Effective Date: 23 May 2018
Creative Virtual values your privacy. This privacy policy explains what personal data we collect from you and how we use it. This privacy policy applies if you visit Creative Virtual’s corporate websites or social media or other web pages located on third-party websites, use any mobile application(s) provided by Creative Virtual or register to attend any of Creative Virtual’s corporate events or webinars. This privacy policy also applies if you use Creative Virtual’s websites, hosted services, products, applications and/or content (collectively, the “Services”) directly or through a Creative Virtual customer (for example, on a Creative Virtual customer’s website or mobile application).
What does Creative Virtual do?
What information do we collect from you?
How does Creative Virtual collect information from you?
How does Creative Virtual use the information it collects about me?
Does Creative Virtual use cookies?
Sharing of information collected
Access and changes to personal data
How does Creative Virtual keep my information secure?
Additional mobile considerations
What does Creative Virtual do?
Creative Virtual provides mobile and online messaging technologies that enable digital communication between our business customers and consumers through chat, voice, messaging and other methods.
What information do we collect from you?
If you engage with a brand that uses our Services, we may collect:
- Chat and messaging transcripts on behalf of the brand,
- Information on behalf of and/or requested by the brand, such as information related to your browsing, purchasing and online behaviour and activities, and
- Automatic information, such as IP address, operating system and type of device used.
If you visit our websites or use our apps, we may also collect:
- Information you provide to us, including:
- Personal information, such as your name and contact information,
- Surveys, transcripts and recordings of your communications with us,
- Information you provide to our website communities (such as the Labs Community, Developer Community and Customer Community), message boards and blogs
- Automatic information, such as:
- Web browser and usage information, including IP address, browser types, page view tallies, time spent on each page, page browsing information, operating system and type of device used.
How does Creative Virtual collect information from you?
We collect information when you engage with a brand that uses our Services, which may be enabled on the brand’s website or in its mobile applications, voice or SMS messaging capabilities, social media page/profile or other digital engagement solutions.
In addition, we may collect information through the following methods if you visit our websites or use our apps:
- Your communications with Creative Virtual,
- Your requests for information, news and other content,
- Your participation in one or more Creative Virtual communities, message boards or blogs,
- A technical support request you submit,
- Your participation in a Creative Virtual promotion, or
- Recruitment and job applications.
We may also collect information from our direct interactions with you (such as through your attendance at a trade show or through sales inquiries), publicly available data or data provided by third-party sources, such as marketing opt-in lists.
How does Creative Virtual use the information it collects about me?
We use the information we collect to provide and improve our services.
If you engage with a brand that uses our Services, we use the information we collect on behalf of and as directed by the brand. For example, we may use your information to determine whether to deploy a chat button to allow the brand to engage with you or to deploy content, such as a banner offering a coupon, on your browser.
If you visit our websites or use our apps, we may also use your information for the following purposes:
- To deliver information requested by you, for example in response to technical support requests,
- To deliver marketing or other materials to you,
- For promotions you may enter into, or
- If you submit a resume or CV, to considering you for employment with Creative Virtual.
Creative Virtual may retain your information for a period of time consistent with the original purpose of collection. For example, if you engage with a brand that uses our Services, we may retain your information for the period of time agreed on with the brand. We may also retain your information during the period of time needed for Creative Virtual to pursue our legitimate business interests, conduct audits, comply with our legal obligations, resolve disputes, and enforce our agreements.
Does Creative Virtual use cookies?
We may use cookies and other identification technologies for record keeping purposes and to enhance your experience, if you choose to visit our websites.
Cookies:
Cookies are small text files stored on a visitor’s web browser and applications. Cookies are often used to make web-browsing easier by performing functions such as saving passwords and maintaining lists of personal preferences regarding the use of the website.
Our websites, apps and Services may use the following types of cookies:
- Strictly Necessary Cookies – these cookies are essential to enable you to browse our websites, apps and Services and use the available features.
- Performance Cookies – these cookies collect information about how you use our websites, apps and Services. For instance, these cookies track which pages you visit most. This data may be used to help optimize our websites, apps and Services and make it easier for you to navigate within them. These cookies do not collect information that identifies you; all information is aggregated and anonymous.
- Functionality Cookies – these cookies allow our websites, apps and Services to remember choices you make while browsing, such as geographic location and preferences such as text size and fonts. The information collected by these cookies will not personally identify you.
Other identification technologies that may be used by Creative Virtual websites, apps and Services:
- Pixel tags (also called beacons or pixels) – these are small blocks of code installed on (or called by) a webpage or application, which can retrieve certain information about your device and browser, including device type, operating system, browser type and version, website visited, time of visit, referring website, IP address and other similar information.
- Software Development Kits (also called SDKs) – function like pixels and cookies, but operate in the mobile application context where pixels and cookies cannot always function. The application developer can install pieces of code (the SDK) into the application to collect certain information about user interaction with the application and information about the user device and network information.
Third-party technologies:
Creative Virtual may use third-party service providers who are authorized to place cookies, pixel tags or similar technologies on our websites, apps and Services with our permission. These technologies help us compile metrics and analytics (without collecting personally identifiable information) to help improve our websites, apps and Services. Third-party cookies and technologies are covered by the third party’s privacy policy.
Your choice:
Web browsers are usually set to accept cookies. However, if you prefer not to receive cookies, you typically have the option of setting your browser to refuse cookies. If your browser is set to refuse cookies, it is likely that some of the functionality offered by Creative Virtual will not be available or will not work as effectively for you.
For further information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, you can visit www.allaboutcookies.org and www.youronlinechoices.eu.
Do Not Track
Various browsers, including Internet Explorer, Firefox and Safari, currently offer a “do not track” or “DNT” option that relies on a technology that sends a signal to websites a user visits about that user’s browser DNT preferences. While Creative Virtual attempts to honour the DNT instructions received from a user’s browser, Creative Virtual cannot guarantee that it will always respond to such signals because a common industry standard for DNT has not been adopted. Creative Virtual will continue to monitor developments around DNT browser technology.
Sharing of information collected
Creative Virtual does not sell, trade or rent personal information provided by you in any transcript, survey, form or recording for direct marketing or any other purpose, except as provided in this privacy policy or with your permission. Creative Virtual does not disclose the contents of transcripts, surveys, forms or recordings other than to service providers performing services on behalf of Creative Virtual, other than as provided in this privacy policy or with your permission.
Information is shared in the following cases.
With a brand you have engaged with through the Services
If you engage with a brand that uses our Services, we may share your information with that brand.
For legal reasons
We may share your information if we reasonably believe that it: (i) is necessary to comply with a legal process (such as a court order, subpoena, or search warrant) or other legal requirement of any governmental authority; (ii) would potentially mitigate our liability in an actual or potential lawsuit; (iii) is necessary to enforce this privacy policy or any other agreement in place between you and Creative Virtual; (iv) is necessary to investigate and prevent unauthorized transactions or other illegal activities; and/or (v) is otherwise necessary or appropriate to protect our rights or property or the rights or property of any person or entity.
To deliver and improve the Services
We may aggregate information so that it is not personally identifiable and use and share such aggregated information for training and quality assurance purposes and to deliver and improve our Services.
Service providers
We use a limited number of third-party service providers to assist us in making our websites and Services available to visitors and users. For example, we may share data with third parties who provide services to us, such as credit card processing services, analytics and data storage services. These third parties may access, process or store personal data to provide their services.
Access and changes to personal data
If you elect to engage in any communication or engagement session with Creative Virtual or a customer that uses our Services, it is up to you to decide what, if any, information to provide during such session. Depending on your request, it may not be possible for us or our customer to address all of your questions without further information from you. Nevertheless, if you do not wish to provide certain information, then you should not do so.
How can I review, correct, delete, or receive a copy of my information with Creative Virtual or withdraw my consent from Creative Virtual processing my personal data?
If you have signed up to receive Creative Virtual’s marketing or advertising communications, you may, at any time, opt out of receiving further communications by clicking on the unsubscribe link at the bottom of a marketing or advertising email you receive. You may also contact us at [email protected] to opt out or to request changes to your personal information.
You may request to review, correct, delete, or receive a copy of any of the personal information you’ve provided to a brand that uses the Services or withdraw your consent to Creative Virtual processing your personal data by either contacting the brand directly or by contacting us at [email protected], and we will respond within a reasonable period of time and can help coordinate with and support the brand as needed to respond to your request. Depending on your request, it may not be possible for us or our customer to address all of your request without further information from you. In cases where transactions are stored anonymised, pseudonymised or in any other way that makes it impossible to connect it to a natural person, it might not even be technically possible or commercially viable for us to fulfil all your requests. In which case we will support the brand to explain the situation to you and find an acceptable workaround.
How does Creative Virtual keep my information secure?
We use security measures designed to protect against the loss, misuse and alteration of the information under our control. For certain Services, chat/messaging transcripts are encrypted during transmission. In addition, transcripts that we store are maintained and archived on secure, hardened servers that are hosted on highly secure data centres. Access to this data is protected by multiple layers of controls, including firewalls, role-based access controls, authentication mechanisms and monitoring. Data is backed up, and archives are stored off-site in a secure location. We also offer additional encryption functionality and data masking to our customers.
If you are communicating with a brand that uses our Services, you should review the privacy practices of that brand to understand which security measures they use.
Additional mobile considerations
In addition to the other terms in this policy, if you use our mobile applications, access our mobile-optimized websites or have a conversation with a Creative Virtual customer that uses our Services in its mobile application, we may receive information about your mobile device, including a unique identifier for your device.
If you receive SMS messages from one of our customers, you may opt out by following the opt-out instructions provided by the brand you are communicating with or by contacting the brand. You may also contact us at [email protected], and we can help put you in touch with the brand regarding your request.
Please note that we may transfer your personal data outside your country of origin. By providing or making available your personal data, you consent to that transfer.
We will take steps to ensure that your data is subject to appropriate safeguards required under this privacy policy, applicable data protection laws, and appropriate legally recognized data transfer adequacy mechanisms which may include entering into European Commission-approved standard contractual clauses related to transfers of personal information. For residents of the European Economic Area and Switzerland, Creative Virtual we will execute standard contractual clauses among Creative Virtual affiliates for the purpose of its lawful transfers of personal data.
As mentioned above, we use a limited number of third-party service providers to make our websites and Services available that may access, process, or store personal data in the course of providing services. We currently maintain contracts with these third parties restricting their access, use and disclosure of personal data. Creative Virtual is responsible if these third parties process personal data in violation of the GPDR principles (unless Creative Virtual can prove that it’s not responsible for the third party’s action that violated the GDPR principles).
In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you are under the age of 18, you may not provide any personal information to us. If you are a parent of an individual under 18 and believe your child has provided personal information to Creative Virtual, please contact us at [email protected], where you may request to exercise your applicable access, rectification, cancellation, and/or objection rights. The aforementioned commercial, technical and legal restrictions to the fulfilment of such a request apply. Creative Virtual reserves the right to immediately delete the information of any individual, to the extent permitted by law, who it believes is under the age of 18.
We recommend that you review this privacy policy periodically, as we may update it from time to time. Your use of our websites, apps and Services, as applicable, constitutes your consent to the new privacy policy to the fullest extent permitted by law. Any inquiries or complaints regarding our data privacy practices may be directed to [email protected]. We will respond within 30 days and provide appropriate recourse at no cost to you
We are not responsible for and do not control the privacy practices of any of our customers or any other third party. We encourage you to review the privacy practices of each third party.
We welcome your feedback on our privacy policy. Please send any comments or questions to [email protected] or to Creative Virtual Ltd, Attn.: Office Manager, 165-167 Cannon Workshops, 5 Cannon Drive, London E14 4AS, United Kingdom.
