Privacy Policy

Who We Are

Creative Mornings, Inc. has created this Privacy Policy to demonstrate our firm commitment to protecting your personal information and to outline our information gathering and sharing practices. We will not share your personal information with anyone except as described in this Privacy Policy.

By using the CreativeMornings.com or CreativeGuild.com websites, or any related platform or downloadable application (collectively, the “Services”), you consent to our collection and use of any personal and other information you provide in accordance with this Privacy Policy. If you do not agree to this Privacy Policy, please do not use the Services.

If you have any questions or concerns related to this Privacy Policy, please contact us via e-mail at [email protected] or write to us:

Attention: CM Online Privacy
Morrison Tenenbaum, PLLC.
87 Walker Street, Second Floor
New York, New York 10013

This Privacy Policy is supplemental to our Terms of Use.

The Services

When you use the Services, you may view information and content that is owned, licensed, or provided by us, our parent companies, subsidiaries and affiliates (together, “Creative Mornings”). We may also provide information and services owed by third parties and distributed by virtue of a license, grant or some other form of agreement. When used in this Privacy Policy, “we”, “us” and “our” mean Creative Mornings.

Using the Website

You can review website content without providing any personal or individually identifiable information. You may also be able to set the security settings on your browser or network connected device to prevent certain tracking and logging features. If you do that, the Services may be less functional for you.

To actively utilize the Services and interact with the Community, you will be required to provide personally identifiable information upon registration. Registration provides you with the ability to use interactive features, enter and view information, receive e-mails from us, participate in discussions, leave comments, sign up for events or participate in special promotions. If you choose to register or if you conduct transactions through the Services, we will collect information about the transactions you engage in and your other activities. We need certain information from you to register you, authenticate you and process your registration information and transactions.

Kinds of Information We Collect

We may collect information that you voluntarily give us, as well as location-based information and site visitorship data as described below.

Personally Identifiable Information

We may collect information that you voluntarily give us, as well as location-based information and site visitorship data as described below.

Personally Identifiable Information

In order to take advantage of certain features, you may be asked to provide personally identifiable information about you that would enable us to contact you directly. Personally identifiable information includes your e-mail address, name, gender, date of birth, postal/mailing address, telephone numbers, shipping and billing addresses, or persistent identifier (such as a customer number held in a cookie) which is associated with personally identifiable information, as well as other information, that you may provide voluntarily. We collect such personally identifiable information that you give us so that we may:

  • • provide you with information and instructions regarding the Services;
  • • verify that the information we have about you is correct;
  • • provide information to our third party marketing partners, subject to this policy;
  • • provide information about products and services offered by our partners;
  • • notify you about new features and products available through the Services;
  • • respond to your requests for information;
  • • process survey results and other data you provide;
  • • process contest entries;
  • • process purchases and payments;
  • • filter the services and information offered to you; and
  • • open, maintain and administer user accounts.

We will use the personally identifiable information we collect to provide you with specific information and services that you request, and with additional information and services that may be of interest to you. We may also use the personally identifiable information to analyze and improve your experience using the Services and to customize your experience to match your preferences. By providing personally identifiable information, you fully understand and consent to the collection and processing of such information in the United States of America. To protect your privacy and security, we may also take reasonable steps to verify your identity, such as requiring a password and user ID, before granting access to your data. While we strive to protect our users’ personal information and privacy, we cannot guarantee the security of any information you disclose online, and you do so at your own risk.

We may also collect non-personal information, such as your IP address and use ‘cookies’. The information obtained from collecting IP addresses and using ‘cookies’ is not personal information about you. For more information, please read the section on Site Visitorship Data below.

Legal Basis for Processing Personal Information (EEA Users Only)

In compliance with the European Union’s new General Data Protection Regulation (GDPR), in effect as of May 25, 2018, the legal basis for us to collect or use the personal information described above for any visitor or customer located in the European Economic Area (“EEA”) is dependent on the personal information and specific context in which it is collected. We will normally collect personal information only when we have received your freely given and informed consent, when it is necessary to perform a contract with you, where the processing of such personal information is in our legitimate interest and not overridden by your data protection interests and when it does not constitute an infringement of your fundamental rights and freedoms.

Location-Based Information

We may collect information relating to your general location based on (1) information you manually provide, (2) the IP address of your network connected device, (3) Global Positioning System (GPS) information sent to us by your GPS-enabled device, and (4) the proximity of your computer, tablet, mobile wireless device, personal digital assistant, personal communication system, or other communications device (your “Personal Communication Device”) to the nearest radio tower or cell site. We may also be able to detect when your Personal Communication Device is activated as well as when and how you are using it. CreativeMornings may collect data to verify the information you provide manually and to provide you with location-based content and advertising. We may associate Personally Identifiable Information with location-based information provided by you and your Personal Communication Device for our internal use and to improve your experience with the Services.

Site Visitorship Data

Site visitorship data is information about the way a website is used that is not associated with an individual’s identity. We use anonymous data regarding online behavior to better understand how people use our Services. To that end, we may use aggregated, anonymous online traffic behavior along with information from third parties to track usage trends and thereby improve the Services. We may also use this aggregated, anonymous information to develop reports that we may share with third party marketing partners and affiliates. The kind of information we may collect includes:

  • • the date and time you use the Services;
  • • your Internet service provider, mobile carrier, or data services provider;
  • • your Internet Protocol (IP) address;
  • • the pages you visit;
  • • the links you click;
  • • the features used;
  • • how and when you interact with the Services;
  • • the content, images and advertisements you select; and
  • • how you arrived at the Website and where you go when you leave.

Most site visitorship data is collected using data collection tools such as web beacons, cookies, embedded web links and other software (together, “Data Collection Tools”). Data Collection Tools are typically small data files or software that are sent to your browser and stored on your computer’s or mobile device’s hard drive. Most browsers and display software can be set to inform you when Data Collection Tools are being used or other tracking software is being sent to your computer or Personal Communication Device. They also provide you with the option of refusing such Data Collection Tools. However, refusing to allow the use of Data Collection Tools may, in some cases, preclude you from using, or negatively impact the display or function of, certain areas or features.

Disclosure of Information

We will not sell, trade, or otherwise release any personally identifiable information to third parties, not including wholly-owned subsidiaries and affiliates under common ownership or control, without your consent except as follows below. You hereby authorize us to use your personally identifiable information as follows:

(1) By providing us your personally identifiable information you grant CreativeMornings the right to use such information to provide you content and services, and for the benefit of CreativeMornings without restrictions; personally identifiable information may be used for research and analysis, content, product and site development, and other proprietary uses.

(2) (2) CreativeMornings may share information we collect with our sponsors, and business and third party marketing partners. If we share your information, we will request that such third parties treat your information in accordance with this Privacy Policy and refrain from disclosing or using your personally identifiable information for purposes other than the provision of Services to you or for the benefit of CreativeMornings. CreativeMornings does not provide personally identifiable information to unaffiliated third parties for use in marketing directly to you.

(3) We may disclose information we collect, including personally identifiable information, to third parties as required or permitted by law. For example, we may disclose information:

  • • to regulators;
  • • to law enforcement authorities pursuant to an official request;
  • • to financial institutions in the event you enter into transactions through any of the Services;
  • • to vendors who provide us with services; and
  • • to companies that may acquire part or all of CreativeMornings or an affiliated company.

When you provide us with information pursuant to a transaction on or through the Services, you agree to the disclosure of any information you provide for the purpose of executing the transaction or fulfilling the request, as the case may be. CreativeMornings is not responsible for the protection of the information you provide to other websites. You should be aware that when you voluntarily disclose personally identifiable information through other applications and websites, such information can be collected and used by others and may result in unsolicited communications.

If you are located in the EEA or Switzerland, you may also:

  • • request access to and receive details regarding the personal information we maintain about you in order to update or correct inaccuracies in such Personal Information, restrict, or reject to the processing of such Personal Information, have the information deleted, as appropriate, to exercise your right to data portability to easily transfer your Personal Information.
  • • have the right to submit a complaint to lodge complaints in your country of residence, place of work or location of incident with a supervising authority responsible for the enforcement of data protection rights.
  • • withdraw consent that you have previously provided regarding any Personal Information that you have allowed for processing, at any time free of charge.

Advertising

We may use third-party companies to serve ads and provide content through the Website. These companies may use cookies and other data collection tools that are not sent by us to learn about your use of the Website and other websites and applications. CreativeMornings is not responsible for such cookies and tracking software.

Commercial Transactions

Circumstances may arise where, whether for strategic or other reasons, we decide to sell, buy, merge or otherwise reorganize our business. Such a transaction may involve the disclosure of personally identifiable information to prospective or actual purchasers or joint venture partners, or the receipt of it from sellers. It is our practice to seek appropriate protection for information in the event such a transaction occurs.

Information Security

Whenever you enter an area of the site that carries, or requires you to enter, sensitive information such as your credit card details, a padlock icon will appear in the address bar of your browser, indicating that the page is secure. CreativeMornings uses the Secure Sockets Layer (SSL) and Private Communications Technology security standards that are supported by Microsoft Internet Explorer 4.0 or later and other popular browsers. SSL encodes your personal information by encrypting credit card number, name, address, phone number, identification number and your password so that they cannot be read by unauthorized parties. While we may at times provide encryption technologies and use other reasonable precautions to protect confidential information and provide suitable security, we do not guarantee that information transmitted through the internet is secure, or that such transmissions will be free from delay, interruption, interception or error.

CreativeMornings may implement certain physical, technological and managerial procedures to safeguard the personally identifiable information we collect. However, these procedures do not guarantee that the information will remain secure against theft or misuse.

Communications

From time to time, CreativeMornings and its affiliates may communicate with you regarding your transactions, the administration of your account, current projects, special offers, invitations to events, offers for services, new product previews and updates to the Services, press releases and announcements, contests and sweepstakes, as well as important changes to our Terms of Use and this Privacy Policy. By providing us with your e-mail address and/or your mobile phone number, you consent to receiving such communications. If at any time you decide for any reason that you no longer wish to receive such communications, you may “opt out” of receiving them through any of the following methods:

  • • Select the “opt out” or “unsubscribe” link, or follow the opt-out instructions that may be included in such communication.
  • • Where applicable, return to the web page or service where you originally registered your preferences and follow the opt-out instructions.
  • • E-mail us at [email protected]. Be sure to provide your name, e-mail address and postal address, and specific relevant information about the particular communication you no longer wish to receive.

Please be aware that when you opt out of receiving communications, it may affect your use of the Website. By registering as a user or entering into transactions through the website, you consent to receiving administration and transaction related communications.

Hyperlinks and Referrals

Other websites and applications accessible through the Services (through hyperlinks, advertisements or otherwise) have their own privacy policies and data collection, use and disclosure practices. Please consult their Terms and Conditions and their Privacy Policies prior to use. We do not, even periodically, review the Privacy Policies or Terms of Use of third parties and we are not responsible or liable for their privacy practices, availability or reliability of the website they may provide, their services or the accuracy or completeness of their content. We seek to protect the integrity of our site and welcome you to e-mail us about linked sites (including if a specific link does not work).

One such third party we use is YouTube API services. As part of Google, they are governed by Google Privacy Policy, located here: https://www.google.com/policies/privacy

Children’s Privacy

We do not knowingly collect or distribute personally identifiable information from children under the age of 13. If we know a visitor is under the age of 13, we will collect a parent’s permission before we collect, use, store or disclose any personal information supplied by that visitor. We will also allow parents/guardians to review any personal information we collect from children under 13 and to request that we stop using and delete such information at any time. If our policies change with regard to personal information that we previously received parental consent to collect, we will notify the parents of the changed policies. If you are the parent or guardian of a child under the age of 13 and believe that we have collected personally identifiable information contrary to this policy or, in the United States, the Children’s Online Privacy Protection Act (COPPA), please contact us by e-mail so that we may delete such information. You can learn more about COPPA at the United States Federal Trade Commission website:

https://www.ftc.gov/tips-advice/business-center/privacy-and-security/children%27s-privacy

Safe Harbor Data Privacy Notice

The United States Department of Commerce and the European Commission have agreed on a set of data protection principles and frequently asked questions (the “Safe Harbor Principles”) to enable U.S. companies to satisfy the requirement under European Union law that adequate protection be given to personal information transferred from the EU to the United States. CreativeMornings adheres to the Safe Harbor Principles with respect to personally identifiable information it receives from users in the European Union. This notice outlines our general policy and practices in compliance with the Safe Harbor Principles, including the type of information to which this notice applies, how we use information, and your choices regarding our use of, and your ability to correct, your personally identifiable information. For purposes of this notice, “personally identifiable information” includes information (a) transferred from the European Union to the United States; (b) recorded in any form by us; and ( c) pertaining to a specific individual who is identified in, or is identifiable from, the data. This notice applies to all personally identifiable information we collect on-line (except as noted below). If there is any conflict between this Privacy Policy and the Safe Harbor Principles, the Safe Harbor Principles will govern.

Disclosure

The privacy principles in this Policy are based on the Safe Harbor Principles. CreativeMornings will not disclose personally identifiable information in any manner that is inconsistent with this Policy.

Notice and Choice

We obtain personal information only as permitted by the Safe Harbor Principles or with the consent of the individual affected. We may ask for your consent to collect, use, and/or disclose personal information in certain ways, and you may be required to give your consent in order to use the website or our services. Individuals will be provided clear and conspicuous, readily available, and affordable mechanisms to exercise choice. To the extent permitted under the Safe Harbor Principals, we reserve the right to process personal information in the course of providing services through the Website without the knowledge of individuals involved.

Transfers

CreativeMornings will obtain assurances from its agents that they will safeguard personal information consistently with this Privacy Policy. If CreativeMornings learns that an agent is using or disclosing personal information in a manner contrary to this Privacy Policy, CreativeMornings will take reasonable steps to prevent or stop the use or disclosure. Transfers of information permitted under this notice, either to third parties or within CreativeMornings, may include the transfer of data from one jurisdiction to another, such as transfers to and from the United States of America.

If you are located in the EEA, we will comply with EU data protection law when transferring your Personal Information outside of the EEA. However, we may transfer your Personal Information to non-EEA countries, including the United States where we have our headquarters.

Security & Enforcement

Creative Mornings will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction, and it will conduct compliance audits of its relevant privacy practices to verify adherence to this Privacy Policy. Any questions or concerns regarding the use or disclosure of personal information should be directed to CreativeMornings at [email protected]. CreativeMornings will investigate and attempt to resolve complaints and disputes regarding the use and disclosure of personal information in accordance with the principles contained in this Privacy Policy. For complaints that cannot be resolved between the Company and the complainant, the Company has agreed to participate in the dispute resolution procedures of the American Arbitration Association to resolve disputes pursuant to the Safe Harbor Principles.

Effective Date

This Privacy Policy is effective as of June 15, 2019. We reserve the right to change this Privacy Policy at any time. If we change it, we will post the then-current Privacy Policy on this page. Any changes to this Privacy Policy will be effective as of the day they are posted.

Contact Us

It is important for us to know what visitors have to say about our Services. To contact us with your questions or comments please email us at [email protected].

Terms of Use

https://creativemornings.com/terms