Privacy Policy

Privacy Policy

Effective date: 30 July 2025
Who we are: This website is operated by Enzo Jiovarni Holm trading as “Enzo Jiovarni” (the “Company”, “we”, “us”, “our”), based in London, United Kingdom.

1) Data Controller & Contact
   •    Data Controller: Enzo Jiovarni Holm
   •    Email: [info@enzojiovarni.com]
   •    Postal: [Business Address, London, UK]
If you are in the EEA, we may appoint an EU Representative. Details will appear here if/when applicable.

2) What We Collect

We collect and process personal data you provide and data we collect automatically when you use our site or services.

Data you provide:
   •    Identity & contact: name, email, phone, social handles, billing/shipping address.
   •    Booking & project info: styling needs, measurements (optional), preferences, mood boards, event details, brand sizes.
   •    Content & consent: photographs, video, credits, signed releases/permissions (for editorial/portfolio use).
   •    Payment info: processed via third-party providers; we do not store full card details.
   •    Comms: emails, DMs, testimonials, enquiries, newsletter sign-ups.

Data collected automatically:
   •    Device, browser, IP, general location (city/region), pages viewed, time on site, referring URLs, and cookie/analytics data.

3) Why We Use Your Data (Lawful Bases)

We process your data only when we have a lawful reason:
   •    Contract: to provide styling, creative direction, editorial and consultancy services; to manage bookings, invoices, and deliverables.
   •    Consent: sending marketing emails/texts; placing non-essential cookies; using client imagery in portfolio/case studies. You can withdraw consent anytime.
   •    Legitimate interests: to run and protect our business, improve our site/services, prevent fraud, and grow our brand — balanced against your rights.
   •    Legal obligation: tax, accounting, and compliance records.

4) How We Use Your Data
   •    Manage enquiries, proposals, bookings, fittings, and project delivery.
   •    Curate and share editorial/portfolio content (with appropriate permissions).
   •    Process payments and issue invoices/receipts.
   •    Send service updates and (with consent) marketing/newsletters.
   •    Run site analytics, troubleshoot, and enhance performance.
   •    Protect security, prevent abuse, and comply with the law.

5) Sharing Your Data

We share data only with trusted service providers who act on our instructions (“processors”), such as:
   •    Hosting & email: [e.g., Web host, email service]
   •    Analytics & ad tech: [e.g., Google Analytics, Meta Pixel]*
   •    Payments: [e.g., Stripe, PayPal]
   •    Scheduling/CRM/file storage: [e.g., Calendly, Notion, Google Drive/Dropbox]
   •    Couriers/print houses: where relevant to deliver items.

We require processors to safeguard your data and not use it for their own purposes. We only disclose data to others (e.g., legal authorities) where required by law.

*If you use ad/analytics tools, we’ll reflect their specific cookies and options in the Cookie section.

6) International Transfers

Some providers may store data outside the UK/EEA. Where this occurs, we rely on appropriate safeguards (e.g., UK IDTA/EU SCCs or an adequacy decision) to protect your data.

7) How Long We Keep Data
   •    Client/project files: generally 6 years after the end of the tax year in which the project closes (for legal/accounting).
   •    Enquiries: up to 24 months if no contract follows.
   •    Marketing lists: until you unsubscribe or we remove inactive contacts.
   •    Cookies/analytics: per cookie lifespan; see Cookie section.
We may anonymise data for research/statistics and keep it indefinitely (no longer personal data).

8) Your Rights (UK GDPR / EEA GDPR)

You have the right to:
   •    Access your data and get a copy
   •    Rectify inaccurate or incomplete data
   •    Erase (where applicable)
   •    Restrict or object to certain processing
   •    Data portability (receive/transmit your data)
   •    Withdraw consent at any time (doesn’t affect prior lawful processing)

To exercise your rights, contact us at [info@enzojiovarni.com]. You also have the right to complain to your supervisory authority in the UK (the Information Commissioner’s Office) or in your EEA country.

9) Marketing Preferences

We only send marketing with your consent. You can unsubscribe via the link in our emails or by emailing [info@enzojiovarni.com]. We’ll still send essential service messages (e.g., booking confirmations).

10) Cookies & Similar Technologies

We use cookies and similar tech to run the site and understand performance. You can manage preferences via our cookie banner and your browser settings.

Types of cookies we may use:
   •    Strictly necessary (essential): site security, session management, consent records.
   •    Performance/analytics: understanding traffic and usage (e.g., page views, time on site).
   •    Functionality: remembering preferences.
   •    Advertising/retargeting: only if enabled and consented.

Sample cookie table (customise):

Cookie    Purpose    Provider    Type    Duration
_ga    Analytics (page stats)    Google    1st party    13 months
_gid    Analytics (session stats)    Google    1st party    24 hours
_fbp    Ad measurement/retargeting    Meta    1st party    3 months
cookiebanner_prefs    Stores cookie choices    Site    1st party    6–12 months

You can withdraw non-essential cookie consent at any time via the banner link or your browser.

11) Photography, Portfolio & Credits

We respect image rights. We will only use identifiable client images in our portfolio, social channels, or press with your consent (or under a signed release). For group shoots or events, we will obtain appropriate permissions; for minors, parental/guardian consent is required.

12) Children’s Privacy

Our services are not directed at children under 13. We do not knowingly collect data from children. Where work involves minors (e.g., family shoots, commercial campaigns), we require verified parental/guardian consent and handle data with heightened care.

13) Security

We use appropriate technical and organisational measures to protect data (access controls, encryption in transit where supported, least-privilege access, regular reviews). No method is 100% secure; we continuously improve our safeguards.

14) Automated Decision-Making

We do not engage in profiling or automated decisions that produce legal or similarly significant effects on you.

15) Third-Party Links & Social

Our site may link to external sites or social platforms. Their privacy practices apply to your use of those services. Please review their policies.

16) Changes to This Policy

We may update this Privacy Policy to reflect changes in law or our practices. We’ll post the updated version here with a new effective date. Significant changes may be notified by email or on-site notice.

17) How to Contact Us

Questions, requests, or complaints about this Policy or your data?
Email: info@enzojiovarni.co.uk
Postal: London, UK

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