DRAFT: this document has not been reviewed or approved by a lawyer and is not yet in force. Items in square brackets are unknown or undecided and must be completed or removed before it is published.
Privacy Policy
This Privacy Policy explains what personal information Creava collects, why, who can see it, and what choices you have. It applies to the Creava website and the Creava mobile apps.
Version: [PLACEHOLDER: document version]. Effective: [PLACEHOLDER: effective date]. Draft label recorded with acceptances: "draft-1".
1. Who we are
Creava is operated by Create Me FZ LLC, United Arab Emirates ("we", "us"). Registered address: [PLACEHOLDER: registered address of Create Me FZ LLC]. Licence details: [PLACEHOLDER: trade licence number and issuing authority or free zone].
Privacy contact: [PLACEHOLDER: privacy contact email address]. Data protection officer or privacy lead: [PLACEHOLDER: data protection officer or privacy lead, if one is appointed].
[LEGAL REVIEW: confirm whether Create Me FZ LLC is the data controller for all processing described here, and which data-protection laws apply to it (for example UAE federal law and any free-zone regulations), and to people in other countries who use Creava.]
2. Information we collect
We collect the following, mostly because you give it to us when you create and use your profile.
- Account information: your email address and password. Your password is handled by our authentication service. We use your email address to send you the link that confirms your account and any password-reset link you ask for.
- Profile information you enter: display name, username, role or title, city, country, a short bio, and a profile picture.
- Private profile details: your gender, your date of birth and the date you confirmed your age, and an optional phone number with its country calling code. These are not shown on your public profile. [CONFIRM: the decision to keep the full date of birth, rather than only an age band, still needs legal sign-off.]
- Content you add: entries in your profile modules (for example work experience, education, life timeline, skills, hobbies and languages), photos and, when available, videos, captions, and how you arrange and colour your profile.
- Security information: if you turn on two-step verification, the details of the authenticator-app factor you register, and sign-in sessions.
- Technical information: your device or browser keeps your sign-in session (in the browser's local storage on the web, and in the device's secure storage in the apps). Our hosting and security systems process your IP address, and we use a one-way scrambled form of it to limit abuse of the media features. [CONFIRM: what the hosting and email providers log, once they are final.]
We do not currently use advertising, analytics or tracking software in the Creava website or apps. [CONFIRM: re-check this before every release.]
3. What is public and what is private
Your profile is private until you choose to publish it, and it is only reachable by the public while it is published and complete (all required sections have at least one entry) and your email address is verified.
- Shown on a public profile: your display name, username, role or title, city, country, bio, profile picture, the entries in your profile sections, and any photos or videos you set to public.
- Never shown on a public profile: your email address, date of birth, gender, age band, phone number, security settings, and photos you keep private.
- A public profile can be opened by anyone who has its link, and may be listed by search engines. Signed-in members can search for published profiles by name or username. [CONFIRM: the exact search scope and what a search result shows.]
- You can unpublish your profile or make photos private again at any time. Copies that other people have already saved or that a search engine has already stored may remain outside our control for a time.
4. How we use information
- To create and run your account, show your profile as you chose, and let you search and be found.
- To verify your email address, keep your account secure, and prevent abuse and misuse of the service.
- To provide features tied to your plan, such as the free trial and the media limits that apply to your plan.
- To respond to your questions and requests, and to meet our legal obligations.
[LEGAL REVIEW: state the legal basis for each use where the applicable law requires one, and whether consent is relied on for any of them.]
6. Transfers across borders
Our providers store and process information in countries other than the one you live in, including outside the United Arab Emirates.
[LEGAL REVIEW: the legal mechanism and safeguards for international transfers under the applicable law.]
7. How long we keep information
We keep your information while your account exists. Retention periods: [PLACEHOLDER: retention periods for each kind of information].
You can delete your account in the app (Account security) or on the website. Your profile is hidden at once. You then have 30 days to change your mind by signing in again and cancelling. After 30 days your account and the information and files you added are permanently deleted. Your username is kept out of use for 90 days afterwards so that nobody else can take it. [CONFIRM: these periods are how the product works today; a lawyer must confirm them.]
[PLACEHOLDER: what is kept after deletion (for example copies in backups, records we must keep by law, and records of your acceptance of these documents), and for how long.]
8. Your choices and rights
You can change your profile details, make your profile or photos private, and unpublish your profile in the app. You can also turn on two-step verification.
[LEGAL REVIEW: list the rights available under the applicable data-protection laws (for example access, correction, deletion, restriction, objection, portability and withdrawal of consent) and any exceptions.] To make a request, contact [PLACEHOLDER: privacy contact email address]. If you are not satisfied, you may contact [PLACEHOLDER: supervisory authority or regulator to contact about a complaint].
9. Age
Creava is for people aged 16 or over. [CONFIRM: the minimum age of 16 is the current product rule; a lawyer must confirm it for every country where the apps are offered.] We ask for your date of birth when you set up your profile and do not allow accounts under the minimum age. If we learn that someone under that age has an account, we will remove it.
10. Security
We protect information with measures that include encrypted connections, access rules in our database so that members can only reach their own private data, optional two-step verification with an authenticator app, and limits on automated use of our features. No system is completely secure, and we cannot guarantee absolute security.
12. Changes to this policy
[PLACEHOLDER: how and when we will notify you of changes, and how earlier versions are kept.]
13. Contact
Questions about this policy: [PLACEHOLDER: privacy contact email address]. Company: Create Me FZ LLC, United Arab Emirates, [PLACEHOLDER: registered address of Create Me FZ LLC].