Privacy Policy

Thanks for visiting. This policy explains the what, how, and why of the information we collect when you visit one of our websites, or when you use our Services. It also explains the specific ways we use and disclose that information. We take your privacy extremely seriously, and we never sell lists or email addresses.

The policy: This policy explains how we comply with the GDPR (General Data Protection Regulation), the DPA (Data Protection Act) [pre GDPR enforcement] and the PECR (Privacy and Electronic Communications Regulations).

This policy will explain areas of this website that may affect your privacy and personal details, how we process, collect, manage and store those details and how your rights under the GDPR, DPA & PECR are adhere to. Additionally it will explain the use of cookies or software, advertising or commercial sponsorship from third parties and the download of any documents, files or software made available to you (if any) on this website. Further explanations may be provided for specific pages or features of this website in order to help you understand how we, this website and its third parties (if any) interact with you and your computer / device in order to serve it to you. Our contact information is provided if you have any questions.

The DPA & GDPR May 2018

We and this website complies to the DPA (Data Protection Act 1998) and already complies to the GDPR (General Data Protection Regulation) which comes into affect from May 2018. We will update this policy accordingly after the completion of the UK's exit from the European Union.

THE BASICS

1. Definitions

These definitions should help you understand this policy. When we say "we," "us," and "our," we are referring to Creativity Sells Ltd, a UK registered limited liability company, registration number 05691082. We provide online platforms that you may use to market to or stay in contact with others, including creating, sending, and managing emails and other information related to your Subscribers (the "Services"). When we say "Member," we are referring to the person or entity that is registered with us to use the Services. When we say "you," we are referring either to a Member or to some other person who visits any of our Websites. A "Subscriber" is a person you contact through our Services, or a person who you might choose to contact at some point in the future through the use of our Services. In other words, a Subscriber is anyone on your Distribution List or about whom you have given us information. "Personal Information" means any information that identifies or can be used to identify you or a Subscriber, directly or indirectly, including, but not limited to, first and last name, date of birth, email address, gender, occupation or other demographic information. A "Distribution List" is a list of Subscribers and all associated information related to those Subscribers (for example, email addresses).

We offer the Services on at least our websites https://www.dealerwebs.com https://www.creativitysells.co.uk, and https://esendy.co.uk. This Privacy Policy applies to these specific websites, as well as any other sites or mobile applications owned or operated by us (each a "Website" and together the "Websites"). The "Websites" include the Websites themselves, and any web pages, interactive features, applications, widgets, blogs, social networks, social network "tabs," or other online, mobile, or wireless offerings that post a link to this Privacy Policy, whether accessed via computer, mobile device, or other technology, manner or means. While providing the Services, and as described in more detail below, we may collect Personal Information about a Website visitor, Member, person or email address on or related to a Distribution List, or Subscriber.

2. Changes

We may change this Privacy Policy at any time and from time to time. The most recent version of the Privacy Policy is reflected by the version date located at the bottom of this Privacy Policy. All updates and amendments are effective immediately upon notice, which we may give by any means, including, but not limited to, by posting a revised version of this Privacy Policy or other notice on the Website. We encourage you to review this Privacy Policy often to stay informed of changes that may affect you, as your continued use of the Website signifies your continuing consent to be bound by this Privacy Policy. Our electronically or otherwise properly stored copies of this Privacy Policy are each deemed to be the true, complete, valid, authentic, and enforceable copy of the version of this Privacy Policy which were in effect on each respective date you visited the Website.

3. Scope

This Privacy Policy is effective with respect to any data that we have collected, or collect, about and/or from you.

4. Questions & Concerns

If you have any questions or comments, or if you want to update, delete, or change any Personal Information we hold, or you have a concern about the way in which we have handled any privacy matter, please use our contact form to send us a message. You may also contact us by post at:

Creativity Sells Ltd
Attn. Privacy Officer
Tapton Park Innovation Centre
Brimington Road
Chesterfield
Derbyshire
S41 0TZ
UK

YOUR INFORMATION

5. Information We Collect

(a) Information you voluntarily provide to us: When you sign up for and use the Services, consult with our customer service team, send us an email, post on our blog, integrate the Services with another website or service (for example, when you choose to connect your e-commerce account with Creativity Sells Ltd), or communicate with us in any way, you are voluntarily giving us information that we collect. That information may include either your or your Subscribers' name, physical address, email address, IP address and phone number. By giving us this information, you consent to this information being collected, used, disclosed and stored by us, as described in this Privacy Policy.

(b) Information we collect automatically: When you use the Services or browse one of our Websites, we may collect information about your visit to our Websites, your usage of the Services, and your web browsing. That information may include your IP address, your operating system, your browser ID, your browsing activity, and other information about how you interacted with our Websites or other websites. We may collect this information as a part of log files as well as through the use of cookies or other tracking technologies. Our use of cookies and other tracking technologies is discussed more below, and in more detail in our Cookie Statement here.

(c) List and email information: When you add a Distribution List or create an email with the Services, we have and may access the data on your list and the information in your email. If a Subscriber chooses to forward an email you send to a friend, it will allow the Subscriber to share your email content with individuals not on your Distribution List. When a Subscriber forwards an email to a friend, we do not store your Subscriber's email address or their friend's email address, and no one is added to any Distribution List as a result. The Member who created the email campaign only sees an aggregate number of times their email campaign was forwarded by a Subscriber and does not have access to the email addresses used to share or receive that forwarded content.

(d) Information from your use of the Service: We may receive information about how and when you use the Services, store it in log files or other types of files associated with your account, and link it to other information we collect about you. This information may include, for example, your IP address, time, date, browser used, and actions you have taken within the application. This type of information helps us to improve our Services for both you and for all of our users.

(e) Cookies and tracking: We and our partners may use various technologies to collect and store information when you use our Services, and this may include using cookies and similar tracking technologies on our Website, such as pixels and web beacons, to analyze trends, administer the website, track users' movements around the website, serve targeted advertisements, and gather demographic information about our user base as a whole. Our third party partners may use cookies or similar tracking technologies in order to provide you advertising or other content based upon your browsing activities and interests. If you wish to opt out of interest-based advertising click http://www.youronlinechoices.eu/. Please note you might continue to receive generic ads. For more information about our use of cookies and other tracking technologies, as well as how to opt out of the use of cookies, please refer to our Cookie Statement here.

(f) Web beacons: We use web beacons on our Websites and in our emails. When we send emails to Members, we may track behavior such as who opened the emails and who clicked the links. This allows us to measure the performance of our email campaigns and to improve our features for specific segments of Members. To do this, we include single pixel gifs, also called web beacons, in emails we send. Web beacons allow us to collect information about when you open the email, your IP address, your browser or email client type, and other similar details. We also include Web Beacons in the emails we deliver for you. We use the data from those Web Beacons to create reports about how your email campaign performed and what actions your Subscribers took. Reports are also available to us when we send email to you, so we may collect and review that information.

6. Use and Disclosure of Personal Information

We may use and disclose Personal Information only for the following purposes:

(a) To promote use of our services to you and others. For example, if you intentionally submit Personal Information when you visit our Website but do not sign up for any of the Services, we may send you an email inviting you to sign up. If you use any of our Services and we think you might benefit from using another Service we offer, we may send you an email about that. You can stop receiving our promotional emails by following the unsubscribe instructions included in every email we send. In addition, we may use information we collect in order to advertise our Services to you or suggest additional features of our Services that you might consider using. For more information on how we use cookies or other tracking technologies for these purposes, as well as how to opt out of the use of cookies, please see our Cookie Statement here.

(b) To send you informational and promotional content in accordance with your marketing preferences. You can stop receiving our promotional emails by following the unsubscribe instructions included in every email.

(c) To send you System Alert messages. For example, we may inform you of temporary or permanent changes to our Services, such as planned outages, new features, version updates, releases, abuse warnings, and changes to our Privacy Policy.

(d) To communicate with our Members about their account and provide customer support.

(e) To enforce compliance with our Terms of Use and applicable law. This may include developing tools and algorithms that help us prevent violations.

(f) To protect the rights and safety of our Members and third parties, as well as our own.

(g) To meet legal requirements, including complying with court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms.

(h) To provide information to representatives and advisors, including legal teams and accountants, to help us comply with legal, accounting, or security requirements.

(i) To prosecute and defend a court, arbitration, or similar legal proceeding.

(j) To respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.

(k) To provide, support, and improve the Services we offer. This includes our use of the data that our Members provide us in order to enable our Members to use the Services to communicate with their Subscribers. This also includes, for example, aggregating information from your use of the Services or visit to our Websites and sharing this information with third parties to improve our Services. This might also include sharing your information or the information you provide us about your Subscribers with third parties in order to provide and support our Services or to make certain features of the Services available to you. When we do have to share Personal Information with third parties, we take steps to protect your information by requiring these third parties to enter into a contract with us that requires them to use the Personal Information we transfer to them in a manner that is consistent with this policy.

(l) To transfer your information in the case of a sale, merger, consolidation, liquidation, reorganization, or acquisition. In that event, any acquirer will be subject to our obligations under this Privacy Policy, including your rights to access and choice. We will notify you of the change either by sending you an email or posting a notice on our Website.

7. Data Collected for and by our Users

As you use our Services, you may import into our system Personal Information you have collected from your Subscribers or other individuals. We have no direct relationship with your Subscribers or any person other than you, and for that reason, you are responsible for making sure you have the appropriate permission for us to collect and process information about those individuals. Consistent with the uses of Personal Information covered in Section 6, we may transfer Personal Information of you or your Subscribers to companies that help us promote, provide, or support our Services or the services of our Members ("Service Providers"). All Service Providers enter into a contract with us that protects Personal Information and restricts their use of any Personal Information consistent with this policy. As part of our Services, we may use and incorporate into features information you have provided, we have collected from you, or we have collected about Subscribers. We may share this information, including Subscriber email addresses, with third parties in line with the approved uses in Section 6.

If you are a Subscriber and no longer want to be contacted by one of our Members, please unsubscribe directly from that Member's newsletter or contact the Member directly to update or delete your data. If you contact us, we may remove or update your information within a reasonable time and after providing notice to the Member of your request.

We will retain Personal Information we process on behalf of our Members for as long as needed to provide our Services or to comply with our legal obligations, resolve disputes, prevent abuse, and enforce our agreements.

8. Public Information and Third Party Websites

(a) Social media platforms and widgets. Our Websites include social media features, such as the Facebook Like button. These features may collect information about your IP address and which page you are visiting on our Website, and they may set a cookie to make sure the feature functions properly. Social media features and widgets are either hosted by a third party or hosted directly on our Website. We also maintain presences on social media platforms including Facebook, Twitter, and Instagram. Any information, communications, or materials you submit to us via a social media platform is done at your own risk without any expectation of privacy. We cannot control the actions of other users of these platforms or the actions of the platforms themselves. Your interactions with those features and platforms are governed by the privacy policies of the companies that provide them.

(c) Links to third-party websites. Our Websites include links to other websites, whose privacy practices may be different from ours. If you submit Personal Information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any Website you visit.

9. Third Parties

We may disclose Personal Information to the following types of third parties for the purposes described in this policy:

(a) Service Providers. Sometimes, we share your information with our third party Service Providers, who help us provide and support our Services. For example, if it is necessary to provide you something you have requested (like enable a feature such as Social Profiles), then we may share your and/or your Subscribers' Personal Information with a Service Provider for that purpose. Just like with the other third parties we work with, these third party Service Providers enter into a contract that requires them to use your Personal Information only for the provision of services to us and in a manner that is consistent with this policy. Examples of Service Providers include payment processors, hosting services and content delivery services.

(b) Advertising partners. We may partner with third party advertising networks and exchanges to display advertising on our Websites or to manage and serve our advertising on other sites and may share Personal Information with them for this purpose. All third parties with which we share this information are required to use your Personal Information in a manner that is consistent with this policy. We and our third party partners may use cookies and other tracking technologies, such as pixels and web beacons, to gather information about your activities on our Websites and other sites in order to provide you with targeted advertising based on your browsing activities and interests. For more information about cookies and other tracking technologies, please see our Cookie Statement here.

10. Competitions and Promotions

We may, from time to time, offer surveys, competitions or other promotions on our Websites or through social media (collectively "Our Promotions"). Participation in our Promotions is completely voluntary. Information requested for entry may include personal contact information such as your name, address, date of birth, phone number, email address, username, and similar details. We use the information you provide to administer Our Promotions. We may also, unless prohibited by the Promotion's rules or law, use the information provided to communicate with you, or other people you select, about our Services. We may share this information with our affiliates and other organizations or Service Providers in line with this policy and the rules posted for the Promotion.

11. Content of Email Campaigns

When you send an email marketing campaign, it bounces from server to server as it crosses the Internet. Along the way, server administrators can read what you send. Email was not built for confidential information. Please do not use Creativity Sells Ltd to send confidential information.

Sometimes we review the content of our Members' email campaigns to make sure they comply with our Terms of Use. To improve that process, we have software that helps us find email campaigns that may violate our Terms. Our employees or independent contractors may review those particular email campaigns. This benefits all Members who comply with our Terms of Use because it reduces the amount of spam being sent through our servers and helps us maintain high deliverability.

YOUR LISTS

12. Your Distribution Lists

A Distribution List can be created in a number of ways, including by importing contacts, such as through csv or directly from your email client. Your Distribution Lists are stored on a secure Creativity Sells Ltd server. We do not, under any circumstances, sell your Distribution Lists. If someone on your Distribution List complains or contacts us, we might then contact that person. Only authorized employees have access to view Distribution Lists. You may export (download) your Distribution Lists from Creativity Sells Ltd at any time.

We will use and disclose the information in your Distribution Lists only for the reasons discussed in Sections 6-9. We will not use and disclose the information in your Distribution Lists to:

If we detect abusive or illegal behavior related to your Distribution List, we may share your Distribution List or portions of it with affected ISPs or anti-spam organizations.

SECURITY

13. Notice of Breach of Security

If a security breach causes an unauthorized intrusion into our system that materially affects you or people on your Distribution Lists, then Creativity Sells Ltd will notify you as soon as possible and later report the action we took in response.

14. Safeguarding Your Information

We take reasonable and appropriate measures to protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the Personal Information.

Creativity Sells Ltd accounts require a username and password to log in. You must keep your username and password secure, and never disclose it to a third party. Because the information in your Distribution Lists is so sensitive, account passwords are encrypted, which means we cannot see your passwords. We cannot resend forgotten passwords either. We will only reset them.

COMPLIANCE

15. We Operate in the United Kingdom and the EU

Our servers and offices are located in the United Kingdom and the EU, so your information may be transferred to, stored, or processed in the United Kingdom and the EU. While the data protection, privacy, and other laws of the United Kingdom might not be as comprehensive as those in your country, we take many steps to protect your privacy. By using our Websites, you understand and consent to the collection, storage, processing, and transfer of your information to our facilities in the United Kingdom, the EU and those third parties with whom we share it as described in this policy.

16. Accuracy and Retention of Data

We do our best to keep your data accurate and up to date, to the extent that you provide us with the information we need to do so. If your data changes (for example, if you have a new email address), then you are responsible for notifying us of those changes. Upon request, we will provide you with information about whether we hold, or process on behalf of a third party, any of your Personal Information. We will retain your information for as long as your account is active or as long as needed to provide you with our Services. We may also retain and use your information in order to comply with our legal obligations, resolve disputes, prevent abuse, and enforce our Agreements.

17. Access

We will give an individual, either you or a Subscriber, access to any Personal Information we hold about them within 30 days of any request for that information. Individuals may request to access, correct, amend or delete information we hold about them by contacting us here. Unless it is prohibited by law, we will remove any Personal Information about an individual, either you or a Subscriber, from our servers at your or their request. There is no charge for an individual to access or update their Personal Information.

Thank you for taking the time to learn about Creativity Sells Ltd's Privacy Policy.

Cookies

This website only uses cookies to help us make the experience on the site better. Cookies are small files which are sent back and forth with web pages which can be used to identify that you have previously visited a site, or to store small bits of information locally with you. If you want to know more about what cookies are and how to control them, AboutCookies.org is a great resource, or read on to see what we use cookies for:

 

Cookie

Name

Purpose

More information

Google Analytics

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We make use of a tool from Google called Google analytics which tells us about the way people are using this website. It uses cookies to detect that someone has been to the site before, so that we can see how often people return to the site, how long they stay, and where on this website they tend to go. We use this to try to work out what kind of experience they're having on the site, so we can make it better. Google Analytics sets cookies to help us accurately estimate the number of people visiting this website, and let us see how they're moving around the site. We use this when we make decisions on the type of content we create and how we structure the site. .

Click here for an overview of privacy at Google

For more information about Google Analytics and the cookies it sets, please take a look at this breakdown of their cookies.

Session Cookies

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Session cookies only last for the duration of a user's visit to a website. Session cookies help improve the functionality of website by passing information on from one page to another. For example, if you log in to our website, session cookies are used to keep you logged in. This cookie is deleted when you close your browser.

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AddThis Cookie

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AddThis is used to give visitors the option to recommend our website content on social networks such as Facebook and Twitter. You will see icons on the top and bottom of each of our web pages.

AddThis privacy policy

Where can I find more information about cookies, and how do I turn cookies off or delete cookies?

Find out more about cookies including how to disable/enable and delete them at the following website www.aboutcookies.org.

You can block most cookies (except for Flash cookies) by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our sites, or you may experience reduced functionality when accessing certain services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies as soon you visit our website.

You can opt-out of receiving cookies from a range of ad servers (including, among others, Doubleclick, Videology, AudienceScience, Flashtalking and Microsoft) by visiting www.youronlinechoices.com and following the instructions provided.

Generally you can't delete Flash cookies (also known as local shared objects) with browser controls, but Adobe's website at www.adobe.com provides information on how to delete or disable Flash cookies. Click here for details. Please note that if you disable Flash cookies, you will not be able to play content on the ITV Player.

If you want to delete cookies from the browser on your mobile phone, you will need to refer to your handset manual.

Updated March 19, 2018