Privacy.

This Privacy Policy sets out the basis on which we will process any Personal Data that we may collect about you as a visitor to our website or our customers or potential customers, or other business partners, or in any other cases where we specifically state that this policy will apply. This policy further sets out how we protect your privacy and your rights in respect of our use of your Personal Data.

WHAT IS PERSONAL DATA?

Personal Data is information that makes it possible to identify a natural person. This includes, in particular, your name, date of birth, address, telephone number, and email address, but also your IP address. Anonymous data exists if no personal reference to the user can be made.

WHAT IS PROCESSING?

"Processing" means and covers virtually any handling of data.

WHAT LAW APPLIES?

We will only use your Personal Data in accordance with the UK's Data Protection Act (“DPA”) and the EU's General Data Protection Regulation (“GDPR”), and of course only as described in this Privacy Policy.

WHO IS THE DATA CONTROLLER?

A “data controller” is a person or organisation who alone or jointly determines the purposes for which, and the manner in which, any personal data is, or is likely to be, processed. In this sense, Spaarc Ltd. trading as Creavo, Milroy House, Sayers Lane, Tenderden, Kent, UK (“Creavo”, “we”, “us”, or “our”) is the data controller. If you have any questions about this policy or about data protection at Creavo in general, you can reach us by email using info@wearecreavo.com with “Data Protection” in the subject line.

WHAT ARE THE LEGAL BASES FOR PROCESSING PERSONAL DATA

In accordance with the DPA and the GDPR, we have to have at least one of the following legal bases to process your Personal Data: a) you have given your consent, b) the data is necessary for the fulfilment of a contract / pre-contractual measures, c) the data is necessary for the fulfilment of a legal obligation, or d) the data is necessary to protect our legitimate interests, provided that your interests are not overridden.

WHAT PERSONAL DATA DO WE COLLECT FROM YOU?

We may collect and process the following Personal Data about you:

a) Personal Data that you give us:

This is information about you that you give to us and in context of our services, mainly when you correspond with us, when we perform services with you, when we conduct research or when you sign up for our mailing lists. When you contact us, the Personal Data we process typically includes, for example, your name, address, email address, and telephone number. The legal basis for processing is our legitimate interest, the provision or initiation of a contract, and your consent.

If you register for our mailing list, we may send you emails for marketing purposes. The only data required for our mailing list is your email address, and this may be stored in our mailing system. The processing bases are your consent and our legitimate interest.

b) Personal Data that our website and other systems collect about you:

If you visit our website, it will automatically collect some information about you and your visit, including the Internet protocol (IP) address used to connect your device to the Internet and some other information, such as the pages on our site that you visit. This is used to monitor the performance of the website and improve the experience of visitors to the website.

The hosting services used by us for the purpose of operating our website is Wix. Wix processes inventory data, contact data, content data, usage data, meta data and communication data of customers, interested parties, and visitors of our website and services, on the basis of our legitimate interests.

We also use Google Tag Manager. Google Tag Manager is a solution enabling us to administer website tags via an interface. Google Tag Manager itself, which implements the tags, is a cookie-free domain and does not record any personal data. However, the tool triggers other tags that may record your Personal Data. Google Tag Manager itself does not access this data. If you refuse Analytical/Performance and/ or Marketing & Social Media Cookies, Google Tag Manager remains in place. The legal basis for the processing is our legitimate interest.

Lastly, for business reasons, we analyse the data we have on web and server traffic patterns, website interactions, browsing behaviour, etc. The analyses serve us alone and are not disclosed externally and processed using anonymous analyses with summarised and/or anonymised values (“Aggregated Data”). Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy. For this purpose we use Google Analytics from Google. The legal basis is our legitimate interest and your consent. For further information on our use of Google Analytics, please refer to our Cookie Policy.

c) Cookies

We use so-called cookies on our website. Cookies are pieces of information that are transmitted from our web server or third-party web servers to your web browser and stored there for later retrieval. Cookies may be small files or other types of information storage. As set out in the UK’s Privacy and Electronic Communications Regulations (“PECR”) and the EU`s Privacy and Electronic Communications Directive (“PECD”), we need to obtain consent for the use of non-essential cookies. The legal basis for the use of essential cookies is our legitimate interest, and the legal basis for the use of non-essential cookies is your consent. For further information on the cookies we use, please refer to our Cookie Policy.

Our website also uses a cookie consent tool to obtain your consent to the storage of cookies and to document this consent. When you enter our website, the following Personal Data is transferred to us: i) Your consent(s) or revocation of your consent(s); ii) Your IP address; iii) Information about your browser; iv) Information about your device; v) Time of your visit to our website. The legal basis for processing is both your consent and our legal obligation.

OTHER USES OF YOUR PERSONAL DATA

We may also collect, store, and use your Personal Data for the following purposes:

to operate, manage, develop, and promote our business and, in particular, our relationship with you and related transactions, including, for example:
- marketing purposes (when we have either gathered prior opt-in consent and/or have a legitimate interest to send you communications which we believe to be relevant and of use to you);
- to operate, administer, and improve our website and other aspects of the way in which we conduct our business;
- to offer you our services;
- to provide you with services or information that you may have requested; and
- to keep you informed and updated on relevant topics or services you may be interested in.
to protect our business from fraud, money laundering, breach of confidence, theft of proprietary materials, and other financial or business crimes;
to comply with our legal and regulatory obligations, bring and defend legal claims and assert legal rights; and
if the purpose is directly connected with an assigned purpose previously made known to you.

We will only process your Personal Data as necessary so that we can pursue the purposes described above and where we have a legal basis for such processing. Where our lawful basis for processing is that such processing is necessary to pursue our legitimate interests, we will only process your Personal Data where we have concluded that our processing does not prejudice you or your privacy in a way that would override our legitimate interest. In exceptional circumstances, we may also be required by law to disclose or otherwise process your Personal Data.

CHANGE OF PURPOSE

We will only use your Personal Data for the purposes for which we collected it as detailed above, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your Personal Data for an unrelated purpose, we will notify you, and we will explain the legal basis which allows us to do so.

DATA SHARING

In certain cases, it is necessary to transmit the processed Personal Data in the course of data processing. In this respect, there are different recipient bodies and categories of recipients.

a) Internal

If necessary, we transfer your Personal Data within Creavo. Access to your Personal Data is only granted to authorised employees who need access to the data due to their job, e.g., to provide our services or to contact you in case of queries.

b) External bodies

Personal Data is transferred to our service providers in the following instances:

in the context of fulfilling our contract with you,
to use marketing services and to advertise our services online,
to communicate with you,
to provide our website, and
to state authorities and institutions as far as this is required or necessary.

c) International transfers

We may transfer your Personal Data to other companies as necessary for the purposes described in this Privacy Policy. In order to provide adequate protection for your Personal Data when it is transferred, we have contractual arrangements regarding such transfers. We take all reasonable technical and organisational measures to protect the Personal Data we transfer.

MARKETING

Insofar as you have given us your consent to process your Personal Data for marketing and advertising purposes, we are entitled to contact you for these purposes via the communication channels you have given your consent to. Our marketing generally takes the form of email but may also include other less traditional or emerging channels. These forms of contact will be managed by us, or by our contracted service providers. Every directly addressed marketing sent by us or on our behalf will include a means by which you may unsubscribe or opt out.

ADVERTISING

We would like to show you interesting advertising outside of our website and use various third-party tools and cookies for this purpose. These collect and process information about your activities on our website - for example, which products you are interested in or which pages you visit. By knowing what you are looking for and how you use our website, we can adapt our advertising to your needs. And thus increase the likelihood that you will also be shown suitable and interesting advertising outside our website.

We also analyse this data to evaluate the relevance of the advertisements and to optimise the advertisements for you. Through the tools, your browser regularly establishes a connection to the server of the tool provider when you visit our website. For some tools, we have no direct influence on what data is processed by the providers. The following personal data may be processed by third-party providers i) HTTP header information (e.g., IP address, web browser, website URL, date and time); ii) measuring pixel-specific data (e.g., pixel ID and cookie ID); and iii) additional information about visits to our website (e.g., orders placed, products clicked on). The legal bases for processing are our legitimate interest and your consent in case of cookies. For further information, please refer to our Cookie Policy.

LINKED SITES

For your convenience, our website may contain hyperlinks to other websites. We are not responsible for the privacy practices of linked websites or companies that are not owned or controlled by us, and this Privacy Policy does not apply to them. The links on our website may collect additional information in addition to the information we collect.

We do not endorse any of these linked websites, their products, services, or any content on their websites. We encourage you to read the privacy policies of each linked website you visit to understand how the information collected about you is used and protected.

SOCIAL MEDIA

We are present on social media based on our legitimate interest. If you contact or connect with us via social media, we and the relevant social media platform are jointly responsible for the processing of your data and enter into a so-called joint responsibility agreement. The Personal Data collected when you contact us is used to process your request, and the basis for this is both your consent and our legitimate interest.

HOW LONG DO WE KEEP YOUR PERSONAL DATA?

We will delete your Personal Data when we no longer need such Personal Data, for instance, where:

it is no longer necessary for us to retain your Personal Data to fulfil the purposes for which we had collected it;
we believe that your Personal Data that we hold is inaccurate; or
in certain cases where you have informed us that you no longer consent to our processing of your Personal Data.

Sometimes, however, there are legal or regulatory requirements which may require us to retain your Personal Data for a specified period, and in such cases we will retain your Personal Data for such specified period; and we may need to retain your Personal Data for certain longer periods in relation to legal disputes, and in such cases we will retain it for such longer periods to the extent required.

DATA SECURITY

Our website uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of confidential content, such as orders, login data or contact requests that you send to us. We have also implemented numerous security measures (“technical and organisational measures"), for example, encryption or need-to-know access, to ensure the most complete protection of Personal Data processed through our website.

YOUR RIGHTS AND PRIVILEGES

Privacy rights

You can exercise the following rights:

The right to access;
The right to rectification;
The right to erasure;
The right to restrict processing;
The right to object to processing;
The right to data portability;

Update your information and withdraw your consent

If you believe that the information we hold about you is inaccurate or request its rectification, deletion, or object to legitimate interest processing, please do so by contacting us.

Access Request

In the event you want to make a Data Subject Access Request, please contact us. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we will tell you why.

Complaint to a supervisory authority

The Information Commissioner's Office (ICO) is the UK`s authority in matters of data protection. You have the right to make a complaint at any time to the ICO (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO in the first instance.

Data Breaches and Notification

Databases or records containing Personal Data may be breached accidentally or through unlawful intrusion. As soon as we become aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised, and the notification will be accompanied by a description of the measures that will be taken to repair the damage caused by the data breach. Notifications will be sent as soon as possible after the violation is discovered.

What we do not do

We do not request Personal Data from minors and children without obtaining parental or legal guardian consent;
We do not sell your Personal Data;
We do not process Special Category Data without obtaining prior specific consent; and
We do not use automated decision-making, including profiling.

HELP AND COMPLAINTS

If you have any questions about this policy or the information we hold about you, please contact us by email using info@wearecreavo.com with “Data Protection” in the subject line.

CHANGES

The first version of this policy was issued on 28th January 2025, and is the current version. Any prior versions are invalid, and if we make changes to this policy, we will revise the effective date.