We respect your privacy and we are committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from).
PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how Creative Brains collects and processes your personal data while you are using our website, including any data you may provide through this website when you sign up to our newsletter, mailing list or take part in a conversation.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
THE DATA WE COLLECT ABOUT YOU
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes (first name, last name).
- Contact Data includes (email address and telephone numbers).
- Technical Data includes (internet protocol (IP) address, language, browser type and version, time zone setting and location).
- Usage Data includes (information about how you use our website, blog and services, the website from which you visited us from).
- Marketing and Communications Data includes (your preferences in receiving marketing from us and our third parties and your communication preferences, information about your business, your website domain, your address, your position, your social data which you set (avatar image, social network connection)].
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity and Contact by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- Fill in a form to learn more about our blog or services;
- subscribe to our blog newsletters;
- request marketing to be sent to you;
- Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
- Analytics & marketing technologies.
We use Google Analytics for the following purposes:
- Remarketing (showing our ads on third party websites). Creative Brains Ltd. and our advertising partners (Google) will use the cookie information to serve our past visitor relevant and optimized ads.
- Google Analytics Demographics and Interest Reporting. We use data from Google’s Interest-based advertising or 3rd-party audience data (such as age, gender and interests) with Google Analytics to inform our marketing strategy.
- Visitors can opt out of Google Analytics for Display Advertising and customise Google Display Network ads using Google’s Ad Settings page: https://adssettings.google.com/authenticated.
- Visitors can opt out of Google Analytics using this browser add-on: https://tools.google.com/dlpage/gaoptout/.
- We also use advertising partners to collect cookie-based information about our website users in order to assist us with better targeting of our advertising.
- For further information on cookies in general, including how to decline and remove cookies from your browser visit www.aboutcookies.org.
HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
If you share with us personal data of the third party, you confirm that such third party gave you consent on collection and processing of his/her data by us. We in our turn will take the same measures and procedures to ensure the safety of such information as we do in the relation to your personal data.
- When we register you as a new customer we collect: your identity and contact in order to perform a contract with you and for further marketing communication.
- In order to manage our relationship with you we collect: your identity, contact, profile in order to check the performance of contract with you and for our legitimate interests (to keep our records updated and to study how customers use our blog/services)
- When you are subscribing for our newsletter or blog, we collect: identity, contact, profile, usage for your legitimate interests and for our legitimate interests (to study how customers use our blog/services, to develop them and grow our business)
- To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) we collect: identity, contact and technical information in order to running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise and to comply with a legal obligation
- To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you we collect: identity, contact, profile, usage, technical and marketing and communication to be able to study how customers use our blog/services, to develop them, to grow our business and to inform our marketing strategy
- To use data analytics to improve our website, blog/services, marketing, customer relationships and experiences we collect technical and usage data in order to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy.
- To make suggestions and recommendations to you about goods or services that may be of interest to you we collect identity, contact, technical and usage data in order to develop our blog/services and grow our business
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You can control your choices through the following personal data control mechanisms.
PROMOTIONAL OFFERS FROM US
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you.
You will receive marketing communications from us if you have requested information from us or you are interested in our services, or if you provided us with your details when you entered into conversation on our blog or subscribed to our newsletter.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out above.
- Internal Third Parties: companies inside our Group.
- External Third Parties: Google, Facebook, CRM-systems and other
- 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 data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Usually, we keep your data for 5 (five) years.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see (Request erasure) below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes or other purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide our website, blog or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
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We do not collect Cookies before you give us your approval. An exception is technical cookies which are “strictly necessary” for the functioning of our website.