It is always a User’s choice whether or not to provide Personal Information. However, if a User chooses not to provide requested Personal Information, that User will not be able to use certain features of the Services. We set out in detail below the information that we collect about Users and Users’ use of our Services. Creative Layer does not collect on its own behalf things like protected health information, date of birth, social security or other government-issued identification number, and other sensitive personal information.
Where our Service is implemented by our Subscribers, we act as data processor and not as data controller. Queries and requests for information by Customers in respect of information processed by us on behalf of our Subscribers should be addressed to our Subscribers.
3. The Information We Collect About Users
We may collect, use, store and transfer different kinds of personal data about Users which we have grouped together follows:
· Identity Data includes first name, last name, or similar identifier (and for Customers may include alternate names such as for gifts)
· Contact Data includes email address and telephone numbers (and for Customers may include the foregoing for alternates such as for gifts).
· Profile Data includes Users’ profile data saved through the Service.
· Content Data includes content information that Users upload to the Service which may include personal information, including without limitation text content, images or other forms of content.
· Technical Data includes internet protocol (IP) address, browser type and version, operating system and platform, device identifiers and pseudonymous unique identifiers.
· Payment Data (in respect of Subscribers only) includes credit card number, bank account number and similar information
· Usage Data includes data about how Users use our Services, such as browsing actions within the portal, the buttons and controls. Users click on, pages of our portal that Users visit, the time spent on those pages, User’s search queries, the dates and times of User’s visits, and workplace usage.
We also collect, use and share Non-personalized data called “Service Data” such as statistical or demographic data for any purpose. Service Data may be derived from User’s Personal Information but is not considered personal information in law as this information does not directly or indirectly reveal User’s identity. For example, we may aggregate User’s Usage Data to calculate the percentage of users accessing a specific Website feature.
We do not collect any Special Categories of Personal Data about Users (this includes details about User’s race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about User’s health and genetic and biometric data). We do not collect any information about criminal convictions and offences.
4. How Is User’s Personal Information Collected
We use different methods to collect data from and about Users including through:
· Direct interactions. Users may give us User Identity, Contact and Profile Data by registering for or using the Services and completing fields within the Services
· Automated technologies or interactions. As Users interact with our Services, we may automatically collect Technical and Usage Data about User’s equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
· Third parties or publicly available sources. We may receive Personal Information about Users from various third parties and public sources as set out below:
· Technical Data from the third parties such as the following:
a. analytics providers such as Google Analytics;
b. search information providers such as Google.
5. Purposes for Which We Will Use User’s Personal Information
We have set out below, in a table format, a description of all the ways we plan to use Users’ Personal Information.
We may also disclose User’s Personal Information:
Upon request, Creative Layer will provide Users with information about whether we hold any of a User’s Personal Information. Creative Layer enables Users to access and correct Personal Information we have collected. If Users have any concerns or suspect unauthorized activities associated with User’s account, please contact us at firstname.lastname@example.org. We will respond to Users request within a reasonable timeframe, and in any event within 30 days of receipt of request.
Creative Layer acknowledges that Users have the right to access, update, revoke permission to process, or request the deletion of User’s Personal Information. Any such query can be directed to Creative Layer’s Data Protection Officer at email@example.com. If requested to remove data under either scenario, we will respond within a reasonable timeframe.
8. Security and Enforcement
The security of User’s Personal Information is important to us. We use security safeguards appropriate to the sensitivity of the information to ensure that User’s Personal Information is stored and maintained in a secure environment. Creative Layer exercises managerial and technical safeguards designed to protect against the loss or unauthorized use or disclosure of Personal Information belonging to our Users. These safeguards include encryption, malware protection, logical and physical access controls, and detection of social engineering attacks.
9. Retention of Data
Creative Layer will keep User’s Personal Information for as long as it remains necessary for the identified purposes set out below or as required by law, which may extend beyond the termination of our relationship with User. Users acknowledge and agree that if a User requests that a User’s name be removed from our databases, it may not be possible to completely delete all User’s Personal Information due to legal constraints.
Identity, Contact and Profile data
Subscription term and 3 months after account termination
To provide the Services to you during the subscription term.
Technical and Usage data
3 years after account termination
To provide the Services to you during the subscription term and to protect against fraud.
10. Managing the Online Collection of Additional Data
As Users navigate through and interact with our Website and Services, we may use automatic data collection technologies to collect certain information about User’s equipment, browsing actions and patterns, including:
We and our third-party service providers may collect information about Users in a variety of ways. We and/or our third-party partners may employ various tracking technologies, such as cookies, web beacons and analytics software, that help us better manage content on our Services by informing us what content is effective.
Cookies are small files saved to the User's computer’s hard drive that track, save and store information about the User's interactions and usage of the Website. This allows the Website, through its server, to provide the Users with a tailored experience within the Website.
Users are advised that if they wish to deny the use and saving of cookies from the Website on to their computers hard drive they should take necessary steps within their web browsers security settings to block all cookies from the Website and its external serving vendors.
Other cookies may be stored on your computer’s hard drive by external vendors when the Website uses referral programs, sponsored links or adverts. Such cookies are used for conversion and referral tracking and typically expire after 30 days, though some may take longer. No Personal Information is stored, saved or collected.
12. Payment Processing
When you use the Services, we will process your payment using third party payment processing providers, such as Stripe. You can find out more about how they secure your sensitive information here: https://stripe.com/en-ca/privacy
Creative Layer does not store or have access to your financial information such as credit card numbers or bank numbers.
Creative Layer may also use Apple Pay or Android Pay if available. You can find out more about how they secure your sensitive information here: https://www.apple.com/ca/apple-pay/ https://pay.google.com/intl/en_ca/about/
The Creative Layer Service may contain third party links, including sponsored links and adverts.
We take no responsibility for any external links or the websites or content to which they may direct Users. Users should click on external links at their own risk. We cannot be held liable for any damages or implications caused by visiting any external links mentioned.
14. Transfers and disclosures of Data
Creative Layer’s headquarters in Canada is our primary location for business operations, but may process or transfer data in or to other jurisdictions in the course of providing the Services.
For example, regarding normal business operations, Creative Layer may engage a third-party to support our data storage, data processing, billing, support services, information technology, or mailings on our behalf, which third party’s facilities may be located in another jurisdiction.
We may also disclose User’s Personal Information as required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect User’s safety, or the safety of others, investigate fraud, or respond to a government request.
15. Additional Privacy Protections for Minors
We join the industry in recognizing that children, including young teens, may not be able to make informed choices about Personal Information requested online. Creative Layer does not solicit or knowingly collect Personal Information of those under the age of sixteen.
17. Contact information.
Creative Layer Privacy Officer
135 Laurier Avenue West
Ottawa, ON K1P 5J2
Updated: Nov 5, 2020