Privacy Policy

Last Revised: June 20, 2022

This Privacy Policy for CreationsRewards.Net LLC ("CreationsRewards", "Company" , "we," "us," or "our"), describes how and why we might collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you visit our website at www.creationsrewards.net (the "Website"), and when you use the CreationsRewards smartphone or tablet app (the "App"). This Policy only applies to information that is collected via the Website and App. It does not apply to information collected offline, or otherwise outside of the Website and App.

To the extent that we provide you notice on the Website of different, or additional, privacy policies or practices (at the point of our collection), then those additional terms shall govern such data collection and use.

1. Acceptance of Privacy Policy

Read this Policy carefully, to understand our policies and practices regarding your information, and how we will treat it. In addition, review the Terms of Service for our website located at www.creationsrewards.net/terms-of-service, which governs you use of the Website and App. If you do not agree to the Terms of Service, or this Policy, you must not access or use the Website and App.

By accessing, or using, the Website, you consent to this Policy and the terms of use and our collection, use and sharing of your information and data, and other activities, as described below.

2. Changes to Privacy Policy

We may update this Policy from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information. Your continued use of the Website following the posting of the revised Policy means that you agree and accept to these changes. However, without your consent, we will not use previously collected Personal Information in a manner that is materially different than represented at the time that it was collected.

3. What Information Does The Website Collect, and When Do We Collect It?

a. When you visit our Website, we may collect two types of information about you: (1) information that can be used to identify you, such as your first and last name, email address, and home address ("Personal Information"), and (2) information related to your activities on the Website that is automatically collected as you interact with the Website ("Usage Information").

b. We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, if you need to provide us Personal Information in connection with fulfilling a reward redemption, when you contact us, or if you voluntarily provide such information through the Website. We will collect Personal Information voluntarily provided (such as name, home address, phone number, and/or email address). If you send us a message, you will be sending to us your name, email address, and any other information, including Personal Information, you choose to include in that communication. You are under no obligation to provide Personal Information, but if you elect not to provide it, you may be unable to collect incentives or redeem rewards or use certain features of, or communicate with us via, the Website. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• names
• email addresses
• mailing addresses
• passwords
• contact preferences
• phone numbers
• All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

c. Information We Collect or Store As You Access and Use The Website. We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes. Like many businesses, we also collect information through cookies and similar technologies.

• The information we collect includes:

  Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).

  Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information. Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

d. Tracking Technologies. We may use various developed methods and technologies to store or collect Usage Information ("Tracking Technologies"). Tracking Technologies may set, change, alter or modify settings or configurations on your Device. A few of the Tracking Technologies include the following (and subsequent technology and methods later developed):

• (1) Cookies and Similar Technologies.
  Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies are widely used by website owners in order to make their websites work, or to work more efficiently, as well as to provide reporting information.

  Cookies set by the Website are called "first party cookies". Cookies set by parties other than the website owner are called "third party cookies". Third party cookies enable third party features or functionality to be provided on or through the website (e.g. like advertising, interactive content and analytics). The parties that set these third party cookies can recognize your computer both when it visits the website in question and also when it visits certain other websites. We use first and third party cookies for several reasons. Some cookies are required for technical reasons in order for our Website to operate, and we refer to these as "essential" or "strictly necessary" cookies. Other cookies also enable us to track and target the interests of our users to enhance the experience on our Online Properties. Third parties serve cookies through our Website for advertising, analytics and other purposes. This is described in more detail below. The specific types of first and third party cookies served through our Website and the purposes they perform are described below (please note that the specific cookies served may vary depending on the specific Online Properties you visit):

  Strictly necessary cookies: These cookies are strictly necessary to provide you with services available through our Website and to use some of its features, such as access to secure areas. Without these cookies, services on the Website cannot be provided.

  Analytics and customization cookies: These cookies collect information that is used either in aggregate form to help us understand how our Website is being used, or how effective our marketing campaigns are, or to help us customize our Website for you. We use third party service providers to provide certain analytics services to use in connection with the operation of the Website. This includes Google Analytics, a web analysis service by Google, Inc. (“Google”), to track Website usage and activity anonymously. Google Analytics uses cookies, and the information generated by such cookies about your use of the Website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information on our behalf for the purpose of evaluating your use of the Website, compiling reports on website activity and providing to us other services relating to website activity and internet usage. Google will not associate your IP address with any other data held by Google. You can prevent Google’s collection and use of data (cookies and IP address) by downloading and installing the browser plug-in available under: https://tools.google.com/dlpage/gaoptout?hl=en-GBM. In addition, further information about Google’s terms and conditions for Google Analytics can be found at: https://www.google.com/analytics/terms/gb.html.

  Advertising cookies: These cookies are used to make advertising messages more relevant to you. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed for advertisers, and in some cases selecting advertisements that are based on your interests.

  Functionality cookies: These cookies are used to allow the Website to remember choices you make, such as the language or region you are located in, and provide enhanced and more personal features. These cookies can also be used to remember your preferences on the Website, such as font, text size, and other aspects of web pages that you can customize. They may also be used to allow an optional service to function. The information provided by these cookies may be anonymized, and these cookies cannot track your browsing activity on other websites.

  (2) You have the right to decide whether to accept or reject cookies.
  You can exercise your cookie rights by setting your cookie preferences in your Web Browser’s settings. Essential cookies cannot be rejected, as they are strictly necessary to provide you with services. If you block all cookies in your Web Browser, you may not be able to access our Website or its services.

  In addition, most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit https://www.aboutads.info/choices/ or https://www.youronlinechoices.com.

  (3) Targeted Advertising: Third parties may serve cookies on your computer or mobile device to serve advertising through our Website. These companies may use information about your visits to this and other websites in order to provide relevant advertisements about goods and services that you may be interested in. They may also employ technology that is used to measure the effectiveness of advertisements. This can be accomplished by them using cookies or web beacons to collect information about your visits to this and other sites in order to provide relevant advertisements about goods and services of potential interest to you. The information collected through this process does not enable us or them to identify your name, contact details or other details that directly identify you unless you choose to provide these.

  (4) Tracking URLs. These are used to determine from which referring website the Website is accessed.

  (5) Web Beacons. Cookies are not the only way to recognize or track visitors to a website. We may use other, similar technologies from time to time, like web beacons (sometimes called "tracking pixels" or "clear gifs"). These are tiny graphics files that contain a unique identifier that enable us to recognize when someone has visited our Website or opened an e-mail including them. This allows us, for example, to monitor the traffic patterns of users from one page within a website to another, to deliver or communicate with cookies, to understand whether you have come to the website from an online advertisement displayed on a third-party website, to improve site performance, and to measure the success of e-mail marketing campaigns. In many instances, these technologies are reliant on cookies to function properly, and so declining cookies will impair their functioning.

  There may be other Tracking Technologies now, and later devised, and used by us in connection with the Website. Third parties may use Tracking Technologies with the Website. We may not control those Tracking Technologies and we are not responsible for them. However, you consent to potentially encountering third party Tracking Technologies in connection with use of the Website, and accept that our statements under this Policy do not apply to the Tracking Technologies or practices of such third parties.

4. Interactions with Third Party Sites; Third Party Ads.

The Website may include: (i) functionality that allows certain kinds of interactions between the Website and your account on a third party web site or application (including participation in Third Party Opportunities – as defined and discussed further in the "How Do We Process and Use the Information Collected?" section below); (ii) third party sites' interfaces or links on the Website to facilitate your sending a communication from the Website; and/or (iii) content served by advertisers or third party ad networks/exchanges. These third parties (including the Advertiser, as defined and discussed further in the "How Do We Process and Use the Information Collected?" section below) may gather and retain any information used or provided in any such communications or other activities, and may enable such third parties to market products or services to you, and to monitor which ads have been served to your browser and which webpages you were viewing when such ads were delivered. They may themselves set and access their own Tracking Technologies on your Device and track certain behavioral Usage Information regarding users of your Device via a Device Identifier. The information they collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

Third-party tracking technologies are not controlled by us, even if they use our technology to help store or collect data. Statements regarding our practices do not apply to the methods for collecting information used by these third-party advertisers and others or the use of the information that such third parties collect.

We do however work with third parties to make efforts to provide you with information on their practices and any available opportunity to exercise choice. The relevant third party's terms of service, privacy policy, permissions, notices and choices should be reviewed regarding their collection, storage and sharing practices. We make no representations regarding the policies or practices of third-party advertisers or advertising networks or exchanges or related third parties.

Further, while we may use a variety of companies to serve advertisements on the website, you may wish to visit https://www.networkadvertising.org/choices, which provides information regarding this practice by Network Advertising Initiative ("NAI") members, and your choices regarding having this information used by these companies, including the "opt-out" procedures of NAI members. Opting out of one or more NAI members only means that those NAI members no longer will be allowed under their own rules to deliver targeted content and/or ads to you, which will affect this and other sites, but does not mean you will no longer receive any targeted content and/or ads. Also, if your browsers are configured to reject cookies when you visit this opt-out page, or you subsequently erase your cookies, use a different device or change web browsers, your NAI opt-out may not, or may no longer, be effective. Additional information is available on the NAI's website accessible by the above link. You may also be able to opt-out of receiving third-party behavioral ads by visiting the Digital Advertising Alliance ("DAA") website at https://www.aboutads.info/choices/. Similar limitations may apply to the DAA opt-out. We are not responsible for effectiveness of or compliance with any third-parties' opt-out options.

5. How Do We Process and Use the Information Collected?

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
• To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
• To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
• To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
• To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
• To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see "WHAT ARE YOUR PRIVACY RIGHTS?" below).
• To deliver targeted advertising to you. We may process your information to develop and display personalized content and advertising tailored to your interests, location, and more.
• To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
• To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
• To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.
• To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.
• To present you with Third Party Opportunities (see "Third Party Opportunities" section, below)

Third Party Opportunities

By registering for an account with us, we will provide you access to Third Party Opportunities. These Third Party Opportunities include, but are not limited to: participating in surveys, exploring content and videos, shopping online, participating in various trials and offers, for which you can obtain various incentives, namely "CR Points", which can be redeemed for various rewards offered through the Website, from time to time.

We may provide you with an encrypted User ID number ("User ID") to participate in said Third Party Opportunities. The User ID does not contain any personally identifying information, and it is used by the website for proper account crediting and identification.

You may optionally complete a detailed, in-depth, demographic profile for which will be used for the purposes of identifying and determining eligibility for Third Party Opportunities.

If you choose to participate in a Third Party Opportunity, each third party company or other provider of the third party opportunity (each defined as an "Advertiser") may contact you directly via various methods, such as email, phone, postal mail, or other means. You may be required to provide Personal Information to said Third Party Opportunity in order to participate in the Third Party Opportunity. Such Personal Information will be provided directly to the Advertiser, and will not be used or collected by us. We are not responsible for the privacy policies or practices of Advertisers.

For additional information regarding disclosure of information to Advertisers, as well as the privacy policies and practices of Advertisers in the "How and When Do We Disclose Information to Third Parties?" section below.

In no event, however, will we sell or rent your Personal Information.

Contests, Promotions, and Sweepstakes: From time to time, we may offer contests, promotions, and sweepstakes (each defined as a "Promotion"), through the Website that may require registration. When choosing to participate in a Promotion, you agree to the official rules that govern said Promotion, which may include specific requirements. Requirements may include, but are not limited to, permitting the Promotion sponsor to use your name, likeness, and voice in marketing materials associated with the Promotion. If you choose to register for a Promotion, Personal Information may be disclosed to third parties, or the public, in connection with administering said Promotion. This includes winner selection, prize fulfillment, and other requirements required by law, or permitted in the official rules of said Promotion.

6. How and When Do We Disclose Information to Third Parties?

General. We may share Personal & Usage Information with third parties. We may share data related to you and your activities on our Website by using your Device Identifiers. We do not share Personal Information that we have collected directly from you on the Website with third parties for those third parties' marketing purposes unless you consent to the sharing at the time of personal information collection. In additional, we may share information we have collected about you, including Personal Information, as disclosed at the time you provide your information, and as described below, or otherwise in this Policy.

When You Request Information From or Provide Information to Third Parties: By registering for an account with us, we will provide you access to Third Party Opportunities. If you choose to participate in said Third Party Opportunities, each Advertiser may contact you directly via email, postal mail, phone, or other means, and you may be required to provide Personal Information in order to participate in the particular Third Party Opportunity. If you choose to participate and provide Personal Information, your Personal Information, and other information, may be disclosed to each Advertiser, and their clients, and all information you disclose will be subject to the Privacy Policies and practices of said Advertiser. In addition, Advertisers, and their clients, and other third parties, may store, collect, or otherwise have access to your information when you interact with their Tracking Technologies, content, apps, tools, etc.

We are not responsible for the Privacy Policies and practices of Advertisers, or any other third parties, and therefore, you should review third party privacy poliices and practices of such third parties prior to requesting information, or interacting with them.

We will not share Personal Information with any Advertisers, however, we may share aggregate social-demographic, behavior, and other information about you. This includes your User ID, zip/post code, gender, martial status, education, ethnicity or race (where permitted by applicable law), and employment-related information. This information will be anonymized in such a manner that will not permit any person other than yourself or us as the data subject or source of the related data by inference or implication. Such information may be used by Advertisers for the purposes of:

• Identifying Third Party Opportunities that you may be eligible for through the Advertisers, including optional follow-up Third Party Opportunities.
• Disclosing such information to clients of Advertisers for audience measurement services
• Appending information to completed Third Party Opportunities and delivering the appended data to clients of the Advertisers for analytical and/or research purposes
• Tracking of incentives upon completion of Third Party Opportunities and providing rewards
• Flagging User IDs of those users suspected of fraudulent activity
• Other such uses as set forth in the Advertisers' Privacy Policies.

We do not have the ability to view your Third Party Opportunity responses, unless provided to us by the Advertisers for the purposes of investigating suspected fraudulent activity.

Third Parties Providing Services on Our Behalf: Third party vendors may be used by us to perform certain services on behalf of us or our Website. This including web hosting, operating and designing features of the Website, tracking Website activity and analytics, and other administrative services. We may provide vendors with access to user information, including Device Identifiers and Personal Information in order to carry out the services they are providing for you, or for us. Third party analytic services may set and access their own Tracking Technologies on your device, and may otherwise collect or have information about you, including potential Personal Information. We are not responsible for those third party technologies, or activities that may arise out of them. We are not responsible for the effectiveness, or compliance, with any third party opt-out options.

Administrative & Legal Reasons: We may access, use, preserve, transfer, and disclose your information, which includes Personal and Device Information, to satisfy applicable laws, regulations, subpoenas, governmental requests, or legal processes, if in our good faith opinion such information is required or permitted by law. We may use Personal and Device Information to protect and/or defend the Terms of Service of this Website, or other policies applicable to the website. This includes investigation of potential violations to our Terms of Service. We may use such information to protect the safety, rights, property, or security of the Website or any third party. Or, we may use such information to detect, prevent, and address fraud, security, or technical issues. Further, we may use Device Identifiers, or IP addresses, to identify users. We may so do in cooperation with third parties such as copyright holders, internet service providers, wireless service providers, and/or law enforcement agencies, including disclosing such information to third parties, all in our discretion subject to applicable law. Such disclosures may be carried out with no notice to you.

Business Transfer: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

7. Other Privacy Rights

In some regions (like the EEA, UK, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided at the end of this document.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you are located in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "How Can You Contact Us About This Notice?" below or updating your preferences.

However, please note that this will not affect the lawfulness of the processing before its withdrawal, nor when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided at the end of this document. You will then be removed from the marketing lists. However, we may still communicate with you, for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Account Information: If you would at any time like to review or change the information in your account or terminate your account, you can:

• Contact us using the contact information provided.
• Log in to your account settings and update your user account.
• Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements. Further note that it is not always possible to completely remove or delete all of your information from our databases and that residual data may remain on backup media or for other reasons.

Do Not Track Signals: Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

8. Do We Collect Information From Minors?

We do not knowingly solicit data from or market to children under 18 years of age. By using the Website, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us by referring to the contact information at the end of this document.

9. How Do We Keep Your Information Safe?

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Website is at your own risk. You should only access the Website within a secure environment.

10. How Long Do We Keep Your Information?

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

11. Is Your Information Transferred Internationally?

Our servers are located in the United States. If you are accessing our Website from outside the United States, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information, in the United States, and other countries.

If you are a resident in the European Economic Area (EEA) or United Kingdom (UK), then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law.

European Commission's Standard Contractual Clauses:

We have implemented measures to protect your personal information, including by using the European Commission's Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers. These clauses require all recipients to protect all personal information that they process originating from the EEA or UK in accordance with European data protection laws and regulations. Our Standard Contractual Clauses can be provided upon request. We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.

12. What Legal Bases Do We Rely On To Process Your Information?

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

• Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.
• Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
• Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
  • Send users information about special offers and discounts on our products and services
  • Provide users with Third Party Opportunities
  • Develop and display personalized and relevant advertising content for our users
  • Analyze how our services are used so we can improve them to engage and retain users
  • Support our marketing activities
  • Diagnose problems and/or prevent fraudulent activities
  • Understand how our users use our products and services so we can improve user experience
• Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
• Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
• For investigations and fraud detection and prevention
• For business transactions provided certain conditions are met
• If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
• For identifying injured, ill, or deceased persons and communicating with next of kin
• If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
• If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
• If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
• If the collection is solely for journalistic, artistic, or literary purposes
• If the information is publicly available and is specified by the regulations

13. Do California Residents Have Specific Privacy Rights?

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided at the end of this document.

If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).

CCPA Privacy Notice

The California Code of Regulations defines a "resident" as:

• (1) every individual who is in the State of California for other than a temporary or transitory purpose and
• (2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose
• All other individuals are defined as "non-residents."

If this definition of "resident" applies to you, we must adhere to certain rights and obligations regarding your personal information.

What categories of personal information do we collect?

We have collected the following categories of personal information in the past twelve (12) months:

A. Identifiers: YES
Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name.

B. Personal information categories listed in the California Customer Records statute: YES
Name, contact information, education, employment, employment history, and financial information

C. Protected classification characteristics under California or federal law: YES
Gender and date of birth

D. Commercial information: NO
Transaction information, purchase history, financial details, and payment information

E. Biometric information: NO
Fingerprints and voiceprints

F. Internet or other similar network activity: YES
Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements

G. Geolocation data: YES
Device location

H. Audio, electronic, visual, thermal, olfactory, or similar information: NO
Images and audio, video or call recordings created in connection with our business activities

I. Professional or employment-related information: NO
Business contact details in order to provide you our services at a business level or job title, work history, and professional qualifications if you apply for a job with us

J. Education Information: NO
Student records and directory information

K. Inferences drawn from other personal information: YES
Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics

We may also collect other personal information outside of these categories instances where you interact with us in person, online, or by phone or mail in the context of:

• Receiving help through our customer support channels;
• Participation in customer surveys or contests;
• Participation in Third Party Opportunities; and
• Facilitation in the delivery of our Services and to respond to your inquiries.

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.

We have not sold any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We have disclosed the following categories of personal information to third parties for a business or commercial purpose in the preceding twelve (12) months:

• Category A. Identifiers, such as contact details like your real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name.
• Category B. Personal information, as defined in the California Customer Records law, such as your name, contact information, education, employment, employment history, and financial information.
• Category C. Characteristics of protected classifications under California or federal law, such as gender or date of birth.
• Category K. Inferences drawn from any of the personal information listed above to create a profile or summary about, for example, an individual's preferences and characteristics.

Your rights with respect to your personal data

Right to request deletion of the data - Request to delete

You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.

Right to be informed - Request to know

Depending on the circumstances, you have a right to know:

• whether we collect and use your personal information;
• the categories of personal information that we collect;
• the purposes for which the collected personal information is used;
• whether we sell your personal information to third parties;
• the categories of personal information that we sold or disclosed for a business purpose;
• the categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
• the business or commercial purpose for collecting or selling personal information.

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

Right to Non-Discrimination for the Exercise of a Consumer's Privacy Rights

We will not discriminate against you if you exercise your privacy rights.

Verification process

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

Other privacy rights

• You may object to the processing of your personal information.
• You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information.
• You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
• You may request to opt out from future selling of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission.
• To exercise these rights, you can contact us by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.

14. Do Third Party Content and Links to Third Party Content Appear on the Website?

The Website may link to third-party websites, online services, or mobile applications and/or contain advertisements from third parties that are not affiliated with us and which may link to other websites, services, or applications. Accordingly, we do not make any guarantee regarding any such third parties, and we will not be liable for any loss or damage caused by the use of such third-party websites, services, or applications. The inclusion of a link towards a third-party website, service, or application does not imply an endorsement by us. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this privacy notice. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services, or applications that may be linked to or from the Services. You should review the policies of such third parties and contact them directly to respond to your questions.

15. How Do I Change My Communication Preferences and Information?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please contact us using the information located at the bottom of this document.

You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided at the end of this document.

However, in regards to Third Party Opportunities, you must contact the Advertiser directly to be removed from their lists. Your participation in Third Party Opportunities does not entitle you to any benefits offered by, or membership with, the Advertisers. We will make good faith efforts to make any requested changes or removals in our then current active databases as soon as reasonably possible.

Please note, if you request us to delete or remove any data, you may be unable to use certain features of the Website, including participating in Third Party Opportunities, or to communicate with us via the Website. Additionally, we may not accommodate a request to change information if we believe the change would violate any law or legal requirement, or cause the information to be incorrect.

For any information provided to third parties, you must contact said third party directly to review, modify, correct, delete, or remove such information.

16. How Can You Contact Us About This Notice?

If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO), Website Administrator:

• Via email at helpdesk (at) creationsrewards.net
• By visiting our Customer Care Portal at https://help.creationsrewards.net
• By postal mail addressed to:
  CreationsRewards.Net LLC
  ATTN: Website Administrator
  118 South 19th Ave
  Manville, NJ 08835
  United States