Privacy Policy

(referred to as “the Company”, “our”, “we”, “us”)
2 Introduction

2.1 We are delighted that you have visited our website and shown interest in the Company. We take the protection of your personal information seriously and want you to feel safe when you are visiting our website and/or engaging with us.

2.2 This Statement sets out how we will handle your personal information, as defined under applicable law, and covers any information, including personal and special personal information, that you give to us or which we collect from third parties (“Personal Information”).

2.3 In delivering our products/ carrying out our services, we will use your Personal Information in accordance with this Statement and applicable law.

2.4 Whilst we try to balance our legitimate business interests with your reasonable expectation to privacy and to take all reasonable measures to prevent unauthorised access to, or disclosure of your Personal Information, it is impossible to guarantee that your Personal Information will be 100% secure.

3 How this Statement applies to you

3.1 This Statement will apply whenever you submit Personal Information to the Company, which will include (but is not limited to) when you browse our website and/or any related (and/or enhanced) mobi-sites, software applications or any other portals specifically made available by the Company in relation to this platform (“Website”) or engage with us or any of our product and/or service offerings including instances where your Personal Information is submitted to us through or by a third party (collectively “Services”). The Statement is even expressly incorporated under our Service Agreements and Terms and Conditions (see:

3.2 Your continued use of this Website and our Services indicates that you (which may include any representative acting on your behalf) have both read and consented to the terms of this Privacy Statement and hereinafter you shall be referred to as “you”, “your or “user”).

3.3 If you do not agree to any of the provisions of this Statement, then you should not submit any Personal Information to the Company. However, we note that if you do not consent to this Statement, or any parts thereof, we may not be able to provide you with our products and services.

3.4 Our Services are only intended to be used by persons aged 18 years or over.

Disclosure and Processing of Personal Information related to Children.

Due to the nature and content of the services we offer, you may provide us with, and we may be privy to or need to process some/limited, Personal Information related to a child or children (such as their name, their photographs (images)). These persons being minors, as legally defined, (“Child”) are afforded additional protections under the applicable law.

To this end, we endeavour to limit the type and extent of any Personal Information that we process in relation to any Child and in doing so to comply with the principles set out under applicable law and this Statement.

However, to the extent that any Personal Information is disclosed or processed related to a Child, either in using this website and/or and any of our services, then you:

a) warrant that you are a competent person and are authorised to consent to the disclosure and processing of such Child’s Personal Information, on their behalf (you consent as their parent or guardian or otherwise authorised person);
b) warrant that you have contracted our services for a legitimate (and not harmful) purpose; and
c) consent to the processing of your/the Child’s Personal Information and agree to be bound by the provisions of this Statement, which shall apply equally in relation to your/the Child’s Personal Information.

4 Licence And Unauthorised Use Of The Website

4.1 Subject to you accepting our Policies and Terms and Conditions (as applicable), we grant you a limited, revocable, non-transferable licence to access and use the Website in accordance with our various pol-icies and agreements which may govern such use and access. We may revoke this licence at any time, including for breach of any of our Policies or Terms and Conditions.

4.2 You may not use the Website for any offensive or unlawful purpose.

4.3 We reserve the right to remove any content from the Website that is untrue, defamatory, offensive, amounts to hate speech or is otherwise unlawful.

4.4 You shall not introduce any virus, worm, trojan horse, malicious code or other program which may damage computers or other computer-based equipment through email communication with us.

4.5 You agree that you are responsible for compliance with any and all laws, rules and regulations that may apply to its use of the Website or the Services.

5 Warranties

5.1 The use of this Website is at your own risk.

5.2 We make no representation or warranty (express or implied) that the Website and Services or will:

5.2.1 meet a user’s needs;
5.2.2 be accessible at all times;
5.2.3 be free from viruses, spyware or malware; and/or
5.2.4 be accurate, current, complete or free from errors.

6 Liability And Indemnity

6.1 Without derogating from any other agreed limitations of liability or indemnifications, in agreeing to the provisions of this Policy you hereby unconditionally agree to indemnify us against any liability, loss or damage (including third party) that may result from your use of this Website.

6.2 As far as is legally permissible, we shall not be liable for (which shall include but is not limited to) any loss or damage arising from access to or reliance on any inaccurate or incomplete information on the Website, any viruses or alike, any delays, interruptions, service failures or other problems inherent in use of the internet and electronic communications or other systems outside of our reasonable control. While a User may have statutory rights, the duration of any such statutorily warranties, will be limited to the shortest period to the extent permitted by required law.

7 Intellectual Property And Copyright

7.1 The content on the Website (including any intellectual property) is owned or licenced by us or other third parties such as; our third-party licensors or suppliers and is protected by law (including Copyright and Trademark law).

7.2 Where we post or list content provided by a third party, that party is responsible for and warrants that that they have all necessary rights to such content and are not infringing or violating any third part rights by such content being posted on the Website. The Company will not be liable for any third-party infringements. Any alleged infringements need to be taken up with party in question.

7.3 You may not use, copy, reproduce, distribute, republish, download, display, post or transmit in any form or by any means, the content of the Website with prior permission or as is legally permitted.

7.4 You hereby indemnify us against any claim, loss or damages (including third party) resulting from your infringement of this clause or any violated rights.

8 Scope of our Processing
8.1 What we Collect
We may collect information that allows you (and/or your child/ren) to be identified, such as:
(a) name, age, sex, physical addresses, e-mail address, phone number, marital status, bank account or payment details, identity number, child/children’s school information and/or the internet address of your domain; and/or;
(b) sensitive and special categories of personal information (e.g., photographs or images).
8.2 How we Collect
8.2.1 You may provide Personal Information to us either directly or indirectly (through and agent or intermediary) or through completing an application form for our products and services or requesting further information about our products and services, whether in writing, through our website, over the telephone or any other means.
8.2.2 We may also collect your personal information from your appointed agent, any regulator, or other third party that may hold such information.
8.3 How we Use Personal Information
8.3.1 We may collect, use, transfer or process your Personal Information:
(a) to provide and perform our Services to you and to improve or evaluate the effectiveness of the Company, its products, services or offerings (including to understand general user trends and patterns so that we can develop and support existing and ongoing marketing strategies and to create market data profiles to improve our offerings- which generally will be in aggregated form);
(b) to respond to and comply with your instructions, complaints or requests;
(c) to operate, develop and manage our website/other platforms;
(d) for security (including fraud and crime prevention/reporting), administrative, auditing, operational, marketing and legal or regulatory purposes (which will include complying with any law enforcement agency requests);
(e) for operational, marketing, auditing, legal and record keeping requirements;
(f) to third parties for reasons set out in this Statement or where it is not unlawful to do so (this may include but is not limited sharing information with prospective buyers or sellers or our business or assets);
(g) outside of the Republic of South Africa, in accordance with applicable law, including for cloud storage and payment purposes and the use of any of our websites;
8.3.2 We may from time to time (and at any time) contact you for market research about services, products and offerings available from the Company or specific affiliates or subsidiaries which we believe may be of interest to you, by email, phone, text or other electronic means, unless you have unsubscribed from receiving such communications. You can unsubscribe from receiving such communications by clicking here. – Login, select My Account, Account Settings
8.4 Disclosure of Personal Information
8.4.1 Your Personal Information may be disclosed with the Company’s affiliates, subsidiaries, employees, agents, sub-contractors and selected third parties who process the information on our behalf.
8.4.2 We may also disclose your Personal Information to third parties for the purposes of rendering our Services and for the reasons recorded in clause 3.3 above, including any third parties with whom our supplies and services are carried out/provided in conjunction with and/or who are involved in the completion of our supplies and services and who may need to have your Personal Information in order to fulfil your request or the services (e.g. Third party payment platform providers or cloud service providers).
8.4.3 Wherever these persons are located outside of the country (and your Personal Information may be transferred cross-border) we will adhere to applicable laws.
8.5 Security
While we cannot ensure or warrant security on the internet or of any of the Personal Information you provide us, we do continue to maintain and improve our security measures over time and in line with legal and technological developments.
8.6 Retention
8.6.1 We may store your Personal Information directly or on a central or separate database. If the location of the central database is in a country that does not have substantially similar data protection laws, we will take all legally mandatory required steps to ensure that your Personal Information is adequately protected.
8.6.2 We may retain your personal information indefinitely, unless you object, in which case we will only retain it if we are permitted or required to do so in terms of applicable law. However, generally, we will not retain your information for longer than is necessary or for the periods required by applicable law.
9 Your Rights
9.1 As a user/data subject, you have certain rights, including the right:
(a) to access your Personal Information stored and processed by us. This may be done by emailing us at the address referred to in clause 5 below;
(b) to correct/rectify Personal Information that we hold on your behalf, in instances where such Personal Information is incorrect or incomplete;
(c) to erase Personal Information (also known as ‘the right to be forgotten’). In simple terms, this enables you to request the deletion or removal of your information where there is no compelling reason for us keep using it. This is not a general right to erase; there are exceptions. For example, we have the right to continue using your personal data if such use is necessary for compliance with our legal obligations or for the establishment, exercise or defence of legal claims;
(d) to restrict/suspend processing of Personal Information to only that which is strictly necessary for us to perform our services to you. Please note that this right is limited in certain situations: when we are processing your personal information that we collected from you with your consent you can only request restriction on the basis of: (a) inaccuracy of data; (b) where our processing is unlawful and you don’t want your personal information erased; (c) you need it for a legal claim; or (d) if we no longer need to use the data for the purposes for which we hold it. When processing is restricted, we can still store your information, but may not use it further;
(e) to complain- if we breach any of the terms of this Privacy Statement, to complain to the requisite data protection authority in South Africa;
(f) to withdraw your consent at any time, if the processing of the Personal Information is based on consent;
(g) to object to processing of Personal Information if such processing is based on legitimate interests; and
(h) to object to the processing of Personal Information for direct marketing purposes.
9.2 The exercise of these rights is free of charge.
10 Complaints
10.1 If, you wish to raise a complaint regarding the processing of your Personal Information then please first reach out to the Company’s designated Information Officer at
10.2 However, if you are still unsatisfied with how we have handled your Personal Information, you can lodge your complaint with the Information Regulator or authority in the applicable and relevant country. We are happy to share further information or guidance in this regard should you need it.
11 Indemnity
In agreeing to the provisions of this Statement, you hereby unconditionally agree to indemnify us against any liability that may result from your use of this website and the processing of your Personal Information, including any loss, damage or injury arising from any inaccurate or incomplete Personal Information provided to us by the you and/or any third party and/or any unintentional disclosure of your Personal Information to any unauthorised persons.
12 Log Files
When you visit our website, even if you do not create an account, we may collect information, such as your IP address, the name of your ISP (Internet Service Provider), your browser, the website from which you visit us, the pages on our website that you visit and in what sequence, the date and length of your visit, and other information concerning your computer's operating system, language settings, and broad demographic information. This information is aggregated and anonymous data and does not identify you specifically. However, you acknowledge that this data may be able to be used to identify you if it is aggregated with other Personal Information that you supply to us. This information is not shared with third parties and is used only within the company on a need-to-know basis. Any individually identifiable information related to this data will never be used in any way different to that stated above, without your explicit permission.
13 Cookies
13.1 We use cookies. A cookie is a small piece of information stored on your computer or smart phone by the web browser. The two types of cookies used on the website are described below:
13.1.1 "Session cookies": These are used to maintain a so-called 'session state' and only last for the duration of your use of the website. A session cookie expires when you close your browser, or if you have not visited the server for a certain period of time. Session cookies are required for the Platform to function optimally but are not used in any way to identify you personally.
13.1.2 "Permanent and functional cookies": These cookies permanently store a unique code on your computer or smart device in order to be able to identify you as an individual user and/or are used to enhance the performance and functionality of our Website but are non-essential to their use. However, without these cookies, certain services and functionality may become unavailable.
13.1.3 You can view and edit permanent cookies by looking in the cookies’ directory of your browser installation. These permanent cookies are not required for the website to work but may enhance your browsing experience.
14 Third Party Links on the Website
The services available through the website, may contain links to other third-party websites. We are not responsible for the content or privacy policies of these third-party websites.
15 Application Of The Electronic Communications And Transactions Act 25 Of 2002 ("Ect Act")
15.1 Data Messages (as defined in the ECT Act) will be deemed to have been received by us if and when we respond to the Data Messages.
15.2 Data Messages sent by us to a user will be deemed to have been received by such user in terms of the provisions specified in section 23(b) of the ECT Act.
15.3 Users acknowledge that electronic signatures, encryption and/or authentication are not required for valid electronic communications between us and users.
15.4 Information to be provided in terms of section 43(1) of the ECT Act:
15.4.1 Users warrant that Data Messages sent to us from any electronic device, used by such user, from time to time or owned by such user, were sent and or authorised by such user, personally.
15.4.2 This Website is owned and operated by eprints School Photography.
15.4.3 Address for service of legal documents: 3, Cowie Rd, Forest Town, 2193, Johannesburg.
15.4.4 Contact Number: 27116464387.
15.4.5 Website - located at
15.4.6 Email address:
16 Amendment of this Statement
16.1 We may amend this Statement from time to time.
16.2 Any such amendment will come into effect and become part of any agreement you have with the Company when notice is given to you of the change by publication on our website. It is your responsibility to check the website often

PAIA Manual -


Prepared in terms of section 51 of the Promotion of Access to Information Act 2 of 2000 (as amended)

DATE OF REVISION: 01/10/2021



1.1 “CEO” Chief Executive Officer

1.2 “DIO” Deputy Information Officer;

1.3 “IO“ Information Officer;

1.4 “Minister” Minister of Justice and Correctional Services;

1.5 “PAIA” Promotion of Access to Information Act No. 2 of 2000( as

1.6 “POPIA” Protection of Personal Information Act No.4 of 2013;

1.7 “Regulator” Information Regulator; and

1.8 “Republic” Republic of South Africa


This PAIA Manual is useful for the public to-

2.1 check the categories of records held by a body which are available without a person having to submit a formal PAIA request;

2.2 have a sufficient understanding of how to make a request for access to a record of the body, by providing a description of the subjects on which the body holds records and the categories of records held on each subject;

2.3 know the description of the records of the body which are available in accordance with any other legislation;

2.4 access all the relevant contact details of the Information Officer and Deputy Information Officer who will assist the public with the records they intend to access;

2.5 know the description of the guide on how to use PAIA, as updated by the Regulator and how to obtain access to it;

2.6 know if the body will process personal information, the purpose of processing of personal information and the description of the categories of data subjects and of the information or categories of information relating thereto;

2.7 know the description of the categories of data subjects and of the information or categories of information relating thereto;

2.8 know the recipients or categories of recipients to whom the personal information may be supplied;

2.9 know if the body has planned to transfer or process personal information outside the Republic of South Africa and the recipients or categories of recipients to whom the personal information may be supplied; and

2.10 know whether the body has appropriate security measures to ensure the confidentiality, integrity and availability of the personal information which is to be processed.


3.1. Chief Information Officer

Name: Gareth Gilmour
Tel: +2711 6464387

3.2. Deputy Information Officer (NB: if more than one Deputy Information Officer is designated, please provide the details of every Deputy Information Officer of the body designated in terms of section 17 (1) of PAIA.

Name: Shannon Hood
Tel: +2711 6464387

3.3 Access to information general contacts


3.4 National or Head Office

Postal Address:
P.O.Box 84158 Greenside 2193

Physical Address: 3A Cowie Rd Forest Town

Telephone: +2711 6464387


Website: &


4.1. The Regulator has, in terms of section 10(1) of PAIA, as amended, updated and made available the revised Guide on how to use PAIA (“Guide”), in an easily comprehensible form and manner, as may reasonably be required by a person who wishes to exercise any right contemplated in PAIA and POPIA.

4.2. The Guide is available in each of the official languages and in braille.
4.3. The aforesaid Guide contains the description of-

4.3.1. the objects of PAIA and POPIA;

4.3.2. the postal and street address, phone and fax number and, if available, electronic mail address of- the Information Officer of every public body, and every Deputy Information Officer of every public and private body designated in terms of section 17(1) of PAIA and section 56 of POPIA ;

4.3.3. the manner and form of a request for- access to a record of a public body contemplated in section 11 ; and access to a record of a private body contemplated in section 50 ;

4.3.4. the assistance available from the IO of a public body in terms of PAIA and POPIA;

4.3.5. the assistance available from the Regulator in terms of PAIA and POPIA;

4.3.6. all remedies in law available regarding an act or failure to act in respect of a right or duty conferred or imposed by PAIA and POPIA, including the manner of lodging- an internal appeal; a complaint to the Regulator; and an application with a court against a decision by the information officer of a public body, a decision on internal appeal or a decision by the Regulator or a decision of the head of a private body;

4.3.7. the provisions of sections 14 and 51 requiring a public body and private body, respectively, to compile a manual, and how to obtain access to a manual;

4.3.8. the provisions of sections 15 and 52 providing for the voluntary disclosure of categories of records by a public body and private body, respectively;

4.3.9. the notices issued in terms of sections 22 and 54 regarding fees to be paid in relation to requests for access; and

4.3.10. the regulations made in terms of section 92 .
4.4. Members of the public can inspect or make copies of the Guide from the offices of the public and private bodies, including the office of the Regulator, during normal working hours.

4.5. The Guide can also be obtained-

4.5.1. upon request to the Information Officer;

4.5.2. from the website of the Regulator (

4.6 A copy of the Guide is also available in the following two official languages, for public inspection during normal office hours-

4.6.1 English and Afrikaans


NB: Please specify the categories of records held by the body which are available without a person having to request access by completing Form C, types of the records and how the records can be accessed. These are mostly records that maybe available on the website and a person may download or request telephonically or by sending an email or a letter.

Below is an example of the table that can be used.

Category of records
Types of the Record
Available on Website
Available upon request
Company Details X X
Privacy Document X X
Terms of Service X X

NB: Please specify all the records which are created and available in accordance with any of the South African legislation. Below is an example of the table that can be used in describing the records and applicable legislation.

Category of Records
Applicable Legislation

Memorandum of incorporation Companies Act 71 of 2008

PAIA Manual Promotion of Access to Information Act 2 of 2000
Privacy and Terms of Service Documentation


The below records are only held as received by the individual clients

Subjects on which the body holds records
Categories of records
Contact information Name, email, phone number, street address
Order History - Order history placed by client


8.1 Purpose of Processing Personal Information

We hold personal information for the purpose of fulfilling online orders and securing clients image/photograph privacy

8.2 Description of the categories of Data Subjects and of the information or categories of information relating thereto

Categories of Data Subjects
Personal Information that may be processed
Customers / Clients name, address, email address, phone number
Employees address, qualifications, gender and race

8.3 The recipients or categories of recipients to whom the personal information may be supplied

Not applicable, we do not supply personal information to any third party, but will consider disclosure with verified due process to the below authority.

Category of personal information
Recipients or Categories of Recipients to whom the personal information may be supplied

Identity number and names, for criminal checks South African Police Services

8.4 Planned transborder flows of personal information

Not applicable

8.5 General description of Information Security Measures to be implemented by the responsible party to ensure the confidentiality, integrity and availability of the information

Information is held in an encrypted format


9.1 A copy of the Manual is available-

9.1.1 on if any;

9.1.2 head office of the eprints for public inspection during normal business hours;

9.1.3 to any person upon request and upon the payment of a reasonable prescribed fee; and

9.1.4 to the Information Regulator upon request.

9.2 A fee for a copy of the Manual, as contemplated in annexure B of the Regulations, shall be payable per each A4-size photocopy made.


The head of eprints will on a regular basis update this manual.

Issued by

Gareth Gilmour