Last updated: February 2019
Kolme Ltd trading as Creative Spirit Co. ("us", "we", or "our") operates https://www.creativespirit.co website (the "Service(s)").
This privacy notice informs you of how we collect, use and disclose personal information when you use our Services and of your rights and choices in connection with this. Please see our Terms and Conditions for other terms governing the use of our Services.
Information we collect
Information you provide to us:
Through your use of the Service, we collect personal information, which is information that identifies you as an individual or relates to you as an identifiable individual. While we do not require you to provide personal information in order to navigate our website, we will need to collect personal information when you use our Services or if you choose to engage in certain activities on our website.
We collect information from you when you:
Open an account: In order to use the Service as our customer, you would need to provide account information which includes contact information, such as your name, e-mail address, physical address, telephone number, billing information, such as your credit or debit card information; and information about your organisation. We use Stripe, a third party provider to process the credit card information and only retain the last four digits of the card as well as the card brand.
We need this information in order to provide you with the Service. If you do not provide this information we would not be able to provide the Service to you.
Interact with our Service: When you engage with us on our various social media platforms, or send us any feedback, questions, comments, suggestions, ideas, or interact with us in any way, you provide us with personal information such as your name and email address.
Please note that information you provide to us through feedback, surveys, suggestions etc., without the parts that identify you, will be treated as non-confidential and non-proprietary and we may use it and share it with third parties.
We collect information from your customers when they:
Use the registration forms our Services facilitate for you. To complete the registration forms we facilitate for you, your customer would need to provide us with their name, email, password, and other custom field data in the registration form which you created.
Information collected automatically:
We automatically collect the following types of information as you use our Service:
Usage Information: which of the pages on our website you access, the frequency of access, how much time you spend on each page, what you click on while on our website, when you accessed the website.
Referral status: whether you were referred to our Service by one of our business partners.
Location Information: information about your estimated location as may be determined from the IP Address.
Device Information: information about the device you are using, such as hardware model, operating system, application version number, browser, and IP addresses.
Cookies and other technologies
Cookies are small pieces of text sent to your web browser by a website you visit. A cookie file is stored in your web browser. Cookies can be "persistent" or "session" cookies. Persistent cookies remain on your personal computer or mobile device when you go offline, while session cookies are deleted as soon as you close your web browser. We use first party cookies, which are cookies that we place on your device ourselves, and third party cookies, which are cookies that we allow third parties to place on your device.
When you use and access the Services, we may place a number of cookies files in your web browser.
We use both session and persistent cookies on the Service and we use the following types of cookies. To learn how you can control information collected about you using cookies and other technologies see here.
Essential cookies. We use essential cookies to authenticate users (both our customers and our customers' end-users) and prevent fraudulent use of user accounts.
Preferences cookies. We use preferences cookies to remember information that changes the way the Service behaves or looks, such as the "remember me" functionality of a registered user or a user's language preference.
Analytics cookies. We use analytics cookies to track information how the Service is used so that we can make improvements. We also use analytics cookies to test pages, features or new functionality of the Service to see how our users react to them.
Google Analytics, Squarespace Analytics
We use Google Analytics and Squarespace Analytics to collect some information we listed above about your use of the Services. We use the information we get from these providers to improve the Services. In order to collect this information, Google Analytics and Squarespace Analytics may set cookies on your browser or mobile device, or read cookies that are already there. Google Analytics may also receive information about you from apps you have downloaded, that partner with Google. We do not combine the information collected through the use of Google Analytics with personally identifiable information. The Google Analytics and Squarespace Analytics products we use collect only anonymised IP addresses for IP's located in the European Union ("EU").
How we Use Your Information
We use the information we collect about you to provide the Service, to communicate with you, to provide technical support, and, with respect to information collected from you (but not from your customers) to improve our Services and customer relations.
To the extent EU data protection law applies to our processing of personal data about you or your employees/representatives as a customer of ours, we act as the "data controller". To the extent EU data protection law applies to our processing of personal data about your customers in the course of providing the Services to you we serve as the "data processor" and process information in accordance with the instructions of our customers.
We process your information for the following purposes as necessary to provide the Services to you and perform our contract with you:
Provide Services: We use your personal information to provide the Services.
Communicate and provide technical support: We use personal information to communicate with you about the Services, to send you account updates or other communications regarding your account or to inform you of any changes to our website or Services, and to provide you support or other Services you request. For example, we may need your information to provide technical support or answer questions about the Service.
We process your information as a user of our services, but not your customers’ information, for the following purposes as part of our legitimate interest in the improvement and marketing of our Services as well in the security of our Services. We apply appropriate safeguards to protect your information as described in various sections below.
Communicate about new features: We send you notifications about new features or information available on our Services or that we feel might be of interest to you. Email firstname.lastname@example.org to learn how you can opt out of receiving these communications at any time.
Maintenance and Improvement: We use personal information to identify your interests and needs in order to provide you with more personalised, relevant, and intelligent services. We also use information that we collect to diagnose any problems with our website and to improve the user experience.
Benchmarking: We aggregate personal information for the purpose of research and benchmarking. For example, to calculate the percentage of users in a particular ZIP or postal code.
In our processing of your information, we also share your personal information to defend our rights and those of others, to efficiently maintain our business and to comply with the law as described below.
How we share your information
We share your information with certain third parties, including our service providers that facilitate our Service, and as necessary to comply with our legal obligations. The legal basis for this is our legitimate interest in providing the Services, complying with the law and protecting our rights and those of others. We apply appropriate safeguards for this sharing of your information as described in the sections below.
Service Providers: We share information with service providers that help us perform Website functions and administer our Services.
We use Stripe to process payment card information. A link to Stripe’s privacy notice is here https://stripe.com/us/privacy.
We use Google Analytics and Squarespace Analytics to conduct data analytics on usage of our Services. A link to the Google privacy notice is https://policies.google.com/privacy; a link Squarespace’s privacy notice is https://www.squarespace.com/privacy.
We also use service providers to provide data storage, email services, cloud documents and software monitoring. A list of these processors and their privacy notices are here:
Party Name Category
Corporate Structure: In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganisation, merger, acquisition, sale, joint venture, assignment, consolidation, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we would share personal information with third parties, including the buyer or target (and their agents and advisors) for the purpose of facilitating and completing the transaction. We would share personal information with third parties if we undergo bankruptcy or liquidation, in the course of such proceedings.
To Prevent Harm: We will share information if we believe it is necessary to detect, investigate, prevent, or take action against illegal activities, fraud, or situations involving potential threats to the rights, property, or personal safety of any person.
Legal Purposes: We will share information where we are legally required to do so, such as in response to court orders, law enforcement or legal process, including for national security purposes; to establish, protect, or exercise our legal rights or contractual obligations; to defend against legal claims or demands; or to comply with the requirements of any applicable law.
With Your Consent: Apart from the reasons identified above, we may request your permission to share your personal information for a specific purpose. We will notify you and request consent before you provide the personal information or before the personal information you have already provided is shared for such purpose. You may revoke your consent at any time.
We implement and maintain reasonable security procedures and practices appropriate to the nature of the information we store, in order to protect it from unauthorised access, destruction, use, modification, or disclosure. We have implemented various policies including, encryption, access, and authentication to guard against unauthorised access to personal data in our systems.
Please be aware that no method of transmission over the internet, or method of electronic storage is 100% secure and we are unable to guarantee the absolute security of the Personal Information we have collected from you.
Transfers of Information
If you are located outside United Kingdom and choose to provide information to us, please note that we transfer the information, including personal information, to United Kingdom and process it there.
We will provide an individual opt-out or opt-in choice before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorised. To request to limit the use and disclosure of your personal information, please submit a written request to email@example.com.
Your choices with respect to your information
Access, correct or delete your information: You may access your account to access, correct or delete the information you provided to us and which is associated with your account by logging into your account or by emailing us at firstname.lastname@example.org.
In the event that we refuse a request under rights of access, we will provide the individual with a reason as to why. Individuals residing in the EU also have rights (described below) and the option to complain as described below.
We will retain your information after your account is deleted under the circumstances described below.
Delete your account: You may request that we delete your account by contacting us at email@example.com. If you choose to delete your account, we will begin the process of deleting your account from our systems. We will retain your information after your account is deleted under the circumstances described below.
Emails: You can opt out of receiving promotional e-mails from us by clicking the “unsubscribe” link provided in each e-mail or by contacting us at firstname.lastname@example.org. We will continue to send you notifications necessary for the Services related to this e-mail address.
All cookies: You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. The Help feature on most browsers provide information on how to accept cookies, disable cookies or to notify you when receiving a new cookie. If you do not accept cookies, you may not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages might not display properly.
For the Chrome web browser, please visit this page from Google: https://support.google.com/accounts/answer/32050
For the Internet Explorer web browser, please visit this page from Microsoft: https://support.microsoft.com/kb/278835
For the Firefox web browser, please visit this page from Mozilla: https://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websites-stored
For the Safari web browser, please visit this page from Apple: https://support.apple.com/kb/PH21411?locale=en_US
For any other web browser, please visit your web browser's official web pages.
Google Analytics: See https://policies.google.com/technologies/partner-sites for information about how Google uses the information provided to Google Analytics and how you can control the information provided to Google. To prevent your data from being used by Google Analytics, you can download the Google Analytics opt-out browser add-on for Google Analytics which can be found here https://tools.google.com/dlpage/gaoptout.
For EU Individuals: Your Rights under the General Data Protection Regulation
If EU data protection law applies to our use of your information, you have rights that are explained below. The rights available to you depend on the reason for our use of your information.
If you are our customers: You may access your Creative Spirit Co. account to access, correct, amend, or delete the information as explained above.
Your request should contain a detailed, accurate description of the data you want access to. For your protection, we may need to verify your identity before responding to your request, such as verifying that the email address from which you send the request matches your email address that we have on file.
The right to access: You have the right to ask us for copies of your personal information. This right has some exemptions, which means you may not always receive all the information we process.
The right to rectification: You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
The right to erasure: You have the right to ask us to erase your personal information in certain circumstances.
The right to restrict processing: You have the right to ask us to restrict the processing of your information in certain circumstances.
The right to object to processing: You have the right to object to processing if we are able to process your information because the process is in our legitimate interests.
The right to data portability: This only applies to information you have given us. You have the right to ask that we transfer the information you gave us from one organisation to another, or give it to you.
The right to lodge a complaint with the supervisory authority. A list of Supervisory Authorities is available here: https://ec.europa.eu/info/law/law-topic/data-protection_en.
If you need further assistance regarding your rights, please contact us using the contact information provided below and we will consider your request in accordance with applicable law. In some cases, our ability to uphold these rights for you may depend upon our obligations to process personal information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.
How Long We Keep Your Information
You can delete your account or request that we delete your account by writing us at email@example.com.
We will retain your information until the earlier of (i) the information is no longer necessary to accomplish the purpose for which it was provided; or (ii) you delete your account as stated above. We will retain your customer’s information under the end of the Services engagement with you or pursuant to a legally binding request for erasure or as otherwise set forth in a binding agreement between us. We retain your information or that of your customer for longer periods for specific purposes to the extent that we are obliged to do so in accordance with applicable laws and regulations and/or as necessary to protect our legal rights or for certain business requirements. To read more about specific reasons we would retain some data for longer periods of time see below:
Security, fraud & abuse prevention - i.e. to protect you, other people, and us from fraud, abuse, and unauthorised access.
Financial record-keeping - when you make a payment to us we are often required to retain this information for a longer period of time for purposes of accounting, dispute resolution and compliance with tax, anti-money laundering, and other financial regulations.
Complying with legal or regulatory requirements - to meet any applicable law, regulation, legal process or enforceable governmental request, as required to enforce our terms of service, including investigation of potential violations.
Direct communications with us - if you have directly communicated with us, through a customer support channel, feedback form, or a bug report, we may retain reasonable records of those communications.
Even if you delete your account, keep in mind that the deletion by our third party providers may not be immediate and that the deleted information may persist in backup copies for a reasonable period of time. For any privacy or data-protection-related questions, please write to firstname.lastname@example.org.
Links To Other Sites
We have no control over, and assume no responsibility for the content, privacy policies or practices of any third party sites or Services.
This website and our Services are not intended for individuals under the age of eighteen (18) years. Accordingly, we do not knowingly collect or share information from children without parental or guardian consent. If you have reason to believe that a child under the age of 16 has provided personal information to us, please contact us using the information below, and we will delete that information from our databases.
Changes To This Privacy Notice
We may change this Privacy Notice from time to time. We will post the changes to this page, and will indicate the date they go into effect. We encourage you to review our Privacy Notice to stay informed. If we make changes that materially affect your privacy rights we will notify you of the changes by posting a prominent notice on our website or using other methods that we select, such as sending you an email.
If you have any questions about this Privacy Notice, please contact us: email@example.com, Address: The Creative Spirit Co., 2.01 Tea Building, 56 Shoreditch High Street, London E1 6JJ, United Kingdom