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Privacy Policy

Effective as of February 14, 2024

1. About Us

1.1 Creed Media ME FZ-LLC (hereinafter referred to as “Creed”, “we”, “us”, “our”) is a marketing platform which connects and facilitates marketing campaigns around the world with a deep focus on the ‘Gen Z’ market. ACOS (hereinafter referred to as “ACOS”,“Program”) is the revolutionary program which will be used in order to facilitate these campaigns.

1.2 Creed is committed to protecting and respecting your privacy. This Privacy Policy (together with our User Agreement and any other documents referred to in it sets out the basis on which any personal data we collect from you, or that you provide to us will be processed by us.)

1.3 Please read the following privacy policy (“Privacy Policy”) carefully to understand our views and practices regarding your personal data and how we will treat it. By accessing our website or our program you are accepting and consenting to the practices described in this Privacy Policy.

1.4 These terms shall be regulated by and interpreted in compliance with the laws of the Emirate of Abu Dhabi and the relevant Federal laws of the United Arab Emirates. Any disputes arising concerning the Privacy Policy shall be exclusively adjudicated within the jurisdiction of the courts of the Emirate of Abu Dhabi.

2. Information we collect from you

2.1 We process the following data from you:

User provided information

This category covers the information and data that is voluntarily given up and shared by you, this is the foundation for the personalized services that are offered on the site or on ACOS. This data is given up through filling the forms on the Creed website or by browsing the website.

When you register with us, via using our Program and/or website, report a problem, correspond to us via email, subscribe to any service, upload any material/content, the formation you provide us may include:

a. Your name, email address, age, user name, company name, password, and any other registration information;

b. Transaction related information, such as when you make any payments, purchases, respond to any offers, download or use ACOS;

c. Information you provide for us when you contact us for help;

d. Information you enter into ACOS such as campaign goals, personal information, etc.

Automatically collected information

Each visit to our website or Program we could and are likely to collect certain information automatically.

The information collected may include, however, is not limited to; technical information such as the type of mobile device you use, your mobile device's unique device ID, the IP address of your mobile device and/or computer, your operating systems and platform, your browser type, time zone settings, browser plug-in types, and information about the way you use the Program.

3. How is my data used?

3.1 Your data may be used by Creed for various reasons. Information held about would be used in the following ways (non-exhaustive list):

- To carry out our obligations and provide you with the information, products and services that you request from us;

- To provide you with information about other services we offer that are similar to those that you have already previously contracted with us for or enquired about;

- To ensure a customized and enhanced online experience;

- To provide you or permit selected third parties to provide you with information about goods and services about goods, or services we feel may interest you;

- To inform you of changes to our service, news, special offers, promotions, surveys, events, communications, notices, etc;

- To ensure that the content from the Program is presented in the most effective manner for you and your device/monitor;

- To support the services offered on the Creed website or ACOS;

- To conduct research about our customer base and contact you about reviews or feedback;

- To reduce credit risk, detect and protect us against error, fraud and other criminal activity;

- To comply with law, regulatory officials or court orders and/or to enforce our legal rights and remedies in any jurisdiction;

- To keep the Program and the Creed website safe;

- To administer the Program and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes, updates and changes in policy;

- For any other purposes notified to you on or before the collection or use of such data.

4. Disclosure of personal data

4.1 You agree that we have the right to share your personal information with:

- Any member of our ultimate parent company, employees or subsidiaries;

- At times, Creed may engage selected third parties to assist in various aspects of our operations and service provisions. These third parties may include business partners, suppliers, subcontractors, advertisers, advertising networks, analytics and search engine providers, credit reference agencies for credit assessment, credit card and payment processing companies, legal advisors, auditors, professional advisors, investors, and potential future investors of Creed. Their involvement is primarily to facilitate the performance of contracts, improve our website or Program, assess credit scores, ensure secure payment processing, and seek legal counsel or financial advice;

- We may also disclose your personal data when under legal obligation, or when necessary to enforce or apply our Terms of Use and other agreements, or to safeguard the rights, property, or safety of Creed, our customers, or others. This may involve sharing information with other companies or organizations for fraud protection and credit risk mitigation.

- The transmission of your personal data to entities or destinations beyond the borders of the United Arab Emirates may be necessary for multiple reasons, encompassing service provision, storage, or processing in alignment with our operational necessities. Your approval for this transfer signifies your recognition that the treatment and administration of your personal data will adhere to the benchmarks delineated in this Privacy Policy and conform to the pertinent regulations overseeing data protection and privacy.

5. Compliance

5.1 Your engagement with Creed's facilities implies an unequivocal commitment to comply with the terms articulated in this Privacy Policy. This commitment entails your irrevocable agreement to the terms herein, which govern the collection, utilization, and disclosure of your personal information. It's crucial to recognize that this Privacy Policy operates in conjunction with and supplements the guidelines articulated in our comprehensive Terms and Conditions, collectively framing the parameters of your association with Creed.

5.2 Furthermore, your explicit and informed consent encompasses a broader spectrum. It encompasses not only your agreement to the specified terms but also extends to the authorization for Creed to leverage any uploaded content, including photographs and personal information, within the Program or otherwise authorized for publication. This authorization grants Creed the prerogative to utilize such materials across various marketing initiatives and social media channels. These materials may serve the purpose of providing insights into our services or products, engaging in marketing endeavors, or facilitating the operational functions integral to Creed's activities.

6. Purpose

6.1 We collect your personal information to enable you to receive the benefit of the Program and services and/or products. Subject to this Privacy Policy, we may use your Personal information for the following purposes:

- To carry out our obligations and to provide you with agreed services and/or products;

- To establish, maintain and administer your account;

- To send you service and/or product or promotional communications and marketing material that is relevant to you to promote and market our services and/or products and the program and those of third parties;

- To notify you about changes to our services and/or products;

- Quality assurance and training;

- Improving our products and services, including site customisation;

- To verify your identity or location, and make security checks, in relation to a purchase;

- To access third-party development platforms or add-on keys;

- Market research and analysis;

- To promote and market our services and/or products (including via any social media pages maintained or operated by us such as but not limited to: Facebook, Instagram, Snapchat, Twitter, Youtube, Twitch, and Mixer)

- Internal record-keeping to facilitate any other Purpose;

-Any other uses identified to you at the time of collecting your personal information or as reasonably contemplated by this Privacy Policy (hereinafter referred to as the “Purpose”).

7. Accessing your personal data

7.1 To the extent required by law, you may review, edit, correct or delete any personal information you submit to us. On request we will, as soon as reasonably possible, provide you with:

- personal data about you that is in our possession or under our control; and

- information about the ways in which the personal data referred to in paragraph above (Disclosure of your personal information) has been or may have been used or disclosed by us during the year preceding the date of the request.

8. GDPR

8.1 If you are a resident of the European Union, you are protected by and enjoy additional rights under the European Union’s General Data Regulation 2016/679 (“GDPR”)

8.2 Additional rights that may be extended to you, amongst these rights include but are not limited to;

- Requesting access to any and all personal data; whenever made possible, you can access, update or request deletion of your personal data by contacting [email protected]. You may also request a copy of all your personal data Creed holds;

- Requesting correction of any data Creed has of you; you have the right to correct any personal data being held by Creed;

- You possess the unequivocal right to deny or withdraw consent for the processing of your personal data. Such denial or withdrawal will not impact the lawfulness of processing based on your consent before its withdrawal.

-You are entitled to request the erasure or removal of your Personal Data when its continued processing lacks substantial justification.

- Additionally, you hold the right to request the transfer of your personal data in a machine-readable format, either directly to yourself or to a third party of your choosing. This right is applicable exclusively to automated information you have consented to or that was utilized to fulfill a contractual agreement with you.

- Furthermore, you retain the right to withdraw your consent regarding the utilization of your Personal Data. However, it's important to note that if you choose to withdraw your consent, it may impact your access to certain specific functionalities of our services.

9. Retention of your personal data

9.1 In our unwavering commitment to prioritizing your privacy, we dedicate ourselves to the responsible management of personal data. We assure you that we will exhaust all reasonable efforts to discontinue the retention of documents containing personal data and eliminate any means linking such data to specific individuals. This commitment is activated as soon as it is reasonable to assume that the original purpose for collecting the personal data is fulfilled and is no longer served by its retention. Additionally, our proactive stance extends to instances where the retention of personal data is no longer necessary for legal or business purposes. This conscientious approach underscores our dedication to transparency, ethical practices, and our recognition of the evolving landscape of privacy expectations. We aim not only to meet but exceed your expectations in terms of privacy and data protection.

10. Accuracy

10.1 We are committed to maintaining the accuracy, completeness, and currency of the personal information we hold about you. While we take reasonable steps to achieve this, we recognize the collaborative nature of this effort. We primarily depend on your cooperation to inform us of any changes to your personal information. By agreeing to this Privacy Policy, you affirm your commitment to making reasonable efforts to promptly provide corrections and updates to your personal data, ensuring that the information we hold remains accurate and reflects the latest details about you. This collaborative approach underscores our shared responsibility in safeguarding the integrity of your personal information.

11. Links

11.1 Our platforms will contain links that will direct you to other websites, platforms, affiliates, programs, and partner sites. Using these links, relieves Creed all and any liability and responsibility for the Privacy Policy the destination may have. It is essential that you check and ensure to find out the Private Policy that the destination may have to stay informed and protected prior to submitting any data to these destinations.

12. Use of cookies

12.1 Creed may from time to time, through the Program or website use several different cookies for a plethora of matters. A cookie is a small text file that is placed on a computer or other device and is used to identify the user or device and to collect information. This helps us to provide you with a good experience when you browse our Website and Program and allows us to improve our Website. The cookies are not used to get data from your hard drive, your email or any other identifiable data.

12.2 Refer to our Cookie Policy for additional details on this matter.

13. What are my opt-out rights?

13.1 You can stop all collection of information by Creed easily by uninstalling ACOS. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network. You can also request to opt-out or delete your account via email, at [email protected].

14. Data retention policy, managing your information

14.1 We will retain User Provided Information for as long as you use the Program for a reasonable time thereafter. If you’d like us to delete User provided information that you have provided via the program and/or Website, please contact us at [email protected] and we will respond in a reasonable time. Please note that some or all of the User Provided Information may be required in order for the Website and/or Program to function properly. If you wish to correct or update your personal data, you may do so at any time by accessing your account setting through the Website and/ or the program if available.

15. Data retention policy, managing your information

15.1 We are committed to diligently employing all reasonable measures to cease the retention of documents containing personal data or eradicate the means by which personal data can be linked to specific individuals. This commitment is undertaken promptly upon the reasonable assumption that the original intent behind collecting the personal data is no longer pertinent or when the retention ceases to be essential for legal or business objectives.

16. Applicable age

16.1 Our platform caters to individuals aged 18 years and older. Users under this specified age bracket must have an account created on their behalf by a legal guardian or a responsible adult. This policy ensures compliance with legal requirements and safeguards the involvement of younger users by requiring oversight and involvement of a trusted adult for their account creation.

17. Regions covered

17.1 EU & UK Compliance (GDPR and UK Regulations): In conformity with the General Data Protection Regulation (GDPR) and the UK data protection regulations, we uphold stringent measures. This includes obtaining explicit user consent before processing any personal data, ensuring transparency, and providing individuals in these regions with comprehensive control over their data.

17.2 UAE Regulations: Our operations in the United Arab Emirates (UAE) are anchored firmly in compliance with the local data protection laws. This commitment underscores the significance of respecting and aligning with the specific regulations governing data privacy in the UAE.

17.3 California, USA (CCPA Compliance): Within California, USA, our practices align with the California Consumer Privacy Act (CCPA). This empowers California residents with the right to opt-out of particular data processing activities. We prioritize respecting these rights and providing individuals in California with clear avenues to control their data.

17.4 Canada Privacy Laws: Our activities in Canada adhere meticulously to the country's privacy laws. This entails transparently outlining our data usage practices and procuring informed consent from users. We place significant emphasis on providing detailed information to users in Canada and ensuring their informed consent forms the basis of our data processing activities within the region.

18. Governing law

18.1 The Privacy Policy of Creed and ACOS is to be governed in accordance with the laws of the United Arab Emirates. By agreeing to this Privacy Policy, it is understood that any disputes arising concerning matters related to this Privacy Policy shall be subject to a mandatory and agreed-upon 1-year mediation period. During this period, both parties commit to engaging in a monthly mediation meeting for the duration of one year.

18.2 The Customer agrees that any dispute must be brought forward within three (3) months of the dispute occurring, disputes that date prior to the three (3) month threshold will be considered void.

18.3 It is to be agreed that the mediator must be a truly neutral natural third party.

19. Consent

19.1 By utilizing the facilities provided by Creed, you are explicitly and unconditionally agreeing to abide by this Privacy Policy. Your consent is integral to the collection, utilization, and disclosure of your personal information as delineated within this Privacy Policy. It is imperative to understand that this Privacy Policy operates in conjunction with our Terms and Conditions, collectively shaping the parameters of your engagement with Creed.

19.2 By consenting to the Privacy Policy, you are also consenting to Creed and ACOS respectively, updating and amending the Privacy Policy constantly, without announcing it to you at any scale, it is your responsibility to check and ensure that you are well aware and knowledgeable of the Privacy Policy.

19.3 You consent to us posting and using any photographs, content and/or personal information you might upload on the ACOS or have otherwise provided consent to publish on the ACOS, Creed platforms, in our marketing material or social media channels, which we may use in order to provide information on our services and/or products, the marketing of our services and/or products or for the purpose of our functions and/or activities.

20. Contact us

20.1 Should you have any inquiries, concerns, or feedback regarding our privacy practices, we encourage you to reach out to us without hesitation at [email protected]. Your input is valuable to us, and we are committed to addressing any queries or feedback you may have about our Privacy Policy promptly and efficiently.