PRIVACY NOTICE
Last updated June 20, 2023
This privacy notice for Creative Freedom Team Limited ('Company', 'we', 'us', or 'our',), describes how and why we might collect, store, use, and/or share ('process') your personal information when you use our services ('Services'), such as when you:
• Visit our website at http://www.creativefreedom.app, www.creativefreedomapp.com or any website of ours that links to this privacy notice
• Engage with us in other related ways, including any sales, marketing, or events
Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, your choice is not to use our Services. For more information or to address any concerns, please contact us at info@creativefreedom.app
SUMMARY OF KEY POINTS
What personal information do we process? We may process personal information depending on how you interact with Creative Freedom Team Limited and the Services, the choices you make, and the products and features you use.
Do we process any sensitive personal information? We do not process sensitive personal information unless explicitly provided by you for specific services, with your explicit consent.
Do we receive any information from third parties? We may receive information from third parties only when necessary and legally permissible.
How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.
In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties, under strict data processing agreements.
What are your rights? Depending on where you are located geographically, you have certain rights regarding your personal information. In all regions, we comply with requests for data access, rectification, deletion, and other rights as required by applicable law.
How do you exercise your rights? Contact us to exercise your rights. We will consider and act upon any request in accordance with applicable data protection laws.
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide to us.
The personal information we collect may include the following, all of which you voluntarily provide to us:
• names
• email addresses
• contact preferences
• mailing addresses
• usernames
• phone numbers
• billing addresses
Sensitive Information. We do not process sensitive information unless it's crucial for our Services and with your explicit consent.
Payment Data. We collect data necessary to process your payment if you make purchases. All payment data is stored by Stripe. You may find their privacy notice link(s) here: https://stripe.com/gb/privacy.
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
Information automatically collected
In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.
Like many businesses, we also collect information through cookies and similar technologies.
The information we collect includes:
Log and Usage Data. Our servers automatically collect and log service-related, diagnostic, usage, and performance information when you access or use our Services. This log data may include details like your IP address, device information, browser type, operating system, and settings, as well as information about your activity in the Services (such as date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take, including which features you use), device event information (such as system activity, error reports or 'crash dumps', and hardware settings).
Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information like your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system configuration information, and system configuration information.
Location Data. We collect data about your device's location, which can be precise or imprecise. The extent of information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt-out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. Please note, opting out may affect the functionality of certain Services.
2. HOW DO WE USE YOUR INFORMATION?
In Short: We use your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with laws. In certain cases, we may also use your information for other purposes with your consent.
We use your personal information for a range of purposes, depending on how you interact with our Services, which include:
Facilitating account creation and authentication and managing user accounts.
Delivering and facilitating the delivery of services to the user.
Responding to user inquiries and offering support to users.
Sending administrative information to you about our products, services, changes to our terms, policies, etc.
Enabling user-to-user communications.
Protecting an individual's vital interest, for instance, preventing harm.
3. WHAT LEGAL BASES DO WE RELY ON TO USE YOUR INFORMATION?
In Short: We only use your personal information when we have a legitimate reason (legal basis) to do so under applicable laws, such as with your consent, to comply with laws, to provide you with services, to fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate business interests.
4. WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
In Short: We share your information under specific circumstances as described in this section, and/or with certain third parties.
Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf and require access to such information to do that work. These third parties are contractually obligated to protect your personal information and can only use it as instructed by us.
5. OUR USE OF COOKIES AND TRACKING TECHNOLOGIES
In a Nutshell: We might use cookies and other tracking technologies to collect and store your information.
We could use cookies and similar tracking technologies (like web beacons and pixels) to access or store your information. You can find detailed information about how we utilize these technologies and how you can decline certain cookies in our Cookie Notice.
6. THE DURATION OF STORING YOUR INFORMATION
In a Nutshell: We hold on to your information as long as it's needed for the purposes we outline in this privacy notice, or if required by law.
We only retain your personal information as long as it's needed for the purposes stated in this privacy notice, or for a longer period if the law requires or permits it. We won't require your personal information for more than two (2) months after you terminate your user account.
Once we no longer need to process your personal information for business reasons, we will either delete or anonymize it. If this isn't possible (for instance, your personal information is in backup archives), we will securely store your personal information and separate it from any further processing until we can delete it.
7. HOW WE PROTECT YOUR INFORMATION
In a Nutshell: We strive to keep your personal information safe using a mix of organizational and technical security measures.
We have put in place reasonable technical and organizational security measures to safeguard the personal information we process. However, no online system is entirely secure, so we can't promise that hackers, cybercriminals, or other unauthorized third parties won't be able to compromise our security and improperly collect, access, steal, or modify your information. While we'll do our utmost to protect your personal information, any transmission of personal information to and from our Services is at your own risk. We recommend only accessing the Services within a secure environment.
8. INFORMATION COLLECTION FROM MINORS
In a Nutshell: We don't knowingly collect data from or market to children under 18.
We don't intentionally collect data from or market to children under the age of 18. By using our Services, you affirm that you're at least 18, or that you're the parent or guardian of a minor and consent to the minor's use of the Services. If we find out that we've collected personal information from a user under 18, we'll deactivate the account and take reasonable steps to promptly erase such data from our records. If you discover any data we might have collected from children under 18, please contact us at info@creativefreedom.app.
9. YOUR PRIVACY RIGHTS
In a Nutshell: In certain regions, such as the European Economic Area (EEA), United Kingdom (UK), and Canada, you have rights that give you more control over your personal information. You can review, change, or end your account at any time.
In some areas (like the EEA, UK, and Canada), you have specific rights under the relevant data protection laws. These rights may include the ability to request access and get a copy of your personal information, to request changes or erasure, to restrict the processing of your personal information, and, where applicable, data portability. In certain situations, you may also object to the processing of your personal information. To make such a request, please contact us using the contact information provided in the 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' section below.
We will consider and act upon any request in line with the relevant data protection laws.
If you reside in the EEA or UK and believe we're unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. Here's where you can find their contact details: https://ec.europa.eu/
For Swiss Residents: If you're based in Switzerland, you can find the contact details for the data protection authorities here: https://www.edoeb.admin.ch/edoeb/en/home.html.
Revoking Your Consent: If we're using your consent, whether explicit or implied, to process your personal information as per the applicable law, you reserve the right to withdraw your consent at any given time. You can exercise this right by contacting us using the contact details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below or by updating your preferences.
Please be aware that your withdrawal won't affect the legality of the processing carried out before your withdrawal or the processing of your personal information performed on lawful processing grounds other than consent, if allowed by law.
Opting out of Marketing Communications: If you wish to unsubscribe from our marketing and promotional communications, you can do so at any time by clicking on the 'unsubscribe' link in our emails, or by contacting us using the details in the 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' section below. We will then remove you from our marketing lists. Nonetheless, we may still need to communicate with you for non-marketing purposes, such as sending you service-related messages essential for managing your account or responding to your service requests.
Account Information
If you ever want to review, change, or delete your account information, you can:
Access your account settings and update your user account.
Reach out to us using the contact information provided.
On your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information might be kept in our files to prevent fraud, troubleshoot issues, assist with investigations, enforce our legal terms and/or comply with legal obligations.
Cookies and Similar Technologies: Most web browsers are configured to accept cookies by default. However, you can usually modify your browser settings to remove or reject cookies. If you decide to remove or reject cookies, this could impact certain features or services of our Services. To opt out of interest-based advertising by advertisers on our Services, visit http://www.aboutads.info/choices/.
If you have any queries or comments about your privacy rights, please email us at info@creativefreedom.app.
10. GUIDELINES FOR DO-NOT-TRACK FEATURES
Many web browsers and some mobile operating systems and mobile applications offer a Do-Not-Track ('DNT') feature or setting you can enable to indicate your privacy preference of not having your online browsing activities monitored and collected. However, there is currently no agreed-upon standard for recognising and implementing DNT signals. Therefore, we do not currently respond to DNT browser signals or any other mechanism that automatically conveys your choice not to be tracked online. If a universally accepted standard for online tracking is established that we need to follow in the future, we will inform you about that practice in a revised version of this privacy notice.
11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if you're a resident of California, you're entitled to specific rights concerning your personal information.
California's 'Shine The Light' law, California Civil Code Section 1798.83, allows our users who are California residents to request and obtain from us, once a year and free of charge, information about the categories of personal information (if any) we have disclosed to third parties for direct marketing purposes in the preceding calendar year, along with the names and addresses of these third parties. If you are a resident of California and wish to make such a request, please submit it in writing using the contact information provided below.
If you're below 18 years of age, reside in California, and have a registered account with our Services, you have the right to request the removal of unwanted data that you have publicly posted on our Services. To request such removal, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will ensure the data isn't publicly displayed on the Services, but please note that the data might not be fully or comprehensively removed from our systems (e.g., backups, etc.).
CCPA Privacy Notice
The California Code of Regulations defines a 'resident' as any individual who is in the State of California for more than a temporary or transitory purpose and any individual who is domiciled in the State of California but is outside the State of California for a temporary or transitory purpose. All other individuals are categorized as 'non-residents'.
If you fall under the definition of 'resident', we are obliged to respect specific rights and obligations concerning your personal information.
What categories of personal information do we collect?
Over the past twelve (12) months, we've collected the following categories of personal information:
Category Examples Collected
A. Identifiers Real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name
YES
B. Personal information categories listed in the California Customer Records statute Name, contact information, education, employment, employment history, and financial information
NO
C. Protected classification characteristics under California or federal law Gender and date of birth
NO
D. Commercial information Transaction information, purchase history, financial details, and payment information
YES
E. Biometric information Fingerprints and voiceprints
NO
F. Internet or other similar network activity Browsing history, search history, online behaviour, interest data, and interactions with our and other websites, applications, systems, and advertisements
NO
G. Geolocation data Device location
NO
H. Audio, electronic, visual, thermal, olfactory, or similar information Images and audio, video or call recordings created in connection with our business activities
NO
I. Professional or employment-related information Business contact details, job title, work history, and professional qualifications
NO
J. Education Information Student records and directory information
NO
K. Inferences drawn from other personal information Profile reflecting a person's preferences, characteristics, etc.
NO
Besides these categories, we may collect personal information from you in situations such as:
· When you seek assistance via our customer support channels;
· When you participate in customer surveys or contests; and
· When you interact with us to facilitate our Services or respond to your inquiries.
How do we use and share your personal information?
More information about our data collection and sharing practices can be found in this privacy notice.
You can contact us by email at info@creativefreedom.app, or by referring to the contact details at the bottom of this document.
If you're using an authorized representative to exercise your right to opt out, we may reject a request if the representative fails to provide proof of valid authorization to act on your behalf.
Will we share your information with anyone else?
Your personal information may be disclosed to our service providers in accordance with a written agreement between us and each provider. Each provider is a profit-oriented entity that processes the information on our behalf.
Your personal information may be used for our internal business purposes, such as conducting research for technological development and demonstration. This usage does not constitute a 'sale' of your personal information.
Over the past twelve (12) months, Creative Freedom Team Limited has not sold any personal information to third parties for business or commercial purposes. However, we have disclosed the following categories of personal information for such purposes:
Category A. Identifiers including contact details like your real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name.
Category D. Commercial information such as transaction information, purchase history, financial details, and payment information.
Information about the third parties to whom we've disclosed personal information for a business or commercial purpose can be found under 'WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?'.
Your rights regarding your personal data
Right to request deletion — You can request the deletion of your personal information. Subject to certain exceptions dictated by law, we will respect your request and delete your personal information.
Right to be informed — Depending on the circumstances, you have a right to know:
· if we collect and use your personal information;
· the categories of personal information we collect;
· the purposes for which we use the collected personal information;
· if we sell your personal information to third parties;
· the categories of personal information we've sold or disclosed for a business purpose;
· the categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
· the business or commercial purpose for collecting or selling personal information.
We are not obligated by law to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.
Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights — We won't discriminate against you for exercising your privacy rights.
Verification process — We will need to verify your identity to process your request. We will use the information provided in your request to match it with information previously provided. Depending on the type of request, we may need additional information to verify your identity. Any additional information will be deleted once verification is complete.
Other privacy rights include:
· The right to object to the processing of your personal information.
· The right to request correction of your personal data if it's incorrect or no longer relevant, or ask to limit the processing of the data.
· The right to appoint an authorized representative to make a CCPA request on your behalf. We may reject a request from a representative who doesn't provide valid proof of authorization.
· The right to opt out from future selling of your personal information to third parties. Upon receiving an opt-out request, we will act upon it as promptly as possible, but no later than fifteen (15) days from the date of the request.
To exercise these rights, contact us by email at info@creativefreedom.app, or by referring to the contact details at the bottom of this document. If you have concerns about how we handle your data, we welcome your feedback.
12. DO WE UPDATE THIS NOTICE?
In Brief: Yes, we revise this notice as required to remain in line with applicable laws.
This privacy notice may be updated periodically. The 'Revised' date will indicate the latest version, which becomes effective as soon as it's accessible. If we implement significant changes to this privacy notice, we may inform you by posting a conspicuous notice of these changes, or by directly sending you a notification. We recommend regularly reviewing this privacy notice to stay informed about how we safeguard your information.
13. HOW CAN YOU REACH US REGARDING THIS NOTICE?
If you have any inquiries or comments about this notice, you may reach out to our Data Protection Officer (DPO), via email at info@creativefreedom.app, or via post to:
Creative Freedom Team Limited
Data Protection Officer
20-22 Wenlock Road
London N1 7GU
United Kingdom
14. HOW CAN YOU ACCESS, MODIFY, OR ERASE THE DATA WE GATHER FROM YOU?
Depending on the laws of your country, you may have the right to access the personal information we gather from you, modify that information, or delete it. To request to review, modify, or erase your personal information, please send an email to info@creativefreedom.app.
15. GOOGLE CALENDAR
User Data Policy - Creative Freedom: We access, use, store, and share Google user data for calendar-related services only, as described in our privacy policy. Data is stored securely, not shared with third parties, and users have control over their data.
Creative Freedom complies with the Google API Services User Data Policy, including the Limited Use requirements.
Creative Freedom use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.
Google API Services User Data Policy: https://developers.google.com/terms/api-services-user-data-policy
At Creative Freedom, we are committed to protecting the privacy and data of our users. This policy outlines how Creative Freedom accesses, uses, stores, and shares Google user data in accordance with our privacy policy.
Access: Creative Freedom may request and access Google user data through authorized Google Calendar scopes, including "See, edit, share, and permanently delete all the calendars you can access using Google Calendar," "View and edit events on all your calendars," "See, create, change, and delete events on Google calendars you own," and "See the events on Google calendars you own." This access is only used for the purpose of providing calendar-related services as described in our privacy policy.
Use: Creative Freedom uses Google user data to provide calendar-related services to our users, including scheduling and managing events, reminders, and notifications. We do not use the data for any other purpose without obtaining explicit consent from the user or as required by law.
Storage: Creative Freedom stores Google user data securely on our servers, using industry-standard security measures to protect against unauthorized access, loss, or theft. We retain the data only as long as necessary to provide the calendar-related services or as required by law.
Sharing: Creative Freedom does not share Google user data with third parties, except as required by law, with the user's explicit consent, or as necessary to provide the calendar-related services, such as sharing event invitations with other attendees. We do not sell or rent user data to any third party.
Privacy Policy: The use of Google user data by Creative Freedom is limited to what is described in this user data policy and our privacy policy. Our privacy policy provides additional information on how we collect, use, and protect user data, and it is incorporated by reference into this user data policy.
User Control: Users have control over their Google user data accessed by Creative Freedom, including the ability to revoke access or delete their data. Users can manage their preferences and permissions through their Google account settings or by contacting Creative Freedom support.
By using Creative Freedom's services that involve Google user data, users agree to the terms of this user data policy and our privacy policy.