Type of website: Service Business
Effective date: 3rd day of December, 2023
www.creatr.uk (the “Site”) is owned and operated by CDR Management Ltd. CDR Management Ltd is the data controller and can be contacted at:
87A Warwick St, Leamington Spa, CV32 4RJ
Purpose
The purpose of this privacy policy (this “Privacy Policy”) is to inform users of our Site of the following:
- The personal data we will collect;
- Use of collected data;
- Who has access to the data collected;
- The rights of Site users; and
- The Site’s cookie policy.
This Privacy Policy applies in addition to the terms and conditions of our Site.
GDPR
For users in the European Union, we adhere to the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, known as the General Data Protection Regulation (the “GDPR”). For users in the United Kingdom, we adhere to the GDPR as enshrined in the Data Protection Act 2018.
We have not appointed a Data Protection Officer as we do not fall within the categories of controllers and processors required to appoint a Data Protection Officer under Article 37 of the GDPR.
Consent
By using our Site users agree that they consent to:
- The conditions set out in this Privacy Policy.
When the legal basis for us processing your personal data is that you have provided your consent to that processing, you may withdraw your consent at any time. If you withdraw
your consent, it will not make processing which we completed before you withdrew your consent unlawful.
You can withdraw your consent by: Contacting the team at: info@creatr.uk.
Legal Basis for Processing
We collect and process personal data about users in the EU only when we have a legal basis for doing so under Article 6 of the GDPR.
We rely on the following legal bases to collect and process the personal data of users in the EU:
- Users have provided their consent to the processing of their data for one or more specific purposes; and
- Processing of user personal data is necessary for us to take, at the request of a user, steps before entering a contract or for the performance of a contract to which a user is a party. If a user does not provide the the personal data necessary to perform a contract the consequences are as follows: A contract will not be fulfilled.
Personal Data We Collect
We only collect data that helps us achieve the purpose set out in this Privacy Policy. We will not collect any additional data beyond the data listed below without notifying you first.
Data Collected Automatically
When you visit and use our Site, we may automatically collect and store the following information:
- IP address;
- Location;
- Hardware and software details;
- Clicked links; and
- Content viewed.
Data Collected in a Non-Automatic Way
We may also collect the following data when you perform certain functions on our Site:
- First and last name;
- Age;
- Date of birth;
- Sex;
- Email address;
- Phone number;
- Address;
- Auto fill data;
- Hardware Information (i.e Model of Smartphone);
- User’s Availability to Work;
- Previous Agency Information (If Necessary);
- Relevant Social Media & Website URL’s;
- OnlyFans Account Information (i.e Monthly Earnings, Number of Fans); 14. Creator Content Information; and
- Images.
This data may be collected using the following methods:
- Application Form;
- Shared Media Drive (i.e Google Drive); and
- E-Mail.
How We Use Personal Data
Data collected on our Site will only be used for the purposes specified in this Privacy Policy or indicated on the relevant pages of our Site. We will not use your data beyond what we disclose in this Privacy Policy.
The data we collect automatically is used for the following purposes:
- Internal User Data & Analytics.
The data we collect when the user performs certain functions may be used for the following purposes:
- Communication with User;
- We Share This Data with Businesses/Persons outside of Infusion Network (CDR Management Ltd) in Order to Deliver Our Service; and
- We Sell This Data to Businesses/Persons whom claim they can deliver the user’s desired service.
Who We Share Personal Data With
Employees
We may disclose user data to any member of our organisation who reasonably needs access to user data to achieve the purposes set out in this Privacy Policy.
Third Parties
We may share user data with the following third parties:
- Booking System (https://calendly.com/); and
- Businesses/Persons seeking to assess the suitability of users for potential collaboration or service opportunities..
We may share the following user data with third parties:
- Full Name;
- Location;
- Email;
- Phone Number;
- Hardware Information (i.e Model of Smartphone);
- Availability to Work;
- Previous Agency Information;
- Social Media & Website URL’s;
- OnlyFans Account Data (i.e Earnings & Fan Count); and
- Images.
We may share user data with third parties for the following purposes:
- Data is communicated to third parties to enable them to make informed decisions about potential business engagements with the users whose data is shared..
Third parties will not be able to access user data beyond what is reasonably necessary to achieve the given purpose.
Other Disclosures
We will not sell or share your data with other third parties, except in the following cases: 1. If the law requires it;
- If it is required for any legal proceeding;
- To prove or protect our legal rights; and
- To buyers or potential buyers of this company in the event that we seek to sell the company.
If you follow hyperlinks from our Site to another Site, please note that we are not responsible for and have no control over their privacy policies and practices.
How Long We Store Personal Data
User data will be stored indefinitely.
You will be notified if your data is removed upon achieving the purpose in which it was collected for.
How We Protect Your Personal Data
In order to protect your security, we use the strongest available browser encryption and store all of our data on secure servers. All data is only accessible to our employees unless otherwise mentioned. Our employees are bound by strict confidentiality agreements and a breach of this agreement would result in the employee’s termination.
While we take all reasonable precautions to ensure that user data is secure and that users are protected, there always remains the risk of harm. The Internet as a whole can be insecure at times and therefore we are unable to guarantee the security of user data beyond what is reasonably practical.
International Data Transfers
We transfer user personal data to the following countries:
- All EU member states;
- All EFTA States;
- All EU or EEA institutions, bodies, offices or agencies;
- Canada;
- Japan;
- The United States of America; and
- All other countries that the UK Government announced (on August 2021) that it is working in partnership with that may be subject of adequacy regulations in the future
When we transfer user personal data we will protect that data as described in this Privacy Policy and comply with applicable legal requirements for transferring personal data internationally.
If you are located in the United Kingdom or the European Union, we will only transfer your personal data if:
- The country your personal data is being transferred to has been deemed to have adequate data protection by the European Commission or, if you are in the United Kingdom, by the United Kingdom adequacy regulations; or
- We have implemented appropriate safeguards in respect of the transfer. For example, the recipient is a party to binding corporate rules, or we have entered into standard EU or United Kingdom data protection contractual clauses with the recipient..
Your Rights as a User
Under the GDPR, you have the following rights:
- Right to be informed;
- Right of access;
- Right to rectification;
- Right to erasure;
- Right to restrict processing;
- Right to data portability; and
- Right to object.
Children
We do not knowingly collect or use personal data from children under 16 years of age. If we learn that we have collected personal data from a child under 16 years of age, the personal
data will be deleted as soon as possible. If a child under 16 years of age has provided us with personal data their parent or guardian may contact our privacy officer.
How to Access, Modify, Delete, or Challenge the Data Collected
If you would like to know if we have collected your personal data, how we have used your personal data, if we have disclosed your personal data and to who we disclosed your personal data, if you would like your data to be deleted or modified in any way, or if you would like to exercise any of your other rights under the GDPR, please contact our privacy officer here:
George Dalby
87A Warwick St, Leamington Spa, CV32 4RJ
Do Not Track Notice
Do Not Track (“DNT”) is a privacy preference that you can set in certain web browsers. We respond to browser-initiated DNT signals. If we receive a DNT signal that indicates a user does not wish to be tracked, we will not track that user. We are not responsible for and cannot guarantee how any third parties who interact with our Site and your data will respond to DNT signals.
How to Opt-Out of Data Collection, Use or Disclosure
In addition to the method(s) described in the How to Access, Modify, Delete, or Challenge the Data Collected section, we provide the following specific opt-out methods for the forms of collection, use, or disclosure of your personal data specified below:
- You can opt-out of the use of your personal data for marketing emails. You can opt-out by clicking “unsubscribe” on the bottom of any marketing email.
- After submission of your application, you can opt-out of the sharing and sale of your data to third parties. You can opt-out by by contacting: info@creatr.uk.
Cookie Policy
A cookie is a small file, stored on a user’s hard drive by a website. Its purpose is to collect data relating to the user’s browsing habits. You can choose to be notified each time a cookie is transmitted. You can also choose to disable cookies entirely in your internet browser, but this may decrease the quality of your user experience.
We use the following types of cookies on our Site:
- Functional cookies
Functional cookies are used to remember the selections you make on our Site so that your selections are saved for your next visits;
- Analytical cookies
Analytical cookies allow us to improve the design and functionality of our Site by collecting data on how you access our Site, for example data on the content you access, how long you stay on our Site, etc;
- Targeting cookies
Targeting cookies collect data on how you use the Site and your preferences. This allows us to personalise the information you see on our Site for you; and
- Third-Party Cookies
Third-party cookies are created by a website other than ours. We may use third-party cookies to achieve the following purposes:
- Monitor user preferences to tailor advertisements around their interests.
Modifications
This Privacy Policy may be amended from time to time in order to maintain compliance with the law and to reflect any changes to our data collection process. When we amend this Privacy Policy we will update the “Effective Date” at the top of this Privacy Policy. We recommend that our users periodically review our Privacy Policy to ensure that they are notified of any updates. If necessary, we may notify users by email of changes to this Privacy Policy.
Complaints
If you have any complaints about how we process your personal data, please contact us through the contact methods listed in the Contact Information section so that we can, where possible, resolve the issue. If you feel we have not addressed your concern in a satisfactory manner you may contact a supervisory authority. You also have the right to directly make a complaint to a supervisory authority. You can lodge a complaint with a supervisory authority by contacting the Information Commissioner’s Office.
Contact Information
If you have any questions, concerns or complaints, you can contact our privacy officer, George Dalby, at:
87A Warwick St, Leamington Spa, CV32 4RJ
Type of website: Service Business
Effective date: 3rd day of December, 2023
www.creatr.uk (the “Site”) is owned and operated by CDR Management Ltd. CDR Management Ltd is the data controller and can be contacted at:
87A Warwick St, Leamington Spa, CV32 4RJ
Purpose
The purpose of this privacy policy (this “Privacy Policy”) is to inform users of our Site of the following:
- The personal data we will collect;
- Use of collected data;
- Who has access to the data collected;
- The rights of Site users; and
- The Site’s cookie policy.
This Privacy Policy applies in addition to the terms and conditions of our Site.
GDPR
For users in the European Union, we adhere to the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, known as the General Data Protection Regulation (the “GDPR”). For users in the United Kingdom, we adhere to the GDPR as enshrined in the Data Protection Act 2018.
We have not appointed a Data Protection Officer as we do not fall within the categories of controllers and processors required to appoint a Data Protection Officer under Article 37 of the GDPR.
Consent
By using our Site users agree that they consent to:
- The conditions set out in this Privacy Policy.
When the legal basis for us processing your personal data is that you have provided your consent to that processing, you may withdraw your consent at any time. If you withdraw
your consent, it will not make processing which we completed before you withdrew your consent unlawful.
You can withdraw your consent by: Contacting the team at: info@creatr.uk.
Legal Basis for Processing
We collect and process personal data about users in the EU only when we have a legal basis for doing so under Article 6 of the GDPR.
We rely on the following legal bases to collect and process the personal data of users in the EU:
- Users have provided their consent to the processing of their data for one or more specific purposes; and
- Processing of user personal data is necessary for us to take, at the request of a user, steps before entering a contract or for the performance of a contract to which a user is a party. If a user does not provide the the personal data necessary to perform a contract the consequences are as follows: A contract will not be fulfilled.
Personal Data We Collect
We only collect data that helps us achieve the purpose set out in this Privacy Policy. We will not collect any additional data beyond the data listed below without notifying you first.
Data Collected Automatically
When you visit and use our Site, we may automatically collect and store the following information:
- IP address;
- Location;
- Hardware and software details;
- Clicked links; and
- Content viewed.
Data Collected in a Non-Automatic Way
We may also collect the following data when you perform certain functions on our Site:
- First and last name;
- Age;
- Date of birth;
- Sex;
- Email address;
- Phone number;
- Address;
- Auto fill data;
- Hardware Information (i.e Model of Smartphone);
- User’s Availability to Work;
- Previous Agency Information (If Necessary);
- Relevant Social Media & Website URL’s;
- OnlyFans Account Information (i.e Monthly Earnings, Number of Fans); 14. Creator Content Information; and
- Images.
This data may be collected using the following methods:
- Application Form;
- Shared Media Drive (i.e Google Drive); and
- E-Mail.
How We Use Personal Data
Data collected on our Site will only be used for the purposes specified in this Privacy Policy or indicated on the relevant pages of our Site. We will not use your data beyond what we disclose in this Privacy Policy.
The data we collect automatically is used for the following purposes:
- Internal User Data & Analytics.
The data we collect when the user performs certain functions may be used for the following purposes:
- Communication with User;
- We Share This Data with Businesses/Persons outside of Infusion Network (CDR Management Ltd) in Order to Deliver Our Service; and
- We Sell This Data to Businesses/Persons whom claim they can deliver the user’s desired service.
Who We Share Personal Data With
Employees
We may disclose user data to any member of our organisation who reasonably needs access to user data to achieve the purposes set out in this Privacy Policy.
Third Parties
We may share user data with the following third parties:
- Booking System (https://calendly.com/); and
- Businesses/Persons seeking to assess the suitability of users for potential collaboration or service opportunities..
We may share the following user data with third parties:
- Full Name;
- Location;
- Email;
- Phone Number;
- Hardware Information (i.e Model of Smartphone);
- Availability to Work;
- Previous Agency Information;
- Social Media & Website URL’s;
- OnlyFans Account Data (i.e Earnings & Fan Count); and
- Images.
We may share user data with third parties for the following purposes:
- Data is communicated to third parties to enable them to make informed decisions about potential business engagements with the users whose data is shared..
Third parties will not be able to access user data beyond what is reasonably necessary to achieve the given purpose.
Other Disclosures
We will not sell or share your data with other third parties, except in the following cases: 1. If the law requires it;
- If it is required for any legal proceeding;
- To prove or protect our legal rights; and
- To buyers or potential buyers of this company in the event that we seek to sell the company.
If you follow hyperlinks from our Site to another Site, please note that we are not responsible for and have no control over their privacy policies and practices.
How Long We Store Personal Data
User data will be stored indefinitely.
You will be notified if your data is removed upon achieving the purpose in which it was collected for.
How We Protect Your Personal Data
In order to protect your security, we use the strongest available browser encryption and store all of our data on secure servers. All data is only accessible to our employees unless otherwise mentioned. Our employees are bound by strict confidentiality agreements and a breach of this agreement would result in the employee’s termination.
While we take all reasonable precautions to ensure that user data is secure and that users are protected, there always remains the risk of harm. The Internet as a whole can be insecure at times and therefore we are unable to guarantee the security of user data beyond what is reasonably practical.
International Data Transfers
We transfer user personal data to the following countries:
- All EU member states;
- All EFTA States;
- All EU or EEA institutions, bodies, offices or agencies;
- Canada;
- Japan;
- The United States of America; and
- All other countries that the UK Government announced (on August 2021) that it is working in partnership with that may be subject of adequacy regulations in the future
When we transfer user personal data we will protect that data as described in this Privacy Policy and comply with applicable legal requirements for transferring personal data internationally.
If you are located in the United Kingdom or the European Union, we will only transfer your personal data if:
- The country your personal data is being transferred to has been deemed to have adequate data protection by the European Commission or, if you are in the United Kingdom, by the United Kingdom adequacy regulations; or
- We have implemented appropriate safeguards in respect of the transfer. For example, the recipient is a party to binding corporate rules, or we have entered into standard EU or United Kingdom data protection contractual clauses with the recipient..
Your Rights as a User
Under the GDPR, you have the following rights:
- Right to be informed;
- Right of access;
- Right to rectification;
- Right to erasure;
- Right to restrict processing;
- Right to data portability; and
- Right to object.
Children
We do not knowingly collect or use personal data from children under 16 years of age. If we learn that we have collected personal data from a child under 16 years of age, the personal
data will be deleted as soon as possible. If a child under 16 years of age has provided us with personal data their parent or guardian may contact our privacy officer.
How to Access, Modify, Delete, or Challenge the Data Collected
If you would like to know if we have collected your personal data, how we have used your personal data, if we have disclosed your personal data and to who we disclosed your personal data, if you would like your data to be deleted or modified in any way, or if you would like to exercise any of your other rights under the GDPR, please contact our privacy officer here:
George Dalby
87A Warwick St, Leamington Spa, CV32 4RJ
Do Not Track Notice
Do Not Track (“DNT”) is a privacy preference that you can set in certain web browsers. We respond to browser-initiated DNT signals. If we receive a DNT signal that indicates a user does not wish to be tracked, we will not track that user. We are not responsible for and cannot guarantee how any third parties who interact with our Site and your data will respond to DNT signals.
How to Opt-Out of Data Collection, Use or Disclosure
In addition to the method(s) described in the How to Access, Modify, Delete, or Challenge the Data Collected section, we provide the following specific opt-out methods for the forms of collection, use, or disclosure of your personal data specified below:
- You can opt-out of the use of your personal data for marketing emails. You can opt-out by clicking “unsubscribe” on the bottom of any marketing email.
- After submission of your application, you can opt-out of the sharing and sale of your data to third parties. You can opt-out by by contacting: info@creatr.uk.
Cookie Policy
A cookie is a small file, stored on a user’s hard drive by a website. Its purpose is to collect data relating to the user’s browsing habits. You can choose to be notified each time a cookie is transmitted. You can also choose to disable cookies entirely in your internet browser, but this may decrease the quality of your user experience.
We use the following types of cookies on our Site:
- Functional cookies
Functional cookies are used to remember the selections you make on our Site so that your selections are saved for your next visits;
- Analytical cookies
Analytical cookies allow us to improve the design and functionality of our Site by collecting data on how you access our Site, for example data on the content you access, how long you stay on our Site, etc;
- Targeting cookies
Targeting cookies collect data on how you use the Site and your preferences. This allows us to personalise the information you see on our Site for you; and
- Third-Party Cookies
Third-party cookies are created by a website other than ours. We may use third-party cookies to achieve the following purposes:
- Monitor user preferences to tailor advertisements around their interests.
Modifications
This Privacy Policy may be amended from time to time in order to maintain compliance with the law and to reflect any changes to our data collection process. When we amend this Privacy Policy we will update the “Effective Date” at the top of this Privacy Policy. We recommend that our users periodically review our Privacy Policy to ensure that they are notified of any updates. If necessary, we may notify users by email of changes to this Privacy Policy.
Complaints
If you have any complaints about how we process your personal data, please contact us through the contact methods listed in the Contact Information section so that we can, where possible, resolve the issue. If you feel we have not addressed your concern in a satisfactory manner you may contact a supervisory authority. You also have the right to directly make a complaint to a supervisory authority. You can lodge a complaint with a supervisory authority by contacting the Information Commissioner’s Office.
Contact Information
If you have any questions, concerns or complaints, you can contact our privacy officer, George Dalby, at:
87A Warwick St, Leamington Spa, CV32 4RJ
