Privacy Policy

Last Updated: 21 Jan 2021

This is the Privacy Policy for Creatr (“Privacy Policy”)
and all Creatr Affiliate companies. When you use our apps and services,
including Creatr.com and Creatr.com, you’re trusting us with your information. We understand this is a big responsibility and we work hard
to protect your information and put you in control. This Privacy Policy
explains how and why we collect and use personal information, and what
we do to ensure it is kept private and secure and in compliance with the
applicable laws.

This Privacy Policy is meant to help you understand what
information we collect, why we collect it, and how you can update,
manage, export, and delete your information. For the purposes of data
protection law, we will be a controller of the personal information we
hold about you. This means we make decisions about how and why your
information is used, and have a legal duty to make sure that your rights
are protected when we use it.

1. Definitions

When we use a capitalised term in this Privacy Policy, it will have the meaning given to it in the table below:

“Affiliate”

means in relation to Creatr any entity that from time to
time directly or indirectly controls, is controlled by, or is under
common control with Creatr;

“Apps”

means the Creatr and Creatr applications available on the Google Play Store or the Apple App Store;

“End User”

means an individual using any of our Apps;

“Creatr”

means Creatr.com SV Ltd., a company incorporated registered
in England under company number 11326509, with registered office address
in 71-75 Shelton Street, London, Greater London, WC2H 9JQ, United
Kingdom;

“Partner”

means a business owner who uses the Creatr app to make bookings and engage with customers;

“Privacy Policy”

means this Privacy Policy which may be amended from time-to-time;

“Services”

means any of the services we provide to Partners or individuals through our Apps and Websites;

“Websites”

means www.Creatrbooking.com and www.Creatrbooking.com, including all subdirectories, subdomains, and mobile sites thereof.

2. Who should read this Privacy Policy?

This Privacy Policy will apply to you if you are any of the following:

a Partner on the Creatr platform; an End User; or
a visitor to any of our Websites. By accessing or using the Services or any of our Websites, you agree to the terms of this Privacy Policy. If we make any significant changes to this Privacy Policy, we will notify you through email or directly through our Apps and Websites.

If you have any questions about our Privacy Policy, don’t
hesitate to get in touch with us. Please feel free to reach out to us at
[email protected]

3. The Personal Information We Collect

We collect personal information (meaning anything that could
identify you either by itself, or when combined with other information
we are able to gain access to), as described below. When you use our
Services, we collect information that your browser sends to us that is
called log data, which may include information such as your computer’s
Internet Protocol (“IP”) address, browser version, pages of our Service
that you visit, the time and date of your visit, the time spent on those
pages, and other statistics. You can always choose not to provide us
with your personal information, but it may mean that we are unable to
provide you with the Service you have requested.

Information you provide to us when creating an account

When you create an account using either of our Apps or Websites,
you provide us with personal information, including your name, e-mail
address, postal address, a password, the name of your business (if you
are a Partner) and your phone number (if your device has one). We also
collect demographic information such as your birth date, age, gender and
lifestyle. If you give us permission to do so, we may also collect
information about your social media presence, including your usernames.

Information we collect as you use our Services

Apps and Browsers

We collect information about your device when you download and
install one of our Apps, and about your browser when you visit either of
our Websites.

The information we collect includes:

  • how you found our Website: including but not limited to whether you discovered us through a search engine, a partner website, an ad campaign, or email campaign;
  • technical information: your IP address, device type, language and region settings, and other details about how you interact with our Apps and Website; and
  • location information: if you have activated
    one of our Apps and permitted your mobile or other location-aware device to transmit location data, we will collect this automatically. This may include country, province, city, or neighbourhood information.

When Using Our Services

We collect personal information when you use our Services. This may include:

  • areas of interest: including the types of Merchant offerings that interest you;
  • referrals: information about friends who referred you, or who you have referred to Creatr;
  • correspondence: copies of correspondence, text, email and other communications you have with us or with Merchants via the Apps;
  • participation: we will collect and retain the comments you make to the forums, bulletin boards, discussion groups, chat rooms, reviews, or other methods of communication that may be offered on or through our marketplace from time to time, including those you make on our social media pages;
  • transaction details: information about how you interact with the Creatr app, such as Partner offerings you view, purchase, redeem, and/or post, and the Partners you add to your favourites page; and
  • financial account information: we collect
    minimal financial information as needed for our payment processing partners in order to provide payments functionality to our Partners (such as your credit or debit card number, expiration date, and card verification number).

For Partners

If you are a Partner, we will collect the following details about you:

  • bank details: in order to submit payments to you, we need to collect your bank account and sort code;
  • business related information: your business name, a description of your business, titles, names, and bios of your staff members;
  • availability and scheduling information: information about your business calendars and staff availability from your Creatr account;
  • social media information: information from your Facebook page, Twitter feed, LinkedIn profile, Yelp ratings and additional publicly available data; and
  • customer information: where you upload your
    customer database to our servers, we will retain the personal information it contains subject to our Data Retention Policy in Section
  • Third Parties

    We may receive personal information about you from other sources with which you have registered, Merchants, business partners, affiliate entities (collectively, “Partners“), or other third parties. For example, if an End User creates an account on Creatr through one of our registration partners, such as Google , Apple or Facebook, we may collect personal information from those websites. We may associate this information with the other personal information we have collected about you.

    Through the app, the user can modify his personal information that we have collected and there is also another option for the user to close the account. User can close the account through the app and We will delete all collected user information.

    Steps to close the account in the app:

    Click on the left side menu -> Settings -> Close My Account

  • Information About Others

    Through your use of the Services, we may also collect information
    from you about someone else. If you provide Creatr with personal
    information about someone else, you must ensure that you are authorised
    to disclose that information to Creatr and that, without Creatr taking
    any further steps required by applicable data protection or privacy
    laws, Creatr may collect, use and disclose such information for the
    purposes described in this Policy. See Section 3 for more about
    referrals. If Creatr has been given personal information about you by
    another user and you would not like us to retain it, please contact us
    using the details given in Section 2 above, and we will delete it.

  • 4. Cookies, Pixel Tags and Other Web Beacons

    A cookie is a small file of letters and numbers that we store on
    your browser or device if you agree. Pixel tags and web beacons are tiny
    graphic images placed on website pages or in our emails that allow us
    to determine whether you have performed specific actions. When you
    access these pages or open email messages, the pixel tags and web
    beacons generate a notice of that action to us or our service providers.
    These tools allow us to measure response to our communications and
    improve our web pages and promotions.

  • We use the following types of cookies:
    • Strictly necessary cookies. These are cookies that are required for the operation of our Websites. They include, for example, cookies that enable you to log into secure areas of our
      Websites.
    • Analytical/performance cookies. These cookies allow us to recognise and count the number of visitors and to see how visitors move around our Websites. This helps us to improve the way they work, for example, by ensuring that users are finding what they are
      looking for easily. We use these to remember who you are and keep track of your preferences, e.g. the cities for which you want to be shown Partner offerings. We may also collect information about the website you
      were visiting before you landed on one of our own, and the website you visit after you leave our own, if this information is supplied to us by your browser.
  • We use the following types of cookies:
    • Strictly necessary cookies. These are cookies that are required for the operation of our Websites. They include, for
      example, cookies that enable you to log into secure areas of our Websites.
    • Analytical/performance cookies. These cookies
      allow us to recognise and count the number of visitors and to see how visitors move around our Websites. This helps us to improve the way they
      work, for example, by ensuring that users are finding what they are looking for easily. We use these to remember who you are and keep track of your preferences, e.g. the cities for which you want to be shown Partner offerings. We may also collect information about the website you were visiting before you landed on one of our own, and the website you visit after you leave our own, if this information is supplied to us by
      your browser.
  • Remarketing Cookies

    You may notice that sometimes, after visiting a website, you see
    increased numbers of adverts from the site you visited. That’s because
    the website you visited has placed a cookie on your web browser. Using
    that cookie and web analytics tools, the website owner will be able to
    show you adverts on third-party websites that they think you might be
    interested in. This cookie does not give access to your computer or
    mobile device, but may be able to identify you from other details.

  • Google Analytics

    Our Websites use Google Analytics to show relevant adverts to
    users who have previously visited us as they browse the web. This
    enables us to tailor our marketing to better suit your needs and only
    display ads that are relevant to you. You may see Creatr or one of our
    Partners in search results pages (using Google Adwords), on YouTube, in
    banner adverts on Gmail and on other services run by Google.

    Any information collected will be used in accordance with our own privacy policy and Google’s privacy policy. If you do not wish to see ads, you can:

  • Facebook Remarketing

    We also use similar targeted advertising technology to ensure
    that we only serve people with adverts on their Facebook pages that are
    relevant to them. To enable us to do this, we include a piece of code on
    our websites, called the Facebook Pixel. The information collected, for
    example which pages you visited, which device you used and what actions
    you took, will be used in accordance with our own privacy policy, as
    well as Facebook’s privacy policies. The Facebook Pixel only lasts for
    sixty (60) days. Using the Facebook Pixel, we can also remarket adverts
    to you through Instagram, which is owned by Facebook. You can set
    preferences for how Facebook advertises to you using your Facebook ad preferences.

  • Opting Out of Cookies

    You can refuse to accept some or all cookies by modifying
    settings within your browser. For guidance on how to do this, please
    visit http://www.aboutcookies.org. However, if you block strictly
    necessary cookies, you may be unable to access certain parts of our
    Websites. If you wish to opt out of remarketing cookies, please visit
    the Network Advertising Initiative Opt-out Page.

  • 5. How We Use Your Personal Information

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

    • where we need to perform a contract with you (e.g. to create an appointment or to process a payment);
    • where it is necessary for our legitimate interests (or those
      of a third party) and your interests and fundamental rights do not override those interests (see the “Legitimate Interests” section below);
      and
    • where we need to comply with a legal or regulatory obligation.
  • We may use personal information held about you in order to:
    • provide you with offers for products and services from
      participating Partners, including offers based on variables such as stated and anticipated customer interests, personal characteristics, or
      location;
    • recommend certain Partners offerings to you (e.g., to suggest
      Partners to add to your favourites page or remind you when it’s time to rebook a service);
    • facilitate and fulfil requests for appointments for Partner offerings, including their purchase and redemption;
    • evaluate eligibility of customers for certain offers, products or services, and evaluate the types of offers, products or services
      that may be of interest to End users;
    • track redemption of Partner offerings and perform other analytics;
    • improve our Services, including performing analysis, tracking
      your use of the Services for the purposes of displaying advertising and content;
    • provide customer support, including to our Partners or business partners;
    • communicate and provide additional information that may be of interest to you or Partner clients about Creatr and our Partners and business partners, such as Creatr news, special offers and coupons, announcements, and marketing materials;
    • send you reminders, technical notices, updates, security alerts and support and administrative messages;
    • provide advertisements to you through the Services, email
      messages, text messages, applications, push notifications, or other
      methods of communication;
    • administer surveys, sweepstakes, contests, or other promotional activities or events sponsored by us or our partners;
    • manage our everyday business needs such as administration of
      the Services, forum management, fulfilment, analytics, fraud prevention,
      enforcement of our corporate reporting obligations, terms of use, or to comply with the law.

    Your information will be treated in accordance with applicable data protection law.

  • 6. Legitimate Interests

    We may rely on legitimate interests to process your personal
    information, provided that your interests do not override our own. Where
    we rely on legitimate interests, these interests are:

    • providing, maintaining, and improving the Services to meet the needs of our End Users and Partners;
    • understanding how the Services are used to improve their performance in the future;
    • customising the Services to provide you with a better user experience;
    • marketing to inform End Users and Partners about other Services we offer that might benefit or interest them;
    • providing advertising;
    • detecting, preventing, or otherwise addressing fraud, abuse, security, or technical issues with our services; and
    • enforcing legal claims.
  • 7. Keeping Your Personal Information Safe

    We employ a variety of physical and technical measures to keep
    your personal information safe and to prevent unauthorised access to,
    use or disclosure of it. Databases are stored on secure servers and we
    control who has access to them (using both physical and electronic
    means).

    Where we have given you (or where you have chosen) a password
    which enables you to access our Services, you are responsible for
    keeping this password confidential. We ask you not to share a password
    with anyone. We cannot absolutely guarantee the security of the
    internet, external networks, or your own device, accordingly any online
    communications (e.g. information provided by e-mail, through our Website
    or our Apps) are at your own risk.

  • 8. Storage and Retention

    Where we store your personal information

    We are a multinational company with group companies in the United
    States, United Kingdom, Australia, Poland, and the United Arab
    Emirates. Where possible, our data is hosted and stored within the
    European Economic Area or with partners protected by Privacy Shield
    agreements. When necessary, the information that we collect from you may
    be transferred to, and stored at, a destination outside the United
    Kingdom and the European Economic Area (“EEA”), and may
    also be processed by staff operating outside the United Kingdom or the
    EEA who work for us or for one of our partners. Whenever data is
    transferred outside of the UK or EEA, we will take all steps reasonably
    necessary to ensure that any transferred personal information is treated
    securely and in accordance with applicable data protection laws.

Data Retention

Creatr will store personal data as long as Partner accounts
continue to use our software, and for a period of not more than 24
months thereafter. Users may elect to have their data removed from
Creatr either by contacting the Partner directly or by contacting users
on Creatr.com. In the case that a Partner explicitly indicates their
intention to cease to use our software and have their data deleted,
personally identifiable information stored with their account shall be
encrypted and/or removed. Other information related to activity on the
Apps will be retained for reporting and analytical purposes, or other
purposes at set forth in Section 9.

9. Disclosing Your Personal Information

Except as otherwise stated in this Privacy Policy, we do not
sell, trade, rent, or otherwise share the personal information that we
collect with third parties, unless you ask or authorise us to do so.
However, there are occasions where we may need to disclose your personal
information. Where we do so, any such disclosure will be on the basis
that these third parties are required to keep the information we give
them confidential and secure, and will not use it for any other purpose
than to carry out the services they are performing for us. We may
disclose personal information as follows:

  • to affiliated companies (e.g., subsidiaries and other companies owned by or controlled by Creatr);
  • to service providers that are hired by us to provide administrative and communication services on our behalf, such as website hosting, the processing and delivery of mailings, providing customer support, or providing credit card processing services;
  • to Partners where you have purchased services from a Partner through Creatr, or participated in an offer, contest or other activity
    sponsored or offered through Creatr on behalf of the Partner. We may also provide Partners with other personal information about you on your Creatr account to send customised offers, to validate the purchases, to aid and troubleshoot redemption, to combat fraud, as part of legal proceedings affecting Creatr and the Partner, to facilitate a direct
    relationship between Partners and customers, and to enable Partners to
    communicate electronically with customers who make purchases from the Partner;
  • when you rate or review a Service which you have purchased, your rating, review, photo, your first name and last initial will be published on the Creatr app and may appear on third party websites. For Partners whose businesses have received reviews on the Creatr Marketplace, these reviews may be syndicated on third party websites;
  • to business partners and other advertisers as part of an offer, contest, distribution partnership, or other activity that is provided by or in conjunction with Creatr and its business partners and in which you have elected to participate. For example, if you are referred to Creatr from a business partner’s website or through an invitation facilitated by or in conjunction with a Creatr business
    partner, Creatr may provide that business partner with contact information and transactional information;
  • to the public when any user of the Creatr app access your favourites page. You may, however, hide this information from the public
    by marking your favourites page as private;
  • to third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to
    acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal information in the
    same way as set out in this policy; and
  • to our professional advisors

Aggregated Data

We may use aggregated non-personally identifiable data to:
assist us to better understand how our customers are using the Services,
provide our customers with further information regarding the uses and benefits of the Services,
enhance small business productivity, including by creating
useful business insights from that aggregated data and allowing you to
benchmark your business’s performance against that aggregated data, and
otherwise to improve the Services.

10. Disclosures Required by Law.

We are subject to the law like everyone else. We may be required
to give information to legal and/or regulatory authorities if they so
request, or if they have the proper authorisation such as a search
warrant or court order
We also may need to retain and disclose certain personal
information about you to legal and/or regulatory authorities and to
appropriate agencies to conduct anti-money laundering checks and to
assist with fraud prevention. We will disclose this information as is
required by law.

12. Your Rights

We want you to remain in control of your personal information.
Part of this is making sure you understand your legal rights, which are
as follows:

where your personal information is processed on the basis of consent, the right to withdraw that consent;
the right to confirmation as to whether or not we are holding
any of your personal information and, if we are, to obtain a copy of it;
the right to have inaccurate personal information rectified;
the right to object to your personal information being used
for marketing or profiling, or on the basis of our or a third party’s
legitimate interests;
the right to restrict how your personal information is used; and
the right to be forgotten, which allows you to have your
personal information erased in certain circumstances (though this is not
an absolute right and may not apply if we need to continue using it for
a lawful reason).

If you would like further information about any of your rights or
wish to exercise them, please contact us using the details given in
Section 2.

Please keep in mind that there are exceptions to the rights above
and, though we will always try to respond to your satisfaction, there
may be situations where we are unable to do so (for example, because the
information no longer exists or there is an exception which applies to
your request).

13. Updating this Privacy Policy

We may update this Privacy Policy at any time. When we do, we
will post a notification on the main page of our Website and we will
also revise the updated date at the bottom of this page. We encourage
users to frequently check this page for any changes to stay informed
about how we are helping to protect the personal information we hold.