Paint Lab Privacy Policy
Last updated: 1 September 2026
Paint Lab respects your privacy and is committed to protecting your personal data.
This Privacy Policy explains how personal information is collected, used, stored and protected when you visit the Paint Lab website, participate in Paint Lab surveys or prize draws, subscribe to updates, contact us or otherwise interact with Paint Lab.
Paint Lab is developed and operated by The Chroma Institute.
This policy should be read together with the Chroma Institute Privacy Policy.
1. Who We Are
Paint Lab is a product and service developed and operated by:
The Chroma Institute
CRO No. 791282
6 Acorn Lane
Dundrum
D16 DH93
Ireland
For the purposes of the General Data Protection Regulation (GDPR) and the Data Protection Act 2018, The Chroma Institute is the data controller responsible for personal data processed for Paint Lab's purposes.
Questions concerning this Privacy Policy or the processing of personal data may be submitted using the contact details provided on the Chroma Institute website.
2. Information We May Collect
The personal information we collect depends on how you interact with Paint Lab.
Information you provide directly
This may include:
We ask that you do not provide personal information that is unnecessary for the relevant purpose.
Survey information
Paint Lab conducts research to understand miniature painters, painting practices, paint use, purchasing behaviour, preferences and potential demand for Paint Lab features and services.
Survey responses may include demographic information and information about your miniature-painting activities, preferences, paints, tools, purchasing practices and opinions.
We will explain the purpose of a survey and relevant privacy information when information is collected.
Survey results may be analysed and published in aggregated or anonymised form.
Prize Draw information
Where you enter a Paint Lab prize draw, we may collect information including:
Prize Draw information will not automatically be used to subscribe you to marketing communications.
3. How We Use Personal Information
Depending on how you interact with Paint Lab, we may process personal information to:
We do not sell personal information.
We will not use identifiable personal information for a purpose incompatible with the purpose for which it was collected unless an appropriate lawful basis exists.
4. Our Legal Bases for Processing
The GDPR requires us to have a lawful basis for processing personal data.
Depending on the processing activity, we may rely on:
Legitimate interests
We may process personal information where reasonably necessary for our legitimate interests in researching, developing, operating, securing and improving Paint Lab, understanding its potential market and users, administering our business and preventing fraud or abuse, provided those interests are not overridden by the rights and interests of the individual.
Contract and steps connected with a contract
Where you choose to enter a Prize Draw or otherwise enter into an arrangement with us, certain processing may be necessary to administer that arrangement and fulfil the commitments made to you.
Consent
We rely on consent where this is appropriate, including where you expressly choose to subscribe to Paint Lab electronic marketing communications.
Where processing is based on consent, you may withdraw that consent at any time.
Legal obligation
We may process personal information where necessary to comply with an applicable legal obligation.
5. Paint Lab International Miniature Painting Survey
The Paint Lab International Miniature Painting Survey is intended to help The Chroma Institute understand the miniature-painting community and inform the development and commercial planning of Paint Lab.
Participation is voluntary.
The survey is available through Google Forms.
Survey responses may be analysed by The Chroma Institute and used to produce statistics, reports, presentations and other research or business-development materials.
Where results are published or shared externally, including with paint manufacturers or other industry organisations, we intend to present results in aggregated or anonymised form so that individual participants are not identified.
We will not sell individual survey responses or participants' personal information.
Participation in the survey does not require participation in the associated Prize Draw.
6. Paint Lab International Miniature Painting Prize Draw
The Chroma Institute may operate a Prize Draw in connection with the Paint Lab International Miniature Painting Survey.
Participation is voluntary and free.
Information submitted through the Prize Draw entry form may be used to:
Survey responses do not affect the probability of winning.
The rules governing the Prize Draw are contained in the Paint Lab International Miniature Painting Prize Draw Terms and Conditions.
7. Marketing and Paint Lab Updates
We may offer you the opportunity to receive Paint Lab news, launch information, feature announcements and other updates by email.
Where affirmative consent is required for electronic marketing, we will ask for it separately.
Consent to marketing is not required to complete a survey or enter a Prize Draw.
If you subscribe, you may withdraw your consent at any time by using the unsubscribe mechanism contained in our emails or by contacting The Chroma Institute.
Withdrawing consent will not affect processing carried out lawfully before consent was withdrawn and will not affect eligibility for a Prize Draw.
8. Google Forms
The Paint Lab International Miniature Painting Survey and associated Prize Draw currently use Google Forms.
Information submitted through these forms is therefore processed using services provided by Google.
Google may process technical information associated with the use of its services in accordance with its applicable privacy terms and data-processing arrangements.
The Chroma Institute controls the purposes for which survey and Prize Draw information collected on its behalf is subsequently used.
Participants should also review Google's applicable privacy information when using Google Forms.
9. Website Hosting and Service Providers
Paint Lab may use third-party providers to operate its website, forms, communications and associated services.
These may include:
These providers may process information where necessary to provide their services.
Some providers may process or store information outside the European Economic Area. Where personal data is transferred internationally, applicable transfer mechanisms and safeguards will be used as required by data-protection law.
10. Cookies and Similar Technologies
The Paint Lab website and services used to provide it may use cookies and similar technologies.
Some technologies may be necessary for security, operation and functionality. Others may be used for analytics or to understand website usage.
Where consent is legally required for a cookie or similar technology, it will be used in accordance with applicable consent requirements.
Users may also control cookies through their browser settings, although disabling necessary technologies may affect website functionality.
11. Sharing Personal Information
The Chroma Institute does not sell or rent personal information collected through Paint Lab.
Information may be processed by service providers where necessary to provide the services described in this Privacy Policy.
We may also disclose information:
Survey findings may be shared with paint manufacturers, industry participants or the public in aggregated or anonymised form.
12. International Data Transfers
Some service providers used by Paint Lab may process or store information outside the European Economic Area.
Where personal data is transferred internationally, The Chroma Institute relies on appropriate transfer mechanisms and safeguards as required by applicable data-protection law.
13. Data Retention
We retain identifiable personal information only for as long as reasonably necessary for the purpose for which it was collected and for applicable legal, regulatory or record-keeping requirements.
Survey data
Survey responses required for research, analysis and business planning may be retained for the duration of the Paint Lab research and development programme and for an appropriate period afterwards.
Where survey information has been effectively anonymised so that an individual can no longer be identified, it is no longer personal data and may be retained for research, statistical and business-analysis purposes.
Prize Draw data
Personal information collected solely to administer the Prize Draw will be retained only for as long as reasonably necessary to administer and conclude the Prize Draw, distribute the prize, resolve any queries or disputes and maintain appropriate legal or administrative records.
Information that is no longer necessary will be securely deleted or anonymised as appropriate.
Marketing subscriptions
Where you have separately subscribed to Paint Lab marketing communications, the information necessary to maintain that subscription may be retained until you unsubscribe or the information is otherwise no longer required.
We may retain limited information necessary to record and respect an unsubscribe request.
14. Security
The Chroma Institute takes reasonable technical and organisational measures to protect personal information against unauthorised access, alteration, disclosure, loss or destruction.
We also use third-party services and security technologies where appropriate.
No method of electronic transmission or storage can be guaranteed to be completely secure.
15. Your Data-Protection Rights
Under the GDPR, depending on the circumstances, you may have the right to:
These rights are subject to the conditions and exceptions provided by applicable data-protection law.
Where survey information has already been effectively anonymised and can no longer be connected to you, it may no longer be possible to identify or remove an individual response.
To exercise your rights, please contact The Chroma Institute using the contact details provided on its website.
16. Complaints
If you have concerns about the way personal information is processed through Paint Lab, please contact The Chroma Institute so that we can investigate your concern.
You also have the right to lodge a complaint with the Irish Data Protection Commission.
17. Children
The current Paint Lab Prize Draw is restricted to persons aged 18 years or over.
Where Paint Lab undertakes activities directed specifically towards children in the future, we will review the relevant data-protection requirements and provide appropriate information and safeguards.
18. Third-Party Websites
The Paint Lab website may contain links to third-party websites and services.
The Chroma Institute is not responsible for the privacy practices of independently operated third-party websites. We recommend reviewing their privacy information before providing personal information.
19. Relationship with the Chroma Institute Privacy Policy
Paint Lab is operated by The Chroma Institute.
This Paint Lab Privacy Policy provides information specifically concerning processing associated with Paint Lab.
The Chroma Institute Privacy Policy provides additional information concerning The Chroma Institute's wider processing activities.
Where appropriate, the two policies should be read together.
20. Changes to this Privacy Policy
We may update this Privacy Policy to reflect changes to Paint Lab, the services we use, our processing activities or applicable legal requirements.
Any revised version will be published on the Paint Lab website and the date at the top of this policy will be updated.
21. Contact
For privacy questions, data-subject requests or other enquiries concerning personal information processed through Paint Lab, please contact:
The Chroma Institute
CRO No. 791282
6 Acorn Lane
Dundrum
D16 DH93
Ireland
Please use the contact details provided on the Chroma Institute website.