Details on how theCreativeRoute processes and stores your data.
Last updated: April 5, 2018
3. Transparency/Notice – Types Of Personal Information We Collect And How We Use It
The types of Personal Information we may collect (directly from you or from Third-Party sources) and our privacy practices depend on the nature of the relationship you have with TheCreativeRoute and the requirements of applicable law. Some of the ways that TheCreativeRoute may collect Personal Information include:
- You may provide Personal Information directly to TheCreativeRoute through interacting with the Services, requesting Services, or information.
- As you navigate the Services, certain passive information may also be collected about your visit, including through cookies and similar technologies as described below. We endeavor to collect only that information which is relevant for the purposes of Processing. Below are the ways we collect Personal Information and how we use it.
We endeavor to collect only that information which is relevant for the purposes of Processing. Below are the ways we collect Personal Information and how we use it.
A. Types Of Personal Information We Collect
TheCreativeRoute collects Personal Information regarding its current, prospective, and former clients, customers, users, visitors, and guests (collectively “Individuals”).
- Information You Provide Directly to Us. When you use the Services or engage in certain activities, such as registering for an account with TheCreativeRoute, purchasing a Plan from TheCreativeRoute, requesting Services or information, or contacting us directly through the “Contact Us” feature or by some other method, we may ask you to provide some or all of the following types of information:
- Communications with Us. We may collect Personal Information from you such as name, email address, phone number, company or organization name, location, or mailing address when you use the “Contact Us” feature, register for TheCreativeRoute, choose to request information about our Services, request to receive customer or technical support, or otherwise communicate with us. We may also receive a confirmation when you open an email from us, which helps us make our communications with you more interesting and improve our Services.
- Purchase of a Subscription or a Product. Before you make a purchase you must provide your email address, first and last name, credit card number, card expiration date and card CVC code. The credit card information is obtained by a Third Party payment processor for processing and storage to a high security vault according to strict industry standards. No credit card information is received or retained in TheCreativeRoute’s own systems. Your credit card information is not exposed anywhere in our own systems. Please do not send your credit card information to our team directly, for example by emailing this information to our contact email. Please use our secure, online payment process to enter your credit card information.
- Information Submitted Via Services. You agree that TheCreativeRoute is free to use the content of any communications submitted by you via the Services, including any ideas, inventions, concepts, techniques, or know-how disclosed therein, for any purpose including developing, manufacturing, and/or marketing goods or Services. TheCreativeRoute will not release your name or otherwise publicize the fact that you submitted materials or other information to us unless: (a) you grant us permission to do so; (b) we first send notice to you that the materials or other information you submit to a particular part of a Service will be published or otherwise used with your name on it; or we are required to do so by law.
- No Sensitive Data or Sensitive Personal Information. TheCreativeRoute does not collect Sensitive Data as defined under the laws of the European Union.
B. How TheCreativeRoute Uses Your Information
We acquire, hold, use, and Process Personal Information about Individuals for a variety of business purposes, including:
- To Provide Products, Services, or Information Requested. TheCreativeRoute may use information about you to fulfill requests for products, Services, or information, including information about potential or future Services, including to:
- Generally manage Individual information and accounts;
- Respond to questions, comments, and other requests;
- Contact you to answer requests for customer support or technical support;
- Process payment for products or Services purchased;
- Prevent potentially prohibited or illegal activities;
- Enforce our Terms.
- Marketing TheCreativeRoute Products and Services. TheCreativeRoute may use Personal Information to provide you with materials about offers, products, and Services that may be of interest, including new content or Services. TheCreativeRoute may provide you with these materials by phone, postal mail, facsimile, or email, as permitted by applicable law. Such uses include:
- To tailor content, advertisements, and offers;
- To notify you about offers, products, and services that may be of interest to you;
- To provide Services to you and Third Parties
- For other purposes disclosed at the time that Individuals provide Personal Information; or
- Otherwise with your consent.
You may contact us at any time to opt-out of the use of your Personal Information for marketing purposes, as further described in Section 5 below.
- Research and Development. TheCreativeRoute may use Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and Services or develop new products and Services.
- Email. Individuals who provide us with Personal Information, or whose Personal Information we obtain from Third-Parties, may receive periodic emails, newsletters or mailings from us with information on TheCreativeRoute’s or our business partners’ products and services or upcoming special offers/events we believe may be of interest. We offer the option to decline these communications at no cost to the Individual by following the instructions in Section 5 below.
C. Cookies, Pixel Tags/Web Beacons, Analytics Information, And Interest-Based Advertising
- Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Site may not work properly.
- Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.
- Analytics. We may also use certain analytics tools to collect information regarding visitor behavior and visitor demographics on some of our Services, and to develop Site content. This analytics data is not tied to any Personal Information.
If you would like to opt-out of the Technologies we employ on our Sites and Services, you may do so by blocking, deleting, or disabling them as your browser or device permits.
D. Third-Party Websites & Social Media Platforms
The Site may contain links to other websites and other websites may reference or link to our Site or other Services. These other domains and websites are not controlled by us, and TheCreativeRoute does not endorse or make any representations about Third-Party websites or social media platforms. We encourage our users to read the privacy policies of each and every website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk. TheCreativeRoute’s Services may include publicly accessible blogs, community forums, or private messaging features. The Site and our other Services may also contain links and interactive features with various social media platforms (e.g., widgets). If you already use these platforms, their cookies may be set on your device when using our Site or other Services. You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible blog, social media platform or otherwise online, or that you share in an open forum may be viewed and used by others without any restrictions. We are unable to control such uses of your information when interacting with a social media platform, and by using such services you assume the risk that the Personal Information provided by you may be viewed and used by Third-Parties for any number of purposes.
E. Third-Party Payment Processing
When you purchase a subscription for the Services, we process your payments through a Third-Party payment processor. The Third-Party payment processor may collect certain financial information from you to process a payment on behalf of TheCreativeRoute, including your name, email address, address and other billing information.
4. Onward Transfer – TheCreativeRoute May Disclose Your Information
A. Information We Share
- Business Partners. TheCreativeRoute may share Personal Information with our business partners, and affiliates for our and our affiliates’ internal business purposes or to provide you with a product or Service that you have requested. TheCreativeRoute may also provide Personal Information to business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you. In such cases, our business partner’s name will be presented with the product. TheCreativeRoute requires our affiliates and business partners to agree in writing to maintain the confidentiality and security of Personal Information they maintain on our behalf and not to use it for any purpose other than the purpose for which TheCreativeRoute provided them.
- Privacy Shield. With respect to onward transfers to Agents under Privacy Shield, Privacy Shield requires that TheCreativeRoute remain liable should its Agents Process Personal Information in a manner inconsistent with the Privacy Shield Principles.
- Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures). We may access, preserve, and disclose your Personal Information, other account information, and content if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect yours’, ours’ or others’ rights, property, or safety; (iv) to enforce TheCreativeRoute policies or contracts; (v) to collect amounts owed to TheCreativeRoute; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.
B. Data Transfers
All Personal Information collected via or by TheCreativeRoute may be stored anywhere in the world, including but not limited to, the United States, the European Union, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to TheCreativeRoute, you consent to the storage of your Personal Information in these locations.
5. Opt-Out (Right To Restrict Processing)
You have the right to opt-out of certain uses and disclosures of your Personal Information. Where you have consented to TheCreativeRoute’s Processing of your Personal Information or Sensitive Personal Information, you may withdraw that consent at any time and opt-out to further Processing by contacting us at firstname.lastname@example.org.
B. Email And Telephone Communications
WE MAINTAIN TELEPHONE “DO-NOT-CALL” AND “DO-NOT-MAIL” LISTS AS MANDATED BY LAW. WE PROCESS REQUESTS TO BE PLACED ON DO-NOT-MAIL, DO-NOT-PHONE AND DO-NOT-CONTACT LISTS WITHIN 60 DAYS AFTER RECEIPT, OR SUCH SHORTER TIME AS MAY BE REQUIRED BY LAW
C. “Do Not Track”
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
D. Cookies And Interest-Based Advertising
As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may opt-out of certain mobile ads via their device settings.
The online advertising industry also provides websites from which you may opt-out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, or http://www.youronlinechoices.eu/ and www.aboutads.info/choices/.
6. Rights Of Access, Rectification, Erasure, And Restriction
Although TheCreativeRoute makes good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which TheCreativeRoute is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If TheCreativeRoute determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, TheCreativeRoute will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.
7. Data Retention
8. Security of Your information
By using the Site or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Site. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Site or sending an e-mail to you. You may have a legal right to receive this notice in writing.
9. International Users
If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and to Processing of your data globally. By providing your Personal Information, you consent to any transfer and Processing in accordance with this Policy.
10. Children’s Privacy
The Services are not directed to children under 13 (and in certain jurisdictions in the EU under the age of 16) years of age, and TheCreativeRoute does not knowingly collect Personally Identifiable Information from children under 13 (and in certain jurisdictions in the EU under the age of 16) years of age. If you are under the age of 18, you must have your parent’s permission to access the Services. TheCreativeRoute urges parents to instruct their children never to give out their real names, addresses, or phone numbers, without parental permission, when online. If you learn that your child has provided us with Personal Information without your consent, you may alert us at email@example.com. If we learn that we have collected any Personal Information from children under 13 (and in certain jurisdictions in the EU under the age of 16), we will promptly take steps to delete such information and terminate the child’s account.
11. Redress/Compliance and Accountability
If you are an EU citizen and feel that TheCreativeRoute is not abiding by the terms of this Policy, or is not in compliance with GDPR, please contact TheCreativeRoute at the contact information provided above.
12. Other Rights and Important Information
- New Uses of Personal Information. Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will endeavor to provide information regarding the new purpose and give you the opportunity to opt-out. Where consent of the Individual for the Processing of Personal Information is otherwise required by law or contract, TheCreativeRoute will endeavor to comply with the law or contract.
The following capitalized terms shall have the meanings herein as set forth below.
- “Agent” means any Third-Party that Processes Personal Information pursuant to the instructions of, and solely for, TheCreativeRoute or to which TheCreativeRoute discloses Personal Information for use on its behalf.
- “Personal Information” is any information relating to an identified or identifiable natural person (“Individual”).
- “Privacy Shield Principles” means the seven (7) principles of the Privacy Shield Framework: (1) notice, (2), choice, (3) accountability for onward transfer, (4) security, (5) data integrity and purpose limitation, (6) access, and (7) recourse, enforcement, and liability. Additionally, it includes the sixteen (16) supplemental principles described in the Privacy Shield: (1) sensitive data, (2) journalistic exceptions, (3) secondary liability, (4) performing due diligence and conducting audits, (5) the role of the data protection authorities, (6) self-certification, (7) verification, (8) access, (9) human resources data, (10) obligatory contracts for onward transfers, (11) dispute resolution and enforcement, (12) choice – timing of opt-out, (13) travel information, (14) pharmaceutical and medical products, (15) public record and publicly available information, and (16) access requests by public authorities.
- “Process” or “Processing” means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
- “Sensitive Data” or “Sensitive Personal Information” is a subset of Personal Information which, due to its nature, has been classified by law or by policy as deserving additional privacy and security protections. Sensitive Personal Information includes Personal Information regarding EU residents that is classified as a “Special Category of Personal Data” under EU law, which consists of the following data elements: (1) race or ethnic origin; (2) political opinions; (3) religious or philosophical beliefs; (4) trade union membership; (5) genetic data; (6) biometric data where Processed to uniquely identify a person; (6) health information; (7) sexual orientation or information about the Individual’s sex life; or (8) information relating to the commission of a criminal offense.
- “Third Party” is any company, natural or legal person, public authority, agency, or body other than the Individual, TheCreativeRoute or TheCreativeRoute’s Agents.