Privacy Policy at Create! Magazine

Updated: 9/28/2020

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are, how and why we collect, store, use, and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.

We collect, use and are responsible for certain personal information about you. When we do so we are compliant with state and federal laws of the United States, and subject to the General Data Protection Regulation which applies across the European Union (including in the United Kingdom), and we are responsible as “controller” of that personal information for the purposes of those laws.

Key terms

It would be helpful to start by explaining some key terms used in this policy:

We, us, our

Create! Magazine, LLC; Create! Magazine

Personal information

Any information relating to an identified or identifiable individual

Special category personal information

Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership; genetic and biometric data; data concerning health, sex life or sexual orientation.

Personal Information We Collect About You

Your name and contact information, including email address and telephone number;

Information to enable us to check and verify your identity, and whether you are of appropriate age to access content, e.g., your date of birth;

Your gender information, if you choose to give this to us;

Location data, if you choose to give this to us;

Your billing information, transaction and payment card information, as applicable;

Your interests and preferences;

Your contact history, purchase history and saved items;

Information from accounts you link to us, e.g. Facebook, Instagram, and/or other platforms;

Information about how you use our website, IT, communication and other systems;

Your responses to surveys, competitions, and promotions;

Data, content, videos, photos, and any other information you provide via public posts, interactions, comments, and other chat or communication features

This personal information is required to provide services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing services to you.

How Your Personal Information is Collected

We collect most of this personal information directly from you, by email and/or via our website and apps. However, we may also collect information:

From publicly accessible sources;

Directly from a third party, e.g., social media accounts and other platforms that you link to us;

From a third party with your consent, e.g., your bank or credit card provider;

From cookies on our website; and

Via our IT and third-party systems, automated monitoring of our websites and other technical systems, such as our computer networks and connections, access control systems, communications systems, email, and instant messaging systems.

How and Why We Use Your Personal Information

Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.:

To comply with our legal and regulatory obligations;

For the performance of our agreement to provide services to you or to take steps at your request before entering into an agreement;

For our legitimate interests or those of a third party; or

Where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what we use your personal information for, and our reasons for doing so:

What we use your personal information for

Our reasons

To provide services to you.

For the performance of our agreement to provide services to you or to take steps at your request before entering into an agreement.

To prevent and detect fraud against you or Create! Magazine.

For our legitimate interests or those of a third party, i.e., to minimize fraud that could be damaging for us and for you.

Conducting checks to identify our customers and verify their identity.

To comply with our legal and regulatory obligations.

Ensuring business policies are adhered to, eg policies covering security and internet use.

For our legitimate interests or those of a third party, i.e., to make sure we are following our own internal procedures so we can deliver the best service to you.

Operational reasons, such as improving efficiency, training and quality control.

For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service to you.

Ensuring the confidentiality of commercially sensitive information.

For our legitimate interests or those of a third party, i.e., to protect trade secrets and other commercially valuable information

To comply with our legal and regulatory obligations.

Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures.

For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service to you.

Preventing unauthorized access and modifications to systems.

For our legitimate interests or those of a third party, i.e., to prevent and detect criminal activity that could be damaging for us and for you.

To comply with our legal and regulatory obligations.

Updating and enhancing customer records

For the performance of our agreement to provide services to you or to take steps at your request before entering into an agreement.

To comply with our legal and regulatory obligations.

For our legitimate interests or those of a third party, e.g., making sure that we can keep in touch with our customers about existing and new services.

Marketing our services and those of selected third parties to:- existing and former customers; - third parties who have previously expressed an interest in our services;- third parties with whom we have had no previous dealings.

For our legitimate interests or those of a third party, i.e., to promote our business to existing and former customers.

The above table does not apply to special category personal information, which we will only process with your explicit consent.

Promotional Communications

We may use your personal information to send you updates (by email, text message, telephone, mail, or in-app) about our services, including exclusive offers, promotions or new services.

We have a legitimate interest in processing your personal information for promotional purposes (see above “How and why we use your personal information”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

You have the right to opt-out of receiving promotional communications at any time by:

contacting us (see below: “How to contact us”).

using the “unsubscribe” link in emails or “STOP” number in texts

updating your marketing preferences on our website

We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

Who We Share Your Personal Information With

We routinely share personal information with:

Third parties we use to help deliver our services to you, e.g., payment service providers;

Third parties that use the information to perform services on our behalf and/or help us run our business. These third parties provide a variety of services to us, including without limitation: sales, marketing, website hosting, provision of content and features, advertising, analytics, research, data storage, security, fraud prevention, bug reporting, crash reporting, in-app chats, user surveys, and other services;

Third parties approved by you, e.g., social media sites you choose to link your account to or third party payment providers;

Our insurers and brokers;

Our bank(s);

Third parties we use to collect and analyze data for compliance, website improvement, and for scientific research, including but not limited to data science teams and data visualization tools.

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers to ensure they can only access, process, store, or use your personal information in furtherance of providing services to us and to you.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a restructuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

Where Your Personal Information is Held

Information may be held at our offices, third party agencies, service providers, representatives and agents as described above (see above: “Who we share your personal information with”).

Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: “Transferring your personal information out of the EEA”.

How Long Your Personal Information Will Be Kept

We will keep your personal information while you have an account with us or we are providing services to you. Thereafter, we will keep your personal information for as long as is necessary:

To respond to any questions, complaints or claims made by you or on your behalf;

To show that we treated you fairly;

To keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this policy.

Transferring Your Personal Information Out of the EEA

To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), eg:

• With our offices outside the EEA;

• With your and our service providers located outside the EEA;

• If you are based outside the EEA;

• Where there is an international dimension to the services we are providing to you.

These transfers are subject to special rules under European and UK data protection law.

The following countries to which we may transfer personal information have been assessed by the European Commission as providing an adequate level of protection for personal information: United States.

These non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure.

If you would like further information please contact us (see below: “How to contact us”).

Your Rights


The right to be provided with a copy of your personal information (the right of access).


The right to require us to correct any mistakes in your personal information.

To be forgotten

The right to require us to delete your personal information, in certain situations.

Restriction of processing

The right to require us to restrict processing of your personal information, in certain circumstances, e.g., if you contest the accuracy of the data.

Data portability

The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations.

To object

The right to object:- at any time to your personal information being processed for direct marketing (including profiling);- in certain other situations to our continued processing of your personal information, e.g., processing carried out for the purpose of our legitimate interests.

Not to be subject to automated individual decision-making

The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner's Office (ICO) on individuals rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please:

Email, call, or write to us (see below: “How to contact us”);

Let us have enough information to identify you (e.g., your full name and email address);

Let us have proof of your identity (e.g., a copy of your driver's license or passport); and

Let us know what right you want to exercise and the information to which your request relates.

Keeping Your Personal Information Secure

We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

How to Complain

We hope that we can resolve any query or concern you raise about our use of your information.

The General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.

Changes to This Privacy Notice

This privacy notice was published on 9/28/2020 and last updated on 9/28/2020.

We may change this privacy notice from time to time. When we do we will inform you via the email associated with your account.

How to Contact Us

Please contact us by email or telephone if you have any questions about this privacy policy or the information we hold about you.

Our contact details are shown below:

Do You Need Extra Help?

If you would like this notice in another format (e.g.,: audio, large print, braille) please contact us (see above: “How to contact us”).