Privacy Policy

Creatore

Privacy Policy

Last Updated: March 30, 2023

This privacy policy (the “Privacy Policy”) describes the types of Personal Information Creatore, LLC (“Creatore,” “we,” “us,” or “our”) may collect from all visitors, users, Influencers, and Businesses ("User," “you,” or "your") or that you may provide to us when accessing and using our website and/or our mobile application (collectively, the "Site").

Please read this Privacy Policy carefully before accessing and using the Site to understand our policies and procedures regarding your Personal Information and how we will treat it.

THIS PRIVACY POLICY ONLY COVERS THE PERSONAL INFORMATION WHICH WE COLLECT, DIRECTLY OR INDIRECTLY, FROM YOU OR FROM THIRD-PARTIES. IT DOES NOT COVER, AND WE HAVE NO CONTROL OVER, THE INFORMATION THAT USERS REQUEST FROM OR PROVIDE TO EACH OTHER ON OUR PLATFORM. IF YOU SHARE PERSONAL INFORMATION WITH OTHER USERS THROUGH THE PLATFORM, YOU DO SO ENTIRELY AT YOUR OWN RISK AND ANY SUCH DISCLOSURE IS SOLELY BETWEEN YOU AND THE OTHER USER(S).

Capitalized terms not otherwise defined herein have the meaning set forth in our Terms of Use, which is hereby incorporated by reference.

Acceptance

By accessing and using our Site, you agree to the collection and use of your Personal Information in accordance with this Privacy Policy. Please do not use the Site if you do not agree with our policies and procedures.

Updates

We reserve the right to modify this Privacy Policy at any time by posting an updated Privacy Policy on the Site. If we make changes, we will notify you by revising the date at the top of the policy. If we make any material changes, we may notify you on the Site and, at our sole discretion, provide registered Users with an email notice of those changes. You are responsible for regularly reviewing this Privacy Policy, and your continued use of the Site after we make changes is deemed to be acceptance of the updated Privacy Policy. If any modification is unacceptable, you shall cease using the Site. If you have any questions about this Privacy Policy or wish to exercise any of your rights under this Privacy Policy, you may contact us at jack@creatoremkt.com.

Personal Information We Collect About You

To provide the Site, we may collect Personal Information from you. “Personal information” identifies, relates to, or could reasonably be linked with you or your household. For example, it could include your name, social security number, email address, records of products purchased, internet browsing history, geolocation data, fingerprints, and inferences from other Personal Information that could create a profile about your preferences and characteristics.

We collect Personal Information from the following categories of sources: (a) directly from you; (b) indirectly/automatically from you; and (c) from third parties.

Personal Information We Collect Directly From You

While you are accessing or using our Site, we may ask you to provide us with certain Personal Information about you that is necessary to provide you with our Site, and you may also choose to provide us with additional Personal Information.

You may also provide us with information about you at the time of registering an account with us to access and use our Platform, post content on the Platform, provide Feedback, or request customer support, which may include the following:

Contact Information: first and last name, email address, billing address, mailing address, business name, business address, and telephone number;
Personal Information: hobbies, interests, favorite activities, employment information, and other information that you provide us through access to your Social Media Accounts;
Business Information: business name, email address, and physical address;
Payment Information: our third-party Payment Processor may also collect your credit card information and provide us with your name, and the date and time of the transaction. To use certain features of the Platform, you may have to connect your account with our Payment Processor, and the creation or use of a Payment Processor account is between you and the Payment Processor and not defined by the terms of this Privacy Policy;
Account Information: username and password, display name, age, profile photo, account activity, and other content and files you record or upload to your account;
Communication Information: any content of any communications you send and/or receive through the Site or other communication, such as email, to or from us;
Customer Testimonials: any customer testimonials and comments on our Site, which you provide us through consent; and
Feedback and Support: information you provide through our customer service helpdesk, including subjects, descriptions, request type, and attachments.

We will not ask or require you to provide sensitive information such as information related to your finances, health, marital status, or any other information not required to provide the Site. We will not ask for, and you should not provide us with, information regarding protected classifications, including: race, color, religion, national origin, sex/gender, gender identity, sexual orientation, marital status, medical condition, and disability information (as described under the appropriate state or federal law).

Information We Automatically Collect From You

While you are accessing and using our Site, we may automatically collect certain information from you. This information may include, but is not limited to:

Your device's internet protocol address (e.g. IP address), browser type and version;
Access date and time, pages of our Site that you visit and the time spent on those pages, and other actions while using the Site;
Geolocation data, such as the precise or approximate location determined from your IP address;
When you access the Site by or through a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data;
Information about the device you use to access our Site, including the hardware model, operating system and version, unique device identifiers, and cookie data;
Other diagnostic data.

The information we automatically collect from you is only statistical data and does not include Personal Information, but we may maintain it or associate it with Personal Information we collect in other ways to help us improve our Site and deliver a better and more personalized service. We use these technologies for a number of purposes, including enabling you to use the Site, facilitating the functioning of and your access to the Site, better understanding how you navigate through the Site, and detecting and preventing fraud.

The technologies we may use for this automatic data collection may include:

Cookies (or browser cookies). Cookies are small files placed on your computer’s hard drive when you access certain websites that record your preferences. We use cookies to track the use of and improve our Site.

Flash Cookies. Certain features of our Site may use locally-stored objects (or Flash Cookies) to collect and store information about your preferences and/or your activity on our Site.

Web Beacons. Certain sections of our Site and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, or single-pixel gifs) that permit us to determine whether you performed a specific action, for example, if you visited our Site or opened an email.

Third-Party Use of Cookies

Some content or applications on the Site are served by third parties, including payment processors and content and application providers. These third parties may use cookies, web beacons, or other tracking technologies to collect information about you when you access or use our Site. The information they collect may be associated with your Personal Information, and/or they may collect information related to 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. We do not control these third-party tracking technologies or how they may be used. You should contact the responsible provider directly if you have questions about an advertisement or other targeted content. For more information about how to opt out of receiving targeted advertising from many providers, see the Network Advertising Initiative’s opt-out page and Google Ads setting page.

Personal Information We Collect from Third Parties

We may collect Personal Information about you from other sources, including but not limited to (i) third-party services that you use to link or connect with our Services, such as Facebook, Instagram, Pinterest, Twitter, TikTok, Twitch, Snapchat, and YouTube, and (ii) service providers, analytics companies, advertising networks, and other third parties that, to the extent permitted by applicable law, provide us with additional information about you.

The information we collect from such third-parties may include the following:

Name, account information, and friends lists or contacts, in accordance with the authorization procedures determined by such social media site; and
Identification Information: government-issued photo ID, and User profile pictures.

Uploading and Posting Personal Information on the Site

You may provide Personal Information to be displayed in public areas or transmitted to other Site Users or third parties. This Personal Information is posted on and transmitted to others at your own risk. While all Site Users must abide by our Terms of Use, we cannot guarantee that their use of Personal Information that you provide directly to them or through the Site will be handled in accordance with this Privacy Policy. Commenting may be moderated by Creatore administrators and subject to approval before appearing on the Site, and we may remove a comment at any time at our discretion. You need to contact us if you want the Personal Information posted to the comments section removed.

How We Use Your Personal Information

We use the Personal Information you provide or we collect:

To present our Site and Platform to you;
To provide and maintain the functionality of the Site and Platform, including monitoring the usage of our Site;
To notify you about changes to our Site and our Platform;
To allow you to participate in interactive features of our Site and Platform when you choose to do so;
To provide customer support;
To create and manage your account;
To allow you to log into the Platform;
To provide you with news, special offers, and general information about other goods, services, and events that we offer that are similar to those you have already purchased or inquired about, unless you have opted not to receive such information;
For our internal business purposes, such as data analysis, audits, and so forth;
To gather analysis or valuable information so that we can improve our Site and our Platform;
To fulfill our obligations and enforce our rights arising from any contracts you entered with us;
To monitor the usage of our Site;
To detect security incidents and protect against deceptive, illegal, or unauthorized activities;
To comply with the law;
To evaluate and/or conduct a divestiture, restructuring, dissolution, merger, or other transfer or sale of some or all of our assets;
In any other way we may describe when you provide the information; and
For any other purpose with your consent.

How We Share and Disclose Your Personal Information

Where permissible under applicable law, we may share your information in the following situations:

With Registered Businesses. When an Influencer submits a Bid or otherwise communicates with a Business on the Platform, the Business is provided the Influencer’s name, social media account links, and any other information that the Influencer provides directly to the Business.
With Service Providers. We may share your Personal Information with service providers, contractors, and other third parties we use to support our business and who are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes we disclose it to them. Our service providers include:
1. Amazon Web Services: For website hosting and to provide the Platform; and
2. Stripe: For payment processing.
With Business Partners. We may share your Personal Information with our business partners to offer you certain products, services, or promotions, and they are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them.
With Other Users. When you interact in public areas with other Users, such Personal Information may be viewed by all Users and may be publicly distributed.
For Business Transfers. We may share or transfer your Personal 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.
As Aggregated Information. We may disclose aggregated information about our users and information that does not identify any individual to our advertisers, business partners, or any other third party.
To Enforce Our Agreement. We may disclose your Personal Information to enforce and administer our agreements, including but not limited to our Terms of Use, Influencer Agreement, and Business Agreement.
To Protect Our Rights. We may disclose your Personal Information to protect the rights, property, or personal safety of our company, its employees, its members, and the public.
For Legal Compliance. We may disclose your Personal Information to comply with the law, a court order, or legal process, including: (a) notices of intellectual property infringement, (b) claims that User-Generated Content violated the rights of third parties, (c) government or regulatory request, and/or (d) investigate the use of or respond to alleged violations or infringement of Third-Party Content.
With Your Consent. We may disclose your Personal Information for any other purpose with your consent.

How We Secure Your Personal Information

We use commercially reasonable technical safeguards to secure any Personal Information we collect about you. The secure server software ("SSL") encrypts all information you input before sending it to us. In addition, your account information is password-protected for your privacy and security. You should always take steps to protect the confidentiality of the password you select. You must protect yourself against unauthorized access to your password and computer. Be sure to sign off when you finish using a shared computer.

The security of your Personal Information is important to us, but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security. If you have any questions about our services’ security, you can contact us at jack@creatoremkt.com.

How You Can Manage Your Personal Information

You may correct, amend, or delete the information we hold about you. After receiving proof of your identity, you may request that we delete or change any or all of your Personal Information (subject to certain exceptions), and we will do our best to respond to your request within thirty (30) days of receipt.

You are responsible for keeping your Personal Information up to date. If you are registered on our Platform, most of your account information can be changed in the "Edit Profile" section.

Retention of Your Personal Information

We may retain your Personal Information for as long as your account is active or as needed to provide you with the Site. We will also retain and use your Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

We will also retain statistical data for internal analysis purposes for any period of time as we choose unless we are legally obligated to retain this data for longer periods.

Consent to Processing of Your Personal Information in the United States

Please be aware that your Personal Information may be processed by us (and third parties on our behalf as further described in this Privacy Policy) outside of your home country, including to the United States, where data protection and privacy regulations may not offer the same level of protection as privacy laws in your country. If you create an account with us, you agree to this Privacy Policy, and you consent to the transfer of all information you provide to us in the United States.

Opting-Out of Personalized Ads

You may choose to opt out of receiving emails and newsletters from us and delete, disable, and manage browser cookies and flash cookies.

Marketing Emails Opt-Out. If you no longer want to receive marketing emails from us, you may click the “Unsubscribe” link in an email, follow the instructions provided in any email we send, or contact us at jack@creatoremkt.com.
Tracking Opt-Out. You can opt out of accepting cookies (or browser cookies) by activating the appropriate setting on your browser or setting your browser to alert you when cookies are being sent. However, if you disable or refuse, you may not be able to access and use some parts of our Site. Flash Cookies are not managed by the same browser settings as those used for Browser Cookies; please visit Adobe’s Flash player settings page for more information on managing Flash cookies.

Third-Party Websites

We may provide links to third-party websites within the Site, but this Privacy Policy does not apply when you access third-party websites directly from the Site. Please note that we have no control or responsibility over their data collection, use, or disclosure practices. You will be subject to their privacy policies when you click on links that take you to external websites. If you access and transmit information to third-party websites, you do so at your own risk. You should carefully review the privacy policy of any third-party website you visit before using it or disclosing your Personal Information to its provider.

Collection of Payment Information

We use a third-party Payment Processor for processing payments and any other fees applicable to your use of the Platform and for any Influencer Services that you purchase through the Platform. Our current Payment Processor, Stripe, collects all necessary payment information, and we will not store or collect your payment card details. Payment information will be provided by you directly to our Payment Processor, whose use of your Personal Information is governed by their privacy policy. For more information about Stripe’s privacy policy, please visit the Stripe website.

Personal Information of Minors

The Site is intended for individuals 16 or older. If you are under 16, you may not use the Site nor have an account on the Platform. We do not knowingly collect information from or direct any of our content specifically to children under 16. If we learn or have reason to suspect that you are a User who is under the age of 16, we will have to close your account. If you believe we might have any information from or about a child under the age of 16, please contact us at jack@creatoremkt.com.

Supplemental Notice to California Residents

Users of the Site that reside in California may have additional rights afforded to them under California privacy laws.

Additional Definitions Applicable to California Privacy Laws

“CCPA” or “California Consumer Privacy Act” means California Civil Code § 1798.100 et seq.

"Consumer," "Business," "Sell," and "Service Provider" will have the meanings given to them in the CCPA.

California Consumer Privacy Act ("CCPA")
1. Your Rights. If the processing of your Personal Information is subject to the CCPA, you have the right to:
  1. Request us to disclose the categories and specific pieces of Personal Information we collect, use, disclose, and sell;
  2. Know the categories of Personal Information that we collect and the purposes for which we collected or used such Personal Information and whether that information is sold or shared;
  3. Know the categories of sources from which the Personal Information was collected;
  4. Know the categories of third parties with whom we shared or to whom we sell your Personal Information;
  5. Know whether we collected or sold your Personal Information for business or commercial purposes;
  6. Request deletion of Personal Information we collected from you, subject to certain exceptions;
  7. Opt-out of the sale of their Personal Information; and
  8. Not receive discriminatory treatment by us for exercising their rights set out in the CCPA.

Categories of Personal Information Collected by Us

For information about what categories of Personal Information we may collect from our Users in the twelve (12) months preceding the date this Privacy Policy was last modified, the sources of such information, the purposes for collecting and using that information and what types of third-party service providers we may share that information with please see the following sections in this Privacy Policy titled: “Personal Information We Collect About You”; “How We Use Your Personal Information;” and “How We Share and Disclose Your Personal Information.” For more information about how to review and change your Personal Information collected through the Site, please see the section titled “How You Can Manage Your Personal Information.”

Categories of Personal Information Disclosed for a Business Purpose

The following is a summary of the categories of Personal Information we have disclosed for a business or commercial purpose in the 12 months preceding the date this Privacy Policy was last modified.

Categories of Personal Information we collect include:

Parties with whom each category of Personal Information may be shared include:

Identifiers: Real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.

Service providers, payment processors, our affiliates, our business partners, third-party vendors to whom you or your agents authorize us to disclose your Personal Information in connection with our Site, other users of the Site where you consent to display your Personal Information publicly.

Categories of Personal Information described in California Civil Code §1798.80(e): Name, mailing address, billing address, and telephone number.

Financial Information: billing address, bank account number, credit card number, debit card number, or any other financial information.

Payment Processors, our affiliates, and our business partners to whom you or your agents authorize us to disclose your Personal Information in connection with our Site.

Commercial Information: Records and history of Subscription Plans purchased, obtained, or considered, or other purchasing consuming histories or tendencies.

Service providers, payment processors, our affiliates, our business partners, and third-party vendors to whom you or your agents authorize us to disclose your Personal Information in connection with our Site.

Internet and other similar network activity.

Geolocation Data

Such categories of Personal Information may be collected, used, or disclosed for business and commercial purposes, which may include the following examples:

To operate and improve our Site and our Platform;
To provide you with our Site and the Platform, respond to your inquiries, and give you the necessary support;
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
As described to you when collecting your Personal Information or as otherwise set forth in the CCPA;
For internal administrative and auditing purposes; and
To detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity, including, when necessary, to prosecute those responsible for such activities.

Do Not Sell My Personal Information

As a California consumer, you have the right to opt out of the sale of your Personal Information. To make such a request, please contact us by email at jack@creatoremkt.com.

In the past 12 months, we have not sold your Personal Information other than to utilize Google Analytics to gain insights regarding how users interact with the Site and to better provide the Site. See the heading titled ‘Google Analytics’ of this Privacy Policy for more information about our use of Google Analytics and the categories of Personal Information collected by Google Analytics.

Minors

If you are under 18 and registered with our Site, you have the right to request and obtain the removal of content or information you have publicly posted under the California Business and Professions Code Section 22581. Be aware that your request does not guarantee the complete or comprehensive removal of content or information posted online, as the law may not permit or require removal in certain circumstances.

Do not Track Features

California law requires us to let you know how we respond to web browser Do Not Track (DNT) signals. However, no uniform technology standard for recognizing and implementing DNT signals exists presently. As such, we do not currently respond to or support DNT signals or any other mechanism that automatically communicates your choice not to be tracked online.

California’s Shine the Light Law

Under California's Shine the Light Law, California Consumers may request the type of Personal Information we disclosed to third parties for their direct marketing purposes and a list of those third parties (if any). We have not disclosed Personal Information to third parties for direct marketing purposes.

To make any requests regarding your California Privacy Rights, please contact us by email at jack@creatoremkt.com.

Social Media Metrics Collection and Use

Our application integrates with various social media platforms, including Google's YouTube Data API, Instagram, Facebook, Twitch, and TikTok, to enhance your experience by calculating your 'Creator Score' using metrics from your posted content. Here are the specifics of our data collection and usage practices:

Data We Collect

YouTube Metrics: Like and comment counts of a limited number of your posted videos.
Instagram Metrics: Likes, comments, content views, and follower counts from your posts.
Facebook Metrics: Likes, comments, content views, and follower counts from your posts.
Twitch Metrics: Views, comments, likes, and follower counts from your streams and videos.
TikTok Metrics: Likes, comments, views, and follower counts from your videos.

Purpose of Data Collection

The collected metrics are used solely to calculate your 'Creator Score' within our application. We do not use this data for any other purposes.

Data Storage

We store the collected metrics securely and ensure that your personal data is protected. No other data from your social media accounts is stored or used.

Data Sharing

We do not share your data with third parties. Your data is used exclusively within our application to calculate and display your 'Creatore Score'.

User Consent

By connecting your social media accounts, you consent to our collection and use of your content metrics as described in this policy.

Data Security

We implement industry-standard security measures to protect your data from unauthorized access, disclosure, or alteration.

User Control

You have control over your data. You can disconnect your social media accounts at any time, and we will promptly delete the stored metrics from our servers.

Compliance with Platform Policies

Our data handling practices comply with the limited use requirements and user data policies of each social media platform. We ensure that the data we collect is used solely for the purposes stated above and is not shared with third parties.

Links

Google Services User Data Policy: https://developers.google.com/terms/api-services-user-data-policy

Contact Information

If you have any questions or complaints about this Privacy Policy or our handling of your Personal Information, please contact us at jack@creatoremkt.com.

Privacy Policy

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