General

This policy statement provides information on the obligations and policies of Photo2Painting, its subsidiaries, affiliates, and associated companies (the “Company”) equal to any in the world in respect of the protections they provide to an individual. As such, the Company undertakes to apply, where practicable, those principles and the processes set out herein to its operations globally.

Our Corporate Privacy

The Company’s officers, management, and members of staff shall, at all times, respect the confidentiality of and endeavor to keep safe any and all personal data collected and/or stored and/or transmitted and/or used for, or on behalf of, the Company. The Company shall endeavor to ensure all collection and/or storage and/or transmission and/or usage of personal data by the Company shall be done in an appropriate manner for membership applications, and internal purposes. Where an individual legitimately requests access to and/or correction of personal data relating to the individual, held by the Company, then the Company shall provide and/or correct that data in an appropriate time and manner.

Statement of Practices

Types of Personal Data Collected : For the purpose of carrying on the Company’s business, including registration and administration of the Company’s related products and services (including relevant online services), you may be requested to provide personal data such as, but not limited to, the following, without which it may not be possible to satisfy your request:
1.Your name;
2.Correspondence address, and/or billing address;
3.Payment details, including credit card and banking information;
4.Contact details, including contact name and telephone number or email address
In some instances, you may also be requested to provide certain data that may be used to further improve our products and services and/or better tailor the type of information presented to you. In most cases, this type of data is optional although, where the requested service is a personalised service, or provision of a product or dependent on your providing all requested data, failure to provide the requested data may prevent us from providing the service to you.

Accuracy of Personal Data

Where possible, we will validate data provided using generally accepted practices and guidelines. This includes the use of check sum verification on some numeric fields such as account numbers or credit card numbers. In some instances, we are able to validate the data provided against pre-existing data held by the Company. In some cases, the Company is required to see original documentation before we may use the personal data such as with Personal Identifiers and/or proof of address.

Storage and Retention of Personal Data

Photo2Painting will endeavor to take all reasonable steps to keep secure any personal information recorded, and to keep this information accurate and up to date. The information is stored on secure servers if in digital format, or in locked areas if in hardcopy format: these repositories are protected in controlled facilities. In some cases these facilities may be overseas. The Company will destroy any personal data it may hold in accordance with our internal retention policy.
The policy states that:
1.Personal data will only be retained for as long as is necessary to fulfill the original or directly related purpose for which it was collected, unless the personal data is also retained to satisfy any applicable statutory or contractual obligations; and
2.Personal data are purged from the Company’s electronic, manual, and other filing systems in accordance with specific schedules based on the above criteria and the Company’s internal procedures.

Disclosure of Personal Data

All personal data held by the Company will be kept confidential but the Company may, where such disclosure is necessary to satisfy the purpose, or a directly related purpose, for which the data was collected provide such information to the following parties:
1.Any subsidiaries, holding companies, associated companies, or affiliates of, or companies controlled by, or under common control with the Company;
2.Any person or company who is acting for or on behalf of the Company, or jointly with the Company, in respect of the purpose or a directly related purpose for which the data was provided;
3.Any other person or company who is under a duty of confidentiality to the Company and has undertaken to keep such information confidential, provided such person or company has a legitimate right to such information; and
4.Any financial institutions, charge or credit card issuing companies, credit information or reference bureau, or collection agencies necessary to establish and support the payment of any services being requested.
Personal data may also be disclosed to any person or persons that have a right under Singaporean law to gain access to such information provided they are able to prove their authority to access such information. For example, if the Company were served with a court order demanding certain customer information then the Company would disclose the information to the duly appointed officer of the court or such other persons as the court orders.

Security of Personal Data

Physical records containing personal data are securely stored in locked areas and/or containers when not in use. Computer data are stored on computer systems and storage media to which access is strictly controlled and/or are located within restricted areas. Access to records and data without appropriate management authorization are strictly prohibited. Authorizations are granted only on a “need to know” basis that is commensurate with an individual’s Company responsibilities and their training. Records of the Company are under the control of assigned information officers who are responsible to ensure the transfer of or access to information is legitimate. Audit records may be produced to validate data modifications in order to verify the data’s integrity. There may be violations logging processes for investigation of any unauthorized attempt to access information. Encryption technology, such as SSL, may be employed for the transmission of data collected online.

Photo2Painting and links to other web sites

Photo2Painting provides links to web sites outside of the Photo2Painting site. These linked sites are not under the control of Photo2Painting, and Photo2Painting is not responsible for the conduct of companies linked to the Photo2Painting web site, nor for the performance or otherwise of any content and/or software contained in such external websites.

Change Policy

Photo2Painting reserve the right to alter any of the clauses contained herein in compliance with local legislation, to meet its global policy requirements, and for any other purpose deemed necessary by the Company.