Creatrify is a place to livestream events and classes. Event organizers can sell tickets, products, and classes and receive tips during the broadcast, all in one platform. This policy explains how Creatrify Inc., (“Creatrify”, “we”, or “us”) treats your personal information. By using or accessing the services, platforms and applications provided by Creatrify (the “Creatrify Services”), which includes accessing our website, creatrify.com (our “Website”), you acknowledge
your acceptance of the policies and practices outlined in this Privacy. Your use of the Creatrify Services is your consent to Creatrify to collect, use, and share your information in the manner below. In addition, your use of Creatrify
Services is subject to our Terms of Use which are also available on our Website. Any terms we use in this Privacy Policy without defining them have the definitions give to them in our Terms of Use.
Where we need to collect Personal Data, defined below, by law, or under the Terms of Use or another agreement we have with you, and you fail to provide that data when requested, we may not be able to perform the agreement we have or are trying to enter into with you, for example allowing you to utilize the Creatrify Services.
You may contact us at anytime with questions and comments about our collection and use of Personal Data and your rights and choices regarding Personal Data by email or post at:
Email Address: disputeresolution@creatrify.comWhere this Privacy Policy directs or allows you to email us, you may do so at the email address above and your inquiry will be forwarded to the relevant Data Protection Officer, Data Privacy Officer, or other appropriate personnel based on the nature of your inquiry and your location.
This Privacy Policy covers how we treat Personal Data that we gather when you access or use the Creatrify Services. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules, or regulations. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage.
We collect Personal Data about you from you when
(i) you provide such information directly to us including when you register for an account, send us an email, or post information or other content through the Creatrify Services, and
(ii)when Personal Data about you is automatically collected in connection with your use of the Creatrify Services. When you purchase products or services from or through the Creatrify Services we require billing and payment information
and certain additional Personal Data including A. Personal Identifiers as defined below.
We also collect Personal Data about you from third parties (“Third Parties”). Third Parties that share your Personal Data with us may include:
| Category of Personal Data | Personal Data Collected | Source of this Personal Data? | |
|---|---|---|---|
| A. | Personal identifiers | Real name, username or similar identifier, phone numbers, username or similar identifier, IP Address and Device ID when connected to the Internet | You/Third Parties |
| B. | Contact information | Home and/or business address, email address, and telephone numbers | You/Third Parties |
| C. | Profile and usage information | Username and password, order and browsing history, your interests, feedback, survey responses, information about how you use the Creatrify Services, and your preferences including your communications and marketing preferences | You/Third Parties |
| D. | Customer records identified by state law (including the California Customer Records statute (Cal. Civ. Code § 1798.80(e))) | Organizers to get paid out: social security, bank account, routing number, credit card number, driver license People who pay for tickets: bank account, credit card, debit card, driver license | You/Third Parties |
| E. | Transaction data | Payment details, products and services you have accesses or used through the Creatrify Services – we do not store credit card details, payments are processed by third-parties as indicated in the Terms of Use | You/Third Parties |
| F. | Protected classification characteristics under state or federal law | Age, race, national origin, citizenship, sex, marital status | You/Third Parties |
| G. | Internet or other similar network activity information | Browsing, search, interaction history within Creatrify products, IP Address IP and Device ID when connected to the Internet, URLS from websites you visit before and after using the Creatrify Services, software and hardware attributes, IDFA and/or Advertising IDs, browser type and version | You |
| H. | Geolocation data | Physical location | You/Third Parties |
| I. | Sensory data | Audio and visual, including livestreaming feeds which you appear in as you contribute or interact with the Creatrify Services | You/Third Parties |
| J. | Professional or employment-related information | Current and past job history if users choose to provide | You/Third Parties |
| K. | Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) | Education background if users choose to provide | You/Third Parties |
| L. | Age or date of birth | Age, date of birth | You/Third Parties |
| M. | Special categories of data under the EU General Data Protection Regulation | Race, national origin | You/Third Parties |
We track the data you see when using the Creatrify Services and how you interact with our Website and platform by automatically collecting certain information such as “Internet or other similar network activity information”. To obtain such information, we may use web logs or applications that recognize your device and gather information about its online activity. We treat this information as Personal Data if we combine it with or link it to any of your information that otherwise is categorized as Personal Data. Otherwise, it is used in aggregate form only.
The Creatrify Services and emails we send you may use cookies and similar technologies such as pixel tags, web beacons, clear GIFs, and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser and tell us how and when you visit and use the Creatrify Services, to analyze trends, learn about our user base and operate and improve the Creatrify Services. A web beacon is an electronic file that usually consists of a single-pixel image. It can be embedded in a web page or in an email to transmit information. For example, it allows an email sender to determine whether a user has opened a particular email. Generally, Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone, or similar device when you use that device to visit the Creatrify Services. We may also supplement the information we collect from you with information received from third-parties, including third-parties that have placed their own Cookies on your device(s). Creatrify uses the following types of cookies:
You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your computer. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some of the Creatrify Services and functionalities may not work. Because of our use of Cookies, the Creatrify Services may not support “Do Not Track” requests sent from your browser, which means that we may collect information about your online activity both while you are using the Creatrify Services and after you leave our Website.
How you manage your cookie settings, including deletion, may differ per browser. Please use the “Help” function in your browser and look in the “preferences” or “options” section of your browser’s menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit https://www.allaboutcookies.org/. If you want to disable cookies from specific parties, you can do so via www.youronlinechoices.com
Creatrify keeps Personal Data contained in your cookies and obtained through the other tracking technologies confidential. We do not set any cookies outside of our Website domain. Creatrify also may partner with certain third parties to collect, analyze, and use some of the Personal Data described in this section. For example, we may allow third parties to set cookies or use web beacons on the Creatrify Services or in email communications from Creatrify or Organizers. This information may be used for a variety of purposes, including analytics and online behavioral advertising.
You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways
You can also delete all Cookies that are already on your computer. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some of the Creatrify Services and functionalities may not work.
When on ‘Incognito’ mode on Google Chrome, you have to manually adjust some preferences to allow Creatrify services and functionalities to work. Google Chrome “Incognito” mode blocks 3rd party cookies by default.
Click the ‘eye icon’ to the right of your Chrome browser’s address bar and wait for a pop-up that enables you to allow 3rd party cookies. The browser should then refresh automatically and let you proceed with your session.
Because of our use of Cookies, the Creatrify Services may not support “Do Not Track” requests sent from your browser, which means that we may collect information about your online activity while you are using the Creatrify Services and after you leave our Website.
Creatrify may also collect and store information (including Personal Data) locally on your device using mechanisms such as browser web storage (including HTML 5) and application data caches.
We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without providing you notice.
As noted in the list above, we may communicate with you if you’ve provided us the means to do so. For example, if you’ve given us your email address, we may send you promotional email offers or email you about your use of the Creatrify Services. Also, we may receive a confirmation when you open an email from us, which helps us improve the Creatrify Services. If you do not want to receive communications from us, please indicate your preference by emailing us.
We disclose your Personal Data only for business purposes. We may disclose your Personal Data to service providers and other parties for the following business purposes:
We may disclose your Personal Data to the following categories of service providers and other parties:
We may also disclose your Personal Data to parties who acquire your Personal Data through an acquisition or other change of control of Creatrify. Personal Data may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business, in whole or in part.
Over the past twelve months, we have disclosed the following categories of your Personal Data to service providers or other parties for the business purposes listed above, or may do so in the future:
Creatrify has or may sell your Personal Data.
We may also disclose your Personal Data if required to do so by law or when we believe in good faith that we are lawfully authorized or required to do so or that doing so is reasonably necessary or appropriate to comply with the law or legal processes or respond to lawful requests or legal authorities, including responding to lawful subpoenas, warrants or court orders. We may also disclose your Personal Data when we believe that disclosure is necessary to protect our rights or the rights, property or safety of others, to enforce or apply this Privacy Policy, our Terms of Use or our other policies or agreements.
We may also share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your Personal Data but is not considered Personal Data under applicable law as it will not directly or indirectly reveal your identity or Personal Data. We do not link this aggregate user data with Personal Data. Our Privacy Policy does not restrict or limit our collection and use of aggregated data.
As indicated in the Terms of Use, we do not knowingly collect or solicit Personal Data from children under 16. If you are a child under 16, please do not attempt to register for or otherwise use the Creatrify Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 16, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided us Personal Data, please contact us.
We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the Internet or storing data is completely secure. We cannot guarantee the complete security of any data you share with us, and except as expressly required by law, we are not responsible for the theft, destruction, loss or inadvertent disclosure of your information or content.
We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you with the Creatrify Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.
We may serve advertisements, and also allow third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors and research firms, to serve advertisements through the Creatrify Services. These advertisements may be targeted to users who fit certain general profile categories or display certain preferences or behaviors (“Interest-Based Ads”). Information for Internet-Based Ads (including Personal Data) may be provided to us by you, or derived from the usage patterns of particular users on the Creatrify Services and/or services of third parties. Such information may be gathered through tracking users’ activities across time and unaffiliated properties, including when you leave the Creatrify Services. To accomplish this, we or our service providers may deliver Cookies, including a file (known as a “web beacon”) from an ad network to you through the Creatrify Services. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Web beacons allow ad networks to view, edit or set their own Cookies on your browser, just as if you had requested a web page from their site.
By signing up for the Creatrify Services and providing us with your wireless number, you confirm that you want Creatrify to send you information regarding your account or transactions with us that we think may be of interest to you, which may include Creatrify using automated dialing technology to text you at the wireless number you provided, you agree to receive communications from Creatrify, and represent and warrant that each person you register for the Creatrify Services or for whom you provide a wireless phone number has consented to receive these communications. You agree to indemnify and hold harmless Creatrify, its affiliates, vendors, contractors, and personnel from and against any and all claims, liabilities, damages (actual and consequential), losses and expenses (including attorneys’ fees) arising from or in any way related to your breach of this representation and warranty.
The Creatrify Services and content provided therein may contain links to other sites and applications. Any Personal Data you provide on the linked pages is provided directly to that third-party and is subject to that third- party’s privacy policy. Our Privacy Policy does not apply to such linked sites, and we are not responsible for the content or privacy and security practices and policies of these sites or any other sites that are linked to from the Creatrify Services
This section explains how to exercise the rights provided by applicable laws and under this Privacy Policy. This procedure applies to the rights afforded in the following jurisdictions which are more fully explained and defined below:
Nevada – right to opt-out of Personal Data sales;
California – rights to access, deletion, and to opt-out of Personal Data sales;
European Union – right to access, rectification, erasure, withdrawal of consent, portability, objection
and restriction of processing, each defined below;
Philippines – withdrawing consent; and India – right to access, withdrawing consent.
To exercise these rights you must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data, and (2) describes your request in sufficient detail to allow us to understand, evaluate, and respond to it including the right you are exercising. The request may be submitted by email or post at the number and addresses set forth above under “Contact Information”. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify you and complete your request. You do not need an account to submit a Valid Request.
We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive, or manifestly unfounded. If we determine that your Valid Request warrants a fee, and charging a fee is permitted by applicable law, we will notify you of the fee and explain that decision before completing your request.
Creatrify may need to change this Privacy Policy from time to time and will alert you to changes by placing a notice on our Website, by sending you an email, and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Creatrify Services, and you are still responsible for reading and understanding them. If you use the Creatrify Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.
If you are a Nevada consumer, you have the rights under the Nevada Revised Statutes Chapter 603A (“NRS 603A”) outlined in this section in addition to those set forth above, where there are conflicts, the portion that is more protective of your Personal Data shall control.
The definition of “Personal Data” used throughout this Privacy Policy includes “personal information” as that term is defined by NRS 603A.040. NRS 603A.040 defines “personal information” to mean a natural person’s first name or first initial and last name in combination with any one or more of the following data elements, when the name and data elements are not encrypted:
The “Categories of Personal Data We Collect” section above details the Personal Data that we collect from you.
The “How We Share Your Personal Data” section above details the categories of third parties with whom your Personal Data is shared.
The “Sources of Personal Data” and “Information Collected Automatically” sections above detail how we and third parties collect your information through the Creatrify Services and different websites including by the use of Cookies.
Creatrify has or will sell the Personal Data of Nevada consumers.
The “Changes to this Privacy Policy” section above describes the process by which we will let you know of any changes this Privacy Policy.
The Effective Date of this Privacy Policy is set forth at beginning of the Privacy Policy, immediately below the title.
If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data.
If you are a resident of Nevada, you have the right to review and request changes to your Personal Data.
To exercise your right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data, please submit a Valid Request following the procedure set forth above in the section entitled “Procedure to Exercise Your Privacy Rights.”
To exercise your right to review your Personal Data, please submit a Valid Request following the procedure set forth above in the section entitled “Procedure to Exercise Your Privacy Rights.” In response to a Valid Request we will provide you with the specific pieces of Personal Data that we have collected about you.
To exercise your right to request changes to your Personal Data, please submit a Valid Request following the procedure set forth above in the section entitled “Procedure to Exercise Your Privacy Rights.” Such Valid Request must include the specific items of Personal Data you are requesting us to change, that is the information we have collected and the change to it you are requesting.
We will work to respond to your Valid Request opt-out, review, or change within 60 days of receipt. If we are not able to respond to your request within 60 days, we will let you know that we may need additional time to respond, up to 30 additional days.
This section applies only to California residents. If you are a California resident, you have the rights under the CCPA outlined in this section in addition to those set forth above, where there are conflicts, the portion that is more protective of your Personal Data shall control. Please contact us by post or email if you have any questions about this section or whether any of the following applies to you. Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes, any such request shall be made by sending a Valid Request following the procedure set forth below under “Exercising Your Rights.”
You have the right, but no more than twice in a twelve-month period, to request certain information about our collection and use of your Personal Data over the past 12 months. We will provide you with the following information:
You have the right to request that we delete the Personal Data that we have collected from you. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Creatrify Services or complete a transaction or other action you have requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request.
You have the right to opt-out of the sale of your Personal Data. To do so send a Valid Request following the procedure set forth below under “Exercising Your Rights.” Once you have submitted an opt-out request, we will not ask you to reauthorize the sale of your Personal Data for at least 12 months. However, you may change your mind and opt back into Personal Data sales at any time by contacting us. Please note we do not permit use of our Website or the Creatrify Services by persons under 16 years of age.
To exercise the rights described above, please submit a Valid Request following the procedure set forth above in the section entitled “Procedure to Exercise Your Privacy Rights.”
We will work to respond to your Valid Request within 45 days of receipt. If we are not able to respond to your request within 45 days, we will let you know that we may need additional time to respond, up to 90 additional days.
We will not discriminate against you for exercising your rights under the CCPA. We will not deny you the Creatrify Services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA. However, we may offer different tiers of the Creatrify Services as allowed by applicable data privacy laws (including the CCPA) with varying prices, rates, or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.
If you are a resident of the European Union (“EU”), United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below. Creatrify’s services are not currently targeted to or intended for use by persons subject to protection under the GDPR, nonetheless, Creatrify will utilize reasonable efforts to comply with the requirements of the GDPR.
For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. Creatrify will be the controller of your Personal Data processed in connection with the Creatrify Services. If there are any conflicts between this this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us by email or post at the addresses set forth above under “Contact Information”.
The “Categories of Personal Data We Collect” section above details the Personal Data that we collect from you.
The “How We Use Your Personal Data” section above explains how we use your Personal Data. We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include (1) consent, (2) contractual necessity, (3) our “legitimate interests” or the legitimate interest of others, and (4) other processing grounds based on legal necessity, as further described below.
(1) Consent. In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.
(2) Contractual Necessity. We process Personal Data as a matter of “contractual necessity”, meaning that we need to process the data to perform under our Terms of Use with you, which enables us to provide you with the Creatrify Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Creatrify Services that require such data. We process the following categories of Personal Data as a matter of “contractual necessity”:
(3) Legitimate Interest. We process each of the categories of Personal Data in the chart appearing above in the section titled “Categories of Personal Data We Collect” when we believe it furthers the legitimate interest of us or third parties. Examples of these legitimate interests include:
(4) Other Processing Grounds. From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.
The “How We Share Your Personal Data” section above details how we share your Personal Data with third parties.
You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, contact us by email or post at the addresses set forth above under “Contact Information.” Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need to you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request. Your rights include the following.
The Creatrify Services are hosted and operated in the United States (“U.S.”) through Creatrify and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Creatrify
Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Creatrify in the U.S. and will be hosted on U.S. servers, and you authorize Creatrify
to transfer, store and process your information to and in the U.S., and possibly other countries. You hereby consent to the transfer of your data to the U.S. pursuant to:
(i) a data processing agreement incorporating standard
data protection clauses promulgated by the European Commission,
(ii) binding corporate rules for data protection that align with the GDPR’s requirements, or
(iii) adherence to an industry- or technology-specific approved code
of conduct blessed by the European Commission.
If you are a resident of the Republic of the Philippines, you have the rights outlined in this section. If there are any conflicts between this section, the Philippines Privacy Statement, and any other provision of this Privacy Policy and you are a Philippines resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us. In addition to this Philippines Privacy Statement and the general terms of this Privacy Policy set forth above, your use of the Creatrify Services and the relationship between you, your data and Creatrify is set forth in the Terms of Use available on our Website.
The “Categories of Personal Data We Collect” section above details the Personal Data that we collect from you when you utilize the Creatrify Services or correspond with us. Website usage information is collected using Cookies as explained above.
We will use the information you and third-parties provide us for the purposes set forth in the sections above titled “How We Use Your Personal Data” and “How We Share Your Personal Data”.
Personal data will be kept confidential but, subject to the provisions of any applicable law, we may share your personal data with the persons set forth above in the section title “How We Share Your Personal Data”. This may include parent and affiliated companies located within and outside the Philippines. This may also include any government departments or other appropriate governmental or regulatory authorities, or if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms of Use and other agreements, or to protect our rights, property, or safety and those of our customers or others.
Creatrify will make all reasonable arrangements to ensure that Personal Data in our possession or under our control are protected against unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks as set forth above in the section titled “Data Security and Retention”.
By utilizing the Creatrify Services and providing us with Personal Data, you consent to Creatrify’s use of your personal information for promotional or direct marketing activities by way of email, SMS and post. If at any time you are unsure of how to access or correct your information please contact us. If you do not want your personal information to be utilized by us for promotional or direct marketing activities, please submit a Valid Request following the procedure set forth above in the section entitled “Procedure to Exercise Your Privacy Rights.”
You may ask us to stop collecting, using and disclosing your personal data at any time by submitting a Valid Request following the procedure set forth above in the section entitled “Procedure to Exercise Your Privacy Rights” which shall be processed by our Data Protection Officer. However, if you do not provide this personal data or ask us to stop collecting, using or disclosing it, we may not be able to maintain your registration with the website, fulfil your orders, process your payments, provide products and services to you, respond to your correspondence, or comply with applicable laws.
You have a right to request a copy of the information that we hold about you and information about the ways in which we have used and disclosed that information. If you would like this information, submit a Valid Request following the procedure set forth above in the section entitled “Procedure to Exercise Your Privacy Rights.” We may ask you to pay a nominal charge for this to cover our reasonable costs of compliance. We want to make sure that your personal information is accurate and up to date. You may ask us to correct information you think is inaccurate by submitting a Valid Request.
Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. This information enables us to distinguish you from other users of the website, which helps us to provide you with a good experience when you browse the website. This information is also used to track visitor use of the website and to compile statistical reports on website activity, allowing us to improve the website.
Most browsers are initially set to accept cookies. If you prefer, you can set your browser not to accept cookies, and remove cookies from your browser, or inform you when they are set. However, in a few cases some of our website features may not function as a result.
Our Website contains links to other websites. This privacy policy only applies to this website, so when you link to other websites you should read their own privacy policies.
We reserve the right to amend this Privacy Policy at any time with or without notice and will place any updates on this webpage.
If you have any questions about our data protection policies and practices or the information we hold about you, contact our Data Protection Officer using the information set forth above in the section titled “Contact Information”.
If you are utilizing the Creatrify Services in India or by means of a computer or computer system located in India, you have the rights outlined in this section. The general terms of this Privacy Policy set forth above are applicable but this section explains its particular application under the Information Technology Act, 2000 (referred to in this section as the “Act”) and the Information Technology (Reasonable Security Practices And Procedures And Sensitive Personal Data Or Information) Rules, 2011 (in this section the “Rules”). This section sets out Creatrify’s policy governing the collection, use, possession, transfer, processing, storage, dealing, disclosure and handling of the Personal Information (“PI”) and the Sensitive Personal Data or Information (“SPDI”) by Creatrify in accordance with Rule 4 of the Rules.
The term “Personal Information” or “PI” as defined under the Rules, shall mean any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available with a Body Corporate, is capable of identifying such person.
The term “Sensitive Personal Data or Information” or “SPDI” as defined under the Rules, shall include the following information: (i) password, (ii) financial information such as bank account or credit card or debit card or other payment instrument details, (iii) physical, physiological and mental health condition, (iv) sexual orientation, (v) medical records and history, (vi) biometric information, (vii) any detail relating to foregoing clauses as provided to Creatrify for providing services, and (viii) any information received under the above clauses by a body corporate for collection, use, transferring, processing, possessing, storing, dealing, disclosing and handling under lawful contract or otherwise. Any information that is freely available or accessible in public domain or furnished under the Right to Information Act, 2005 or any other law for the time being in force shall not be regarded as Sensitive Personal Data or Information.
All capitalized terms not defined herein shall have the meaning assigned to them under the Act and the Rules.
Creatrify will, or may, collect, use, receive, possess, process, store, deal, disclose, transfer or handle the Personal Information or PI for the purposes outlined in the sections above entitled “How We Use Your Personal Data” and “How We Share Your Personal Data”. To the extent any such purpose is not otherwise permitted, your use of the Creatrify Services constitutes your express consent to such purpose.
The “Categories of Personal Data We Collect” section above details the PI and SPDI, referred to in our general policy as Personal Data, that we collect from you which shall include, but is not limited to, information regarding name, address, telephone number, date of birth, gender, e-mail id, financial information, biometric information, etc.
The sections above entitled “Sources of Personal Data” and “Information Collected Automatically” detail how we obtain your Personal Data including PI and SPDI.
The section above entitled “How We Share Your Personal Data” details how we share and disclose your Personal Data including PI and SPDI. In addition to the explanation above, please be aware that we may share Personal Data including PI and SPDI with (a) Governmental Agencies, Courts or Regulators as required under the applicable law; (b) any agent, contractor or third party or service provider in connection with Creatrify’s business; and (c) any other person under duty of confidentiality to Creatrify.
The person whose PI and/or SPDI is collected, received, possessed, processed, stored, transferred, dealt or handled may inquire as to the nature of data stored or processed by Creatrify and will be provided reasonable access to the their PI and SPDI held by Creatrify. If any data is inaccurate or incomplete, such person may request that the data be amended or modified or updated. To exercise these rights submit a Valid Request following the procedure set forth above in the section entitled “Procedure to Exercise Your Privacy Rights.”
You have the option to withdraw your consent to Creatrify to use the PI or SPDI collected by Creatrify in accordance with this Policy. However, your use of the Creatrify Services is conditioned on giving us such consent and therefore you will no longer be able to utilize the Creatrify Services. To exercise these rights submit a Valid Request following the procedure set forth above in the section entitled “Procedure to Exercise Your Privacy Rights.”
Any other questions, disputes, or grievances with respect to the processing of PI or SPDI can be referred to the Data Privacy and Grievance officer designated by Creatrify by contacting us at the post or email addresses listed in the section above entitled “Contact Information.”
Creatrify’s services are not currently targeted to or intended for use by persons subject to the Act and the Rules. Nonetheless, Creatrify will utilize reasonable security practices and procedures for the security and protection of PI and SPDI, in line with the internationally accepted standards which includes, technical, operational and physical security control measures. Creatrify will use reasonable efforts to observe the following guidelines when using, receiving, possessing, processing, storing, dealing, disclosing, transferring or handling the PI and SPDI:
Creatrify reserves the right to add, revise, amend, modify or delete any part of the Privacy Policy or this India-specific portion, in part or in full in its sole discretion. Changes shall be made and communicated as set forth in the section above entitled “Changes to this Privacy Policy.” In the event of any change in the Act or the Rules or in case of any requirement arising under any of the applicable law, this Privacy Policy shall be deemed to be amended or modified to the extent necessary to comply with such amendment to the Act or the Rules or to meet any requirement under the applicable laws.