolio or promotional materials.

Where we rely on consent, you can withdraw it at any time going forward.

Legal obligation
We may process personal data where required to comply with legal, tax, accounting or regulatory obligations.

7. Photography days, sessions and galleries

Where a child is registered for a photography day or session, we may use the information provided to prepare for the day, organise the photography workflow, take photographs, and create a private gallery for the purpose of viewing and ordering images.

Photography may include, where relevant:

  • individual nursery portraits

  • sibling photographs

  • class or group photographs

  • graduation portraits

  • parent/child or family mini sessions

  • certificate presentation or event photographs where agreed

Access to galleries is intended to be private. Parents and guardians should keep gallery links, QR codes, access codes and login details secure and should not share them more widely than necessary.

If a gallery access code or QR card is lost, we may need to verify information before reissuing access.

8. If you do not want your child photographed

If a parent or guardian does not want their child to be photographed, they should let the nursery or Early Chapter know as early as possible using the method provided for that photography event.

Where we are told that a child should not be photographed, we will take reasonable steps to honour that instruction.

Nursery photography days and events can be busy environments, so it is important that any opt-out, restriction or concern is communicated clearly and in good time before the photography day or session.

9. Marketing and promotional use of images

We do not use a child’s image on our website, social media, printed marketing, brochures, portfolio or other promotional material unless we have clearly explained that use and appropriate separate permission has been given.

This permission is separate from standard photography day participation, private gallery access and ordering.

Saying no to marketing image use will not affect a child’s participation in a photography day, access to a private gallery, or ability to order photographs.

Where permission for promotional image use is given, it can be withdrawn going forward by contacting us. Withdrawal will not necessarily affect materials already produced, published or circulated before the request is received.

10. Marketing communications

We may send marketing communications where permitted, for example where a parent, guardian, customer or nursery contact has opted in or where another lawful route applies.

Marketing emails will include an unsubscribe option where required. You can also ask us to stop sending marketing communications by contacting hello@earlychapter.co.uk.

Service-related messages, such as gallery access emails, order updates, delivery information, booking reminders or important photography day updates, are not usually treated as marketing.

11. Who we share information with

We may share personal data with trusted service providers where needed to operate our business and deliver our services. This may include:

  • gallery and workflow platform providers

  • payment processors

  • print labs

  • fulfilment partners

  • delivery providers and couriers

  • website providers, such as Squarespace

  • form or booking providers where relevant

  • email and customer communication providers

  • analytics providers where enabled

  • IT, hosting, storage or cloud service providers

  • nurseries, where needed to organise photography days, permissions, attendance, access or agreed nursery arrangements

  • professional advisers where necessary

  • regulators, authorities or legal advisers where required

We only share information where it is relevant and appropriate for the service being provided.

13. How long we keep information

We keep personal data only for as long as reasonably necessary for the purposes for which it was collected, including customer service, archive reorders, journey products, business administration, legal, tax and accounting requirements.

Our current approach is broadly as follows:

  • general enquiries: up to 24 months unless a longer period is needed

  • booking and session records: up to 6 years where needed for business, legal, tax or accounting purposes

  • order and transaction records: typically up to 6 years where needed for legal, tax and accounting purposes

  • image galleries, image records and related service data: up to 8 years, or for as long as reasonably necessary to support reorders, archive products, customer service and related record-keeping, unless we are asked to delete them sooner and we are not required to retain them for legal reasons

  • marketing records: until consent is withdrawn, you unsubscribe, or we no longer need the information

  • consent, permission, opt-out and complaint records: for as long as reasonably needed to evidence compliance, manage services and resolve issues

  • website analytics and cookie data: in line with the settings of the relevant tools and our Cookie Notice

We may review and update these retention periods where appropriate.

14. Data security

We take reasonable and appropriate steps to protect the personal data we hold.

These steps may include secure platforms, password protection, restricted access to records and systems, use of established third-party providers, secure handling of order and complaint information, and use of secure portals or controlled access where available.

While no system can ever be entirely risk-free, we work to use safeguards appropriate to the nature of the information we process.

15. Your rights

Depending on the circumstances, you may have rights in relation to your personal data, including the right to:

  • request access to your personal data

  • ask for incorrect information to be corrected

  • request deletion of personal data

  • object to or restrict certain processing

  • withdraw consent where consent has been relied upon

  • request portability in certain circumstances

  • complain to the Information Commissioner’s Office

Some rights are not absolute and may depend on the lawful basis we rely on and the reason we hold the information.

To make a request, please contact us using the details above.

We may ask for proportionate information to confirm identity before actioning a request where appropriate.

If you are unhappy with how your personal data has been handled, you may also have the right to complain to the Information Commissioner’s Office.

16. Cookies and website use

Our website uses cookies and similar technologies to help it function properly and, where enabled, to understand how visitors use the site.

Some cookies are essential to the operation of the website. Others, such as analytics or advertising cookies, help us understand traffic, improve the website or support marketing activity where enabled.

Where required, we will ask for your consent before using non-essential cookies. You can manage your cookie preferences through our cookie banner or your browser settings.

More detailed information about the cookies used on our website is provided in our Cookie Notice.

17. Third-party websites and platforms

Our website, emails or gallery communications may link to third-party websites, galleries, booking tools, payment pages or social media platforms.

Those third-party services may have their own privacy notices and terms. We encourage you to read them where relevant.

18. Changes to this Privacy Notice

We may update this Privacy Notice from time to time to reflect changes to our services, legal obligations, third-party providers or operational processes.

When we do, we will update the “Last updated” date at the top of this page.

19. Contact and complaints

If you have any questions about this Privacy Notice or how personal data is handled, please contact:

hello@earlychapter.co.uk
0333 050 5364

If you are unhappy with how your personal data has been handled, you may also have the right to complain to the Information Commissioner’s Office.

12. International transfers

Some of the service providers we use may store or process personal data outside the UK.

Where this happens, we will take reasonable steps to ensure personal data is protected in line with applicable data protection law and that appropriate safeguards are in place where required.