MIT Cloud Innovation AG is the provider of services called Picturex (the "Service"), accessible at https://picturex.ch. We at Picturex care about how your personal information is used and shared, and we take your privacy very seriously. This policy describes the information we collect during your use of the Service, how we use it, and how it may be shared.
“Personal information” means all information about an identifiable individual.
Picturex is responsible for personal information under its control, and will take all reasonable steps to handle such personal information fairly and to ensure compliance with applicable laws in relation to the collection, use, disclosure and protection of personal information.
PURPOSES FOR COLLECTING PERSONAL INFORMATION
Through the Services and the Website, Picturex collects, uses and discloses to certain third parties personal information for the following primary purposes:
- to develop, manage, maintain and deliver our products and the Services to our customers;
- to contact our customers directly about products and services that may be of interest;
- to ensure high standards of service to customers;
- to contact customers with product and service updates, upgrades and enhancements;
- to meet regulatory requirements; and
- to verify a customer’s identity.
The paragraphs below provide further information about what types of personal information we collect and how we use and disclose it for each of the Services and the Website.
COLLECTED INFORMATION PROVIDED BY USER
Picturex requires several pieces of personal information to operate as designed. Name and active Email-address are required to use any Picturex Service. We may, however, request additional information, which may be required for certain Services and features.
ADDITIONAL COLLECTED INFORMATION
On our Website, Picturex collects non-personally identifiable information. This will typically include browser type, language preference, referring site, and the date and time of each visitor request. Picturex collects this data to optimize our service to users.
Additionally, Picturex collects limited information from its mobile phone users (who have installed the Picturex application) in a similar manner to optimize the mobile experience. Picturex does NOT collect user’s location information or mobile phone numbers. We collect mobile screen resolution, device make and manufacturer, as well as the device's unique identifier to authenticate users (in the iPhone's case, a UDID).
„Cookies“ are small text files containing small amounts of information which are downloaded to your device when you visit a website, so that the website can remember some information about your browsing activity on the website, either for the duration of your visit or for repeat visits. The cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes that cookie. Cookies are useful because they allow a website to recognize a user’s device. They do many different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improving your user experience. In general, cookies make the interaction between you and the website faster and easier. They cannot be used to run programs or deliver viruses to your device. In general, cookies do not identify you personally.
The following describes the types of cookies that Picturex currently uses or may in the future use on our Website:
These are temporary cookies that expire when you close your browser. A session cookie assigns a randomly-generated, unique identification number to your device when you access the Website. Assigning your device a number facilitates the proper functioning of the features of our Website by permitting us to maintain a persistent “state” for your session, including information relating to orders that you may place. We also use session cookies to collect anonymous information (i.e., information that does not identify you personally) about the ways users use the Website, such as which pages they visit, which links they use, and how long they stay on each page. We analyze this information (known as “click-stream information”) to better understand our user’s interests and needs and to improve the content and functionality of the Website.
Unlike a session cookie, a “persistent cookie” does not expire when you close your browser. It stays on your device until the expiration date set in the cookie (for example, at the end of a calendar month) or until you delete it. Persistent cookies can be used to “tag” your device so that the next time you visit (or someone using your device visits), our server will recognize you, not by name, but by the “tag” on your device. This will enable us to provide you with a personalized experience even if we do not know who you are. It will also allow us to collect more accurate information about the ways people use the Website, for example, how people use the Website on their first visit and how often they return. Using persistent cookies permits us to provide you with a more personalized experience and, in some cases, may save you the trouble of re-entering information already in our database.
STRICTLY NECESSARY COOKIES
These cookies are essential for the running of our Website. Without these cookies, parts of our Website would not function. They enable you to move around the Website and use its features, such as accessing secure areas. These cookies do not track where you have been on the Internet and do not gather information about you that could be used for marketing purposes.
These cookies are used to monitor the performance of our Website, for example, to determine the number of page views and the number of unique users the Website has. Web analytics services may be designed and operated by third parties on Picturex’s behalf. The information provided by these cookies allows us to analyze patterns of user behaviour, and we use that information to enhance user experience or identify areas of the Website which may require maintenance. These cookies do not collect information that identifies a visitor. All information collected through these cookies is aggregated and therefore anonymous.
These cookies allow the Website to remember choices you make (such as your preferences, language or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize. The information these cookies collect may be anonymized, and they cannot track your browsing activity on other websites.
TARGETING OR ADVERTISING COOKIES
These cookies, which may be placed on your device by us or our trusted third party service providers, remember that you have visited a website and use that information to provide you with advertising which is tailored to your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They remember that you have visited a website and this information is shared with other organizations such as advertisers. Although this type of cookies can track your activity around the Internet, they cannot identify you personally. Without these cookies, online advertising you encounter will be less relevant to you and your interests.
When you visit our Website, your device may receive one or more “web beacons” in order to assist us with delivering cookies, to collect anonymous information about the use of the Website by our users, and to deliver customized or targeted content to you on the Website and through our partners. Web beacons (also referred to as “tracking pixels,” “1×1 gifs,” “single-pixel gifs,” “pixel tags,” or “action tags”) are graphic images, usually no larger than a 1×1 pixel, placed at various locations on the Website. They also help us identify browser types, search terms that bring users to our Website, and the domain names of websites that refer traffic to us. We also utilize web beacons to provide us with more information on any emails we send out. In particular, a web beacon in an email communication will send us information to let us know that you have received, opened, or acted upon an e-mail you have chosen to receive from us.
By using our website, you agree that we can place these types of cookies on your device.
Some people find the idea of a website storing information on their device intrusive. If you would prefer to opt out of cookies, it is possible to manage them by changing the cookie settings on your device, in your browser settings. Existing cookies that have already been set can be deleted from your hard drive. You can also block some or all cookies. However, you should be aware that you might lose some features and functionality of our Website if you do so. If you need assistance with your cookie settings, consult the help menu within your Internet browser. For more detailed information about cookies and how to manage and delete them, visit http://www.aboutcookies.org or http://www.allaboutcookies.org.
Picturex’s Website may contain links to third party sites, and we recommend and encourage you to read the privacy policies posted on those third party sites. Picturex is not responsible for the privacy policies or practices of any third party.
The form of consent can vary, depending on the sensitivity of the information and the circumstances. Consent may be express or implied depending on the nature of the personal information or the use. At times, consent for one use can fairly be implied to include consent for other included or related uses. When determining the appropriate form of consent, Picturex will be guided by what a reasonable person would consider fair and appropriate in the circumstances.
Your consent may be provided to Picturex orally, in writing or electronically, either personally or through an authorized individual. Consent can be implied when you are informed that information will be used for certain purposes and you submit the information with this knowledge, or consent can be implied where the purpose for collecting, using or disclosing the personal information would be considered obvious and the individual voluntarily provides personal information for that purpose.
Picturex may collect, use or disclose personal information without your knowledge or consent in the following limited circumstances:
When the collection, use or disclosure of personal information is permitted or required by law (including subpoenas, search warrants, court orders and government orders);
In an emergency that threatens an individual’s life, health or personal security;
When the personal information is available from a public source (e.g. a telephone directory);
- When we require legal advice from a lawyer;
- For the purposes of collecting a debt;
- In connection with criminal justice, taxation or regulatory activities;
- To protect ourselves from fraud or to protect the rights and property of Picturex;
- To investigate an anticipated breach of an agreement or a contravention of law; or
- In the event of a reorganization, merger or sale of Picturex.
Subject to certain exceptions (e.g. where the personal information is necessary to provide Services, or the withdrawal of consent would frustrate the performance of a legal obligation), you may withdraw or refuse to provide your consent to Picturex, or request that your personal information be removed from our databases and records, by giving reasonable notice. All communications with respect to the withdrawal of consent should be made in writing and addressed to Picturex’s Privacy Officer.
If you refuse or withdraw consent, or request that your personal information be removed from our databases and records, Picturex will make you aware of the likely consequences of this action. In some cases, it may prevent Picturex from providing you with the Services.
Picturex will restrict its collection of personal information to that information which is necessary and relevant for the legitimate purposes identified. Picturex will not collect excessive personal information, and will limit the purposes of collection to what a reasonable person would consider fair and appropriate in the circumstances.
Picturex will collect personal information only by fair and lawful means, will be transparent, up front and open with you, and will communicate in a manner that is clear and reasonably understood.
LIMITED USE DISCLOSURE AND RETENTION
Except as set forth in this policy, Picturex uses provided and collected information only for internal purposes and does not disclose data to third parties. Picturex may occasionally inform users of new releases and features via any communication methods you have provided to the Service.
: MIT Cloud Innovation AG with Picturex occasionally hires other companies (vendors) to provide limited services on its behalf, such as handling the processing and delivery of mailings, hosting websites, processing transactions, or performing statistical analysis of our services. Those service providers will be permitted to obtain only the personal information they need to deliver the service. They are required to maintain the confidentiality of the information and are prohibited from using it for any other purpose than for delivering the service to Picturex, in accordance with MIT Cloud Innovation AG with Picturex’s instructions and policies. However, our vendors may use aggregate data for fraud detection to help improve their services. This helps them to more accurately detect fraudulent transactions.
: Picturex may share data internally with its affiliate companies and may disclose certain information in the event that it is merged, acquired, sold, or some of its assets are acquired. If, in MIT Cloud Innovation AG's Picturex discretion, your information will be handled in a materially different manner after such a transaction than it was by Picturex, you will be contacted and will have the opportunity to opt-out of having your information shared with any acquirer.
: Picturex may disclose data to respond to valid legal process from competent authorities, meet legal requirements, exercise our legal rights or defend against legal claims, protect MIT Cloud Innovation AG. With Picturex’s interests, fight against fraud, and to enforce our policies or to protect anyone's rights, property, or safety.
Picturex will retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, or as required for legal or business purposes. After this time, any personal information you have provided to us will be destroyed, deleted or made anonymous.
ACCURACY and RECTIFICATION
Picturex will make reasonable efforts to ensure that the personal information collected and used by us is accurate, complete and up-to-date to meet the purposes for which it is collected and used. Picturex does not routinely update personal information unless it is necessary to meet the purposes for which it is collected. Picturex therefore relies on you to keep your personal information accurate and current.
You may request correction to your personal information to ensure its accuracy and completeness. Any request to correct personal information must be made in writing to Picturex’s Privacy Officer and must provide sufficient detail to identify the personal information and the correction being sought.
If your personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any third party to whom we disclosed the personal information in the previous year. If the correction is not made, we will note your correction request in the relevant records.
SAFEGUARDING PERSONAL INFORMATION
Picturex will make reasonable security arrangements and use appropriate technical and organizational measures to protect all personal information under our control (regardless of the format in which it is held) against unauthorized access, loss, theft, collection, use, disclosure, duplication, modification, disposal or similar risks, by both individuals outside of Picturex as well as within. The types of security safeguards that we use vary, depending on the nature and sensitivity of the personal information, the harm that might result from its improper use or loss, and how it is stored (e.g. in paper or electronically). Picturex’s security safeguards include locked filing cabinets, physically secured offices where personal information is held, limited employee access, the use of IDs, passwords, restricted servers, firewalls and encryption for electronic files, as well as contractual requirements for service providers to provide comparable security measures.
Picturex will use appropriate security measures when disposing of and destroying personal information, such as shredding documents and deleting electronically stored information, in order to prevent unauthorized access.
Picturex will continually monitor compliance with this policy and will investigate any suspected breaches swiftly and effectively. If a breach is found to have occurred, Picturex will comply with all applicable data breach laws, including notifying relevant individuals and regulatory bodies where required. Picturex and its employees will respond promptly and in accordance with applicable laws to any notices or demands issued by a Privacy Commissioner or similar regulatory body in any relevant jurisdiction.
Picturex will also continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.
YOUR RESPONSIBILITY ONLINE
In general, you should remain aware that any information you share online can be accessed by others. MIT Cloud Innovation AG with Picturex is not responsible for the actions of those who obtain your content in this manner. MIT Cloud Innovation AG with Picturex cannot guarantee your safety and security and you should be aware that submitting any information and using the Picturex Service is done at your own risk.
REQUESTS FOR ACCESS
You have the right to access your personal information, subject to limited exceptions under applicable laws such as solicitor-client privilege, disclosure that would reveal personal information about another person, legal obligations and proprietary rights. Picturex’s Privacy Officer will assist you with your request. This includes:
- Identification of and access to any or all of your personal information under Picturex’s custody or control.
- An explanation of how that personal information is or has been collected, used or disclosed by Picturex.
- The names of any individuals and organizations to which your personal information has been disclosed by Picturex.
All requests should be made in writing (by mail, fax or email), provide sufficient detail to identify the information being sought, and be directed to Picturex’s Privacy Officer. Picturex’s Privacy Officer may require further information defining the request more succinctly.
We will respond to written requests within thirty (30) days of receiving such request. We will either make the requested information available within that time period, or provide written notice of an extension where additional time is required to fulfill the request. If Picturex cannot fulfill your request in full or in part, you will be provided with a response in writing that documents the reason for refusal and the recourse available to you.
A minimal fee may be charged for providing access to personal information, where permitted under applicable law. Where a fee applies, we will inform you of the cost and request further directions from you on whether or not we should proceed with your request.
MIT Cloud Innovation AG
All information passed through Picturex is primarily handled in Switzerland but may from time to time be handled in any country in which MIT Cloud Innovation AG with Picturex or its affiliate companies operate. By using the Service, you agree that the handling of your personal information and any communication through the Service will be governed by the laws of Switzerland and any applicable state laws.
Last Updated April 2018.
© 2018 MIT Cloud Innovation AG.