DRAG

Anna Voloshyna Photography

Privacy & Cookie Policy

This Privacy & Cookie Policy explains how Anna Voloshyna Photography collects, uses, stores, shares and protects personal data when you visit voloshyna.com, contact us, request a quotation, become a Client, participate in a photography or video production, or otherwise interact with our Services. It also explains how cookies and similar technologies are used on the Website and how you can manage your preferences. This Policy should be read together with our Terms & Conditions and, where applicable, our Image & Video Licensing Terms.

Updated: Last updated: 10 August, 2026

PART I

PRIVACY POLICY

In this section

    1. Who We Are

    Anna Voloshyna Photography is the trading name of:

    Legal name: Anna Voloshyna Photography
    Legal form: Eenmanszaak
    Registered address: Rennemigstraat 60, 6413BV Heerlen

    Chamber of Commerce (KVK): 97909386
    VAT number: NL005295653B49
    Email: anna@voloshyna.com
    Website: voloshyna.com

    For personal data for which we determine the purposes and means of processing, Anna Voloshyna Photography acts as the Data Controller.

    Privacy-related questions and requests may be sent to:

    Privacy Contact:
    anna@voloshyna.com

    2. Scope of This Policy

    This Policy applies to personal data processed in connection with:

    • voloshyna.com and associated Website pages;

    • contact and quotation forms;

    • email and other direct communications;

    • photography and video Projects;

    • Client administration;

    • models, employees, event participants and other photographed or filmed individuals;

    • delivery and review of photographs or video;

    • portfolio and case-study publication;

    • invoicing and accounting;

    • Website analytics and cookies;

    • legitimate business administration.

    This Policy does not govern the independent processing activities of third-party websites or services that you choose to visit or use.

    3. What Is Personal Data?

    Personal data means information relating to an identified or identifiable natural person.

    Depending on the circumstances, this may include names, contact information, online identifiers, correspondence, billing information, photographs, video recordings and other information that can reasonably be linked to an individual.

    Information relating solely to a legal entity is not necessarily personal data, although information relating to individual employees, directors, contacts or representatives may be.

    4. Personal Data We May Collect

    The categories of information processed depend on how you interact with us.

    4.1. Website Enquiries and Quote Requests

    When you contact us or request a quotation, we may process:

    • first and last name;

    • email address;

    • telephone number where provided;

    • company or organisation;

    • selected service or package;

    • project description;

    • preferred dates or deadlines;

    • location;

    • intended usage;

    • budget or production information;

    • products, people or services involved;

    • reference links or materials;

    • information included voluntarily in your message.

    We use this information primarily to respond to your enquiry, assess the proposed Project and prepare a quotation or production plan.

    4.2. Client and Contract Information

    When a Project proceeds, we may additionally process:

    • Client and authorised-contact details;

    • company and invoicing information;

    • VAT and business-registration information;

    • billing and payment records;

    • quotation and contract details;

    • licensing information;

    • delivery details;

    • correspondence;

    • project schedules;

    • approval and revision records;

    • information relating to products, locations, employees or participants;

    • contractual permissions and releases.

    4.3. Photographs and Video

    Photography and video containing identifiable people may constitute personal data.

    Depending on the Project, we may process:

    • photographs;

    • video footage;

    • audio recordings;

    • names connected to photographs or video;

    • roles or job titles;

    • appearance and likeness;

    • location and event information;

    • image-selection information;

    • model or participant releases;

    • publication permissions;

    • other information required to organise and deliver the Production.

    We do not intentionally use photographs for biometric identification unless this has been expressly agreed for a lawful purpose.

    4.4. Website and Technical Data

    When you use the Website, certain technical information may be processed automatically, including:

    • IP address;

    • browser type and version;

    • device type;

    • operating system;

    • requested pages;

    • date and time of access;

    • referring page or URL;

    • technical logs;

    • cookie and consent preferences;

    • information generated through permitted analytics technologies.

    The precise information depends on your cookie choices and the technical services active on the Website.

    4.5. Communications

    If you contact us through email, telephone, WhatsApp, Telegram, social media or another communication platform, we may process the information necessary to communicate with you.

    The provider of that communication platform may independently process personal data under its own terms and privacy policy.

    4.6. Suppliers and Production Participants

    Where you participate in or supply services for a Production, we may process information such as:

    • name;

    • contact details;

    • professional role;

    • availability;

    • contractual information;

    • payment information;

    • model or performer agreements;

    • usage restrictions;

    • relevant production correspondence.

    5. Where Personal Data Comes From

    We normally receive personal data directly from you.

    In some Projects, information may instead be provided by:

    • a company commissioning photography involving its employees;

    • an agency acting for an End Client;

    • an event organiser;

    • a model or casting agency;

    • another participant in the Project;

    • a supplier;

    • a publicly available professional or business source where reasonably necessary.

    Where information has not been obtained directly from you, applicable GDPR transparency requirements will be followed where required.

    6. Why We Process Personal Data

    We process personal data only where we have an appropriate purpose and legal basis.

    6.1. Enquiries and Quotations

    Purpose:
    Responding to enquiries, discussing proposed Services and preparing quotations or Project proposals.

    Legal basis:
    Steps taken at your request before entering into a contract and, where appropriate, our legitimate interest in managing genuine business enquiries.

    6.2. Performing a Client Agreement

    Purpose:
    Planning, producing, editing, delivering and administering photography, video and related Services.

    This may include scheduling, communicating with the Client, handling products, organising participants, delivering files and administering agreed licences.

    Legal basis:
    Performance of a contract or steps necessary to enter into a contract.

    For people who are not themselves the contracting Client, another appropriate basis may apply depending on the circumstances.

    6.3. Business Administration

    Purpose:
    Maintaining Client records, project histories, contractual records, licences, approvals, correspondence and reasonable internal business records.

    Legal basis:
    Our legitimate interests in operating, documenting and protecting the business and its contractual relationships.

    6.4. Accounting and Tax Records

    Purpose:
    Issuing invoices, maintaining accounts and complying with tax and financial obligations.

    Legal basis:
    Compliance with legal obligations.

    6.5. Website Operation and Security

    Purpose:
    Operating and protecting the Website, preventing misuse, maintaining technical stability, diagnosing problems and securing our systems.

    Legal basis:
    Our legitimate interest in operating a safe and functional Website and, where applicable, legal obligations.

    Strictly necessary cookies and comparable technical storage may also be used for these purposes without optional cookie consent where permitted by law.

    6.6. Website Analytics

    Purpose:
    Understanding how visitors use the Website and improving content, usability and performance.

    Legal basis:
    Consent where the analytics technology requires consent.

    Analytics that meet the conditions for a lawful low-impact exemption may be treated differently where applicable.

    6.7. Marketing and Advertising Technologies

    Purpose:
    Measuring advertising, understanding campaign performance, remarketing or personalising marketing where such services are used.

    Legal basis:
    Consent where required.

    Marketing and tracking technologies are not activated before the required consent has been obtained.

    6.8. Direct Marketing

    Where you have expressly subscribed to marketing communication, we may send relevant news, portfolio updates, offers or similar communications.

    Legal basis:
    Consent or another lawful basis where specifically permitted by applicable law.

    You can unsubscribe or object to direct marketing at any time.

    We will not use the fact that you requested a quotation as automatic consent to receive unrelated marketing.

    6.9. Legal Claims and Protection of Rights

    Purpose:
    Establishing, exercising or defending legal claims, resolving disputes, preventing fraud and enforcing contractual or intellectual-property rights.

    Legal basis:
    Legitimate interests and, where applicable, legal obligations.

    7. Photography, Video and Personal Data

    Photography and video require particular attention because Deliverables may contain identifiable individuals.

    7.1. Private Client Photography

    Where a private individual commissions a portrait or other personal photography service, Voloshyna will normally act as Controller for information required to administer and perform the Client Agreement.

    Portfolio or promotional publication is treated separately from the provision of the commissioned service.

    Where permission or consent is required for promotional publication, it will be obtained separately.

    Refusing optional portfolio use does not prevent the Client from receiving the commissioned Services.

    7.2. Business and Corporate Projects

    For business photography, employer-branding photography, corporate portraits, events and similar Projects, the Client and Voloshyna may have different data-protection responsibilities.

    For example, the Client may determine:

    • which employees participate;

    • why employees are photographed;

    • how company photographs will be used;

    • where the photographs will be published;

    • internal employee communications and permissions.

    Voloshyna may separately determine certain processing required to produce, administer, protect or lawfully promote the creative work.

    The legal role of each party therefore depends on the actual Project and processing activity.

    The parties may act as:

    • independent Controllers;

    • Joint Controllers for a particular activity; or

    • Controller and Processor.

    The label used in a contract does not override the actual circumstances.

    7.3. Processing on Client Instructions

    Where Voloshyna processes personal data solely on documented instructions from a Business Client and qualifies as a Processor under the GDPR, the parties will enter into a Data Processing Agreement where legally required.

    That agreement may address:

    • subject matter and duration;

    • processing instructions;

    • categories of personal data;

    • data subjects;

    • confidentiality;

    • security;

    • sub-processors;

    • data-subject requests;

    • deletion or return of information;

    • international transfers.

    7.4. Employees and Other Participants

    Where a company controls the participation of its employees, contractors or invited guests, the Client is normally responsible for providing appropriate information to those individuals about the planned photography or filming and its intended use.

    Where a separate release, consent or other permission is required for a particular use, responsibility for obtaining it should be established during Project planning.

    7.5. Events

    Photographs or video created during business events may contain guests, employees, speakers and other attendees.

    Event organisers should provide appropriate notices or other information to participants where required.

    Particular requests concerning identifiable individuals should be communicated before or during the event where reasonably possible.

    7.6. Models and Performers

    Professional models, actors, voice artists and other performers may be subject to releases, agency terms or usage agreements.

    Such information may be retained where reasonably necessary to establish the permitted use of the corresponding photography or video.

    8. Portfolio, Case Studies and Self-Promotion

    Voloshyna may display selected work in its professional portfolio where a lawful basis exists and where doing so is compatible with:

    • contractual confidentiality;

    • project embargoes;

    • privacy and data-protection law;

    • portrait rights;

    • participant permissions;

    • model agreements;

    • Client agreements.

    Possible portfolio channels may include:

    • voloshyna.com;

    • case studies;

    • professional social-media accounts;

    • portfolio platforms;

    • presentations;

    • awards;

    • exhibitions;

    • professional publications.

    Private Consumer photography is not automatically treated as available for promotional publication merely because the Services were commissioned.

    Where consent is relied upon, it may be withdrawn in accordance with applicable law.

    Withdrawal of consent does not affect processing that was lawful before the withdrawal.

    9. Special Categories of Personal Data

    Photography or correspondence may occasionally contain information that could reveal sensitive characteristics, for example health information, religious beliefs or other special-category information.

    We do not intentionally collect or infer special-category information unless this is necessary for a specific lawful purpose.

    Where special-category processing is required, an additional condition under applicable data-protection law must apply.

    Clients should avoid sending unnecessary sensitive personal information through general enquiry forms.

    10. Children and Minors

    The Website and commercial photography Services are not specifically directed at children.

    Projects involving minors must be discussed in advance.

    Where parental or guardian authorisation, consent or another legal safeguard is required for participation, processing or publication, the necessary arrangements must be made before the relevant activity.

    11. Automated Decision-Making

    We do not currently make decisions about Clients or Website visitors based solely on automated processing that produce legal effects or similarly significant effects.

    If this changes, this Policy will be updated and the information required by applicable law will be provided.

    PART II

    PRIVACY POLICY

    In this section

      12. Who May Receive Personal Data

      We do not sell personal data as a commercial database or standalone product.

      Personal data may be disclosed where reasonably necessary to the following categories of recipients:

      Service Providers

      Providers supporting:

      • Website hosting and infrastructure;

      • Website development and maintenance;

      • email and communications;

      • cloud storage;

      • file transfer and delivery;

      • client galleries;

      • accounting and bookkeeping;

      • banking and payment administration;

      • analytics and tag management;

      • cookie-consent management;

      • IT and security;

      • project-management or customer-management systems.

      Production Suppliers

      Where necessary for a Project:

      • photographers;

      • videographers;

      • assistants;

      • retouchers;

      • editors;

      • stylists;

      • producers;

      • model or casting agencies;

      • other specialist contractors.

      Only information reasonably necessary for their role should be provided.

      Professional Advisers

      Information may be shared where reasonably necessary with accountants, legal advisers, insurers or other professional advisers.

      Authorities

      Personal data may be disclosed where required by law, court order, regulatory requirement or another lawful request from a competent authority.

      Business Transfer

      If the business is sold, reorganised or transferred, relevant records may be transferred to a successor where legally permitted and subject to appropriate safeguards.

      13. Processors and Sub-Processors

      Where an external provider processes personal data on our behalf as a Processor, we select providers with regard to appropriate privacy and security arrangements and use the contractual measures required by applicable law.

      Where Voloshyna itself acts as a Processor for a Client, any engagement of a relevant sub-processor will be handled in accordance with the applicable Data Processing Agreement.

      14. International Data Transfers

      Some technology, communications, cloud or production providers may process information outside the European Economic Area.

      Where personal data are transferred to a country outside the EEA, we use an appropriate transfer mechanism where required.

      Depending on the recipient and destination, this may include:

      • an applicable European Commission adequacy decision;

      • Standard Contractual Clauses;

      • another legally recognised safeguard;

      • an applicable statutory derogation in limited circumstances.

      Additional technical or organisational safeguards may be used where appropriate.

      Information about relevant safeguards may be requested by contacting anna@voloshyna.com.

      15. How Long We Keep Personal Data

      We do not retain personal data indefinitely merely because storage is technically possible.

      Retention depends on the purpose, legal requirements, contractual obligations, licensing considerations and whether information is needed to establish or defend legal rights.

      The following periods are our normal starting points.

      Unsuccessful or Unconfirmed Project Enquiries

      Normally retained for up to 24 months after the last meaningful communication, unless there is a reason to retain them for a shorter or longer period.

      This allows us to respond to returning enquiries and maintain reasonable records of quotations and project discussions.

      Active Client and Project Records

      Kept during the Project and afterwards for a reasonable period necessary for:

      • Client service;

      • contractual records;

      • licensing;

      • project history;

      • complaints;

      • dispute management;

      • legal claims.

      Records no longer reasonably required will be deleted or anonymised.

      Financial and Accounting Records

      Invoices and other accounting records are retained for the period required by applicable Dutch tax law.

      The standard Dutch retention period for core business administration is generally seven years.

      Working Photography and Video Files

      RAW photographs, source footage, editing files, rejected material and other working files are not guaranteed to be stored permanently.

      Where they contain personal data, they may normally be retained for a limited period after Project completion for editing, quality control, backup and reasonable Project administration, and then deleted when no longer required.

      Unless a different Project-specific period is agreed, Clients should not rely on Voloshyna as a permanent archive.

      Final Deliverables

      Final photographs and videos may be retained where reasonably necessary for:

      • contractual and licensing records;

      • lawful business archives;

      • handling future Client requests;

      • evidencing the creative work;

      • agreed portfolio and case-study use;

      • establishment or defence of rights.

      Where retained material contains identifiable people, continued retention and publication remain subject to an appropriate lawful basis.

      Model Releases and Publication Permissions

      Records evidencing a licence, model release, permission or consent may be retained for as long as the corresponding use continues and afterwards for a period reasonably necessary to demonstrate the lawful basis for that use.

      Website Logs

      Technical logs are retained only for the period reasonably required for Website operation, troubleshooting and security.

      Current technical retention:
      1 year.

      Analytics Data

      Analytics retention depends on the analytics configuration selected for the Website.

      Current analytics retention:
      1 year.

      Cookie-Consent Records

      Records of consent choices may be retained for as long as reasonably necessary to remember your preferences and demonstrate compliance.

      They may be renewed periodically.

      16. Security

      We use reasonable technical and organisational measures appropriate to the nature of the information and the risks involved.

      Measures may include, where appropriate:

      • access restrictions;

      • authentication controls;

      • encrypted connections;

      • secure file-transfer systems;

      • backups;

      • software and system updates;

      • confidentiality obligations;

      • limited access by production suppliers;

      • secure deletion or anonymisation where appropriate.

      No internet transmission or digital storage system can provide an absolute guarantee against every security incident.

      17. Your Privacy Rights

      Depending on the circumstances, the GDPR provides individuals with rights including:

      Access

      You may request confirmation of whether we process personal data concerning you and request access to that data.

      Rectification

      You may ask us to correct inaccurate or incomplete personal data.

      Erasure

      You may request deletion where the applicable legal conditions are met.

      The right to erasure is not absolute. Information may need to be retained where a legal obligation, contractual matter, legal claim or other lawful ground applies.

      Restriction

      You may request restriction of processing in circumstances provided by law.

      Data Portability

      Where applicable, you may request certain information you provided to us in a structured, commonly used and machine-readable format.

      Objection

      Where processing is based on legitimate interests, you may object on grounds relating to your particular situation.

      You have the right to object at any time to processing for direct-marketing purposes.

      Withdrawal of Consent

      Where processing is based on consent, you may withdraw your consent at any time.

      Withdrawal does not affect processing that took place lawfully before consent was withdrawn.

      Complaint to a Supervisory Authority

      You have the right to lodge a complaint with the competent data-protection authority.

      For Anna Voloshyna Photography, the principal supervisory authority is the Dutch Data Protection Authority:

      Autoriteit Persoonsgegevens

      You may also have the right to contact the supervisory authority in the EEA country where you live, work or believe an infringement occurred.

      18. Exercising Your Rights

      Requests may be sent to:

      anna@voloshyna.com

      Please state sufficiently clearly:

      • which right you wish to exercise;

      • the information or processing concerned;

      • any information reasonably necessary to identify the relevant records.

      Where we have reasonable doubts about identity, we may request additional information necessary to verify that a request concerns the correct person.

      We will respond within the period required by applicable law.

      The normal GDPR response period is one month, although the period may be extended where legally permitted for complex or numerous requests.

      19. Requests Concerning Photographs or Video

      A privacy request concerning a photograph or video should, where possible, identify:

      • the Project or event;

      • approximate date;

      • Client or organiser;

      • page or platform where the material appears;

      • the photograph or video concerned.

      A request to remove a photograph is not automatically equivalent to a valid right to erasure in every situation.

      The appropriate response depends on the processing purpose, legal basis, contractual circumstances, freedom-of-expression considerations, applicable portrait rights and other relevant legal obligations.

      Each request will therefore be assessed individually.

      20. Direct Marketing Objections

      You may object to direct marketing at any time.

      Where necessary, we may retain a minimal suppression record—for example your email address and the fact that you opted out—so that we can respect the request and avoid adding you back to the same mailing activity.

      21. Data Breaches

      Where a personal-data breach occurs, we will assess the incident and take appropriate action under applicable data-protection law.

      Where legally required, this may include notifying the competent supervisory authority and affected individuals.

      22. External Websites and Social Media

      The Website may contain links to:

      • social-media platforms;

      • messaging applications;

      • portfolio websites;

      • stock-photography platforms;

      • Client websites;

      • other third-party services.

      When you follow an external link or interact directly with a third-party service, that provider may independently process personal data.

      Its own privacy policy and terms apply to that independent processing.

      PART III

      COOKIE POLICY

      In this section

        23. What Are Cookies?

        Cookies are small files or similar pieces of information stored on or read from your computer, phone, tablet or other device when you use a Website.

        Similar technologies may include local storage, pixels, tags and comparable browser or device technologies.

        They can be used for purposes such as:

        • keeping a Website operational;

        • remembering preferences;

        • measuring Website usage;

        • analysing performance;

        • measuring advertising;

        • recognising visitors across sessions or services.

        24. Cookie Categories Used on the Website

        The Website's consent system currently separates cookies and comparable technologies into four principal categories.

        Essential Cookies

        Essential cookies are necessary for technical operation, security or another function requested by the visitor.

        They may be used for purposes such as:

        • security;

        • session management;

        • Website stability;

        • load balancing;

        • storing cookie-consent choices;

        • preventing duplicate consent requests.

        Where a cookie or similar technology is strictly necessary, consent is not normally required.

        Essential technologies cannot be disabled through the cookie-preference tool where doing so would prevent the Website from functioning correctly.

        Functional Cookies

        Functional cookies support optional Website features and preferences.

        They may, where applicable, remember information such as:

        • language choices;

        • display preferences;

        • interface settings;

        • optional interactive functions.

        Where a functional technology is not strictly necessary and applicable law requires consent, it will not be activated before consent.

        Analytical Cookies

        Analytical cookies help us understand how visitors use the Website.

        Depending on the analytics service, they may process information relating to:

        • pages viewed;

        • session duration;

        • navigation;

        • device or browser;

        • referring source;

        • approximate location derived from technical information;

        • technical performance.

        Where consent is required for the analytics configuration being used, analytical cookies will not be activated until consent has been given.

        Marketing Cookies

        Marketing cookies and similar technologies may be used to:

        • measure advertising;

        • attribute conversions;

        • create advertising audiences;

        • recognise users across websites or services;

        • provide remarketing;

        • personalise advertisements.

        Marketing and tracking technologies requiring consent will not be activated before you give that consent.

        25. Google Tag Manager

        The Website may use a tag-management system to manage Website scripts and integrations.

        A tag manager allows other services to be activated through a central configuration.

        The presence of a tag-management system does not itself mean that every possible analytics or advertising service is active.

        Only services actually configured and permitted under your cookie preferences should be loaded.

        The current list of analytics and marketing tags must be reflected accurately in the Cookie Register below.

        26. Consent

        Where consent is required, optional cookies are not activated before you make a choice.

        The cookie banner should provide a clear choice between:

        Accept All Cookies

        and

        Accept Only Necessary Cookies

        You may also choose individual categories through:

        Adjust Your Preferences

        Optional categories must not be pre-selected where active consent is required.

        Continuing to browse the Website without making an affirmative choice does not itself constitute consent.

        27. Changing or Withdrawing Cookie Consent

        You can change or withdraw cookie consent at any time.

        A permanent Cookie Settings or equivalent link should be made available from the Website so that you can reopen the preference tool.

        Withdrawing consent must be possible as easily as giving it.

        Withdrawal prevents future processing based on that consent but does not make earlier lawful processing unlawful.

        Cookies already stored on your device may also be removable through your browser settings.

        28. Browser Controls

        Most browsers allow you to:

        • inspect stored cookies;

        • delete cookies;

        • block all or selected cookies;

        • limit third-party storage;

        • clear Website data.

        Blocking necessary cookies through browser settings may prevent some Website functions from operating correctly.

        Browser controls do not necessarily stop server-side processing or other technologies, so the Website cookie-preference tool should be used where available.

        29. Third-Party Cookies and Technologies

        Some optional Website functions may be provided by third parties.

        Where such providers independently receive personal data, their own privacy terms may also apply.

        The Cookie Register should identify the provider of each relevant cookie or technology and, where applicable, link to the provider's privacy information.

        Third-party marketing or analytics services requiring consent must remain disabled until the required consent has been obtained.

        30. Cookies and Similar Technologies Used on the Website

        Voloshyna.com uses cookies and similar technologies to operate the Website, remember preferences, understand how visitors use the Website and, where enabled, measure the effectiveness of advertising.

        The Website currently uses or may contain integrations for Google Analytics 4, Google Tag Manager, Hotjar and Google Ads.

        The actual cookies placed on your device depend on the Website's current configuration and your cookie preferences.

        Optional analytics and marketing technologies are activated only where the required consent has been obtained.

        30.1. Essential Cookies

        Essential cookies and similar technologies are necessary for the Website to function correctly, maintain security and remember your privacy choices.

        These may include a cookie or browser-storage item used by the Website's cookie-consent mechanism to remember whether you have accepted, rejected or customised optional cookies.

        Essential technologies do not normally require consent because the Website cannot provide the requested functionality without them.

        The exact name and retention period of the consent-management cookie may depend on the consent-management technology currently used by the Website.

        30.2. Google Analytics 4

        We use Google Analytics 4 (GA4) to understand how visitors use voloshyna.com and to improve the Website, its content and user experience.

        Depending on the configuration, Google Analytics may use cookies including:

        _ga — used to distinguish visitors and measure Website usage. The standard Google Analytics retention period is up to two years.

        ga<measurement-id> — used to maintain session state for the relevant Google Analytics property. The standard retention period is up to two years.

        Google Analytics may also use other browser storage or identifiers depending on the configuration and features enabled.

        Google Analytics is classified as an Analytical technology.

        Where consent is required, GA4 is activated only after the visitor has given the relevant consent.

        For more information about Google's processing of information collected through Google Analytics, please consult Google's applicable privacy documentation.

        30.3. Google Tag Manager

        We use Google Tag Manager (GTM) to manage and deploy Website tags.

        Google Tag Manager is a tag-management system rather than an analytics service itself. It allows us to manage integrations such as Google Analytics, Hotjar and advertising-related tags from a central configuration.

        The presence of Google Tag Manager does not mean that every service available through GTM is automatically active.

        The cookies and similar technologies actually placed on your device depend on the tags configured in our Google Tag Manager container.

        Where a tag requires consent, the relevant tag should not be activated before the required consent has been obtained.

        30.4. Hotjar

        We use Hotjar to better understand how visitors interact with the Website and to identify usability and user-experience improvements.

        Hotjar may use cookies and similar browser-storage technologies to distinguish visitors, maintain sessions and analyse interaction with the Website.

        Depending on the current Hotjar configuration, these may include:

        hjSessionUser<site_id> — used to assign a Hotjar User ID and associate activity with the same Website visitor. The standard retention period is approximately 365 days.

        hjSession<site_id> — used to maintain information relating to the current Hotjar session. The standard retention period is approximately 30 minutes and may be extended while the visitor remains active.

        Hotjar may also use short-lived technical storage items to test whether cookies, local storage or session storage are available in the visitor's browser.

        Hotjar is classified as an Analytical technology.

        We do not currently use Hotjar's survey or poll functionality on voloshyna.com.

        Where consent is required, Hotjar is activated only after the visitor has given the relevant consent.

        For information about Hotjar's processing and cookies, please consult Hotjar's current privacy and cookie documentation.

        30.5. Google Ads

        The Website contains or may contain an integration with Google Ads through Google Tag Manager.

        At present, we are not actively using Google Ads for ongoing advertising campaigns.

        However, Google Ads or related conversion-tracking functionality may remain configured within the Website's tag-management environment.

        Depending on the configuration, Google Ads and Google's conversion-linking technology may use cookies such as:

        gclaw, gcldc or other gcl* cookies — these may be used to store information associated with advertising clicks and help attribute conversions.

        The exact Google Ads cookies used depend on whether the relevant Google Ads tags and conversion-linking functionality are currently active.

        Google Ads is classified as a Marketing technology.

        If Google Ads advertising or conversion-tracking functionality is activated, the relevant technologies will only be used where the required consent has been obtained.

        If we permanently discontinue the Google Ads integration, this section and the corresponding cookie configuration will be updated.

        30.6. Analytics and Marketing Technologies

        The Website currently distinguishes between the following categories:

        Essential — technologies required for the operation, security or basic functionality of the Website, including remembering privacy preferences.

        Functional — optional technologies used to provide additional Website functionality or remember optional preferences.

        Analytical — technologies such as Google Analytics 4 and Hotjar that help us understand Website usage and improve the Website.

        Marketing — technologies such as Google Ads that may be used for advertising, conversion measurement or related marketing purposes.

        Optional Analytical and Marketing technologies are not activated before the required consent has been obtained.

        30.7. Cookie Preferences

        When you first visit the Website, you may choose whether to allow optional cookies.

        You can:

        • accept all available cookie categories;

        • reject optional cookies and allow only necessary technologies; or

        • customise your preferences by category.

        You may change or withdraw your consent at any time through the Cookie Settings link available on the Website.

        Withdrawing consent does not affect processing that was lawful before the withdrawal.

        Your browser may also allow you to delete or block cookies. Blocking essential cookies may affect the operation of the Website.

        30.8. Changes to the Cookie Register

        The technologies used by the Website may change when we add, remove or update Website functionality, analytics services or advertising integrations.

        For this reason, this Cookie Policy should be read together with the Website's current cookie-preference tool.

        We will update this Policy where a material change affects the way personal data or device information is processed.

        The cookie configuration should also be periodically checked against the live Website to ensure that this Policy accurately reflects the technologies actually being loaded.

        PART IV

        < class="transform-up " >GENERAL PROVISIONS

        In this section

          31. Changes to This Policy

          We may update this Privacy & Cookie Policy where:

          • our Services change;

          • Website technology changes;

          • processors or providers change;

          • legal requirements change;

          • our data-processing activities change.

          The updated version will show a revised Last Updated date.

          A material change will not retrospectively create consent for processing that legally requires consent.

          32. Relationship With Other Agreements

          This Policy explains personal-data processing.

          It does not replace:

          • the Terms & Conditions;

          • Image & Video Licensing Terms;

          • Client Project Agreements;

          • model releases;

          • participant releases;

          • Data Processing Agreements;

          • project-specific confidentiality terms.

          Where a separate agreement contains data-protection provisions applicable to a particular Project, those provisions should be read together with this Policy.

          33. Contact

          Questions, privacy requests or concerns may be sent to:

          Anna Voloshyna Photography

          Legal name:
          Anna Voloshyna Photography

          Registered address:
          Rennemigstraat 60, 6413BV Heerlen
          The Netherlands

          KVK: 97909386
          VAT: NL005295653B49

          Privacy Contact:
          anna@voloshyna.com

          Website:
          voloshyna.com