- Who are we?
Creed & Culture (or C&C) is operated by CREED & CULTURE LTD a company registered in England and Wales under registration number 12646058 and our registered address is c/o 85 Great Portland Street, London, England, W1W 7LT. We are the data controller for the purposes of this Privacy Notice. This Privacy Notice relates to Creed & Culture with premises offering an integrated marketing agency at locations in London, Manchester, Toronto, Paris, Jakarta and Kuala Lumpur.
- What is this Privacy Notice for?
This Privacy Notice gives you information about how we will use personal data and other private information collected by or provided by you to Creed & Culture. When we refer to ‘personal data’ in this Privacy Notice it means any information that relates to you from which you can be identified. This Privacy Notice governs the processing of your personal data, including in connection with your use of our Site, so please read it carefully.
- What Personal Data may we collect?
We may collect the following personal data about you:
- The personal details you provide (such as name, address, e-mail address, business or personal address, phone number) when working with Creed & Culture.
- Payment details that we require for the purpose of processing any payments for work completed by Creed & Culture on your instruction.
- Personal details you choose to give when corresponding with us by phone, email, online job application or that you provide to us when you visit Intermarketing.
- Any other personal or private information about you that you choose to submit to this Site or any other websites we operate.
- Information about your preferences (e.g. cookie data, clickstream data, browsing history, responses to direct marketing, and opt-outs from direct marketing) and any information provided to us by third parties.
7. How do I change my cookie preferences?
You can change your cookie preferences within your browser. Your browser will offer you the possibility to decide to accept, refuse or delete cookies in general or from specifier providers.
Please note that if you block cookies on our website, you may be unable to access certain website areas and/or functions and pages will not work in the usual way.
- How we use your data
We may use your personal data in the following ways:
- To operate our business and provide you with services you have requested.
- To display the content of this Site, and any customisations you may select.
- To verify your identity.
- To acknowledge, confirm and deal with your enquiry, job application, brief or order.
- Where we are asked to deal with any other enquiries or complaints you may make.
- To notify you about any changes to this Site, or services provided through this Site.
- To provide you, with information about our services. Any marketing email that you receive from us will allow you to unsubscribe to further email promotions.
- To contact you in connection with user/customer/member surveys and use any information you choose to submit in response.
- To administer our Site and ensure that our Site is presented in the most effective manner for your and your computer/device.
- For internal business/technical operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes and as part of our efforts to keep our Site secure.
- On an aggregate basis, to understand how individuals collectively use the features of our Site.
- To give effect to your legal rights and your rights under this Privacy Notice.
- To protect against fraud, identity theft, and other unlawful activity.
- To establish or exercise any legal rights or claims.
- To satisfy our obligations under applicable law, this Privacy Notice, and any other policies or terms that are applicable to our relationship with you.
- For other purposes to which you have consented, and we may combine personal data that you provided to us with other information we collect about you for the purposes set out in this Privacy Notice.
- Disclosure of your personal data
We may share your personal data with third parties in the following situations:
- We may disclose your personal data to our employees and agents to the extent necessary to provide you with the services you have requested.
- We may make your personal data available to selected third parties who act on our behalf to support our operations (for example card processing or payment services (see the section below headed ‘Payment Information’) and credit reference agencies to protect against possible fraud, subject to appropriate contractual protections in accordance with applicable law.
- Our IT suppliers and contractors (e.g. data hosting providers or delivery partners) who may need to have access to your personal data to provide IT support and enable us to provide products and services, subject to appropriate contractual protections in accordance with applicable law.
- If we sell or transfer all, or any portion, of our business or our company assets to any third party, personal data held by us from you may be one of the transferred assets.
- To protect us or contractors against loss or damage (including without limitation, exchanging information with the police, courts or law enforcement organisations).
- To the extent necessary to establish, exercise or defend legal rights or claims, or for the purposes of investigating actual or suspected unlawful activity.
- Payment Information
Any payments made to Creed & Culture will be processed by Intermarketing, and the payment data you submit will be securely stored and encrypted using up to date industry standards and this is in accordance with this Privacy Notice.
We take the security of our clients’ data very seriously and we use appropriate measures to protect all personal information collected in a secure, controlled environment consistent with GDPR legislation. The personal data that we collect from you is stored on UK based servers. Unfortunately, the transmission of information over the internet or public communications networks can never be completely secure. When you submit your personal information through our websites this is at your own risk.
- Data Retention
We will only retain your personal data for as long as we require the personal data in connection with the purposes set out in this Privacy Notice, except where we are required, or permitted, under applicable law, to retain your personal data for additional periods of time.
- Your Data Protection Rights
Subject to applicable law, you may have the following rights in relation to your personal data:
- The right to request access to, or copies of, your personal data that we process.
- The right to request correction of any inaccuracies in your personal data.
- The right to object, on legitimate grounds, to the processing of your personal data.
- The right to lodge a complaint with a supervisory authority (The Information Commissioner’s Office).
- The right to request that your personal data are deleted. This does not affect your statutory rights. If you wish to exercise any of these rights please contact us as described in the section below headed ‘Contact’. We may also need to ask you for further information to verify your identity before we can respond to any request.
Processing personal data of former, present and potential customers and their employees
Creed & Culture(Creed & Culture or we/us/our) maintains a large network of leading and authentic digital influencers that we may connect to our customers who have brand portfolios in the beauty, fashion, lifestyle and food industry.
In order to collaborate with you and/or fulfill our contract with you as our customers, we need to process certain personal data. You may be a customer and/or an employee of a customer with whom we now work with, or have worked with some time ago, or with whom we would like to work in the future. In any case, your privacy is highly important to us. This Privacy Statement, will inform you about the way we process your personal data when you are a customer, former customer or potential customer in our network. It is important that you read and understand this Privacy Statement, so you can make informed decisions and genuine choices about the data that we process.
Change to our Privacy Notice
If we change this Privacy Notice, we will let you know about the changes by publishing the updated version on our website, https://creedandculture.xyz. We are committed to protecting and respecting your privacy and will continue to do so in any future changes we make to this Privacy Notice.
Questions, comments or requests regarding this Privacy Notice should be addressed to our Data Protection Team by email: Hello@creedandculture.xyz or post at: Creed & Culture, WeWork John Dalton Street, M2 6DS.
Processing personal data of former, present and potential influencers
WeAreCreed & Culture(C&C or Creed and Culture/us/our) maintains a large network of leading and authentic digital influencers that we may connect to our customers who have brand portfolios in the beauty, fashion, lifestyle and food industry.
In order to connect you to the marketing portfolios of our customers, we need to process certain personal data of you. You may be an influencer with whom we now work with, or have worked with some time ago, or with whom we would like to work with in the future. In any case, your privacy is highly important to us. In this Privacy Statement, we will inform you about the way we process your personal data when you are an influencer, former influencer or potential influencer in our network. When processing your personal data, we make use of our internal Creed & Culture platform, where we store information that we may receive from you, obtain from public sources or receive from third parties upon your consent. It is important that you read and understand this Privacy Statement, so you can make informed decisions and genuine choices about the data that we process.
To whom does this Privacy Statement apply?
This Privacy Statement is applicable to you when you are an influencer in our network. This is the case if you are or have been involved in digital influencer marketing campaigns with us. Another possibility is that you are in our network because you are an active professional digital influencer with whom we do not yet have a contractual relationship, but we may like to work together with you in the future. In that case you are a potential influencer.
When you are an influencer, we may obtain information about you via your public profile on social media or via your public website(s). Also, we may have received information directly from you or your agent/management in relation to our contractual relationship. We may also obtain information from third parties, such as social media channels or other digital service providers on the effect of your posts. When you are a potential influencer, the information that we process originates from your public social media profiles or your public website(s) or directly from you or your agent/management.
What types of personal data do we process?
We may process the following types of personal data in regard to influencers:
- Personal data of (former) influencers. The personal data we process of our influencers includes your name and address data, gender, date of birth, your public profile photo from social networks, email address, phone number, social media accounts and/or website, account name, nickname, information about preferences, information from your agent or manager if applicable, amount of followers, estimated engagement on social media accounts and assumed target groups. Next to that, the personal data we process includes the details of arrangements made between you and Creed & Culture including start and end date of agreements made, bank details, social security number, Chamber of Commerce number, information that you (or your agent/manager) provide us in the course of our relation and impressions on your social media accounts relating to marketing posts (including the amount of views, types of followers, age groups etc.).
- Personal data of potential influencers. The personal data we process of the potential influencers in our network includes your name and address data, gender, date of birth, your public profile photos from social networks, email address, phone number, social media accounts and/or website, account name, nickname, information about preferences, information from your agent or manager if applicable, amount of followers, estimated engagement on social media accounts and assumed target groups. If you or your agent/manager has been in contact with us, we may process the data that has been provided to us in this respect.
The aforementioned types of personal data may originate from various sources. We may process personal data that we have found on your public profile on social media or your public website to the extent you have made this information public intentionally and not solely for private purposes. When you are an influencer or former influencer, we will process personal data that we have obtained in connection with our cooperation. This data may originate from your agreement with us, from your social media profile(s) or website(s) and from information you (or your agent/manager) provided to us.
4 What are the purposes for the processing of your personal data?
We may process your personal data for various purposes:
When you are an influencer, we may process your personal data for the following purposes:
- Maintaining the administration of our network of (potential) influencers;
- Approaching you for new collaborations;
- Making propositions for our customers;
- Improving our services towards our customers by market analysis, identification of reach and target groups;
- Maintaining contact, handling enquiries, complaints and disputes;
- Compliance with applicable laws and regulations.
- Contract management;
- Rolling out marketing campaigns in collaboration with the influencer;
- Performance of contracts with influencers;
- Auditing the effect of a marketing campaign, measuring impressions.
When you are a potential influencer, purpose 1 to 6 apply.
We will not further process your personal data for other purposes than mentioned in this Privacy Statement.
5 What are the applicable legal grounds for the processing of your personal data?
We only process your personal data when there is a legal ground. When you are an influencer, we will need to process your personal data for the following legal grounds:
- Executing the agreement that we have with you
We process your personal data, because it is necessary for the execution of our agreement with you, for example to connect you to our customers.
- Consent for auditing a marketing campaign and sharing additional social media data
If you are an influencer, we may ask for your consent for auditing a marketing campaign and sharing specific information in relation to (the reach of) your posts, weblogs and vlogs with us. When you give your consent for the sharing of this information, you allow social media channels such as Facebook and other parties, like Google Analytics, to provide data relating to the amount of views or clicks and other aggregated information about your followers or website visitors (e.g. age, location, interests, language) in relation to your posts or website content. The information we receive is not attributable to individual followers or website visitors yet may contain your personal data (in any case your account name or website URL). The parties providing such information will remain data controllers in relation to the personal data they will process in this respect. Creed & Culture will only be the data controller for the further processing of your personal data and we will only process such in accordance with this Privacy Statement. If we rely on your consent to process your personal data, you may withdraw your consent at any time by contacting us at email@example.com.
- Legitimate interests
We may furthermore process personal data of our influencers and of potential influencers based on our -and your- legitimate business interests to the extent such interest is not overridden by your privacy interests or fundamental rights and freedoms. The legitimate interests that we may rely on for the processing of your personal data are to operate and grow our business, to communicate with you on our service and provide support, to keep our platform updated and relevant, to protect our business and prevent fraud and other prohibited or illegal activities and for due diligence purposes if we choose to sell, transfer or merge (parts of) our business.
- Statutory obligations
When required, we may process your personal data to meet our statutory obligations, such as our obligations arising out of tax laws.
6 How long will your personal data be retained?
We will not retain your personal data longer than necessary for the purposes for which we have obtained it. In principle, we may retain your personal data up to a maximum of five years upon the ending of our business relationship, unless we are required to retain your personal data to comply with a statutory obligation.
7 Who has access to your personal data?
Creed & Culture may provide certain personal data to its customers in order to provide them with business propositions or in relation to a marketing campaign of a customer that you participate in. When our customers would further process your personal data, they would do so for their own purposes acting as a data controller. The terms and policies of our customers may apply to such data processing activities.
Next to that, Creed & Culture may involve third party service providers who will act as a data processor on our behalf. Creed & Culture selects its service provides with due care and makes all necessary arrangements with these third parties. In any case, Creed & Culture will enter into a data processing agreement which includes arrangements on data security to protect your personal data against data breaches.
Persons working at or on behalf of Creed & Culture may have access to your personal data on a need-to-know basis. Creed & Culture may further share your personal data with companies within her group of companies.
Creed & Culture may provide your personal data to the competent authorities upon their request to the extent legally required or to the extent this would be necessary to defend Creed & Culture ’s rights in legal proceedings or investigations or if Creed & Culture has a legal obligation to disclose your personal data.
Creed & Culture may provide your personal data to third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Statement.
We will not sell or rent your personal data to third parties.
8 Are your personal data processed outside the EEA?
Our third-party service providers may be located in countries outside the European Economic Area (EEA) which may not offer an adequate level of protection of personal data. In order to protect your personal data and to live up to our statutory obligations, we shall implement additional safeguards, for instance by entering into a data transfer agreement on the basis of the Standard Contractual Clauses as approved by the European Commission prior to engaging service providers outside the EEA.
When necessary, and in the interest of those involved, personal data is shared between our offices in Amsterdam and New York. We have entered into an intra-group data transfer agreement on the basis of the Standard Contractual Clauses, as approved by the European Commission, with our office in New York to ensure that your personal data is adequately transferred.
9 How is your personal data secured?
We will exercise due care when dealing with your personal data. Amongst other things, this means that we will adopt appropriate technical and organizational measures to secure and protect your personal details against loss and unlawful processing. We protect our systems and applications according to the applicable standards for information security and we also make data processing agreements with our service providers which include obligations to implement adequate security measures.
10 Your rights
You have certain privacy rights in relation to your personal data pursuant to the privacy regulations, such as the right of access, the right of rectification, the right of erasure, the right to restriction of processing, the right to data portability and the right to object. Please find below more details on how and when you can exercise your rights.
You have the following rights with regard to your personal data:
- The right to request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- The right to request rectification of your data if it is inaccurate. You may also supplement any incomplete data we have, taking into account the purposes of the processing.
- The right to object to the processing of your personal data. We will comply with your request unless we have a compelling overriding legitimate interest for processing or we need to continue processing your personal data to establish, exercise or defend a legal claim.
- The right to request deletion of your personal data if:
- your personal data is no longer necessary for the purposes for which we collected or processed it; or
- you withdraw your consent if the processing of your personal data is based on consent and no other legal ground exists; or
- you object to the processing of your personal data and we do not have an overriding legitimate ground for processing; or
- your personal data is unlawfully processed; or
- your personal data has to be deleted for compliance with a legal obligation.
- The right to restrict the processing of personal data, if:
- the accuracy of your personal data is contested by you, for the period in which we have to verify the accuracy of the personal data; or
- the processing is unlawful and you oppose the deletion of your personal data and request restriction; or
- we no longer need your personal data for the purposes of the processing, but your personal data is required by you for legal claims; or
- you have objected to the processing, for the period in which we have to verify overriding legitimate grounds.
- The right to data portability. You may request us to receive the personal data that concern you. You may also request us to send this personal data to a third party, where feasible. You only have this right if it regards personal data you have provided to us, the processing is based on consent or necessary for the performance of a contract between you and us, and the processing is done by automated means.
In order to exercise your rights please contact us at Hello@creedandculture.xyz. We aim to respond to your request within one month after receiving such a request. However, this one month term may be extended with two months. In such event, we will inform you within one month after receipt of your request and explain why the extension is necessary. We may ask you in response to your request to identify yourself.
Like any data subject, you will always have the right to issue a complaint with the competent data protection authority in case of violation of the GDPR and other regulations which affects your privacy. The competent authority for the data processing activities described in this Privacy Statement is the British Data Protection Authority.
If you have any questions concerning the manner in which we process your personal data, about this Privacy Statement, or you wish to invoke your rights, you may contact us at firstname.lastname@example.org
This Privacy Statement may be modified from time to time. We encourage you to check this Privacy Statement regularly so that you are aware of any changes.
This Privacy Statement was last updated in June 2020.
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