1. Introduction
This Privacy Policy explains how David Learman ("we", "us", "our") collects, uses, stores and protects personal data when you visit or use davidlearman.com (the "Website").
This Policy should be read together with our Terms & Conditions. Where the two conflict on a matter of data protection, this Privacy Policy prevails.
We aim to handle personal data in line with the principles of the UAE's Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (the "UAE PDPL").
2. Who We Are
The data controller for the Website is:
3. What Personal Data We Collect
We only collect personal data in two ways, described below. We do not collect personal data anywhere else on the Website — there is no newsletter signup, no user account system, and no contact form outside of the print inquiry cart.
3.1 Print Inquiry Cart
If you select photographs to inquire about printing and submit the inquiry form, we collect:
- your name;
- your email address;
- your phone number;
- your country; and
- the photographs, sizes and quantities you selected.
This information is used solely to respond to your print inquiry.
3.2 Automatically Collected Data
Like most websites, the Website automatically records some technical information when you visit, including your IP address, browser type, device type, pages viewed, and the date and time of your visit. This is collected through Google Analytics, described in Section 6 below.
4. How We Use Your Data
We use the personal data described above for the following purposes:
- To respond to print inquiries — the contact and order details you submit through the cart are used to reply to you by email regarding pricing, availability and next steps for the prints you selected.
- To understand how the Website is used — aggregated, largely anonymised analytics data helps us understand which pages and galleries are popular, so we can improve the Website.
- To keep the Website functioning correctly — a technical session identifier keeps track of the contents of your print inquiry cart while you browse.
We do not use your personal data for direct marketing, and we do not sell, rent or trade your personal data to any third party.
5. Cookies and Similar Technologies
The Website uses two categories of cookie:
| Cookie | Purpose | Type |
|---|---|---|
| PHP session cookie | Strictly necessary — keeps track of the images, sizes and quantities you have added to your print inquiry cart while you browse the Website. Does not identify you personally and does not track you across other websites. | Functional (session only — deleted when you close your browser) |
Google Analytics (_ga, _ga_*) |
Helps us understand overall Website traffic and usage patterns. Set and processed by Google. | Analytics (up to 2 years) |
We do not use advertising or marketing cookies, and we do not run any social-media tracking pixels on the Website.
Most browsers let you refuse or delete cookies through their settings. Blocking the PHP session cookie will prevent the print inquiry cart from working correctly; blocking the Google Analytics cookies has no effect on the Website's functionality.
6. Google Analytics
We use Google Analytics (GA4) to understand how visitors use the Website. Google Analytics collects information such as pages visited, time spent on the Website, approximate location (derived from IP address), and device and browser type.
This data is processed by Google LLC and may be transferred to and processed in the United States or other countries where Google operates data centres, under Google's own data processing and security safeguards. You can learn more about how Google handles this data, and opt out of Google Analytics tracking, at policies.google.com/privacy.
7. Who We Share Your Data With
We do not sell your personal data. We share it only in the following limited circumstances:
- Google LLC — as the provider of Google Analytics (see Section 6).
- Our hosting provider — the servers that store the Website and the print inquiry data submitted through it.
- Where required by law — if we are legally required to disclose information to a court, regulator or law enforcement authority.
We do not use any other third-party marketing, advertising or customer-relationship-management tools that process your personal data.
8. International Data Transfers
Your data is primarily stored and processed on servers used to host the Website. Where Google Analytics processes data outside the United Arab Emirates (see Section 6), that transfer is made under Google's own international data transfer safeguards.
9. How Long We Keep Your Data
Print inquiry details (your name, email, phone number, country and selected prints) are kept for as long as reasonably necessary to respond to your inquiry and for our legitimate business records — typically no longer than 24 months from the date of your inquiry, unless a longer period is needed to resolve an ongoing conversation, transaction or legal requirement.
Google Analytics data is retained according to the retention settings of our Google Analytics account, currently set to expire automatically after a defined period in line with Google's standard retention options.
10. How We Protect Your Data
Print inquiry submissions are stored in a location that is not directly accessible over the internet, with access restricted to David Learman and those assisting in fulfilling print inquiries on his behalf. We take reasonable technical and organisational measures to protect personal data against unauthorised access, loss or misuse, though no method of transmission or storage over the internet can be guaranteed to be completely secure.
11. Your Rights
Depending on applicable law, you may have the right to:
- ask us to confirm what personal data we hold about you and to provide you with a copy of it;
- ask us to correct inaccurate or incomplete personal data;
- ask us to delete your personal data, where we are not required to keep it for a legitimate business or legal reason;
- object to or restrict certain uses of your personal data; and
- withdraw any consent you have given, where our use of your data relies on consent.
To exercise any of these rights, contact us using the details in Section 14. We will respond within a reasonable period.
12. Children's Privacy
The Website is not directed toward children, and we do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us and we will take appropriate steps to remove it.
13. Changes to This Policy
We may update this Privacy Policy from time to time. Updates will be published on this page with a revised effective date. Your continued use of the Website following any update constitutes acceptance of the revised Policy.
14. Contact Us
If you have any questions about this Privacy Policy, or wish to exercise any of the rights described in Section 11, please contact: