Privacy Statement

CreatIBI Ltd. Privacy Notice

Last updated MAY 31, 2024

CreatIBI Ltd. (“Company,” “we,” “us,” or “our“) respects your privacy and is committed to protecting it through our compliance with this notice. This notice describes the types of personal data we may collect from you or that you may provide when you visit the website or when you use CreatiBI Platform (our “Services”), how and why we collect, store, use, disclose and protect your personal data and what rights you have in relation to the processing of your personal data. We will not sell your personal data we collect or share it with third parties for cross-context behavioral advertising.

1. PERSONAL DATA WE COLLECT ABOUT YOU AND HOW WE COLLECT IT

Information CreatiBI Receives Directly From You

Information needed to create an account

This includes information that is needed for CreatiBI to create an account for you and manage your ability to log in and out of CreatiBI:

  • Identifiers, including first and last name and email address

  • Your password for CreatiBI (hashed) - unique, long, and strong

  • Information related to a third-party authentication identity provider, (e.g., Google Authenticator)

If you upgrade your account to a paid account, CreatiBI may collect:

  • Billing information, including name, address, and telephone number

  • Financial information, including credit card information or bank account information collected by our payment processors on our behalf

  • Information about your chosen CreatiBI plan

Information you provide to us through your use of CreatiBI

  • Information you provide in creatives, portfolios, projects, messages, scripts, and other features of CreatiBI Information uploaded to CreatiBI, such as attachments

  • Information from emails you forward to xxx@creatibi.com

  • Profile photo and other information you provide to describe yourself, which we only collect if you do choose to provide it, such as your gender pronouns

  • Professional or employment information, which may include your title or role at your company if you elect to provide this information

  • Any other information you choose to provide while using CreatiBI that identifies or can be reasonably associated with you

Other information you may provide to us when you interact with CreatiBI in other ways

If you directly interact with CreatiBI staff, such as our sales, user research, or user operations groups, CreatiBI may process the following information voluntarily provided by you:

  • Your requests, questions, and responses to us via forms, or email, or other means

  • Information you provide in connection with CreatiBI sweepstakes, contests, or research studies, if you choose to participate

  • Information to verify your identity

  • Geographic information, such as region and country

  • Social media information

  • Your date of birth

  • Biometric information associated with call recordings, with your consent in accordance with applicable law

Information automatically processed when you visit our websites or use our mobile or desktop app

We may also collect the following information related to your use of CreatiBI and our websites:

  • Metadata and inference information related to your use of CreatiBI, our websites, and third-party integrations to better understand the way you work in CreatiBI. We may log the actions you take as you use CreatiBI, including but not limited, to the number of CreatiBI workspaces you work in, the number of tasks you are assigned, what tasks or other features you view, when you delete a task or comment, the features and embedded content you interact with, the types of files you transmit, and what, if any, third-party integrations you use.

  • Internet network activity, cookies, and similar tracking technologies, including data our servers automatically record, including your web request, IP address, browser type and settings, referring/exit pages and URLs, number of clicks, date and time stamp information, language preferences, and other such information. Please visit our Cookies Notice for more information about the types of information we collect via cookies, including information about advertising and analytics, and how we use it.

  • Information collected as a result of participation in beta testing, such as error reports or feedback provided by you

  • Information about how you interact with our marketing websites, like creatibi.com, such as where you click, how long you visit a page, your scrolling, mouse hovers, and other data to help us better understand your experience and provide you with the best user experience

  • Device information and activity when you use CreatiBI via a mobile device, including the type of device you are using, device IDs, operating system version, and mobile network information to ensure that we are serving you the correct version of our application

  • Derived device geolocation information, including approximate geographic location inferred from an IP address

Information CreatiBI Receives from Other Sources

Sometimes CreatiBI receives your information from third parties (other individuals, marketing services, third-party integrations), which may include

  • Information processed from third-party integrations you set up with CreatiBI. For example, a third-party integration may give us access to information stored in that third party that CreatiBI will process to facilitate the integration

  • CreatiBI's use and transfer of information received from Google APIs to any other app will adhere to Google API Services User Data Policy, including the Limited Use requirements

  • Name, email, and business contact information

  • Information about you provided to us from other individuals or users of CreatiBI

2. HOW WE USE YOUR PERSONAL DATA

We use personal data we collect about you or you provide to us to:

CreatiBI uses your information to operate our products and services, communicate with you, process transactions when you change CreatiBI plans, for security and fraud prevention, and to comply with the law. Specifically, we may process your information to:

Provide services to you and operate our business

  • Maintain, provide, and improve our products and services

  • Suggest CreatiBI Help Center articles that may be relevant to you

  • Help us better understand user interests and needs, and customize CreatiBI for you

  • Analyze and research how you interact with our websites and applications

  • Protect CreatiBI and you, for example:

    • Securing our systems and products against fraud or unauthorized activity

    • Identifying, troubleshooting, and fixing bugs and errors

    • Complying with global laws and regulations

  • Investigate in good faith alleged violations of our User Terms of Service

  • If you use CreatiBI as part of an organization, company, or academic institution, CreatiBI will process your information as required by our contract with your organization or academic institution. Those contractual terms may differ from, and, in the event of a conflict, take precedence over, the uses described in this Privacy Statement.

In addition, we use information about your use of CreatiBI, account information (which may include your email address and name), and information related to third-party integrations to:

  • Communicate with you:

    • About CreatiBI by phone, text, email, or chat

    • To provide important notices and updates, product changes, and other necessary notices such as security and fraud alerts

    • To market CreatiBI services to you. via email, phone, and mail. You have the ability to unsubscribe from promotional marketing communications at any time

  • Advertise CreatiBI to you

  • Facilitate reporting and analyze performance of the CreatiBI platform or features available in CreatiBI

  • Provide webinars or public presentations

  • Demonstrate CreatiBI or provide you access to a demo CreatiBI instance

  • Process your information at your direction

  • Provide cross-device management of your account. For example, we may locate or try to locate the same unique users across multiple browsers or devices (such as smartphones or tablets), or work with service providers that do this, in order to save your preferences across devices and analyze usage of our products and services.

  • Provide you with support and get your feedback

    • Respond to your requests for information

    • Help identify and troubleshoot any issues with your account and answer your questions

    • Resolve support requests

    • Provide you with reports about usage

    • Survey your opinions through surveys, research studies, and questionnaires

Combined Information

Unless otherwise prohibited by law, we may combine the information that we collect through your use of our products and services with information that we receive from other sources, both online and offline, and use that combined information as set out above.

Aggregated and de-identified data

We may aggregate and/or de-identify information related to your use of CreatiBI (for example, how many tasks or projects you created) so that such information can no longer be linked to you or your device. We may use such aggregated and de-identified data for any purpose, including but not limited to, research and marketing purposes and may also disclose such data to any third parties, including advertisers, promotional partners, sponsors, event promoters, and/or others.

Artificial Intelligence and Machine Learning

Some features in CreatiBI are powered by artificial intelligence (AI) and machine learning. Admins and super admins can adjust AI preferences for your domain at any time by visiting the admin console.

When features powered by CreatiBI AI are enabled in your domain, we use metadata related to your domain’s use of CreatiBI to train machine learning models. Depending on the model and the feature, these machine learning models power features, both in your domain and other CreatiBI domains.

When features powered by AI Partners are enabled in your domain, we leverage third-party LLM service providers. Our third-party LLM service providers do not use customer data to train their models.

3. HOW LONG DO WE STORE YOUR DATA

When you use CreatiBI, some information about you will be stored in the United States. When you use our products and services, information about you will be transferred to the United States where the majority of CreatiBI’s data processing occurs.

We will only keep your personal data for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

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

4. WHEN WILL WE DISCLOSE YOUR PERSONAL DATA

We need to disclose the information we collect about you to make our products and services run smoothly and to operate our business under the following conditions:

  • Service providers and subprocessors. We may provide access or disclose your information to select third parties that use the information on our behalf to assist in providing CreatiBI’s services, website, and features. These third parties provide a variety of services to us, including without limitation sales, marketing, provision of content and features, artificial intelligence enabled functionality, advertising, analytics, research, data storage, security, fraud prevention, and other services.

  • Advertising partners. We may also provide information collected when you visit a CreatiBI website (which may include email addresses) to service providers, who may “match” this information in de-identified form to cookies (or mobile ad identifiers) and other proprietary IDs, in order to provide you with more relevant CreatiBI ads when you visit other websites. Our advertising partners may also use cookies and similar technologies on our website to display more relevant advertising about CreatiBI on other websites that you visit. Please see our Cookies Notice for more information about how we use targeting cookies and your options for managing them.

  • Because you ask us to disclose. We may disclose your information to third parties when you ask us to do so.

  • Consistent with your settings within our products and services. Please note that the information you submit through and post to CreatiBI may be viewable by other users in your workspace, team, division, or organization, depending on the specific settings you have selected and if an organization has been created for your domain.

  • Business transfers. If the ownership of all or substantially all of our business changes, or all or some of our assets are sold as part of a bankruptcy or other proceeding, we may transfer your information to the new owner so that the services can continue to operate. In such case, your information would remain subject to the promises and commitments contained in this Privacy Statement until the acquiring party updates it. If such transfer is subject to additional mandatory restrictions under applicable laws or agreements, CreatiBI will comply with those restrictions.

  • Compliance with legal obligations. We will notify individuals or customers of that request unless: we are prohibited from doing so by law or court order; or there are exceptional circumstances, such as an emergency involving the risk of bodily injury or death to a person or group of people or potential harm to minors.

  • Your company’s own CreatiBI account administrator (if you have one). If you’re using CreatiBI in connection with an organization, academic institution, or company domain, your company’s own CreatiBI account administrator can export data associated with the domain they manage if they have a subscription plan that allows them to do so.

  • Public Forums. Our public forums, such as the CreatiBI community forum, make it possible for you to upload and post comments or feedback publicly with other users. Any information that you submit through such public forums is not confidential and CreatiBI may use it for any purpose (including in testimonials or other CreatiBI marketing materials). Any information you post openly in these ways will be available to the public at large and potentially accessible through third-party search engines. Such information can be read, collected and/or used by other users and could be used to send you unsolicited messages.

We use and disclose the categories of information we collect from and about you consistent with the various business purposes we discuss throughout this Privacy Statement. We do not disclose your information to third parties for their own direct marketing purposes.

5. CROSS-BORDER TRANSFER OF YOUR DATA

If you are located within the European Economic Area ("EEA”).

For users located in the EEA, in case your personal data is transferred to countries located outside of the EEA, we will ensure that it will be protected in a manner consistent with legal requirements. This can be done in a number of different ways, such as:

  • the recipient of the personal data is located within a country that benefits from a full “adequacy” decision of the European Commission;

  • the recipient may have adhered to binding corporate rules (only for intragroup transfers); or

  • the recipient has signed a “model contractual clauses” approved by the European Commission, obliging it to protect your personal data;

For more information about the safeguards relating to personal data transfers outside of the EEA, please contact us using the details set out in “HOW TO CONTACT US?” section below.

6. CHILDREN UNDER AGE OF 16

Our Services are designed for adults and not intended for children under 16 years of age. We do not knowingly collect personal data from children under age 16. If we learn we have collected or received personal data from a child under age 16 without verification of parental consent, we will delete that information. If you believe we might have any data from or about a child under 16, please contact us.

7. WHAT ARE YOUR DATA PROTECTION RIGHTS?

We would like to make sure you are fully aware of all of your data protection rights. Depending on your jurisdiction, you may have the following rights:

Right to access.

You have the right to obtain information regarding the processing of your personal data and request us for copies of your personal data which we hold about you.

Right to rectification.

You have the right to request that we correct inaccurate information that we have about you. You also have the right to request us to complete information if it is incomplete.

Right to erasure.

You have the right to request that we erase your personal data, under certain conditions. Please note that there may be circumstances where you ask us to erase your personal data, but we are legally entitled to retain it;

Right to restrict processing.

You have the right to request that we restrict the processing of your personal data, under certain conditions. There may be circumstances where you ask us to restrict our processing of your personal data, but we are legally entitled to continue processing your personal data and/or to refuse that request;

Right to object to processing.

You have the right to object to us processing of your personal data, under certain conditions. There may be circumstances where you object to our processing of your personal data, but we are legally entitled to continue processing your personal data and/or to refuse that request;

Right to data portability.

You have the right to receive personal data in a structured, commonly used and machine-readable format and/or request that we transmit your personal data to a third party where this is technically feasible under certain conditions. Please note that this right only applies to personal data which you have provided to us;

Right to withdraw consent.

You have the right to withdraw your consent to our processing of your personal data. Please note, however, that we may still be entitled to process your personal data if we have another legitimate reason (other than consent) for doing so. For example, we may need to retain your personal data to comply with a legal obligation;

Right to complain.

You have the right to lodge a complaint with the supervisory authority if you think that any of your rights have been infringed by us.

You also have right not to be subject to a decision based solely on automated processing.US State consumer privacy laws may provide their residents with additional rights regarding our use of their personal data. If you are a resident of California, Colorado, or Virginia, you have the right to

  • Either limit (opt-out of) or require consent to process sensitive personal data.

  • Opt-out of personal data processing for targeted advertising; sales; or profiling in furtherance of decisions that produce legal or similarly significant effects.

The exact scope of these rights may vary by state. You can exercise your rights by contacting us using the details set out in the “ CONTACT US” section below. You will not be subject to discrimination for exercising your rights.

If you make a request, we will respond to you within the time required by applicable law. To appeal a decision regarding a consumer rights request,contact us at: privacy@creatibi.com.

8. WHAT ARE COOKIES

Cookies are small files that a site or its service provider transfers to your computer's hard drive through your Web browser (if you allow) that enables the site's or service provider's systems to recognize your browser and capture and remember certain information. For instance, we use cookies to help us remember and process the items in service. They are also used to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.

We use cookies to understand and save user's preferences for future visits and compile aggregate data about site traffic and site interactions to offer better site experiences and tools in the future. We may also use trusted third-party services that track this information on our behalf.

You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. Since each browser is a little different, look at your browser's Help Menu to learn the correct way to modify your cookies.

9. DIRECT MARKETING

You can opt-out of marketing messages we send you at any time by clicking on the “unsubscribe” link in the marketing e-mails we send you.

10. HOW WE PROTECT YOUR PERSONAL DATA

We have adopted organizational, physical and technical security measures that are in line with the industry standards to protect the personal data you provide, and to prevent any unauthorized access, disclosure, use, modification, damage or loss of data.

11. CHANGES TO OUR PRIVACY NOTICE

We may update this privacy notice from time to time. If we make material changes to how we treat your personal data, we will communicate it to you by email to your email address in our records. The date the privacy notice was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you.

12. CONTACT US

To ask questions or comment about this privacy notice and our privacy practices, contact us at: privacy@creatibi.com.

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