Privacy Policy
Effective Date:
January 1, 2015
Introduction
HowToGetCreative.com, along with its subsidiaries and affiliates (collectively, “we,” “us,” “our,” “Company,” “The Company,” or “The Website”), provides digital media services through various online platforms (our “Websites”). This Privacy Policy applies to The Websites that link to this policy and details how we collect, utilize, and disclose information about you when you access our Website(s) or engage with us in other ways. Specific applications and parts of our Website may be subject to additional terms, which will prevail in the event of any inconsistency with this Privacy Policy.
Privacy Practices and Legal Compliance
Our privacy practices are aligned with the legal requirements of the regions where we operate, incorporating region-specific provisions that apply only to customers situated in certain geographic areas or as mandated by law.
Data Privacy Notice
Certain data privacy laws across various states provide rights related to the personal information of natural persons (“Consumer,” “you,” or “your”) that we may collect, use, disclose, sell, or share. This Data Privacy Notice (“Notice”) supplements our Privacy Policy and explains how we handle your personal information—whether collected through HowToGetCreative.com, during communications with us, when you purchase products, or as part of our general business operations.
This Notice is designed to inform you of your rights and further clarify our practices in the collection, use, and sharing of personal information. All defined terms within applicable data privacy laws are to be interpreted as intended within this Notice. Any capitalized term used in this Notice that is not specifically defined will carry the meaning assigned to it in our Privacy Policy.
By accessing or using HowToGetCreative.com, submitting information to us, or otherwise acknowledging this Notice, you agree to and consent to the collection and use of your personal information as outlined in this Notice and our Privacy Policy.
Changes to This Privacy Policy
We may update this Privacy Policy periodically. When changes are made, we will update the policy's date and may provide further notice by posting an announcement on the homepage of our website or by sending you a notification. By continuing to use our Website or Services after these changes, you acknowledge, consent to, and agree to adhere to the updated Privacy Policy. We encourage you to review the Privacy Policy regularly when you use our Services or interact with us to stay informed about how we manage your information and the options available to you.
Scope of This Policy
This Privacy Policy outlines our approach to handling your personal data (“processing”) when you engage with our Services, including when you:
- Access our Websites and any other platforms or applications that refer to this Privacy Policy.
- Create and manage an account with us.
- Conduct transactions or make payments through our services.
- Subscribe to, or participate in, our electronic newsletters or other communications.
- Interact with our social media channels.
- Click on advertisements we post on third-party websites.
- Communicate with our service representatives or utilize communication features such as chat, email, text, or phone.
- Have other interactions with us.
Additionally, this Privacy Policy covers personal information we may receive about you from third parties.
Exceptions to This Policy
However, this Privacy Policy does not cover:
- Third-Party Sites: This includes websites, applications, videos (whether embedded or directly linked), or other content (each referred to as a “Linked Site”) that we link to but do not operate. Our links to other sites do not imply endorsement, and this Privacy Policy only covers your use of our Websites and Services. We are not responsible for the privacy practices of any external sites linked from or to our Website, and you should review the privacy statements of each website you visit to understand how they collect and use your information.
- Workforce and Recruitment Information: The personal data of job applicants, candidates, and our employees is not covered by this Privacy Policy.
- Non-Personal Data: We may process data that does not identify or cannot be linked back to an individual, including aggregated non-identifying information, for any legitimate business purpose without falling under the guidelines of this Privacy Policy.
Personal Data Collection and Usage
The term “personal information” or “personal data” varies in definition across different jurisdictions. For this Privacy Policy, it refers to information that can identify an individual on its own or in combination with other data.
The type of personal information we collect from you depends on your interactions with us and our Services. It is also influenced by your choices regarding the Services, the features you enable, your location, the devices you use, and the legal requirements applicable. Below are the categories and methods of personal information we collect:
Information We Collect
We collect any information you voluntarily provide or submit through various means, as detailed in our Data Privacy Notice. This includes creating an online profile, logging in through social media, engaging with interactive features on our Service, making purchases online or in-store, contacting customer support, joining contests, and promotions, or subscribing to our mailing lists. Additionally, if you reach out to us via email, phone, or any other form of communication, we may gather relevant information from those interactions. For example, when completing a purchase through our Service, we may collect details such as your name, billing and shipping address, payment information, phone number, and email address.
Automatically Collected Information: When you interact with our Service, emails, or online ads, certain types of data are automatically gathered and stored. This may include details such as your IP address, browsing behavior on our site, device and browser specifications, referring URLs, operating system details, and any third-party links, partner offers, advertisements clicked, or content accessed or downloaded from the Service. Additionally, information may be collected through third-party vendors integrated with our Service.
Email and Support Tickets: When you contact us via email or through our support ticket system, we collect any information you provide within those communications, including the content of your messages and any additional details necessary to assist you.
Personal Information Provided by You
- Identifying Information: This includes your name, email, phone number, physical address, gender, and other contact or identification details.
- Account and User Identifiers: Such as usernames, screen names, customer numbers, or other unique identifiers.
- Marketing Preferences: Your choices regarding receiving marketing communications from us.
- User-Generated Content: Any emails, messages, photos, videos, or other content you submit or post.
- Survey and Feedback Data: Information you provide through surveys, contests, or promotions.
- Contest and Event Entries: Personal details submitted during contests, sweepstakes, or prize drawings.
- Communication Data: Details of your interactions with our communications, such as whether you open them or engage with them.
- Social Media Interactions: Information from social media interactions and registrations.
- Additional Information: Any other personal information you provide for specific services or features.
- Inferred Data: Personal information inferred based on the data you provide or your interactions with us.
- Chat Interactions: Information collected through our live chat features.
- Payment Information: Details of transactions and payments, such as payment card numbers and banking details.
- Geolocation Data: Either derived from your IP address or provided by you directly to enhance service personalization and legal compliance.
Personal Information Derived Through Service Use
We may engage third parties to provide analytics services and deliver targeted advertising on our behalf across the Internet and mobile applications. The technologies they use, like cookies and web beacons, help in collecting information that includes:
- Device and Browser Details: Identifiers that point to your device or browser.
- General Location Data: A broad approximation of your location, short of precise GPS details.
- Browsing and Search History: Records of what you view and search for on our sites.
- Interaction Records: Real-time data of your interactions on our sites, potentially recorded as videos to improve website functionality.
- Log and Usage Data: Information on how you use our site, including the features you interact with.
- Engagement and Advertising Data: Metrics on your engagement with ads and content on our sites.
- Video Viewing History: Details of the videos you watch on our sites.
Information from Third Parties
While most personal data is collected directly from you, we may also gather information via third parties, such as identity verification services, credit agencies, or public databases. Additionally, if you link your account through a social media or third-party service, we access certain information as authorized by those services.
Note: Information may also be collected about individuals who are not registered as users, particularly if shared by others in their networks or through their interactions on our platforms.
Utilization of Your Personal Information
We use your personal information for a range of purposes based on your interactions with our Services. These purposes include:
- Service Delivery: Providing you with our services, which encompasses customer support, communications, and security. This includes sending newsletters you've subscribed to, adding you to our mailing lists, informing you of changes to terms or policies, and offering you special deals from third parties via our services.
- Policy Compliance: Enforcing our terms of service, acceptable use, anti-spam, and similar policies.
- Marketing Activities: Sending you advertising and marketing materials through physical and electronic channels, conducting market research and analytics, developing new products, and related activities.
- Targeted Advertising: Customizing ads based on your interaction contexts with our site or app, utilizing tracking technologies such as cookies and pixels, and enabling site features like geo-specific pricing or logging.
- Interaction and Ad Metrics: Auditing interactions with our site or apps, counting ad impressions to unique visitors, verifying the position and quality of ad impressions, and other related activities.
- Customer Support: Offering customer support, maintaining and servicing accounts, training staff for quality assurance, and similar functions.
- Fraud and Security: Detecting and preventing security incidents and illegal or fraudulent activities and prosecuting those responsible.
- Transaction Processing: Processing orders and transactions, verifying customer information, processing payments, determining eligibility for promotions, and similar operations.
- Public Health Measures: Implementing screenings or checks for public health and safety, such as COVID-19 symptom checks.
- Legal and Claims Management: Investigating and responding to legal disputes, claims, or litigation, and complying with law enforcement requests as mandated by law, court orders, or government regulations.
- Employment Processes: Determining employment eligibility, verifying references and employment history, and conducting background checks.
- Benefits Management: Processing claims and administering benefits as required by law.
- Internal Communications: Contacting our employees or those listed as emergency contacts.
- Corporate Transactions: Evaluating or executing mergers, divestitures, restructurings, dissolutions, or other asset transfers, including during bankruptcy or liquidation, where user information may be transferred as one of the assets.
- Additional Uses: Your personal information may be described at the point of its collection or as otherwise outlined in the CCPA.
How We Share Your Personal Information
In addition to our use of your personal information, we may share your data under the following circumstances:
- Authorized Parties: When you give us permission, we may share your information with third parties whom you have authorized.
Business Services Providers:
We partner with various service providers to support our business operations, which include:
- IT Operations: Such as cloud computing, website hosting, customer service, email delivery, internet services, data security and backup, infrastructure, and other similar services.
- Operational Support: Day-to-day business operations support from entities like payment processors (e.g., Stripe, Shopify), security vendors, business software services, banks, and others.
- Professional Advisors: Lawyers, accountants, auditors, consultants, and security experts we consult for legal, and contractual compliance, or to protect ourselves from fraud or attacks and ensure the safety of our operations, customers, and the public.
- Marketing and Advertising: Entities involved in advertising and marketing efforts such as direct marketing, lead generation, affiliate programs, retargeting platforms, data brokers, ad networks, and marketing consultants.
Affiliates: We may share information with our parent companies, affiliates, subsidiaries, or other entities under common control and ownership.
Legal and Compliance: To entities or individuals when necessary or appropriate, including under legal processes like subpoenas or court orders, to respond to public and government authority requests, to enforce our Terms and Conditions, and to protect our rights, privacy, safety, or property, as well as to pursue remedies or limit damages.
Business Transactions: In the event of mergers, acquisitions, consolidations, asset sales, bankruptcy, reorganization, or other business transactions, and during subsequent integration phases.
Authorized Disclosures: To any party, as authorized by the individual whose information is being shared.
Non-Personal Information: We reserve the right to use and disclose non-personal information as permitted by law, except as restricted by this Privacy Policy.
Publicly Posted Content
Users of this site may post content to various public forums, such as user-generated pages, chat rooms, and bulletin boards available on our website. Be aware that any personal information you voluntarily disclose in these forums may be collected and used by others, potentially resulting in unsolicited communications. You are responsible for the personal information you choose to share in these settings. Exercise caution when engaging in these public areas. You can request the removal of your posted content by submitting a Support Ticket and specifying the content you wish to have removed. Please note, however, that removing content may not ensure the complete deletion of all traces of the content from our forums.
Data Retention
We retain your personal information only as long as necessary to fulfill the purposes for which it was collected, including legal, accounting, or reporting requirements. The retention period for personal information is determined by considering its quantity, nature, and sensitivity; the potential risk of harm from unauthorized use or disclosure; the purposes for processing your personal information and whether these can be achieved by other means; and applicable legal requirements. Under certain conditions, you may request that we delete your information. We may also anonymize your personal information for research or statistical purposes, in which case it can be used indefinitely without further notification to you.
Data Security
We implement reasonable security measures to protect your personal information from unauthorized access, destruction, use, modification, or disclosure, tailored to the nature of the data. While we strive to secure your information, no security system is infallible. Data protection laws vary by country, offering different levels of protection. Regardless of processing location, we apply the same protective measures across all data.
Our Clients
For clients and business partners of this site, the contractual agreements between your company and us will supersede this Privacy Policy where there are discrepancies.
International Data Transfers
We operate from the United States and may transfer personal information to countries outside your jurisdiction, including the United States, for processing. The laws governing personal information in the United States or other countries may differ from those in your country. These transfers may involve transferring data to service providers in other jurisdictions. We strive to ensure that all service providers align with our privacy and security standards and comply with applicable privacy laws.
Cookie Policy
CCPA Compliance:
When you visit our website(s), we store cookies on your browser to collect information related to you, your preferences, or your device. This information ensures that our site functions properly and enhances your personalized web experience. While you have the option to block certain types of cookies, please note that doing so may affect your experience and the services we offer. However, you cannot opt out of our First Party Strictly Necessary Cookies, as they are essential for the proper operation of our site. Additionally, some cookies used for analytics or advertising may fall under the definition of a “sale” or “sharing” of personal information under applicable laws. You may opt out of this by selecting “Do Not Sell or Share My Personal Information” or enabling Global Privacy Control in supported browsers or extensions.
GDPR Compliance:
We use cookies to deliver content or ads, measure their effectiveness, and create a personalized experience. This information is shared with our partners, based on your consent, through the Transparency and Consent Framework. You have the ability to manage your consent preferences, either for specific purposes or at a partner level, using the provided links under each purpose. Your choices are communicated to our vendors within this framework.
IAB Framework:
We use cookies to deliver content or ads, measure their effectiveness, and create a personalized experience. This information is shared with our partners, based on your consent, through the Transparency and Consent Framework. You have the ability to manage your consent preferences, either for specific purposes or at a partner level, using the provided links under each purpose. Your choices are communicated to our vendors within this framework.
Cookies Usage and Information:
Cookies help us deliver and enhance the use of our Service, optimize user experiences, and serve relevant ads based on your interaction with our websites. We also use cookies to track ad impressions, understand how our ad services are used, and how these interactions are linked to visits on our site. For instance, cookies allow us to recognize you as a returning user, provide personalized content, and improve your overall experience with our Service.
By default, most browsers accept cookies automatically, but you can choose to adjust your browser settings to decline them. However, be aware that refusing cookies might limit your access to certain features or functionality of our Service, such as logging into your account.
For more details about cookies and how they work, please visit www.aboutcookies.org. Additionally, to learn more about targeted advertising and how to opt out, you can visit the Digital Advertising Alliance’s website at https://www.aboutads.info/choices or the Network Advertising Initiative at https://www.networkadvertising.org/choices.
Data Privacy Laws:
If you reside in a state with enacted data privacy laws (such as California), please review our Data Privacy Notice and Notice at Collection for more details tailored to your jurisdiction.
Purposes for Collecting Your Information:
According to this Policy, the information we collect may be used for several purposes, which include:
- Providing the goods or services you have requested;
- Completing transactions where your personal information is collected;
- Fulfilling any contractual obligations between you and us;
- Using your information in ways that you would reasonably expect within our ongoing business relationship;
- Performing services on our behalf;
- Ensuring security and integrity, to the extent that your personal information is reasonably necessary and proportionate for such purposes;
- Delivering services or goods that you would reasonably expect;
- Short-term use, such as displaying non-personalized ads during your current interaction with us, provided that your information is not shared with third parties or used to build a profile about you or alter your experience beyond the present interaction;
- Verifying or maintaining the quality or safety of any service or device owned, manufactured, or controlled by us;
- Offering advertising and marketing services to you;
- Complying with federal, state, or local laws, or responding to a court order or subpoena;
- Cooperating with law enforcement agencies in cases where we have a reasonable and good faith belief that a law may have been violated;
- Responding to civil, criminal, or regulatory inquiries, investigations, subpoenas, or summons by authorities at any level (federal, state, or local);
- Exercising or defending against legal claims.
Data Privacy Notice for Specific States:
For residents of states that have adopted specific data privacy laws (e.g., California), please fully review our Data Privacy Notice herein and Notice at Collection to obtain further information pertinent to your rights and our practices.
Disclosure of Your Information
We use the information we collect to enhance our Service's content and quality. Without your explicit consent, we do not sell, share, license, or disclose your personal information to third parties for commercial purposes, except in the following situations: (a) to provide and operate the Service, (b) when you grant us permission, and/or (c) in the instances outlined below:
- Affiliates: We may share the information collected with our subsidiaries and affiliates for operational, marketing, or promotional activities.
- Service Providers: Your information may be shared with service providers who assist in various business operations, such as web hosting, storage, shipping, fulfillment, mobile marketing, analytics, call center services, sweepstakes management, and payment processing. When engaging these providers, we ensure they handle personal information appropriately through contractual obligations or other suitable safeguards, aligning with this Policy. The specific entities acting as service providers are listed in our Data Privacy Notice.
- Legal Disclosures and Business Transfers: We may disclose your information when required by law, without your consent, particularly if compelled by a court order or an authorized entity with jurisdiction to demand such information (e.g., subpoenas). Moreover, if there are reasonable grounds to suspect that the information could aid in investigating or preventing illegal activities (such as suspected fraud, potential threats to physical safety, or breaches of our Terms of Use), we may share this information voluntarily with law enforcement or investigative bodies.
- Business Transactions and Transfers: In the event of a merger, acquisition, reorganization, change of control, asset sale, or bankruptcy, we may sell, transfer, or disclose some or all assets, including any personal information collected from you, as part of such transactions.
State-Specific Data Privacy Laws:
If you are a resident of a state with a specific data privacy law (such as California), please click here to view our Data Privacy Notice and Notice at Collection for further information relevant to your jurisdiction.
Links to Third-Party Websites
Our Service includes links to external websites. If you decide to visit an advertiser by clicking on a banner ad or another form of advertisement, or if you click on a third-party link, you will be taken to that third party’s site. Please note that providing a link or displaying an advertisement does not imply our endorsement, authorization, or affiliation with the third party, nor does it signify our approval of their privacy practices or information security policies. We do not control or manage the content or policies of these third-party websites.
These external sites may use their own cookies or other tracking technologies, collect your data, or request personal information. Since these websites may have their own policies regarding the use and disclosure of the personal data you provide, we strongly recommend reviewing the privacy policies or statements of any third-party sites you choose to visit.
Social Media Sharing
Our Service may include social sharing features or integrated tools from platforms like Facebook, Twitter, Instagram, YouTube, and Pinterest, which allow you to share your activities on our Service with other media, and vice versa. Using these features can result in information being shared with your friends or made public, depending on the privacy settings you establish with the social media provider. Linking to or offering tools for social media sharing does not imply our endorsement, authorization, or affiliation with these social media sites, nor does it represent our support for their privacy or security practices.
For more information regarding the data collection and processing associated with social sharing features, please review the privacy policies of the respective third parties offering these services.
Securing Your Personal Information
We take steps to protect your personal information and ensure it is secure from loss, theft, unauthorized access, or disclosure. However, it’s important to note that no e-commerce solution, website, mobile app, database, or system can be entirely secure or immune to hacking. Therefore, it is also your responsibility to take reasonable measures to protect your personal information from unauthorized access or misuse.
Text Messages
You may opt in to receive recurring text messages from us, which may include updates about our products, services, offers, promotions, news, events, and other information. If you wish to cancel these messages, simply text “STOP.” Once we receive your “STOP” message, we will send a confirmation text to verify your unsubscription, and you will no longer receive messages from that short code. Should you have any questions about the text messages, you can text “HELP” to receive instructions on how to contact us. Please note that message and data rates may apply, and we are not responsible for any delayed or undelivered messages.
We will not share your mobile number with any third party, including affiliates or subsidiaries, based on your choice to receive our text messages, except as required by applicable law or as permitted under this Policy.
Your Privacy Preferences
You have several options to manage the collection and use of your personal information:
Adjusting Communication Preferences
- Emails from us: Upon registering on our website, you'll have the option to opt-in for email communications. If you decide later that you no longer wish to receive these emails, you can unsubscribe by clicking the link at the bottom of our emails, or by contacting us here, Contact Us. Please note that opting out of marketing or newsletter emails will not exempt you from receiving transactional emails related to your account, legal updates, or other necessary communications, which are not optional.
- Text Messages: You can opt out of automated text notifications by texting “STOP,” or another keyword we provide. Essential communications about your account or safety may still be sent to you.
Blocking Cookies
- Browser Settings: Most browsers accept cookies by default, but you can adjust your browser settings to decline them. Below are links for managing cookies on popular browsers:
- Google Analytics: To opt out of Google Analytics across websites, follow these instructions from Google. For details on Google's privacy practices, visit their privacy page.
- Interest-Based Ads: To opt out of interest-based advertising, visit Your Ad Choices and Manage My Browser’s Opt-Outs. Mobile device settings may also be configured to limit ad tracking:
- iOS: Limit Ad Tracking
- Android: Opt Out of Ads Personalization
Please note that opting out via these methods will still allow advertisements to be displayed, but they will not be based on your behavioral data. Additionally, the opt-out process for behavioral ads relies on cookies, so you will need to perform the opt-out on each device or after clearing your cookies.
Your Privacy Rights
We recognize that certain jurisdictions grant individuals specific privacy rights. The extent of these rights can vary, but generally include:
- Access and Portability: The right to be informed of, or receive a copy of, the personal information we hold about you.
- Deletion/Restriction: The right to request the deletion or restriction of your personal information, except under certain conditions.
- Correction/Rectification: The right to have inaccurate personal information we hold corrected.
- Opt-Out of Sale/Sharing: The right to opt-out of the sale of your personal information to third parties, which may include certain types of targeted advertising.
- Revoke Consent: Where processing is based on consent, you may withdraw that consent at any time.
- Object to Processing: The right to object to processing based on public interest, official authority, or our legitimate interests, unless we demonstrate overriding legitimate grounds or need to process the information for legal claims.
- Limitation/Restriction: The right to limit or restrict our use or disclosure of your personal information.
- Opt-out of Profiling/Automated Decision-Making: The right to opt-out of profiling and automated decisions that have legal or similarly significant effects on you.
- Non-Discrimination: The right not to be discriminated against for exercising any of these rights. This includes modifications to pricing, quality, or level of service or goods.
You also have the right to lodge a complaint with a governmental authority if you believe your privacy rights are being violated.
We are committed to honoring these rights in accordance with applicable laws and will not discriminate against individuals for exercising their privacy rights.
Exercising Your Privacy Rights
You can exercise your rights regarding access, deletion, correction, and restriction by using our Privacy Portal or by contacting us here, Contact Us. We aim to respond to your requests promptly and in accordance with legal requirements. Should we need additional time to process your request, we will inform you of the extension and the reasons for the delay. If we decide not to fulfill a request, we will provide you with our reasons and, if applicable, instructions on how to appeal our decision.
Children’s Privacy
Our services are not designed for individuals under the age of 16. We do not knowingly collect or use personal information from children under 16. If it comes to our attention that we have collected personal information from a child under 13 without verified parental consent, we will remove that information promptly. If you suspect that a child under 13 has provided us with their personal information, please contact us here, Contact Us
Jurisdiction-Specific Privacy Disclosures
Members of the European Economic Area, the United Kingdom, and Switzerland
Legal Grounds for Processing Your Personal Information
We process your personal information in accordance with legal requirements and our contractual obligations. Failing to provide the required information may impede our ability to fulfill these obligations.
We collect and process your personal data with your consent where required by law and based on our legitimate need to provide services. In the European context, the legal bases for processing your information include:
- Contractual Necessity: We process your information as necessary to fulfill our contract with you, for example:
- Creating and maintaining your account.
- Transferring information outside the EU to the United States as part of providing our services.
- Consent: We process certain information based on your explicit consent, which you may withdraw at any time. Such processing includes:
- Use of cookies and similar technologies.
- Verification methods to confirm your address or collect location data.
- Tailoring advertisements based on your online activities and partner data.
- Sending marketing communications as permitted by law.
- Legal Obligations: We may process your information to comply with legal obligations, respond to legal requests, or for tax compliance.
- Vital Interests: In emergencies, we process information to protect your life or safety or that of others.
- Legitimate Interests: We process information to support our legitimate interests or those of third parties while ensuring your rights and interests are considered. This includes:
- Improving and developing our services and understanding user relationships.
- Providing targeted advertising and analyzing its effectiveness.
- Sending marketing communications based on our legitimate interests, except where consent is required by law.
- Sharing information for legal and safety reasons with law enforcement as necessary.
Where we process your information based on legitimate interests, you have the right to object. Upon objection, we will stop processing your information for that purpose unless compelling legitimate grounds for the processing override your interests, or it is necessary for legal claims.
You have the right to lodge a complaint with a supervisory authority if you believe your personal data is being processed unlawfully. If related to EU and UK GDPR, or Swiss data privacy laws, you can lodge a complaint with an authority in your residence, workplace, or the place of alleged infringement. For EU matters, find your authority on the European Data Protection Board's website. For UK matters, contact the Information Commissioner’s Office. Detailed contact information for local Data Protection Authorities can be found here.
Collection and Use of Personal Information
Before collecting or using any personal information, we will inform Consumers of the categories of personal information to be collected or used (including sensitive personal information), the purposes for which those categories will be collected or used, and whether such information is sold or shared. We will not collect or use additional categories of personal information or use existing information for new purposes without first providing Consumers with notice. We will also inform Consumers of the period we intend to retain each category of personal information, including sensitive information. Given that personal information may be collected or used for varying purposes, a precise retention period cannot be provided for every category. However, we can confirm that each category of personal information will be retained for a period that is reasonably necessary to achieve the disclosed purpose (including exercising or defending legal claims or as required by applicable law).
The categories of personal information collected or used, the purposes for which each category is collected or used, and the intended retention period for each category are detailed in our Notice at Collection.
Request to Delete
Consumers have the right to request the deletion of any personal information that has been collected or maintained about them.
Unless an exemption applies or it is impossible or requires disproportionate effort, we are obligated to delete the personal information from our records, inform any service providers or contractors to delete the information from their records, and notify all third parties to whom such information has been sold or shared. This must be done within 45 days of receiving a request (or within 90 days if a written notice of a 45-day extension is provided within the initial 45-day period). To submit a request via HowToGetCreative.com, please submit a Support Ticket. You may also submit a request by contacting our Customer Support team here, Contact Us. Please note, that we are not required to respond to requests that are manifestly unfounded or excessive.
Each request requires that the Consumer provide their name, postal address, and email address. We will verify these details by matching them against the information we have previously collected. If the provided data points cannot be matched, we will notify you in our response to your request. All communications will be sent to the email address provided.
Upon submitting a request, you will need to authenticate your email address within seven (7) days. Failure to authenticate your email within this period will result in your request not being processed.
Please be aware that we are not required to fulfill a deletion request if it is necessary for us or our service provider to retain the personal information in order to:
- Complete the transaction for which the personal information was originally collected.
- Fulfill the terms of a written warranty or conduct a product recall in compliance with federal law.
- Provide a good or service requested by the Consumer.
- Deliver a good or service that the Consumer can reasonably expect within the context of our ongoing business relationship.
- Perform a contract between HowToGetCreative and the Consumer.
- Ensure security and integrity, as long as the use of the Consumer’s personal information is reasonably necessary and proportionate for those purposes.
- Debug and identify or repair errors that impair existing or intended functionality.
- Enable internal uses that are reasonably aligned with the expectations of the Consumer based on their relationship with HowToGetCreative and are compatible with the context in which the Consumer provided the information.
- Comply with any legal obligation.
Request to Correct
Consumers have the right to request corrections to any inaccurate personal information we hold. If you are a registered user on HowToGetCreative.com, you can use the “My Account” self-service feature to update your information. Please note that we cannot modify personal information related to orders that have already shipped. However, if your order has not yet been dispatched, you may contact Customer Service to make corrections. Additionally, if you need to correct personal information tied to promotional emails, simply click the “unsubscribe” link within a promotional email and then re-subscribe using the updated information.
For employees or prospective employees, please be aware that modifying your personal information may have important implications, such as affecting employment verification. Therefore, you should contact your supervisor or the appropriate representative/department to correct any details.
If you still wish to submit a correction request, you can do so by contacting our Customer Support team here, Contact Us.
Please note that a request to correct may be denied if we have already refused the same correction within the past six months. However, if you provide new or additional documentation proving the inaccuracy of the information, we will treat it as a new request. Upon request, we will disclose the specific pieces of personal information we maintain to confirm that the necessary corrections have been made. This disclosure will not be counted as a “request to know” that is subject to the limitation of two requests within a 12-month period.
For sensitive personal information, we will not disclose the actual data but may provide a method for you to confirm that the information we maintain matches what you have provided.
Request to Know
Consumers have the right to request specific information about the personal data we collect, use, disclose, sell, and share. This includes:
- The categories of personal information we have collected about you.
- The categories of sources from which we collected the personal information.
- The business or commercial purpose for collecting, selling, or sharing personal information.
- The categories of personal information sold, shared, or disclosed for a business purpose, and the categories of persons to whom it was disclosed.
- The categories of third parties to whom we disclosed personal information.
- The specific pieces of personal information we have collected about you (you have the right to request these specific details).
We are required to provide the above information within 45 days of receiving a request (or within 90 days if we provide a written notice of a 45-day extension during the initial period). To submit a request for categories of personal information, please contact our Customer Support team here, Contact Us. Note that we are only obligated to respond to such requests up to two times within a 12-month period.
When submitting a request, you will need to provide your name, postal address, and email address. To verify your identity, we will match these details against our records. If we are unable to match the data points, we will inform you in our response to your request. All communications will be sent to the provided email address.
After your request is submitted, you will be asked to authenticate your email address within seven (7) days. If you fail to authenticate within this period, your request will not be processed.
Specific Pieces of Personal Information
To obtain specific pieces of personal information collected about you, please submit a request via HowToGetCreative.com. You can do so by contacting our Customer Support team here, Contact Us. Please note that we are only required to respond to such requests up to two times within a 12-month period.
Each request must include your name, postal address, and email address. Our verification process involves matching these details against our records. If we are unable to match the provided data with the information in our possession, we will inform you in our response to your request. All communications regarding your request will be sent to your provided email address.
After you submit a request, you will be required to authenticate your email address within seven (7) days. If you do not complete this authentication within the specified period, your request will not be processed.
Opt Out of Sale or Sharing of Personal Information
We will not sell or share personal information with a third party unless the Consumer has received explicit notice and has been given the opportunity to opt out.
Certain cookie uses on HowToGetCreative.com—such as for analytics and advertising—may be considered a “sale” or “sharing” of personal information under data privacy laws. You can opt out of these uses by contacting our Customer Support team here, Contact Us or by enabling the Global Privacy Control feature available in certain browsers or extensions. For clarity, “share” or “sharing” means any disclosure, dissemination, transfer, or communication of a Consumer's personal information to a third party for cross-context behavioral advertising in which no money is exchanged.
We do not sell or share the personal information of any Consumers known to be under 16 years of age unless we obtain affirmative consent. Specifically:
Currently, we do not have actual knowledge of selling or sharing the personal information of any Consumers under the age of 16.
If a Consumer directs us not to sell or share their personal information—we will be prohibited from doing so unless subsequent consent is provided by the Consumer (or the parent or guardian for any minor).
Limit the Use of Sensitive Personal Information
Consumers have the right to limit the use of Sensitive Personal Information. However, we are permitted to use such information without limitation for the following purposes:
- To provide services or goods that a typical Consumer would reasonably expect based on their request.
- To prevent, detect, and investigate security incidents that could compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted personal information.
- To resist malicious, deceptive, fraudulent, or illegal actions against us and to take legal action against those responsible.
- To ensure the physical safety of individuals.
- For short-term, transient use, such as displaying non-personalized advertising as part of a Consumer’s current interaction with us, provided that the information is not disclosed to third parties or used to build a profile or alter the Consumer’s experience outside of their current interaction.
- To perform services on our behalf.
- To verify or maintain the quality or safety of a product, service, or device that is owned, manufactured, or controlled by us.
- To improve, upgrade, or enhance a product, service, or device that is owned, manufactured for, or controlled by us.
- To collect or process sensitive personal information when the purpose is not to infer characteristics about a Consumer.
Since we only use Sensitive Personal Information for the purposes listed above, it is not necessary to submit a request to limit its use.
Discrimination Prohibited
We are prohibited from discriminating against any Consumer who exercises their rights under data privacy laws. This means we cannot:
- Deny goods or services to a Consumer.
- Charge different prices or rates for goods or services, including applying discounts, offering benefits, or imposing penalties.
- Provide a different level or quality of goods or services.
- Imply that a Consumer will receive a different price, rate, or quality of goods or services based on exercising their privacy rights.
- Retaliate against an employee, job applicant, or independent contractor for exercising their privacy rights.
However, we may offer different prices, rates, or levels of service if such differences are reasonably related to the value of the Consumer’s data.
Please note that we are permitted to offer loyalty programs, rewards, premium features, discounts, or club card programs in a manner that complies with data privacy laws.
We may also provide financial incentives related to the collection, sale, sharing, or retention of personal information. If a financial incentive is provided, it may involve a different price, rate, or level of service that is reasonably connected to the value of the Consumer’s data.
In cases where financial incentives are offered, we will provide appropriate notice in accordance with data privacy laws. Should a Consumer decline to provide opt-in consent for such incentives, we will not request opt-in consent again for at least 12 months, as required by law.
Participation in any financial incentive program will only occur with prior opt-in consent from the Consumer. This consent will clearly outline the material terms of the program and may be withdrawn at any time by the Consumer.
We are committed to ensuring that any financial incentive practices we employ are fair, reasonable, and not coercive or exploitative in nature.
Categories of Personal Information Collected
Below is a summary of the categories of personal information we have collected about Consumers over the past 12 months, as well as the categories we may collect based on your interactions with us—whether as a customer, employee, or prospective employee. Please note that “Consumers” encompasses both employees and prospective employees; therefore, information collected within the employment context is included here as well.
For each category of personal information we collect, we will specify:
- The sources from which we obtain this information.
- The business or commercial purposes for which we collect and use the information.
- The categories of third parties to whom we disclose personal information.
Personal Identifiers
Sources | Business or Commercial Purpose(s) | Categories of Third Parties |
---|---|---|
Consumers; Operating Systems and Platforms; Service Providers; Social Networks; Advertising Networks; Data Analytics Providers; and Government Entities | – Provide a good or service requested by the Consumer. – Complete a transaction for which personal information was collected. – Anticipated uses within the context of our ongoing business relationship with the Consumer. – Ensure security and integrity, as necessary and proportionate for these purposes. – Provide advertising and marketing services. – Comply with federal, state, or local laws, or court orders/subpoenas. – Respond to civil, criminal, or regulatory inquiries, investigations, subpoenas, or summons from authorities. – Cooperate with law enforcement agencies as needed to address conduct or activity that may violate the law. – Exercise or defend legal claims. – Perform a contract between HowToGetCreative and the Consumer. – Perform services on our behalf. – Provide services or goods reasonably expected by an average Consumer. – Undertake activities to verify or maintain the quality or safety of services or devices. – Short-term use, provided the Consumer’s personal information is not shared with another third party or used to build a profile beyond the current interaction. | Advertising Networks; Data Analytics Providers; Government Entities; Operating Systems and Platforms; Social Networks; Service Providers |
Other Information Identifying or Relating to a Particular Individual
Other Information Identifying or Relating to a Particular Individual | ||
---|---|---|
Sources | Business or Commercial Purpose(s) | Categories of Third Parties |
Consumers | – Complete transactions for which personal information was collected. – Provide goods or services requested by the Consumer. – Uses anticipated within the context of our ongoing business relationship with the Consumer. – Ensure security and integrity, to the extent the use of personal information is reasonably necessary and proportionate for those purposes. – Comply with federal, state, or local laws, including court orders or subpoenas. – Address civil, criminal, or regulatory inquiries, investigations, subpoenas, or summons by authorities. – Cooperate with law enforcement regarding activities that may reasonably be believed to violate laws. – Exercise or defend legal claims. – Help to ensure the security and integrity of personal information, to the extent it is reasonably necessary and proportionate for these purposes. | Service Providers; Government Entities; Operating Systems and Platforms |
Characteristics of Protected Classifications Under State or Federal Law
Sources | Business or Commercial Purpose(s) | Categories of Third Parties |
---|---|---|
Consumers; Social Networks; Advertising Networks; Data Analytics Providers; Operating Systems and Platforms; Government Entities | – Provide goods or services requested by the Consumer. – Complete transactions for which personal information was collected. – Anticipated uses within the context of our ongoing business relationship with the Consumer. – Ensure security and integrity, to the extent that the use of the Consumer’s personal information is reasonably necessary and proportionate for those purposes. – Provide advertising and marketing services to the Consumer. – Comply with federal, state, or local laws, including court orders or subpoenas. – Address civil, criminal, or regulatory inquiries, investigations, subpoenas, or summons by authorities. – Cooperate with law enforcement regarding activities that may reasonably be believed to violate the law. – Perform a contract between HowToGetCreative and the Consumer. – Exercise or defend legal claims. | Advertising Networks; Service Providers; Data Analytics Providers; Government Entities; Operating Systems and Platforms; Social Networks |
Commercial Information
Sources | Business or Commercial Purpose(s) | Categories of Third Parties |
---|---|---|
Consumers; Social Networks; Advertising Networks; Data Analytics Providers; Operating Systems and Platforms | – Provide goods or services requested by the Consumer. – Complete transactions for which personal information was collected. – Anticipated uses within the context of our ongoing business relationship with the Consumer. – Comply with federal, state, or local laws, including court orders or subpoenas. – Exercise or defend legal claims. | Social Networks; Advertising Networks; Data Analytics Providers; Operating Systems and Platforms; Service Providers |
Internet or Other Electronic Network Activity Information
Sources | Business or Commercial Purpose(s) | Categories of Third Parties |
---|---|---|
Consumers; Social Networks; Advertising Networks; Data Analytics Providers; Operating Systems and Platforms | – Provide goods or services requested by the Consumer. – Complete transactions for which personal information was collected. – Comply with federal, state, or local laws, including court orders or subpoenas. – Cooperate with law enforcement regarding conduct or activity reasonably believed to violate federal, state, or local law. – Provide advertising and marketing services to the Consumer. | Advertising Networks; Data Analytics Providers; Operating Systems and Platforms; Service Providers; Social Networks |
Geolocation Data
Sources | Business or Commercial Purpose(s) | Categories of Third Parties |
---|---|---|
Consumers; Social Networks; Advertising Networks; Data Analytics Providers; Operating Systems and Platforms | – Provide goods or services requested by the Consumer. – Uses anticipated within the context of our ongoing business relationship with the Consumer. – Provide advertising and marketing services to the Consumer. | Social Networks; Advertising Networks; Data Analytics Providers; Government Entities; Operating Systems and Platforms; Service Providers |
Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information
Sources | Business or Commercial Purpose(s) | Categories of Third Parties |
---|---|---|
Consumers; Operating Systems and Platforms; Product Suppliers | – Provide goods or services requested by the Consumer. – Complete transactions for which personal information was collected. – Uses anticipated within the context of our ongoing business relationship with the Consumer. – Comply with federal, state, or local laws, including court orders or subpoenas. – Respond to civil, criminal, or regulatory inquiries, investigations, subpoenas, or summons by authorities. – Exercise or defend legal claims. – Cooperate with law enforcement regarding conduct or activity reasonably believed to violate laws. | Government Entities; Operating Systems and Platforms; Service Providers |
Professional or Employment-Related Information
Sources | Business or Commercial Purpose(s) | Categories of Third Parties |
---|---|---|
Consumers; Social Networks; Government Entities | – Provide goods or services requested by the Consumer. – Complete transactions for which personal information was collected. – Uses anticipated within the context of our ongoing business relationship with the Consumer. – Debug to identify and repair errors affecting intended functionality. – Comply with federal, state, or local laws, including court orders or subpoenas. – Respond to civil, criminal, or regulatory inquiries, investigations, subpoenas, or summons by authorities. – Cooperate with law enforcement regarding conduct or activity reasonably believed to violate laws. – Exercise and defend legal claims. | Service Providers; Government Entities; Operating Systems and Platforms |
Education Information
Sources | Business or Commercial Purpose(s) | Categories of Third Parties |
---|---|---|
Consumers; Social Networks | – Anticipated uses within the context of our ongoing business relationship with the Consumer. – Provide goods or services requested by the Consumer. – Complete transactions for which personal information was collected. – Comply with federal, state, or local laws, including court orders or subpoenas. – Respond to civil, criminal, or regulatory inquiries, investigations, subpoenas, or summons by authorities. – Cooperate with law enforcement regarding conduct or activity reasonably believed to violate laws. – Exercise and defend legal claims. | Service Providers; Operating Systems and Platforms; Government Entities |
The following items constitute Sensitive Personal Information.
This Notice covers the collection of personal information from employees as well, which means much of the information below reflects data collected during the course of employment.
Social Security Number
Sources | Business or Commercial Purpose(s) | Categories of Third Parties |
---|---|---|
Consumers; Government Entities; Operating Systems and Platforms; Social Networks | – Perform services on our behalf. – Help ensure security and integrity to the extent the use of Consumer's personal information is necessary and proportionate for these purposes. – Provide goods or services reasonably expected by an average Consumer who requests them. – Counter malicious, deceptive, fraudulent, or illegal actions directed at us and pursue legal action against those responsible. – Ensure the physical safety of individuals. | Operating Systems and Platforms; Government Entities; Service Providers |
Driver's License Number
Sources | Business or Commercial Purpose(s) | Categories of Third Parties |
---|---|---|
Consumers; Government Entities; Operating Systems and Platforms; Social Networks | – Perform services on our behalf. – Provide goods or services reasonably expected by an average Consumer who requests them. – Ensure security and integrity to the extent necessary and proportionate for these purposes. – Counter malicious, deceptive, fraudulent, or illegal actions directed at us and take legal action against those responsible. – Ensure the physical safety of individuals. – Verify or maintain the quality or safety of a service or device owned, manufactured for, or controlled by us. | Operating Systems and Platforms; Government Entities; Service Providers; Data Analytics Providers |
State Identification Number
Sources | Business or Commercial Purpose(s) | Categories of Third Parties |
---|---|---|
Consumers; Government Entities; Social Networks | – Perform services on our behalf. – Provide goods or services reasonably expected by an average Consumer who requests them. – Ensure security and integrity as necessary and proportionate for these purposes. – Counter malicious, deceptive, fraudulent, or illegal actions directed at us and pursue legal action against those responsible. – Ensure the physical safety of individuals. | Operating Systems and Platforms; Government Entities; Service Providers |
Passport Number
Sources | Business or Commercial Purpose(s) | Categories of Third Parties |
---|---|---|
Consumers; Government Entities; Social Networks | – Perform services on our behalf. – Ensure security and integrity as necessary and proportionate for these purposes. – Counter malicious, deceptive, fraudulent, or illegal actions and take legal action against those responsible. – Ensure the physical safety of individuals. – Provide goods or services reasonably expected by an average Consumer who requests them. | Operating Systems and Platforms; Government Entities; Service Providers |
Racial or Ethnic Origin
Sources | Business or Commercial Purpose(s) | Categories of Third Parties |
---|---|---|
Consumers; Social Networks | – Perform services on our behalf. – Ensure security and integrity as necessary and proportionate for these purposes. – Provide goods or services reasonably expected by an average Consumer who requests them. – Counter malicious, deceptive, fraudulent, or illegal actions and take legal action against those responsible. – Ensure the physical safety of individuals. | Operating Systems and Platforms; Government Entities; Service Providers |
Precise Geolocation
Sources | Business or Commercial Purpose(s) | Categories of Third Parties |
---|---|---|
Social Networks; Operating Systems and Platforms | – Counter malicious, deceptive, fraudulent, or illegal actions and take legal action against those responsible. – Ensure the physical safety of individuals. | Government Entities |
Citizenship or Immigration Status
Sources | Business or Commercial Purpose(s) | Categories of Third Parties |
---|---|---|
Consumers; Government Entities | – Provide services on our behalf. – Ensure security and integrity, as required, when processing personal information. – Fulfill services or goods anticipated by the average Consumer. – Conduct activities to verify or maintain the quality or safety of any services or products we own, manufacture for, or control. | Operating Systems and Platforms; Government Entities; Service Providers; Data Analytics Providers |
Religious or Philosophical Beliefs
Sources | Business or Commercial Purpose(s) | Categories of Third Parties |
---|---|---|
Consumers | – Ensure security and integrity as needed for processing personal information. – Provide services or goods as anticipated by the Consumer's request. | Operating Systems and Platforms |
Contents of Mail, Email, or Text Messages (Not the Intended Recipient)
Sources | Business or Commercial Purpose(s) | Categories of Third Parties |
---|---|---|
Consumers | – Deliver services or provide goods that are reasonably expected based on the Consumer's request. | Operating Systems and Platforms; Service Providers |
Genetic Data
Sources | Business or Commercial Purpose(s) | Categories of Third Parties |
---|---|---|
Consumers | – To provide goods or perform services that are reasonably expected based on a request from the Consumer. | Operating Systems and Platforms; Service Providers |
Health Information
Sources | Business or Commercial Purpose(s) | Categories of Third Parties |
---|---|---|
Consumers; Data Analytics Providers | – Performing services on behalf of HowToGetCreative. – Ensuring security and integrity to the extent required for proportionate use. – Providing goods or services reasonably expected by Consumers. | Operating Systems and Platforms; Government Entities; Service Providers |
Sex Life or Sexual Orientation Information
Sources | Business or Commercial Purpose(s) | Categories of Third Parties |
---|---|---|
Consumers | – Ensuring security and integrity to the extent necessary for proportionate use of personal information. – Providing goods or services reasonably expected by Consumers. | Operating Systems and Platforms; Service Providers |
Disclosure of Personal Information for Business Purposes
Over the past 12 months, we have disclosed the following categories of personal information for business-related purposes:
Personal Identifiers | Other Information That Identifies, Relates To, Describes, or Is Associated with an Individual | Characteristics of Protected Classifications Under State or Federal Law |
---|---|---|
Commercial Information | Internet or Other Electronic Network Activity Information | Geolocation Data |
Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information | Professional or Employment-Related Information | Education Information |
Social Security Number | Driver's License Number | State Identification Number |
Passport Number | Racial or Ethnic Origin | Precise Geolocation |
Citizenship or Immigration Status | Religious or Philosophical Beliefs | Contents of Mail, Email, or Text Messages Where We Are Not the Intended Recipient |
Genetic Data | Health Information | Sex Life or Sexual Orientation Information |
Sale or Sharing of Personal Information
For purposes related to analytics and advertising, the use of certain cookies on our website may be considered a “sale” or “sharing” of personal information under applicable data privacy laws. Over the preceding 12 months, these cookies have facilitated the “sale” or “sharing” of the following categories of consumer personal information:
Personal Identifiers | Internet or Other Electronic Network Activity Information | Geolocation Data |
---|---|---|
Commercial Information | Characteristics of Protected Classifications Under State or Federal Law | Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information |
The categories of information described above were “sold” or “shared” with advertising networks, social media platforms, data analytics providers, and operating systems for advertising and analytics purposes.
Appeal Process
You hold the right to appeal any decision made in response to a request. To initiate an appeal, please submit a Support Ticket.
Authorized Agent
A Consumer is permitted to use an authorized agent to submit requests on their behalf, provided that the Consumer's identity is verified, and a written authorization is supplied, granting explicit permission for the agent to make data requests. This may be achieved by submitting a power of attorney as per applicable legal requirements.
Exemptions from Compliance
Certain obligations under data privacy laws do not limit our capacity to:
- Adhere to federal, state, or local laws, including compliance with court orders or subpoenas.
- Address civil, criminal, or regulatory inquiries, investigations, subpoenas, or summonses from federal, state, or local authorities.
- Collaborate with law enforcement regarding conduct or activities reasonably and in good faith believed to violate any law.
- Support emergency requests for access to personal information if necessary to prevent serious physical harm or death, under specific conditions.
- Exercise or defend legal claims.
- Collect, retain, use, sell, share, or disclose personal information that is either deidentified or aggregate data.
- Engage in commercial transactions that occur entirely outside the jurisdiction of the applicable data privacy law.
We will not reidentify any data that has been deidentified and is maintained in our systems.
Contact Information
For any inquiries, concerns, or feedback, please contact our Customer Support team here, Contact Us.
Notice At Collection
Categories of Personal Information to Be Collected | Business or Commercial Purpose(s) for Which It Will Be Used | Sold or Shared? | Length of Time to Retain Such Category of Personal Information |
---|---|---|---|
Personal Identifiers (e.g., name, postal address, unique personal identifier, online identifier, IP address, email, account name, Social Security number, driver's license number, passport number, and similar identifiers) | Providing goods or services as requested by the consumer; Completing transactions for which personal information was collected; Ensuring security and integrity in line with the use of personal information; Providing advertising and marketing services; Complying with legal obligations; Addressing civil, criminal, or regulatory inquiries; Cooperating with law enforcement concerning possible legal violations; Exercising or defending legal claims; Performing contracts; Undertaking activities to verify or maintain the quality of services or devices; Temporary use ensuring no third-party disclosure outside the context of consumer interactions | Use of certain cookies may constitute a “sale” or “sharing” of personal information in accordance with applicable laws | Retained as long as reasonably necessary to fulfill the disclosed purpose (including legal claims and compliance with applicable laws) |
Other Identifying Information (e.g., information that relates to or describes a particular individual) | Completing transactions for which personal information was collected; Providing requested services; Ensuring security and integrity; Complying with legal obligations; Addressing civil, criminal, or regulatory inquiries; Cooperating with law enforcement; Exercising or defending legal claims | No | Retained as long as reasonably necessary to fulfill the disclosed purpose (including legal claims and compliance with applicable laws) |
Characteristics of Protected Classifications (under state or federal law) | Providing goods or services as requested; Completing transactions; Ensuring security; Providing advertising and marketing; Complying with legal obligations; Addressing legal inquiries; Cooperating with law enforcement; Performing contracts; Exercising or defending legal claims | No | Retained as long as reasonably necessary to fulfill the disclosed purpose (including legal claims and compliance with applicable laws) |
Commercial Information | Completing transactions; Providing requested goods or services; Ensuring security; Providing advertising and marketing; Complying with legal obligations | No | Retained as long as reasonably necessary to fulfill the disclosed purpose (including legal claims and compliance with applicable laws) |
Biometric Information | None | N/A | N/A |
Internet or Other Electronic Network Activity Information | Providing goods or services as requested; Completing transactions; Ensuring security; Complying with legal obligations; Cooperating with law enforcement; Providing advertising and marketing services | Use of certain cookies may constitute a “sale” or “sharing” of personal information in accordance with applicable laws | Retained as long as reasonably necessary to fulfill the disclosed purpose (including legal claims and compliance with applicable laws) |
Geolocation Data | Providing requested goods or services; Reasonably anticipated use within the context of consumer relationships; Providing advertising and marketing services | No | Retained as long as reasonably necessary to fulfill the disclosed purpose (including legal claims and compliance with applicable laws) |
Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information | Providing goods or services; Completing transactions; Complying with legal obligations; Addressing regulatory inquiries; Cooperating with law enforcement; Exercising or defending legal claims | No | Retained as long as reasonably necessary to fulfill the disclosed purpose (including legal claims and compliance with applicable laws) |
Professional or Employment-Related Information | Providing goods or services as anticipated; Completing transactions; Complying with legal obligations; Addressing legal inquiries; Cooperating with law enforcement | No | Retained as long as reasonably necessary to fulfill the disclosed purpose (including legal claims and compliance with applicable laws) |
Education Information | Anticipated use within the context of consumer relationships; Providing requested goods or services; Complying with legal obligations; Addressing regulatory inquiries; Completing transactions; Cooperating with law enforcement; Exercising or defending legal claims | No | Retained as long as reasonably necessary to fulfill the disclosed purpose (including legal claims and compliance with applicable laws) |
Sensitive Personal Information Overview
This notice pertains to certain types of sensitive personal information collected. Since it encompasses data collected from our employees, many of the items detailed below are relevant to information gathered throughout the course of employment with us.
Categories of Personal Information | Business or Commercial Purpose(s) for Use | Sold or Shared? | Retention Duration |
---|---|---|---|
Social Security Number | Services performed on our behalf; ensuring security and integrity where usage is necessary; providing services or goods expected by the consumer; addressing fraudulent activities; maintaining physical safety. | No | Retained as long as necessary for the disclosed purposes, including legal obligations. |
Driver’s License Number | Services performed on our behalf; providing expected services or goods; ensuring security and integrity; addressing fraudulent activities; ensuring safety; verifying or maintaining service quality. | No | Retained as long as necessary for the disclosed purposes, including legal obligations. |
State Identification Card Number | Services performed on our behalf; providing expected services or goods; ensuring security and integrity; addressing fraudulent activities; ensuring physical safety. | No | Retained as long as necessary for the disclosed purposes, including legal obligations. |
Passport Number | Services performed on our behalf; ensuring security and integrity; addressing fraudulent activities; ensuring safety; providing expected services or goods. | No | Retained as long as necessary for the disclosed purposes, including legal obligations. |
Racial or Ethnic Origin | Services performed on our behalf; providing expected services or goods; ensuring security and integrity; addressing fraudulent activities; ensuring physical safety. | No | Retained as long as necessary for the disclosed purposes, including legal obligations. |
Precise Geolocation | Addressing fraudulent activities; ensuring physical safety. | No | Retained as long as necessary for the disclosed purposes, including legal obligations. |
Citizenship or Immigration Status | Services performed on our behalf; providing expected services or goods; ensuring security and integrity; verifying or maintaining service quality. | No | Retained as long as necessary for the disclosed purposes, including legal obligations. |
Religious or Philosophical Beliefs | Providing expected services or goods; ensuring security and integrity. | No | Retained as long as necessary for the disclosed purposes, including legal obligations. |
Health Information | Services performed on our behalf; providing expected services or goods; ensuring security and integrity. | No | Retained as long as necessary for the disclosed purposes, including legal obligations. |
Sex Life or Sexual Orientation Information | Providing expected services or goods; ensuring security and integrity. | No | Retained as long as necessary for the disclosed purposes, including legal obligations. |
Contents of Mail, Email, or Text Messages (where we are not the intended recipient) | Providing expected services or goods. | No | Retained as long as necessary for the disclosed purposes, including legal obligations. |
Genetic Data | Providing expected services or goods. | No | Retained as long as necessary for the disclosed purposes, including legal obligations. |
State-Specific Privacy Rights
Residents of certain U.S. States have the rights indicated below as of the date in which the applicable laws granting such rights are effective, which are as follows:
California: January 1, 2023
Virginia: January 1, 2023
Colorado: July 1, 2023
Connecticut: July 1, 2023
Utah: December 31, 2023
Privacy Rights | Description | CA | VA | CO | CT | UT |
Access/Know | Request confirmation from us as to whether your personal information is being processed by Recurrent and, if so, access to such personal information. | X | X | X | X | X |
Deletion | Request that your personal information be deleted (subject to some limitations). | X | X | X | X | X |
Portability | Request that Recurrent provide a copy of the personal information concerning you that you have provided to us in a usable/readable format. | X | X | X | X | X |
Rectification/Correction | Request that Recurrent correct any inaccurate personal data relating to you (subject to limitations). | X | X | X | X | |
Restriction on Sharing for Cross-Context Behavioral or Targeted Advertising (called “sharing” under California law) | Request that Recurrent stop sharing of your personal information for purposes cross-contextual behavioral of targeted advertising purposes. | X | X | X | X | X |
Sales of Personal Information | Request that Recurrent stop selling personal information about you to third parties. | X | X | X | X | X |
Restriction on Automated Decision-Making or Profiling | Request that Recurrent stop using automated decision-making technology to evaluate you, create a profile of you, and make predictions about your future behavior. | X | X | X | X | |
Limiting the Use and Disclosure of Sensitive Personal Information | Request that Recurrent limit our use and disclosure of your “sensitive personal information,” as that term is defined in the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (CCPA), to the extent required by law. | X | X | X | X | X |
Right to Appeal | Appeal the denial of a privacy rights request under the relevant law | X | X | X |
Opting Out and Exercising Your Privacy Rights
If you wish to opt-out of the sale or sharing of your personal information for cross-context behavioral or targeted advertising, you can do so by contacting us directly here, Contact Us.
We aim to respond to all requests within 45 days. If we require more time, we will notify you and explain the reason for the delay, ensuring that all requests are completed within 90 days from their receipt. If we are unable to fulfill your request, we will provide an explanation and instructions on how to appeal our decision.
California Residents
California residents can make CCPA requests personally or via an authorized agent by contacting us here, Contact Us. Our verification process may vary based on the request type and the sensitivity of the requested information. We may ask for certain details to confirm your identity. If using an authorized agent, proof of your signed permission for the agent shall be required along with verification of the agent’s identity.
Do-Not-Track Signals & Global Privacy Controls
We recognize “do-not-track” signals and support the Global Privacy Control (GPC) initiative, which allows users to set privacy preferences such as opting out of tracking or the sale of personal information. GPC can be enabled through participating browsers or extensions.
California Shine the Light Law
Under California Civil Code Section 1798.83, California residents who use our services may request once a year information about our disclosure of personal information to third parties for direct marketing purposes. Such requests should be sent to us here, Contact Us with “Shine the Light Request” in the subject line.
Notice of Financial Incentive
We may offer loyalty or incentive programs that provide benefits like rewards or exclusive offers, which may be considered “financial incentives” under the CCPA. The value of your personal information is related to the benefits you receive, minus the costs of providing those benefits. Participation in these programs is voluntary, governed by specific terms, and can be terminated at any time as outlined in the program’s terms.
Nevada Residents
While we do not sell personal information as defined under Nevada law, Nevada residents can register an email address with us via our Support Ticket system for future notifications. Should we decide to sell user information in the future, registered users will be notified and can then opt out in accordance with Nevada law. Ensure your contact details remain current to receive these notifications.
Changes to This Policy
We may update this Policy from time to time at our sole discretion or as required by law. Any updates or changes will be posted on our website, and if the changes are substantial, we will provide a more prominent notice, which may include email notification. To stay informed of any updates, please ensure that your primary email address on file is accurate and up to date.
Unsubscribe from Communications
You may receive communications from us regarding our Service, including but not limited to: (a) notices about your use of our Service (such as any notifications of violations), (b) updates or changes to our Service, and (c) promotional materials and information related to our Service. If you wish to unsubscribe from our promotional emails, you may do so at any time by clicking the “unsubscribe” link provided in those emails. However, please note that this will not affect non-promotional communications, such as transactional messages, security alerts, or update notices.
Contact Us
If you have questions, comments, or complaints regarding our Privacy Policy or privacy practices, please reach out to us here, Contact Us.
We are committed to delivering high-quality digital media content. Our focus is on fostering trusted relationships with our audience and partners.