Privacy Policy
Effective Date: August 27, 2019
The ct-photography.co.za website is owned and operated by CTP Photography.
This Privacy Policy provides information as to how CTP Photography, (“CTP Photography,” “we,” or “us“) collects and processes your Personal Data (defined below) through your use of the ct-photography.co.za website, whether you are just a visitor to our Website or whether you use our Website as a customer.
It is important that you read this Privacy Policy together with any other privacy notice we may provide on specific occasions when we collect or process Personal Data about you (“Additional Privacy Notices”) so that you are fully aware of how and why we are use your Personal Data. This Privacy Policy supplements the Additional Privacy Notices and is not intended to override them. In the event of a conflict between this Privacy Policy and Additional Privacy Notices, the express terms of Additional Privacy Notices will apply to the Personal Data to which they relate.
You may have different privacy rights under applicable laws depending on the country you are in when you visit or access our Website.
This Privacy Policy is provided in a numerical listed format so you can scroll through to the specific areas set out below.
WHO WE ARE
The Website is owned and operated by CTP Photography (“CTP Photography”).
CTP Photography
Stillwater Estate, Rondeberg Road, Philadelphia, Cape Town, South Africa.
DATA WE COLLECT ABOUT YOU
Personal Data
As permitted by applicable law in the country from which you access our Website and use our services, we may collect, use, store and transfer different kinds of Personal Data about you. We have grouped these into the following categories of Personal Data:
- “Identity Data” such as first name, maiden name, last name, username or similar identifier.
- “Contact Data” such as billing addresses, email addresses and telephone numbers.
- “Technical Data” such as Device IDs, your login data, access dates and times, browser type and version, device information, cookie data, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Website.
- “Usage Data” such as information about how you use our Website, products and services.
- “Marketing and Communications Data” such as your preferences in receiving marketing from us and our third-parties and your communication preferences.
Non-Personal Data
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Data but is not considered Personal Data since it does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.
If You Fail to Provide Personal Data Where Required to Provide Services to You
Where we need to collect Personal Data by law, or under the terms of a contract we have with you, or a prospective contract, and you fail to provide that Personal Data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel the service you have with us (or requested from us), and you accept that as a condition of service.
Data That You Should Not Provide to Us
We do not require any Special Categories of Personal Data about you. Accordingly, please do not provide this type of personal data to us.
CTP Photography as a Data Processor
CTP Photography acknowledges that you have the right to access your personal information. With respect to Personal Data provided by a client of CTP Photography to CTP Photography, we collect such information under the direction of that client and have no direct relationship with the individuals whose Personal Data we process. If you are a customer of such a CTP Photography client and would no longer like to be serviced by such client, please contact the client directly. If you seek access or want to correct, amend, or delete inaccurate data, you must direct such request to that client (the data controller). If requested to remove data, we will respond within a reasonable timeframe. We may transfer personal information to companies that help us provide our services. Transfers to subsequent third parties are covered by our service agreements with our clients.
We will retain Personal Data that we process on behalf of our clients for as long as needed to provide services to our client. CTP Photography will retain this Personal Data as necessary to comply with our legal obligations, resolve disputes, enforce our agreements, and in accordance with our internal record keeping policies.
HOW DATA IS COLLECTED
We use different methods to collect Personal Data from and about you including, for example:
Direct Interaction
You may give us your identity, contact, billing and other information by filling in forms or by corresponding with us by post, phone, e-mail or otherwise. This includes Personal Data you provide when you:
- request information to be sent to you;
- give us some feedback; or
- otherwise submit Personal Data to us.
Automated Technologies or Interactions. As you interact with our Website, we may automatically collect Technical Data and Usage Data about your equipment, browsing actions and patterns. We collect this Personal Data and Non-Personal Data by using cookies, server logs and other similar technologies. We may also receive Technical Data and Usage Data about you if you visit other websites employing our cookies and other Tracking Technologies (defined below). For more information regarding our use of Tracking Technologies, please refer to “Cookies and Similar Technologies” below.
Third Parties. We may receive Personal Data in the form of Technical Data and Usage Data about you from various third-parties such as analytics providers or advertising networks.
HOW WE USE YOUR DATA
Non-Personal Data
Where permitted by applicable law, we may use your Non-Personal Data for any purpose not prohibited by applicable law or inconsistent with this Privacy Policy or any written representation we have made to you at the point and time of the data collection.
Personal Data
We will only use your Personal Data where permitted by i.e., when we have a business or commercial reason to use your personal data. For example:
- Where we need to perform the contract we are about to enter into with you or have entered into with you
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
- Where we need to comply with a legal or regulatory obligation
- Where you have given us your consent
Purposes for Which We Use Your Personal Data
We have set out below a description of the ways we use your Personal Data, and the legal basis that we rely upon to do so; we will amend this as required. We have also identified what our legitimate interests are where appropriate. We have also provided you with an explanation of some of the terms we use:
- ‘Legitimate Interest’ means our interest in conducting and managing our business, to enable us to give you the best experience when using the Website, products, and services. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
- ‘Performance of Contract’ means processing your Personal Data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
- ‘Comply with a legal or regulatory obligation’ means processing your Personal Data where it is necessary for compliance with a legal or regulatory obligation to which we are subject.
- ‘Consent’ means that you consent to our use of your personal data for one or more specific purposes. Where we rely on your consent to use your personal data, you have the right to withdraw that consent at any time. You can do this by contacting us at info@ct-photography.co.za. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
WHO WE SHARE YOUR DATA WITH
Personal Data
We may share Personal Data with the following parties:
Internal Parties
Companies within our corporate family that comprise the CTP Photography Group. Access to your Personal Data will be controlled and only granted where necessary to provide our services to you and/or to allow us to perform any necessary or legitimate functions.
External Third-Parties
Service providers that we use to support our business and help provide our services to you, including, but not limited to, third-parties that host our Website, assist us to verify your identity, perform website and platform maintenance, risk assessments, and security, perform data and web analytics, provide databases, IT services, customer service, payment platforms and credit card processing, communication services, and email services
We require all third-parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions
Professional advisers such as lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance, financial, auditing, and accounting services to us so we can operate our business
Taxing authorities, such as the South African Revenue Service and other authorities acting as processors based in the Republic of South Africa, who require reporting of processing activities in certain circumstances
Fraud prevention and identity verification services where we believe that disclosure is necessary or appropriate to protect the rights, property, or safety of CTP Photography, our customers or others. This includes exchanging information with third-parties for the purposes of fraud detection and prevention, and credit risk reduction
In connection with or during negotiations of any proposed or actual financing, merger, purchase, sale, sale or transfer of some or all of our assets or stock, joint venture, or any other type of financing, acquisition or business combination of our company(ies), or all or any portion of our assets, or transfer of all or a portion of our business to another company, including without limitation in the event of a divestiture, restructuring, reorganization, dissolution or other event, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding. In the event of a merger, divestiture, restructuring, reorganization, or other sale or transfer of some or all of our assets or stock, Personal Data that we hold about our clients and users of our services will be one of the assets that will be transferred. If a change happens to our business, the new owners may use your personal data in the same way as set out in this Privacy Policy
Other third-parties where you have expressly consented to the disclosure of your Personal Data
Law enforcement agencies, courts, supervisory authorities, regulatory bodies and certain other third-parties, to the extent that we are permitted or required to do so by law, or in order to comply with our legal and regulatory obligations, or in the interests of national security, or to respond to verified requests relating to a criminal investigation or alleged or suspected illegal activity
Non-Personal Data
Where permitted by applicable law, we may share your Non-Personal Data for any purpose not prohibited by applicable law or inconsistent with this Privacy Policy or any written representation we have made to you at the point and time of the data collection.
WHERE YOUR DATA IS TRANSFERRED
CTP Photography is headquartered in the Republic of South Africa. The information that you provide or that we collect as a result of your interaction with the Website and/or your use of our services on the Website is generated in the RSA.
We are committed to upholding the Protection of Personal Information Act Section 14.
With respect to personal data received or transferred pursuant to the Protection of Personal Information Act, we are subject to the regulatory enforcement powers of the RSA Trade Commission. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
HOW LONG YOUR DATA WILL BE KEPT
We will not retain your Personal Data for longer than necessary for the purposes set out in this Privacy Policy. Different retention periods apply for different types of Personal Data and in determining the appropriate retention period, we consider several criteria, including, but not limited to, the purpose for which we hold your Personal Data, our legal, accounting, reporting and/or regulatory obligations in relation to that Personal Data, e.g., financial or tax reporting obligations, whether our relationship with you is ongoing, e.g., where you use more than one of our products and/or services, any specific request you may have made in relation to the deletion of your Personal Data, or where we have a legitimate interest in relation to the management of our own rights, e.g., the defence of any claims. In some circumstances we may anonymize your Personal Data so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you no longer have a relationship with us, we will retain and securely destroy your Personal Data subject to the foregoing and in accordance with applicable laws and regulations. If you request to receive no further contact from us, we will keep some basic information about you on our suppression list in order to avoid sending you unwanted materials in the future.
COOKIES & TRACKING TECHNOLOGIES
CTP Photography and third parties may use cookies or other tracking technologies (e.g., pixels, beacons, scripts, etc.) (“Tracking Technologies”) in connection with the Website to collect information about interactions with the Website.
If you are accessing the Website from other than the RSA, you understand that we apply RSA law and adhere to the Protection of Personal Information Act Section 14.
DATA SECURITY
We use appropriate technical and organizational measures to protect Personal Data we process about you.
However, no transmission of information via the Internet or wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your Personal Data, you acknowledge that there are security and privacy limitations of the Internet which are beyond our control and accordingly, the security, integrity and privacy of data exchanged between you and us through the Website cannot be guaranteed.
We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
The safety and security of your Personal Data also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your login or account credentials with anyone and keep your account information secure. We urge you to be careful about giving out information in public areas of the Website like message boards, where information will be available to other users of the Website. If you believe that your access credentials or Personal Data have been compromised, please contact us immediately.
LINKS TO THIRD PARTY WEBSITES AND SOCIAL MEDIA FEATURES
Our Website may from time to time, contain links to third-party services such as websites, locations, platforms, applications or services operated by third parties. If you follow a link to or otherwise access any of these third-party services, these third-party services may use their own cookies, web beacons, and other Tracking Technology to independently collect information about you and may solicit Personal Data from you. Please note that these third-party services have their own privacy policies and we do not accept any responsibility or liability for these parties’ policies or practices. Please check these policies before you share any Personal Data with these third-party services.
We may offer you the opportunity to use your social media login when interacting with our Website. If you do so, please be aware that you may be sharing your profile information with us. The personal data that is shared will depend on your social media platform settings. Please visit the relevant social media platform and review its privacy policy to understand how your personal data is shared and used in this context.
Social media features may also collect your IP address, which page you are visiting on our Website, and may set a cookie or other Tracking Technologies to enable the applicable social media feature to function properly. Your interactions with these features are governed by the privacy policy of the company providing such features.
The Website may include tools provided by us or third-party services that enable you to send a message to another person. If you use any such tools, please ensure that you only send messages to persons to whom you have permission to send messages. Absent the recipient’s consent, we will only use their Personal Data that you provide us to facilitate such messages.
QUESTIONS OR COMPLAINTS
Data Subjects Located Outside the Republic of South Africa
If you have a complaint, or if you have any questions or requests regarding your Personal Data, please email us at info@ct-photography.co.za, and specify the country in which you are located.
Data Subjects Located within the Republic of South Africa
If you have a complaint, or if you have questions or requests regarding your Personal Data, please email us at info@ct-photography.co.za.
MARKETING
We may use your Personal Data to send you information about the services provided by the CTP Photography; provided, however that we will obtain consent to do so from data subjects. You may unsubscribe from our marketing e-mails by clicking “Unsubscribe” in any promotional e-mail communications we send you. As permitted by applicable law, you cannot opt-out of non-marketing, services-related notices.
CHANGES TO THIS PRIVACY POLICY
We reserve the right to change this Privacy Policy at any time. If we propose to make any material changes, we will notify you by posting a notice on the Website or by issuing an email to the email address listed by registered users prior to the changes becoming effective. You acknowledge that it is your responsibility to maintain a valid email address as a registered user, and to review the Website and this Privacy Policy periodically in order to be aware of any modifications. If you object to any changes to the revised Privacy Policy, you can stop using our services and close your account with us. However, if you continue to use our services (including the Website) after we publish a new or updated Privacy Policy, you acknowledge that such continued use means that the treatment of your Personal Data will be subject to the new or updated Privacy Policy.
MINORS & CHILDREN
Our Services and the Website are not intended for use by persons under the age of 18 years. CTP Photography does not knowingly collect or solicit Personal Data from anyone under the age of 13 or knowingly allow such persons to register to use our Website. In the event that we learn that we have collected Personal Data of a child under the age of 13, we will delete that data to the extent required by applicable law as quickly as possible. If you believe that we might have any Personal Data from or about a child under 13, please contact us at info@ct-photography.co.za
HOW TO CONTACT US
Technical or Customer Service Questions. Wherever you are located, if you have any questions about your account, and/or technical or other customer support questions about your use of our services, please contact us on info@ct-photography.co.za.
Data Privacy Questions. If you have any questions regarding our personal data practices, please contact us on info@ct-photography.co.za.