Creativity Software is committed to honoring the privacy and security of personal data of its website users, job applicants, business contacts, and other individuals whose data we will collect (“user(s)” or “you”).
TYPE OF INFORMATION WE COLLECT
When you make use of our websites or otherwise communicate with us, we collect the following types of information, which may also include individually identifiable information, namely information that identifies an individual or may – with reasonable effort – identify an individual (“Personal Information”):
- when you register online or make an inquiry regarding our products and services, or provide us with comments or feedback. We will capture Personal Information about you so we can communicate effectively with you and address your requests regarding our products or services. We will hold information about your name, the company you work for, address, phone and fax numbers, e-mail address and line of business, etc. We will use this information to help manage your requests.
- if you visit our websites, we will collect Personal Information from your device, such as IP address and other online identifiers (i.e., online data collected from user’s devices and protocols which leave traces which may be used to identify users). We use this to optimise your experience and help us to improve our websites and the ways we communicate with you.
- If you attend one of our events: We collect Personal Information if you attend our corporate events. This information may include your photos, identifying data (e.g., email, name, etc.) and any other information which may be collected by us in connection with our events.
- if you apply for a job with us: we will collect Personal Information about you if you contact us about an employment opportunity. We will collect and use personal information to help assess your skills and your suitability to the relevant job position. We may also use such data to contact you if we believe a specific job position may interest you. Such information may include your name, email address, CV, telephone number, profile photo, job history and other relevant information.
HOW WE USE THE INFORMATION WE COLLECT
- To identify and authenticate your access;
- To conduct analytics in order to improve and customize our websites and the ways we communicate with you;
- To present you and your company business opportunities regarding our products and services;
- To send you marketing communications, updates and newsletters and present personalized content (see below under “Marketing”);
- To manage your application for a job position (as applicable);
- To support and troubleshoot our services, to respond to your queries and communicate with you;
- To investigate violations and enforce our policies, and as required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process or respond to a government request
LEGAL BASIS FOR USING YOUR PERSONAL INFORMATION
We will only collect, use and share your Personal Information where we are satisfied that we have an appropriate legal basis to do this. This may be because:
- we need to use your Personal Information to perform a contract or take steps to enter into a contract with you. For example, when you provide your information with us in order to apply to a job position.
- we need to use your Personal Information for our legitimate interest as a commercial organization. For example, we may collect your Personal Information in order to communicate with you and present you marketing materials and opportunities regarding our products and services.
- we need to use your Personal Information to comply with a relevant legal or regulatory obligation that we have; or
- we have your consent to use your Personal Information for a particular activity.
WITH WHOM WE SHARE THE INFORMATION WE COLLECT
We may share your Personal Information in the manner and for the purposes described below:
- with third parties and service providers who help our business (e.g. for data analytics purposes, communicating promotional and informational materials, etc.). These third parties have agreed to confidentiality restrictions and use any Personal Information we share with them or which they collect on our behalf for the purpose of providing the contracted service to us.
We may also disclose Personal Information, or any information you submitted us, if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our policies, including investigations of potential violations thereof; (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) to establish or exercise our rights to defend against legal claims; (v) prevent harm to the rights, property or safety of us, our users, yourself or any third party; or (vi) for the purpose of collaborating with law enforcement agencies or in case we find it necessary in order to enforce intellectual property or other legal rights.
We may use Personal Information to let you know about our products and services that we believe will be of interest to your company. We may contact you by email, post, or telephone or through other communication channels that we think you may find helpful. In all cases, we will respect your preferences for how you would like us to manage marketing activity with you.
To protect your privacy and to ensure you have control over how we manage marketing activities with you:
- we will take steps to limit direct marketing to a reasonable and proportionate level and only send you communications which we believe may be of interest or relevance to you;
- you can ask us to stop direct marketing at any time you can ask us to stop sending email marketing, by following the “unsubscribe” link you will find on all the email marketing messages we send you.
You can change the way your browser manages cookies, which may be used to deliver online advertising, by following the settings on your browser as explained above.
SECURITY OF YOUR PERSONAL INFORMATION
We take security very seriously. We have implemented and maintain appropriate technical and organisational security measures, policies and procedures designed to reduce the risk of accidental destruction or loss, or the unauthorised disclosure or access to such information appropriate to the nature of the information concerned. Measures we take include, for example:
- placing confidentiality requirements on our staff members and service providers;
- destroying or permanently anonymising Personal Information if it is no longer needed for the purposes for which it was collected; and
- applying security controls in the storage and disclosure of your Personal Information to prevent unauthorised access to it.
As the security of information depends in part on the security of the computer you use to communicate with us and the security you use to protect User IDs and passwords, please take appropriate measures to protect this information. However, due to the open communication nature of the Internet, we cannot guarantee that communications between you and Creativity Software, and Creativity Software and you, will be free from unauthorized access by third parties.
STORING YOUR PERSONAL INFORMATION
In specific circumstances we may store your Personal Information for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your Personal Information or dealings.
TRANSFERRING PERSONAL INFORMATION GLOBALLY
We operate on a global basis. Accordingly, your Personal Information may be transferred and stored in countries outside of Europe that are subject to different standards of data protection.
We will take appropriate steps to ensure that transfers of Personal Information are made in accordance with applicable law and carefully managed to protect your privacy rights and interests, and limited to countries which are recognized as providing an adequate level of legal protection or where we can be satisfied that alternative arrangement are in place to protect your privacy rights. To this end:
- we ensure transfers within our Group will adhere to applicable privacy and data protection laws and that such transfers ensure a consistent level of protection wherever it is transferred within the Group;
- where we transfer your Personal Information outside of Creativity Software to third parties who provide us services, we obtain contractual commitments from them to protect your Personal Information; or
- where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Information is disclosed.
LEGAL RIGHTS AVAILABLE TO HELP MANAGE YOUR PRIVACY
Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you may have, under certain applicable laws, some or all of the following rights in respect to your Personal Information:
- Right to access your own data;
- Accuracy and right of rectification and erasure; and
- Right to object to processing of Personal Information.
- Specific rights for EU data subjects: Under applicable EU data protection laws and regulations, EU data subjects have the following rights in respect to their Personal Information:
- Right to access
- Right of rectification and erasure
You have a right to request that we rectify inaccurate Personal Information. We may seek to verify the accuracy of the Personal Information before rectifying it. You can also request that we erase your Personal Information in limited circumstances where: (i) it is no longer needed for the purposes for which it was collected; (ii) you have withdrawn your consent (where the data processing was based on consent); (iii) following a successful right to object (see right to object); (iv) it has been processed unlawfully. We are not required to comply with your request to erase Personal Information if the processing of your Personal Information is necessary for compliance with a legal obligation or for the establishment, exercise or defense of legal claims.
- Right to restrict the processing of your Personal Information
Where we rely upon legitimate interest to process your Personal Information, then you have the right to object that processing if you believe your fundamental rights and freedoms outweigh our legitimate interests. If you raise an objection, we have an opportunity to demonstrate that we have legitimate interests which override your rights and freedoms. Please note that you also have the right to withdraw consent, in cases where we rely on your consent to collect and process your Personal Information.
- Right to data portability
You can ask us to provide you with your Personal Information that you provided to us, in a structured, commonly used, machine readable format, or you can ask to have it transferred directly to another data controller, but in each case only where: (i) the processing is based on your consent or on the performance of a contract with you; and (ii) the processing is carried out by automated means.
- Right to object to the processing of your Personal Information
You can object to any processing of your Personal Information which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.
- Right to file a complaint with the supervisory authority
You have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your Personal Information. We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority.
- Right to access
If you wish to access any of the above-mentioned rights, we may ask you for additional information to confirm your identity and for security purposes, in particular before disclosing Personal Information to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. You can exercise your rights by contacting us.
Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfil your request. We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.
The website is not directed nor targeted to children under the age of 16. Creativity Software will not knowingly collect information from children. If you are under 16, you may not submit information about yourself to us. In the event that we become aware that a User is under the age of 16 has shared any Personal Information, we will use reasonable efforts to discard such information. If you have any reason to believe that a minor has shared Personal Information with us, please contact us.
In many cases, these tags/files lead to the use of your device’s processing or storage capabilities. Some of these tags/files are set by Creativity Software itself, others by third parties; some only last as long as your browser session, while others can stay active on your device for a longer period of time.
These tags/files can fall into several categories: (i) those that are necessary for functionality or services that you request or for the transmission of communications (functionality tags/files); (ii) those that we use to carry out website performance and audience metrics (analytics tags/files) and (iii) the rest (tracking across a network of other websites, advertising, etc.).
Internet browsers allow you to change your cookie settings, for instance to block certain kinds of cookies or files. You can therefore block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies, you may not be able to access all or parts of the website, due to the fact that some may be functionality cookies. To consult the list of cookies we use on our website, please check your browser’s instructions.
You can find more information about cookies and similar tags/files at the following address: https://www.allaboutcookies.org/.
UPDATES TO THIS POLICY
If you have any questions, concerns or complaints regarding our compliance with this privacy notice, the information we hold about you or if you wish to exercise your rights, we encourage you to email firstname.lastname@example.org . We will investigate and attempt to resolve complaints and disputes and make every reasonable effort to honor your wish to exercise your rights as quickly as possible and in any event, within the timescales provided by data protection laws.