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Updated on Aug 2018

The Creative Labs Company, Inc. (“Creative Labs,” “we,” or “us”) takes the privacy and protection of personal information very seriously. By visiting and using the Creative Labs Offerings or registering for the Creative Labs Offerings and creating an Account, you acknowledge that you accept the practices and policies outlined in this privacy policy (“Privacy Policy”). Unless otherwise defined herein, capitalized terms shall have the meanings assigned to such terms in the Creative Labs Terms of Service and which incorporate this Privacy Policy by reference.

By using and accessing the User acknowledges that they have read this Privacy Policy and that they fully agree with it. The latest update of this Privacy Policy is indicated at the top of this text and it will become effective immediately upon being posted. Creative Labs, thus, recommends reviewing this Privacy Policy from time to time.

Some of the Services offered on the Website may be subject to specific privacy policies that will supplement this general Privacy Policy or, in case they differ from the terms of this Privacy Policy, they will substitute the present Privacy Policy. These additional privacy policies must be accepted by the User before initiating the corresponding Service. Additionally, the access and use of the Website and the accompanying Services are governed by the Terms of Use of


What This Privacy Policy Covers


This Privacy Policy describes Creative Labs' practices with respect to Personal Information and Anonymous Information that we collect when you use the Creative Labs Offerings. This Privacy Policy does not apply to the use of your Personal Information that is collected by third parties that Creative Labs does not own or control or that do not support Creative Labs in providing the SupplyFrame Offerings.

“Personal Information” is information that is personally identifiable like names, addresses, e-mail addresses, as well as other non-public information that is associated with the foregoing.

“Anonymous Information” means information that is not associated with or linked to your Personal Information; Anonymous Information does not permit the identification of individual persons.

We collect and use Personal Information and Anonymous Information as described in this Privacy Policy from users of the Creative Labs Offerings (“Users”).



General Information

As a general principle, your granting of any consent and your provision of any Personal Information hereunder is entirely voluntary; there are generally no detrimental effects on you if you choose not to consent or to provide Personal Information. However, there are circumstances in which Creative Labs cannot take action without certain Personal Information, for example because this Personal Information is required to process your orders or provide you with access to a web offering or newsletter. In these cases, it will unfortunately not be possible for Creative Labs to provide you with what you request without the relevant Personal Information.

As part of a global group of companies, Creative Labs has affiliates and third-party service providers within, as well as outside of, the European Economic Area (the “EEA”). As a consequence, whenever Creative Labs is using or otherwise processing your Personal Information for the purposes set out in this Privacy Statement, Creative Labs may transfer your Personal Information to countries outside of the EEA including to such countries in which a statutory level of data protection applies that is not comparable to the level of data protection within the EEA. Whenever such transfer occurs, it is based on the Standard Contractual Clauses (according to EU Commission Decision 87/2010/EC or any future replacement) in order to contractually provide that your Personal Information is subject to a level of data protection that applies within the EEA.

You can request from Creative Labs at any time details about which Personal Information Creative Labs processes about you and the correction or deletion of such Personal Information. Please note, however, that Creative Labs can delete your Personal Information only if there is no statutory obligation or prevailing right of Creative Labs to retain it. If you request that Creative Labs delete your Personal Information, you will not be able to continue to use any Creative Labs service that requires Creative Labs' use of your Personal Information.

If Creative Labs uses your Personal Information based on your consent or to perform a contract with you, you may further request from Creative Labs a copy of the Personal Information that you have provided to Creative Labs. In this case, please contact the email address below and specify the information or processing activities to which your request relates, the format in which you would like this information, and whether the Personal Information is to be sent to you or another recipient. Creative Labs will carefully consider your request and discuss with you how we can best fulfill it.

Furthermore, you can request from Creative Labs that we restrict your Personal Information from any further processing in any of the following events: (i) you state that the Personal Information Creative Labs has about you is incorrect, (but only for as long as Creative Labs requires to check the accuracy of the relevant Personal Information), (ii) there is no legal basis for Creative Labs processing your Personal Information and you demand that Creative Labs restricts your Personal Information from further processing, (iii) Creative Labs no longer requires your Personal Information but you claim that you require Creative Labs to retain such data in order to claim or exercise legal rights or to defend against third party claims, or (iv) in case you object to the processing of your Personal Information by Creative Labs (based on Creative Labs' legitimate interest as further set out below) for as long as it is required to review as to whether Creative Labs has a prevailing interest or legal obligation in processing your Personal Information.

Please direct any such request to

Right to Lodge a Complaint
If you believe that Creative Labs is not processing your Personal Information in accordance with the requirements set out herein or applicable EEA data protection laws, you can at any time lodge a complaint with the data protection authority of the EEA country in which you live or with the data protection authority of the country or state in which Creative Labs has its registered seat.
Personal Information We Collect
We collect the following Personal Information that you submit to us voluntarily: 
  • If you register for the Creative Labs Offerings and create an Account, we collect a username, your e-mail address, and a password for your Account.
  • When you register for the Creative Labs Offerings we collect, on an optional basis, certain information to complete your profile, including your name, gender, city, state, country, and website.
  • If you participate in one of our surveys, we will collect any Personal Information contained in your responses to such survey and any additional profile information you provide. When you contact us by sending us an e-mail, we will collect any information that is contained in (and/or attached to) your e-mail.
  • If you make a posting or comment on a posting on the Creative Labs Offerings, we will collect any Personal Information contained in such posting.
  • If you sign up for a feature of the Creative Labs Offerings for which we charge a fee, we will collect your first and last name, billing address or payment account number and any other information needed to complete the transaction.
  • We may also collect Personal Information, such as demographic information, from you via the Creative Labs Offerings or at other points in the Creative Labs web sites (“Sites”) that state that Personal Information is being collected.


Personal Information Collected Via Technology

As you use the Creative Labs Offerings, certain information may also be collected passively, including your Internet protocol (IP) address and the browser that you use to visit the Sites. We may use Cookies to improve your experience and a “reverse IP lookup” to determine the company associated with your IP address.

Since the foregoing information may be collected when you are signed into the Creative Labs Offerings or after you click on a link contained in an email sent by us, this information may be associated by us with Personal Information that we have collected from you.


Creative Labs stores small text files called “Cookies” on your computer to make your experience on our website better. We use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them). In order to provide the Creative Labs Offerings and other services, we use a variety of Cookies that perform different functions. We use the following types of cookies:

  • Strictly Necessary Cookies. Strictly necessary Cookies are Cookies which are essential to enable you to move around the website and use its features, such as accessing secure areas of the Sites. Without these Cookies, services you have asked for cannot be provided.
  • Performance Cookies. Performance Cookies collect anonymized information about how you use the Sites. For example, these Cookies may tell us which pages you go to most often and if you receive error messages from our web pages. We use this information to improve how our Sites work. By using our Sites, you agree we can place these cookies on your device.
  • Functionality Cookies. Functionality Cookies allow our website to remember the choices you make, such as your login information (if any), preferred language or region you are in, and can provide enhanced, more personal features. These Cookies can also be used to remember changes you made to text size, fonts and other parts of Sites pages you can customize. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. The information these Cookies collect may be anonymized, and they cannot track your browsing activity on other websites. By using our Sites, you agree we can place these Cookies on your device.
  • Advertising Cookies. These Cookies collect information to deliver you more relevant advertising. They may be placed by us, by third parties acting on our behalf, or by advertising networks with our permission. They remember other websites you have visited, and advertising networks may share this information with others including advertisers. By using our Sites, you agree we can place these Cookies on your device.

While you will still be able to use the Creative Labs Offerings if you disable Cookies in your browser, certain parts of the Creative Labs Offerings may not function as effectively.

Personal Information From Other Sources
We may receive Personal Information about you from outside the Sites, such as from third parties that provide services for us that are related to the Creative Labs Offerings. We may add this information to the information we have already collected from you via the Creative Labs Offerings.
Use Of Information We Collect
In general, information (including Personal Information) you submit to us, or to third parties that support us in collecting information, is used by us to provide you and others with the Creative Labs Offerings, to respond to requests that you make, to improve our Creative Labs Offerings, and to better tailor the features, performance and support of the Creative Labs Offerings.
We may also use your Personal Information to provide you with notifications related to your use of the Creative Labs Offerings, such as newsletters or promotional e-mails.
We may create Anonymous Information records from Personal Information by excluding information (such as your name) that makes the information personally identifiable to you. We may also create Anonymous Information on how you use the Creative Labs Offerings. We may use this Anonymous Information for internal purposes, such as analyzing usage patterns so that we may enhance the Creative Labs Offerings, and we also reserve the right to use and disclose any Anonymous Information at our discretion.
Use Of Personal Data Based On The Law
In the following cases, Creative Labs is permitted to process your Personal Information under the applicable data protection law.
Providing the requested goods or services. If you order goods or services from Creative Labs, we will use the Personal Information that you enter into the order or registration form (usually (a subset of) your name, (email) address, telephone number, company name and address, your job title and role and, if payment is to be made to Creative Labs, credit card number or bank details) only to process your order or to provide the requested goods or service. This may include taking the necessary steps prior to entering into the contract, responding to your related inquiries, and providing you with shipping and billing information, and to process or provide customer feedback and support. This may also include conversation data that you may trigger via the chat functionalities on our Sites, contact forms, emails, or telephone. In this Privacy Policy, “goods and services” includes (access to) Creative Labs Offerings, contests, sweepstakes, other content, non-marketing related newsletters, whitepapers, tutorials, trainings and events.
If you participate in tutorials or trainings provided by Creative Labs, we may also track your learning progress in order to make this information available to you. Furthermore, we communicate on a regular basis by email with users who subscribe to our services, and we may also communicate by phone to resolve customer complaints or investigate suspicious transactions. We may use your email address to confirm your opening of an account, to send you notice of payments, to send you information about changes to our products and services, and to send notices and other disclosures as required by law. Generally, users cannot opt out of these communications, which are not marketing-related but merely required for the relevant business relationship. With regard to marketing-related types of communication (i.e. emails and phone calls), Creative Labs will (i) where legally required only provide you with such information after you have opted in and (ii) provide you the opportunity to opt out if you do not want to receive further marketing-related types of communication from us.
Creative Labs and its products, technologies, and services are subject to the export laws of various countries including, without limitation, those of the European Union and its member states, and of the United States of America. You acknowledge that, pursuant to the applicable export laws, trade sanctions, and embargoes issued by these countries, Creative Labs is required to take measures to prevent entities, organizations, and parties listed on government-issued sanctioned-party lists from accessing certain products, technologies, and services through Creative Labs Sites or other delivery channels controlled by Creative Labs. This may include (i) automated checks of any user registration data as set out herein and other information a user provides about his or her identity against applicable sanctioned-party lists; (ii) regular repetition of such checks whenever a sanctioned-party list is updated or when a user updates his or her information; (iii) blocking of access to Creative Labs' services and systems in case of a potential match; and (iv) contacting a user to confirm his or her identity in case of a potential match.
Furthermore, you acknowledge that any information required to track your choices regarding the processing or use of your Personal Information or receipt of marketing materials (that is to say, depending on the country in which the relevant Creative Labs company operates, whether you have expressly consented to or opted out of receiving marketing materials) may be stored and exchanged between members of Creative Labs as required to ensure compliance.
Use Of My Personal Information Based On My Consent
In the following cases, Creative Labs will only use your Personal Information as further detailed below after you have granted your prior consent into the relevant processing operations.
Creative Labs may provide a hashed user ID to third party operated social networks or other web offerings (such as Twitter, LinkedIn, Facebook, Instagram or Google) where this information is then matched against the social networks’ data or the web offerings’ own data bases in order to display to you more relevant information.
Creative Labs offers you the option to use its Offerings including forums, blogs, and networks linked to its Sites that require you to register and create a user profile. User profiles provide the option to display personal information about you to other users, including but not limited to your name, photo, social media accounts, postal or email address, or both, telephone number, personal interests, skills, and basic information about your company.
These profiles may relate to a single Offering of Creative Labs or may also allow you to access other Offerings of Creative Labs or of other entities of Creative Labs, or both (irrespective of any consent granted under the section “Forwarding Your Personal Data To Other Creative Labs Companies.” below). It is, however, always your choice which of these additional Offerings you use and your Personal Information is only forwarded to them once you initially access them. Kindly note that without your consent for Creative Labs to create such user profiles, Creative Labs will not be in a position to offer such services to you where your consent is a statutory requirement that Creative Labs can provide these services to you.
Within any Offerings, beyond the mere provision of access, your profile is used to personalize interaction with other users (for example, by way of messaging or follow functionality) and by Creative Labs to foster the quality of communication and collaboration through such Offerings and for Creative Labs to provide gamification elements (gamification is the process of taking something that already exists, such as a website, an enterprise application, or an online community, and integrating game mechanics into it to motivate participation, engagement, and loyalty). To the greatest extent supported by the relevant Offerings, you can use the functionality of the relevant Offerings to determine which information you want to share.
If you register for an event, seminar, or webinar of Creative Labs, Creative Labs may share basic participant information (your name, company, and email address) with other participants of the same event, seminar, or webinar for the purpose of communication and the exchange of ideas.
Creative Labs may transfer your Personal Information to other entities owned by Creative Labs. In such cases, these entities will then use the Personal Information for the same purposes and under the same conditions as outlined in this section.
You may at any time withdraw a consent granted. In case of withdrawal, Creative Labs will not process Personal Information subject to this consent any longer unless legally required to do so. In case Creative Labs is required to retain your Personal Information for legal reasons your Personal Information will be restricted from further processing and only retained for the term required by law. However, any withdrawal has no effect on past processing of Personal Information by Creative Labs up to the point in time of your withdrawal. Furthermore, if your use of an Creative Labs Offering requires your prior consent, Creative Labs will not be (any longer) able to provide the relevant service, offer or event to you after your revocation.
U.S.-Specific Provisions
Where Creative Labs is subject to U.S. privacy requirements, the following also applies:
Do Not Track. Your browser may allow you to set a “Do not track” preference. Unless otherwise stated, our Sites do not honor “Do not track” requests. However, you may elect not to accept Cookies by changing the designated settings on your web browser. Please note that if you do not accept cookies, you may not be able to use certain functions and features of our site.
If you provide feedback about the Creative Labs Offerings to us, we may use and disclose such feedback for any purpose, provided we do not associate such feedback with your Personal Information. We will collect any information contained in such feedback and will treat the Personal Information in it in accordance with this Privacy Policy. 
Disclosure Of Personal Information
Please note that we may disclose certain of your Personal Information, such as your username, to other Users of certain Creative Labs Offerings in order to identify you as a User of the Creative Labs Offerings. In addition, certain information that you have provided on an optional basis in connection with registering with our Creative Labs Offerings (your gender, phone number, address, city, state, country, and website) may be made available on your profile to other Users of all the Creative Labs Offerings; please make sure that you only provide the information that you feel comfortable sharing with others in this way.
We may enter into agreements with companies that provide the Creative Labs Offerings by way of a co-branded or private-labeled website or companies that offer their products and/or services on our website (“Third Party Companies”). A Third Party Company may want access to Personal Information that we collect from its customers. As a result, we may disclose your Personal Information to a Third Party Company; however, we will not disclose your Personal Information to Third Party Companies for the Third Party Companies’ own direct marketing purposes, unless you have “opted-in” by following the instructions we provide to allow such disclosure. If you have opted-in to receive e-mail communications from a Third Party Company and later wish to discontinue receipt of these e-mails, please contact the Third Party Company directly to update your preferences. The privacy policies of our Third Party Companies may apply to the use and disclosure of your Personal Information that we collect and disclose to such Third Party Companies. Because we do not control the privacy practices of our Third Party Companies, you should read and understand their privacy policies.
We may provide your Personal Information to third party service providers and suppliers who work on behalf of or with us to provide you with some of the services and features of the Creative Labs Offerings and to help us communicate with our users (including in connection with payments). However, these service providers and suppliers do not have any independent right to use this information except to help us provide the Creative Labs Offerings.
We may share some or all of your Personal Information with any parent company, subsidiaries, joint ventures, or other companies under a common control (collectively, “Affiliates”), in which case we will require our Affiliates to honor this Privacy Policy.
In the event Creative Labs goes through a business transition such as a merger, acquisition by another company, or sale of all or a portion of its assets, your Personal Information will likely be among the assets transferred. You acknowledge that such transfers may occur, and that any acquirer of Creative Labs or its assets may continue to use your Personal Information as set forth in this Privacy Policy. You hereby consent to Creative Labs sharing your Personal Information under the above circumstances.
We may (and you authorize us to) disclose information we have collected from and about you (including Personal Information) if we believe in good faith that such disclosure is necessary to (a) comply with relevant laws or to respond to subpoenas or warrants served on us; (b) to enforce any agreement we may have entered into with you and to enforce the Privacy Policy; or (c) to protect and defend the rights or property of us, other Users, or third parties. 
Choices Regarding Personal Information
We will include unsubscribe instructions in each newsletter or promotional communication you receive from us.
We may send you service-related announcements (such as, but not limited to, notice that we have changed the Service, the Terms of Service, or the Privacy Policy) when we believe it is necessary to do so. You may not opt-out of these communications, which are not promotional in nature, but if you do not wish to receive these announcements, you have the option to terminate the Account you may have with us. You understand that any termination of your Account may involve deletion of your Account information (and associated Content) from our live databases and all the information and data stored for such Account in the Creative Labs Offerings. Creative Labs will not have any liability whatsoever to you for any termination of your Account or related deletion of your information.
Modifying And Deleting Your Personal Information
You may change any of your Personal Information in your Account by editing your profile within the Creative Labs Offerings. You may request deletion of your Personal Information by us, but please note that we may be required (by law or otherwise) to keep this information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete Personal Information that we have collected from or about you, it will be deleted from our active databases but may remain in our archives.
Links To Other Web Sites
The Creative Labs Offerings may contain links to other web sites that are not owned or controlled by Creative Labs. The provision of such links is for your convenience and does not signify our endorsement of such web sites or location or its contents. We have no control over, do not review and are not responsible for the privacy policies of or content displayed on such other web sites. Please be aware that the terms of the Privacy Policy do not apply to any outside web sites.
Privacy Of Minors
We do not intend for our Sites or online services to be used by anyone under the age of 13. If you are a parent or guardian and believe we may have collected information about a child via, please contact us at
Security and Confidentiality
Creative Labs is committed to safeguarding and securing the information we collect online. We use a variety of industry-standard security technologies and procedures to help protect your Personal Information from unauthorized access, use, or disclosure. We also require you to enter a password to access your Account information. Please do not disclose your Account password to unauthorized people. However, no company, including Creative Labs, can fully eliminate security risks associated with Personal Information. 
Changes In This Privacy Policy
As part of the Terms of Service, this Privacy Policy is subject to occasional amendment, in accordance with the terms of the Terms of Service.
Contact Us
If you have any questions or suggestions regarding our Privacy Policy for this website ( please contact us by sending us an e-mail to