Last updated: 29 February 2024

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This Privacy and Data Policy in short:

• We never sell your details to anyone else, including the brands we work with - we sometimes have to share your details, but with the sole purpose of fulfilling a campaign (like sharing your address to send you products)
• We store your details securely, with limited access by our team - only people who really need access can have it
• If you ever want your details deleting or changing, or you have questions about the data we store about you - email data@drpcrd.com and we’ll respond as soon as we can (always within 7 days)
• We use some third parties like TikTok, Meta, and Stripe to run our service - in these cases, those providers keep your data secure, like passwords, bank accounts etc (we can’t see that stuff)
• Some data we are required by law to hold on to, but we don’t hold it longer than we need

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The full details

DRPCRD Limited (“we” or “us” or “our”) respects the privacy of our users (“user” or “you”). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website, including any other media form, media channel, mobile website, or mobile application related or connected thereto (collectively, the “Site”). Please read this privacy policy carefully.  If you do not agree with the terms of this privacy policy, please do not access the site or sign up.

We reserve the right to make changes to this Privacy Policy at any time and for any reason.  We will alert you about any changes by updating the “Last Updated” date of this Privacy Policy.  Any changes or modifications will be effective immediately upon posting the updated Privacy Policy on the Site, and you waive the right to receive specific notice of each such change or modification.
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You are encouraged to periodically review this Privacy Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by your continued use of the Site after the date such revised Privacy Policy is posted.

‍Types of data collection

We may collect information about you in a variety of ways. The information we may collect on the Site includes:

Personal Data‍

Personally identifiable information, such as your name, delivery address, email address, and telephone number, and demographic information, such as your age, gender, hometown, and interests, that you voluntarily give to us [when you register with the Site, fill out surveys, or] when you choose to participate in various activities related to the Site. You are under no obligation to provide us with personal information of any kind, however your refusal to do so may prevent you from using certain features of the Site.

Derivative Data‍

Information our servers automatically collect when you access the Site, such as your IP address, your browser type, your operating system, your access times, and the pages you have viewed directly before and after accessing the Site.

Data From Social Networks‍

User and Content information from social networking sites, such as TikTok, Instagram or Snapchat, including your name, your social network username, location, gender, birth date, email address, uploaded video content, profile picture, and public data for contacts, if you connect your account to such social networks.

Mobile Device Data‍

Device information, such as your mobile device ID, model, and manufacturer, and information about the location of your device, if you access the Site from a mobile device.

Data From Questions, Preferences and Surveys‍

Personal and other information you may voluntarily provide when answering questions on the Site, filling out user surveys or updating your user preferences.

Mobile Application Information

‍If you connect using our mobile application:

Geo-Location Information – We may request access or permission to and track location-based information from your mobile device, either continuously or while you are using our mobile application, to provide location-based services. If you wish to change our access or permissions, you may do so in your device’s settings.‍

Mobile Device Access – We may request access or permission to certain features from your mobile device, including your mobile device’s [bluetooth, calendar, camera, contacts, microphone, reminders, sensors, SMS messages, social media accounts, storage,] and other features. If you wish to change our access or permissions, you may do so in your device’s settings.

‍Mobile Device Data – We may collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and IP address.‍

Push Notifications – We may request to send you push notifications regarding your account or the Application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.

Purposes of data processing

Having accurate information about you permits us to provide you with a smooth, efficient, and customised experience. Specifically, we may use information collected about you via the Site to:
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• Analyse your social data to help brands search and find you for commercial work.
• Assist law enforcement.
• Compile anonymous statistical data and analysis for use internally.
• Create and manage your account.
• Email you regarding the service, or to notify you of a brief.
• Enable user-to-user communications, e.g. communicating with brands.
• Fulfil and manage purchases, orders, contracts, payments, and other transactions related to the Site.
• Generate a personal profile about you to make future visits to the Site more personalised.
• Increase the efficiency and operation of the Site.
• Monitor and analyse usage and trends to improve your experience with the Site.
• Notify you of updates to the Site.
• Offer new products, services, and/or recommendations to you.
• Perform other business activities as needed.
• Prevent fraudulent transactions, monitor against theft, and protect against criminal activity.
• Process payments and refunds.
• Request feedback and contact you about your use of the Site.
• Resolve disputes and troubleshoot problems.
• Respond to product and customer service requests.
• Send you a newsletter.
• Solicit support for the Site.

This list is designed to be comprehensive, but not exhaustive.
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Consent

Upon joining CreatorOS as a listed creator, you are granting permission for:

• Listing on CreatorOS – Your acceptance that your profile will be featured alongside others within a searchable database. This database is exclusively accessible to brands and agencies with the intent of identifying creators for potential commercial collaborations. Access is strictly confined to these entities and is not available to other creators or talent managers.
• Voluntary Departure – The right to terminate your association with the CreatorOS platform at any time by contacting us at hello@drpcrd.com. Upon such request, your data will be promptly removed from our records, except in cases where legal obligations necessitate retaining certain information for a specified duration.
• Social Media Analysis Consent – Agreement to the application of AI technology for the analysis of your social media profile and content. This includes archiving of keywords and descriptors that assist brands in selecting appropriate creators for partnerships.
• Adherence to Our Data Privacy Policy – Assurance that your personal data will be maintained securely and with confidentiality, in strict compliance with the relevant UK legal standards. This includes protocols concerning the storage, utilisation, and disclosure of your information.

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Additional Points to Note:

• Commercial Engagement – Any commercial proposal you receive is entirely optional. You reserve the full right to negotiate, accept, or decline any offers, without obligation, until a formal agreement is executed with the corresponding agency or brand.
• You have a right to removal – You may request to be removed from our network at any given time, in accordance with your preferences.
• Conduct Requirement – Utilisation of our platform is contingent upon adherence to our established professional code of conduct by all creators and talent managers.

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Data recipients 

We may share information we have collected about you in certain situations. Your information may be disclosed as follows: 

By Law or to Protect Rights

If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation.  This includes exchanging information with other entities for fraud protection and credit risk reduction.

Third-Party Service Providers‍

We may share your information with third parties that perform services for us or on our behalf, including payment processing, data analysis, email delivery, hosting services, and customer service. 

Marketing Communications‍

With your consent, or with an opportunity for you to withdraw consent, we may share your information with third parties for marketing purposes, as permitted by law.

Interactions with Other Users‍

If you interact with other users of the Site, those users may see your name, profile photo, and descriptions of your activity, including contractual information when you accept, discuss or sign contractual terms.

Online Postings‍

When you post comments, contributions or other content to the Site, your posts may be viewed by all users and may be publicly distributed outside the Site in perpetuity.

Sale or Bankruptcy‍

If we reorganise or sell all or a portion of our assets, undergo a merger, or are acquired by another entity, we may transfer your information to the successor entity.  If we go out of business or enter bankruptcy, your information would be an asset transferred or acquired by a third party.  You acknowledge that such transfers may occur and that the transferee may decline honour commitments we made in this Privacy Policy.
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We are not responsible for the actions of third parties with whom you share personal or sensitive data, and we have no authority to manage or control third-party solicitations.  If you no longer wish to receive correspondence, emails or other communications from third parties, you are responsible for contacting the third party directly.

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Retention of data

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Active Users‍

For users actively engaging with the CreatorOS platform, we retain personal data for as long as the user account remains active. Active engagement is defined as logging in, updating profiles, participating in deals, or any interaction with the platform that demonstrates ongoing use.

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Inactive Users‍

Users are considered inactive if there has been no activity on their CreatorOS account for a period exceeding 24 months. In such cases, we take the following steps to manage their data:

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• Notification of Inactivity – Inactive users will be contacted via their registered email address, informing them of their inactivity. This communication will provide users with the option to either reactivate their account or opt out and request the removal of their profile and associated data from the platform.
• Grace Period – Following the notification, a grace period of 6 months will be provided. During this time, users can choose to reactivate their account or confirm their intention to opt out and have their data removed.
• Deletion of Data – If no response is received from the user within the 6-month grace period, we will proceed to delete the user’s account and all associated personal data from our platform. This includes removal of their social profile and any other personal information we have stored.

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Exceptions to Deletion‍

Notwithstanding the above, certain data may be retained even after account deletion if required for legal, regulatory, or operational purposes. This includes, but is not limited to:

• Transaction data: Records of transactions may need to be retained for financial reporting, auditing, and compliance with tax laws.
• Legal obligations: Any data that we are legally required to maintain will be retained for the period specified by applicable laws.

Use of cookies and tracking technology

Cookies and Web Beacons

We may use cookies, web beacons, tracking pixels, and other tracking technologies on the Site to help customise the Site and improve your experience. For more information on how we use cookies, please refer to our Cookie Policy posted on the Site, which is incorporated into this Privacy Policy. By using the Site, you agree to be bound by our Cookie Policy.

Website Analytics

We may also partner with selected third-party vendors, such as Google Analytics to allow tracking technologies and re-marketing services on the Site  through the use of first party cookies and third-party cookies, to, among other things, analyse and track users’ use of the Site, determine the popularity of certain content and better understand online activity. By accessing the Site, you consent to the collection and use of your information by these third-party vendors. You are encouraged to review their privacy policy and contact them directly for responses to your questions. We do not transfer personal information to these third-party vendors. 

You should be aware that getting a new computer, installing a new browser, upgrading an existing browser, or erasing or otherwise altering your browser’s cookies files may also clear certain opt-out cookies, plug-ins, or settings.

Third party websites

The Site may contain links to third-party websites and applications of interest, including external services, that are not affiliated with us. Once you have used these links to leave the Site, any information you provide to these third parties is not covered by this Privacy Policy, and we cannot guarantee the safety and privacy of your information. Before visiting and providing any information to any third-party websites, you should inform yourself of the privacy policies and practices (if any) of the third party responsible for that website, and should take those steps necessary to, in your discretion, protect the privacy of your information. We are not responsible for the content or privacy and security practices and policies of any third parties, including other sites, services or applications that may be linked to or from the Site.

Data security

We use administrative, technical, and physical security measures to help protect your personal information.  While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse.  Any information disclosed online is vulnerable to interception and misuse by unauthorised parties. Therefore, we cannot guarantee complete security if you provide personal information.

Policy for children‍

We do not knowingly solicit information from or market to children under the age of 13. If you become aware of any data we have collected from children under age 13, please contact us using the contact information provided below.

Controls for Do-not-track features 

Most web browsers and some mobile operating systems [and our mobile applications] include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected.  No uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.  If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy. Most web browsers and some mobile operating systems [and our mobile applications] include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. If you set the DNT signal on your browser, we will respond to such DNT browser signals.

Policy Updates

Our Privacy and Data Policy is periodically reviewed and updated to reflect the latest regulatory requirements, technological advancements, and operational changes.

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Changes to This Policy

We reserve the right to amend this policy at any time. Changes may be necessitated by:

• New legal requirements.
• Changes in our business practices.
• Technological developments.
• Feedback from our users and stakeholders.

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When we update our policy, the changes will be effective as of the 'Last Updated' date indicated at the top of the policy document. We encourage you to review our Privacy and Data Policy periodically to stay informed about how we are protecting your information.

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Notification of Changes

In certain circumstances, we may decide to notify you of significant changes to our Privacy and Data Policy. This notification may be provided through various channels, including, but not limited to, email notifications, posting on our website, or through our service directly.

However, please note that it is your responsibility to review the updated policy. We encourage you to periodically review this policy for the latest information on our privacy practices.

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Your Continued Use of CreatorOS

By continuing to use CreatorOS after these changes are posted, you agree to the revised policy. If you do not agree with the modifications, you should discontinue your use ASAP.

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Data protection officer

CreatorOS is committed to protecting the privacy and security of your personal data. To ensure this commitment is met, we have appointed a Data Protection Officer (DPO) responsible for overseeing our data protection strategy and its implementation to comply with the GDPR requirements.

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Name of the Data Protection Officer – Tim Mitchell
Position – CEO / Founder
Contact Details

• Email: data@drpcrd.com
• Address: 4-5 King Square, Bridgwater, Somerset, TA6 3YF

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The DPO is available for any questions or concerns you may have regarding our processing of your personal data and your rights under the GDPR. Whether you seek more information on the data we collect, our processing activities, or wish to exercise your rights, please do not hesitate to reach out to our DPO using the contact details provided.

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For further assistance, you may also contact our DPO if you have any inquiries related to data protection laws or wish to lodge a complaint. Our DPO is dedicated to ensuring your data protection rights are respected and upheld at CreatorOS.