Createur Platform
Privacy Policy

Last Updated: 12/14/2020

Createur Inc.  (“Company” or “we”) provides this Privacy Policy to inform users of our policies and procedures regarding the collection, use and sharing of personally identifiable information received and collected as a part of its offering and operation of the Créateur Platform (including related web pages, web applications, software and technologies) (the “Platform”) and from social media sites not owned by Company. This Privacy Policy may be updated from time to time for any reason. We will notify you of any material changes to our Privacy Policy by posting the new Privacy Policy on our website. You are advised to consult this Privacy Policy regularly for any changes. 

By using the Platform, you consent to our processing your information as set forth in this Privacy Policy now and as amended by us. “Processing” means using cookies or Tags (defined below) on a computer or using or touching information in any way, including, but not limited to, collecting, storing, deleting, using, combining and disclosing information. If you reside outside the U.S., your personally identifiable information will be transferred to the U.S., and processed and stored there under U.S. privacy standards. By using the Platform or otherwise providing information to us, you consent to such transfer to, and processing in, the U.S. If you have any questions or comments about this Privacy Policy or our use of your personal data, please contact us at conor@createur.work. 

INFORMATION COLLECTION

Our primary goals in collecting personal data are to provide you with the Platform, to communicate with you, and to manage your registered user account. When collecting information from social media sites not owned by us, our goal is to help users of the Platform connect with other parties for the purposes business development. We collect User Data, Usage Data, and Social Media Data, as discussed below.

User Data. 

The following describes the data about users of the Platform that we collect (collectively, “User Data”). 

If you desire to have access to the Platform, you must become a registered user and submit certain personal data to Company. This may happen in a number of instances, such as when you sign up for a free trial or paid subscription to the Platform. Personally identifiable information that we may collect in such instances may include your user name, password, company title (if applicable), email address, physical address and telephone number. If you become a paying user of the Platform, we may collect information such as your credit card number or other billing information. If you contact us through the Platform, we may keep a record of your contact information and correspondence, and may use your email address, and any information that you provide to us in your message, to respond to you. In addition, we may use your contact information to market to you, and provide you with information about the Platform and our other products and services. If you decide at any time that you no longer wish to receive such information or communications from us, please follow the unsubscribe instructions provided in any of the communications or contact us at conor@createur.work. 

We may collect personal data about users of the Platform and other individuals from: third-parties such as (a) authentication partners who help us create an account for you; (b) technical services partners that provide us with certain data the allows us to provide the features and content of the Platform; (c) payment partners that enable us to send invoices and process payment; and (d) advertisers and other advertising partners in order for us to deliver ads.

Usage Data.

The following describes the data about use of the Platform by users that we collect (collectively, “Usage Data”).

General. We may collect the following information about use of the Platform: (a) information about the type of subscription to the Platform that you use; (b) information about your interactions with the Platform, such as the features that you use and the data that is provided to you; (c) inferences drawn about your preferences and business, including information about the brands and influencers you interact with; (d) information about content you deliver to or through the Platform; (d) certain technical data, which may include URL information, online identifiers including cookie data and IP addresses, and information about the type of devices you use. 

Log Data. When you use the Platform, our servers may automatically record information that your browser or device sends (“Log Data”). This Log Data may include information such as your internet protocol (“IP”) address, browser type or the domain from which you are visiting. For most users accessing the Internet from an Internet service provider the IP address will be different every time you log on. Except in the instances described herein, we do not use this information to identify you personally. We use it to monitor the use of the Platform and of any services we provide via the Platform, and for the Platform’s technical administration. But the same pieces of information are considered non-identifying information when they are taken alone or combined only with other non-identifying information (for example, your viewing preferences). For users of the Platform, we may combine your personally identifiable information with non-identifying information and aggregate it with information we otherwise collect in order  to attempt to provide you with a better experience, to improve the quality and value of the services we provide via the Platform and to analyze and understand how our Platform and business is used. 

Cookies. Like many web sites and web applications, we also use “cookie” technology to collect additional usage data and to improve the Platform and the services we provide. A cookie is a small data file that we transfer to your computer’s hard disk. We do not use cookies to collect personally identifiable information. We may use both session cookies and persistent cookies to better understand how you interact with us and with and any services via the Platform, to monitor aggregate usage by our users and web traffic routing, and to improve usability and performance of the Platform. A session cookie enables certain features of the Platform and is deleted from your computer when you disconnect from or leave the Platform. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits. Persistent cookies can be removed by following your web browser help file directions. Most Internet browsers automatically accept cookies. You can instruct your browser, by editing its options, to stop accepting cookies or to prompt you before accepting a cookie from the web sites you visit. If you do not accept cookies, however, you may not be able to use all portions and features of the Platform. 

Tags. We also use “web beacons,” “pixel tags,” “clear GIFs” or similar means (individually or collectively “Tags”) on the Platform. A Tag is an electronic image, often a single pixel, embedded on web pages. Tags are ordinarily not visible to users. Tags allow us to count the number of users who have visited certain pages or features of the Platform, and to generate statistics about how the Platform is used. 

We use the services of third-party companies to help us carry out and measure the effectiveness of our own advertising campaigns. For example, these third-party companies may ensure that you are shown ads at appropriate frequencies, so that you do not see the same ad repeatedly. As part of these services, one or more Tags may be placed on the Platform. These Tags do not enable third parties to collect your name, e-mail address, phone number or other similar information that directly identifies you. Rather, when you visit the Platform, these Tags will direct your web browser to contact these third party companies, at which time they may set or read a cookie on your device and collect information about your visit – such as your IP address, cookie ID, which parts of the Platform are viewed or clicked, and date/time information. 

Social Media Data

We collect publicly available social media data from social media site APIs (“Social Media Data”). This may include information such as an individual influencer’s or brand representative’s name, email address, photos, location, social media posts, friends, and followers. We use the legitimate interests lawful basis to process personal data from influencers found on social media sites. This lawful basis allows use of people’s data in ways they would reasonably expect and which have a minimal privacy impact. We only collect publicly available information. When influencers and brands publish social media posts publicly, it is a clear indication that they want to be discovered by brands and followers. We process their data in order to facilitate building relationships between brands and influencers. Core to our mission is helping influencers and brands build communities in a scalable, genuine way. This benefits influencers and brands by growing their business via developing genuine relationships. 

USE OF INFORMATION

General. We process and use data, including User Data, Usage Data, and Social Media Data, in order to: (a) provide and personalize the Platform; (b) understand, diagnose, troubleshoot, and fix issues with the Platform; (c) evaluate and develop new features and technologies; (d) market, promote, and advertise the Platform and our other services; (e) comply with legal obligations and law enforcement requests; (f) fulfill contractual obligations to our users and third-parties; (g) establish, exercise, and defend against legal claims; (h) conduct business planning, reporting, and forecasting; (i) process payments; (j) detect fraud, including fraudulent payment and use of the Platform; and (k) conduct research, contests, surveys, and sweepstakes.

Your Sharing. You may choose to make your personal data public, and the Platform may facilitate such sharing. You grant Company permission to share such personal data by using the Platform as designed or by consenting through a presented consent mechanism within the Platform or otherwise provided by Company.

Aggregate Information and Non-Identifying Information. We may share aggregated information that does not include personal data and we may otherwise disclose non-identifying data and Log Data with third parties for industry analysis, demographic profiling and other purposes. Any aggregated information shared in these contexts will not contain your personal data. 

Service Providers. We may engage certain trusted third parties to perform functions and provide services to us, including, without limitation, hosting and maintenance, customer relationship, database storage and management, and direct marketing campaigns. We will share personal data with these third parties, but only to the extent necessary to perform these functions and provide such services, and only pursuant to binding contractual obligations requiring such third parties to maintain the privacy and security of your data. 

Compliance with Laws and Law Enforcement.  Company cooperates with government and law enforcement officials or private parties to enforce and comply with the law. We may disclose any information to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims, legal process (including subpoenas), to protect the property and rights of Company or a third party, the safety of the public or any person, to prevent or stop any illegal, unethical, or legally actionable activity, or to comply with the law.

Business Transfers. If any or all of the assets of Company are acquired by or merged with another entity, we may share some or all of your information with this entity. 

CHANGING OR DELETING INFORMATION 

If you are a registered user of the Platform, you may update or correct the information you provided to us by requesting us to make such changes at www.createur.work. 

If you are an influencer, you may request to access, correct, or delete the information we have collected about you from social media websites by requesting us to make such changes at www.createur.work

SECURITY 

We are very concerned about safeguarding the confidentiality of your personal data. We employ advanced administrative, physical and electronic measures designed to protect personal data from unauthorized access. 

To the extent possible and reasonable, we will disclose any breach of the security, confidentiality, or integrity of your unencrypted electronically stored personal data to you via email or conspicuous posting on the Platform without unreasonable delay, consistent with (a) the legitimate needs of law enforcement or (b) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system. 

INTERNATIONAL TRANSFER 

Personal data may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to provide information to us, we transfer that information to the United States and processes it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer. 

We process data in US-based servers. This processing is supported by compliance for safeguarding any transfers of personal data outside of the EU.

EU GENERAL DATA PROTECTION REGULATION (GDPR)

We comply with the EU General Data Protection Regulation (GDPR), if and as applicable. The GDPR provides certain individuals with the following rights:

  1. THE RIGHT OF ACCESS. You have the right to be informed of, and request access to, the information we process about you.

  2. THE RIGHT TO RECTIFICATION. You have the right to request that we amend or update your personal data where it is inaccurate or incomplete. The right to erasure. You the right to have the company delete your information.

  3. THE RIGHT TO RESTRICT DATA. You have the right to request that we temporarily or permanently stop processing your personal information.

  4. THE RIGHT TO OBJECT. You have the right to object to us processing your information on grounds relating to your particular situation or for direct marketing purposes.

  5. THE RIGHT TO DATA PORTABILITY. You have the right to request a copy of your information in electronic format and the right to transmit that information to any other service.

  6. THE RIGHT NOT TO BE SUBJECT TO AUTOMATED DECISION MAKING. You have the right to not be subject to a decision based solely on automated decision making, including profiling, when such a decision would have a legal effect on you or produce a similarly significant effect.

  7. THE RIGHT TO COMPLAIN: you may file a complaint with the appropriate data protection authority.

The Information we collect and the process is controlled by Createur Inc. a Delaware corporation, USA.

OTHER JURISDICTIONS AND CALIFORNIA PRIVACY RIGHTS

If you are an individual in certain jurisdictions, you have certain rights with respect to the personal data stored by the Platform.

Accessing Account Information. If and as required by law, we will provide you with the means to ensure that personally identifiable information in your registered account is correct and current. You may review this information by contacting us using the contact information below

A Record of Data Transfer. If and as required by law, we will provide the right to request and receive, once a year and free of charge, information about third parties to whom we have disclosed certain types of personal information (if any) about you for our direct marketing purposes in the prior calendar year, and a description of the categories of personal information shared. To make such a request, please contact us using the contact information below, and please include the phrase “Personal Information Privacy Request” in the subject line, portion of the Platform you are inquiring about, along with your name, address, and email address. At our option, we may respond to such requests by providing instructions about how Platform users can exercise their options to prevent our disclosure of personal information to third parties for our direct marketing purposes.

California Online Privacy Protection Act.  If and as required by the California Online Privacy Protection Act (“California Act”) and the California Business and Professions Code, this Privacy Policy identifies the categories of personally identifiable information (as that term is defined above and in the California Act) that we collect through the Platform about individual consumers who use the Platform and the categories of third-party persons or entities with whom such personally identifiable information may be shared. 

California Consumer Privacy Act of 2018 (CCPA). If and as required by the California Act, you have the right to request, twice a year and free of charge, certain information about parties to whom we have disclosed or sold your personal information in the prior calendar year and a description of the categories of personal information shared. Additionally, if and as required by the California Act, upon request, twice a year, and free of charge, we shall provide you any information relating to your personal information and our processing of your personal information in a concise, transparent, intelligible, and easily accessible form using clear and plain language. To make such a request, please use the contact information below, and please include the phrase “Personal Information Privacy Request” in the subject line, the portion of the Platform you are inquiring about, along with your name, address, and email address. You can also ask us to delete your personal data stored in the Platform. If we receive a request to delete your data, we will ask you if you want your personal information to be removed entirely or if you want to be kept on a list of individuals who do not want to be contacted in the future (for a specified period or otherwise). If you exercise your rights under the California Act, Company will not discriminate against you. Requests to know and requests to delete will be honored within 45 days; if more time is needed to respond, Company will notify you. You may use an authorized agent to make a request on your behalf. Company has collected and has disclosed the personal information described below during the last year for business purposes; however, Company does not sell the personal information of users of the Platform.

  • Social Media Identifiers

  • Personal Information listed in California Civil Code § 1798.80(E), including consumer names and payment information. 

LINKS TO OTHER WEBSITES 

The Platform may contain many links to other websites and services. The fact that we link to a web site does not constitute an endorsement, authorization or representation of our affiliation with that third party. We do not exercise control over third party websites. These other web sites will most likely place their own cookies or other files on your computer, collect data or solicit personal information from you. This Privacy Policy addresses the use and disclosure of information that we collect from you through the Platform. Other sites follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit. 

OUR POLICY TOWARDS CHILDREN 

The Platform is not directed to persons under 18 years of age.  If a parent or guardian becomes aware that his or her child has provided us with personally identifiable information without their consent, he or she should contact us at conor@createur.work. If we become aware that a child under 13 has provided us with personally identifiable information, we will remove such information from our files immediately. 

CONTACT 

Contact us by emailing conor@createur.work. Our Data Protection Officer is Conor Begley, who is available at conor@createur.work.