PRIVACY POLICY

Data Controller

Data Controller: www.wearecreativ.com

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We are the controller and responsible for your personal data.

We have appointed a group data protection officer who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the group data protection officer using the details set out at the bottom of this notice.

Privacy Notice

Created: July 2023

We respect your privacy and we are committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. 

This policy applies to information we collect:

• on the Website (including desktop and mobile versions);

• in email, text, and other electronic messages between you and CREATIV;

• when you interact with our advertising on third-party websites and services;

• when you interact with the Website through third-party websites and services;

• from publicly available sources, like your LinkedIn profile; and

• offline, including when we collect a business card at an event.

 

It does not apply to information:

• collected by any third party (including our affiliates) including through any application or content (including advertising) that may link to or be accessible from (or on) the Website; or

• through any other means.

Please read this text carefully to understand our policies and practices regarding your information and how we will treat it. If, despite the privacy choices available to you, you do not agree with our policies and practices, your remaining choice is not to use our Website. By accessing or using our Website, and by consenting to our processing of your personal data (in relation to “The General Data Protection Regulation (GDPR)(EU) 2016/679”) you agree to our collection, use, disclosure, retention, and protection of your personal data as described in this policy. We may change this policy on one or more occasions. Where this change of policy includes a change to the purpose for processing your personal data, we will seek to renew your consent for that personal data processing. Please check the policy frequently for updates.

 

1. What types of information do we collect about you and how do we collect it?

We may collect several types of information from and about users of our Website or service, including personal data:

• by which you may be personally identified, including your name, postal address, email address, telephone number; or

• details of your business, and business dealings and operations, and a record of the communications and meetings you’ve had with CREATIV; or

• about your internet connection, and the software or equipment that you use to access our Website; or

• about your usage of the Website, including the pages that you view and in some cases information about how you clicked to visit the Website; or

• by which you may be pseudonymously identified, including the values of web cookies and mobile device identifiers.

 

We collect this information:

• directly from you when you provide it to us;

• directly from publicly available sources;

• automatically as you navigate through the Website; and

• from third parties, for example, our business partners.

 

1.1 Information you provide to us online

The information we collect on or through our Website may include:

• Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to receive communications, or enquiring about further services.

• Records and copies of your correspondence (including email addresses), if you contact us.

• Your responses to surveys that we might ask you to complete for research purposes.

• Your search queries on the Website.

1.2 The Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, maiden name, last name, marital status, title, date of birth and gender.

• Contact Data includes, home and/or contact address, email address and telephone numbers.

• Employment Data includes your first and last name, contact details, photograph, education, work history, eligibility for role applied for and/or all details that you maintain on LinkedIn when you apply for a role using the LinkedIn option.

• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

• Profile Data includes your interests, preferences, feedback and survey responses.

• Usage Data includes information about how you use our website.

• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

Our Website does not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

 

1.3 Information we collect through automatic data collection technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:

• Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.

• Information about your computer and internet connection, including your IP address, operating system, and browser type.

• We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services.

The technologies we use for this automatic data collection may include: cookies or other local storage and web beacons (or “pixels,” on the Website and including in our emails).

 

1.4 How Is Your Personal Data Collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact and Employment Data by filling in forms on our site or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• apply to use our services;

• request information from us;

• apply for a job with us;

• enter a promotion or survey; or

• give us some feedback.

• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.

 

2. How do we use your information?

We may use information that we collect about you or that you provide to us, on the grounds of the contract between us, legal obligation, your vital interests, or the public interests. The reason for this processing of your personal data may include

• to provide you with information, products, or services that you request from us;

• to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection; and

• to investigate and prevent illegal activities. We may also use information that we collect about you or that you provide to us with your consent, which is given in relation to a purpose. That purpose may include to notify you about changes to any products or services we offer or provide; or

• in any other way we may describe when you give consent and provide the information. We may also use information that we collect about you or that you provide to us on the grounds of our legitimate interests. The reason for this processing of your personal data may include

• to notify you about changes to any products or services we offer or provide;

• to contact you about our own and third parties’ goods and services that may be of interest to you; and

• to fulfill any other purpose for which you provide your personal data. These purposes require that we store personal data for 36 months. We delete it after that time, except where it is renewed by your direct contact with us.

If you do not want us to use your information in these ways, then contact us to let us know. In relation to emails you may receive from CREATIV, where your subscription to a marketing list has caused you to receive the email, you can remove yourself from the marketing list by using the unsubscribe link that you’ll find in the email itself.

For more information, see “What choices do you have about how we use and disclose your information?” The information we collect automatically is grouped by its purpose into one of three categories, either:

• operating the Website; or

• measurement; or

• advertising.

 

2.1 Lawful Basis of Processing

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.

• To provide you with the information or services that you request from the website.

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

• Where we need to comply with a legal or regulatory obligation.

• To consider a job application submitted by you.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by Contacting us.

 

2.2 Automatic data collection for operating the website

Operating the Website includes for the purposes of:

• delivering its pages;

• allowing you to participate in any interactive features on our Website;

• processing and logging your requests;

• maintaining the Website and resolving any technical issues that may occur in its operation;

• investigating and preventing illegal activities; and may include

• personalising the Website for you including by:

• processing and recording the pages you request as you land on them and navigate between them;

• logging information about the software and equipment you use to request pages;

• storing information about your preferences, thus allowing us to customise the Website according to your individual interests; and

• recognising you when you return to our Website.

 

2.3 Automatic data collection for measurement

Measurement includes for the purposes of:

• improving our Website’s technical performance (for example, the speed with which its pages are loading for its visitors);

• improving its content performance (for example, where unpopular content may be revealed as having been produced more poorly than normal, or reflect the changing needs of our visitors);

• testing new versions of the Website (wholly or partially) on a sample of its audience, and measuring the differences in performance between the versions. This involves the storage of information about which version of the website you’ve seen. Measurement rarely involves the study of any individual, but statistical techniques in measurement do rely on personal data.

 

2.4 Automatic data collection for advertising

Advertising includes for the purposes of collecting information about your online activities on the Website and across third-party websites or other online services so that:

• CREATIVcan notify you about changes to any products or services we offer or provide;

• CREATIVcan show advertising;

• this advertising may be shown to you and personalised in relation to your previous behaviour;

• CREATIVcan measure the delivery and performance of the advertising it places; and

• CREATIVcan use reporting on the Website’s visitors, including using data collected from across third-party websites, to inform marketing plans and decisions.

 

3. With whom do we share your information?

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. We may disclose personal data that we collect or you provide as described in this privacy policy:

• To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.

• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganisation, dissolution, or other sale or transfer of some or all of our assets, whether as a going concerning or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website users is among the assets transferred.

• To third parties to market their products or services to you if you have not opted out of these disclosures. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them. For more information, see “What choices do you have about how we use and disclose your information?”

• To fulfill the purpose for which you provide it.

• For any other purpose disclosed by us when you provide the information.

• With your consent.

We may also disclose your personal data:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.

• To enforce or apply our terms and other agreements, including for billing and collection purposes.

If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us, our users, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

 

Data processors

CREATIV(as part of the Croud Group) may use these processors as partners in processing your personal data Relationships with our clients and customers

• HubSpot

• GSuite

• Office 365

• Amazon Web Services

• Google Cloud Platform

 

Measurement

• Google Tag Manager

• Google Analytics (but not its “Advertising Features”)

• Hotjar

 

Advertising

• Google Analytics (including its “Advertising Features”)

• Google AdWords

• DoubleClick

• Facebook

• LinkedIn

 

Social Media Platforms

Communication, engagement and actions taken through external social media platforms that this website and its owners participate on are custom to the terms and conditions as well as the privacy policies held with each social media platform respectively.

Users are advised to use social media platforms wisely and communicate/engage upon them with due care and caution in regard to their own privacy and personal details. This website nor its owners will ever ask for personal or sensitive information through social media platforms and encourage users wishing to discuss sensitive details to contact them through primary communication channels such as by telephone or email.

This website may use social sharing buttons which help share web content directly from web pages to the social media platform in question. Users are advised before using such social sharing buttons that they do so at their own discretion and note that the social media platform may track and save your request to share a web page respectively through your social media platform account. This website and its owners through their social media platform accounts may share web links to relevant web pages. By default some social media platforms shorten lengthy urls. Users are advised to take caution and good judgement before clicking any shortened urls published on social media platforms by this website and its owners. Despite the best efforts to ensure only genuine urls are published many social media platforms are prone to spam and hacking and therefore this website and its owners cannot be held liable for any damages or implications caused by visiting any shortened links.

 

4. What choices do you have about how we use and disclose your information?

We strive to provide you with choices about the personal data you provide to us. We have created mechanisms to provide you with the following control over your information:

• Via our cookies banner you can give or revoke consent for automatic data collection on the website, for either measurement, or also measurement and advertising.

• You’re able to review the way that Google and Facebook process data about you in general (i.e. not just on our Website).

• For Google, you can review the Ads Settings for your Google user account, and this includes being able to opt out of personalised advertising. You can also use the My Activity settings to control data that Google stores about you and decide how it’s used.

• Facebook’s Data Policy includes a link to your account ad controls

• All promotional emails sent from CREATIV include an unsubscribe link, and this can be used to remove yourself from our mailing list.

 

5. How do you access and correct your information?

With respect to the UK and EU GDPR, you have a right to review and correct, export and delete the personal data about you processed by CREATIV. We’ll be happy to accommodate your request if you begin by emailing us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

On a case by case basis, you have the following rights in relation to your personal data processed by CREATIV:

• The right to be informed about how your personal data is collected and used

• The right to request access to a copy of any personal data that we hold about you

• The right to rectify personal data we may hold which is identified as incorrect or misleading

• The right to erasure of any personal data; also known as ‘the right to be forgotten’

• The right to restrict further processing of your personal data

• The right to data portability where technology allows us to send personal data onto a new controller

• The right to object to the processing of certain processing activities 

That email address is also ready to receive any other request in relation to privacy, personal data, and data protection and security.

 

6. Data Security: How do we protect your personal information?

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We have implemented measures designed to secure your personal information from accidental loss and from unauthorised access, use, change, and disclosure. All information you provide to us is stored on secure technology.

Unfortunately, the transmission of information over the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal data transmitted to our Website. Any transmission you make of personal data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

 

7. Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

 

8. Global Business

By using the Website and our services, your information may be transferred to, stored, and processed in and between the United Kingdom, the United States of America, the European Union and any other country or region of the World.

 

9. Do Not Track Policy

Do Not Track (“DNT”) is a privacy preference that you can set in your browser. DNT is a way for you to signal to websites and services that you do not want certain
information about your webpage visits collected over time and across websites or online services. We are committed to providing you with meaningful choices about the information we collect and that is why we provide you with choices including those on the privacy options sidebar. But we do not guarantee any recognition or response to any DNT signals as internet industry consensus is still being sought on the meaning and usefulness of the DNT browser setting, and how to interpret its signal. For more information about DNT signals, you may visit www.allaboutdnt.com.

 

10. Links to other websites

The Website contains links to other sites. Please be aware that we are not responsible for the content or privacy practices of those other sites. We encourage our users to be aware when they leave our Website and to read the privacy statements of any other site that collects personal data.

 

11. Changes to Privacy Policy

We will post any changes we make to our privacy policy on this page. If we make material changes to how we treat your personal data, or to the purpose for which we process it, we will update this policy. You are responsible for making sure we have an up-to-date active and accurate contact information to communicate with you should we need to regarding your preferences or other privacy related matters. When frequently visiting our Website please check this policy for any changes. Please keep us informed if your personal data changes during your relationship with us.