Who we are

Our website address is: https://www.createnu.com.

1. Overview.

CreateNU, Inc. (“CreateNU” or “we,” “us” or “our”) knows that You, our user (“You”) care about how information regarding You is used and shared, and we appreciate Your trust that we will do so carefully and sensibly when You share information via www.createnu.com including all extensions of such URLs, subdomains and mobile versions thereof (the “Websites”).

If You have questions or concerns regarding this privacy policy (the “Privacy Policy”), please contact us via the following link www.createnu/contact.

2. Information We Collect.

We collect information about You and Your use of the Websites. We may collect personally identifiable information such as Your name, address, age, picture, phone number, email address, demographic and biographical information as well as other information that does not personally identify You. We use this information to share Your profile information with other users of the Websites and to do internal research on our users’ demographics, interests and behavior to better understand and serve You and our community. The following sections describe how we collect information:

(a) Registration.

When You register or subscribe to any of the services and features available on our Websites (the “Services”), You provide information to us and we collect a wide variety of information about You. Such information includes personally identifiable information such as Your name, address, age, picture, email address, phone number, demographic and biographical information and other profile information.

(b) Log Files.

Like many web sites, we automatically gather certain information about our Websites traffic and store it in log files. This information includes Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information, which does not identify individual users, to analyze trends, to administer the Websites, to track users’ movements around the Websites and to gather demographic information about our user base.

We may use a third-party tracking service that uses log files and cookies, as discussed below, to track non-personally identifiable information about visitors to the Websites in the aggregate. This service captures usage and volume statistics to improve our Services to our users.

(c) Cookies.

We use cookies to keep track of some types of information while You are visiting our Websites or using our Services. A cookie is a small text file that is stored on a user’s computer for record-keeping purposes. We may also use cookies to automatically collect information about Your online activity on our Websites, for example, which web pages You browsed, which links You clicked on, which profiles You visited, or which searches You conducted on our Websites. While most browsers automatically accept cookies, You can usually modify Your browser setting to decline cookies. If You choose to decline cookies, please note that this may affect Your access to some features of our Websites and may make it more difficult for You to sign in. If You choose to decline our cookies, You assume all responsibility for any resulting loss of functionality or access. This Privacy Policy covers the use of cookies by the Websites only and does not cover the use of cookies by any advertisers. Some of our business partners, including advertisers, use cookies on our Websites. We have no access to or control over such cookies. Please refer to Section 7(b) below for further information regarding third-party advertisers.

(d) Web Beacons (Clear GIFs, Pixel Tags).

We employ and our third party advertising partner may employ a software technology called web beacons, also referred to as clear GIFs or pixel tags, that help manage content on the Websites by tracking what content is effective. Web beacons are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of users in order to further personalize our Websites for our users and to collect a limited set of information about our users. In contrast to cookies, which are stored on a user’s computer hard drive, web beacons are embedded invisibly on web pages and are about the size of the period at the end of this sentence. We also may include web beacons in advertisements or promotional or other e-mail messages or to determine whether messages have been opened or acted upon. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. If You would like to opt-out of such emails, please refer to Section 8 below for further information regarding opting out. We do not tie the information gathered by web beacons to our customers’ personally identifiable information. Please refer to Section 7(b) below for further information regarding third-party advertisers.

(e) Purchase Information.

To process purchases, we may require personally identifiable information such as Your name, address, phone number, email address and credit card information. Such information is used primarily to process Your order or as otherwise described herein.

(f) Surveys or Contests.

We may provide You with the opportunity to participate in contests or surveys on our Websites. If You participate, we will request certain personally identifiable information from You. The requested information typically includes contact information (such as name and shipping address) and demographic information. We use this information to notify contest winners and award prizes, to monitor Websites traffic, or to personalize the Websites (in the case of anonymous information collected in surveys).

(g) Information Regarding Your Friends.

We encourage You to refer a friend to our Websites by sending us a friend’s name and email address. We will collect and keep any such information about a friend. We will invite that person with a one-time e-mail with Your name, and a one-time reminder. You agree to use this feature only for friends who You believe are interested in our Services, and You agree not to abuse this feature.

(h) Public Forums.

We may make discussion boards, forums and chat rooms available to You. You participate in these areas with the acknowledgement that any information You disclose becomes public information, including any personally identifiable information. Please review the guidelines for any of these areas when posting comments for terms and conditions and other specific information.

3. How We Use Your Information.

In general, we may use information that we collect about You to: (i) share information with other users of the Websites; (ii) deliver the products and Services that You have requested; (iii) conduct research and analysis about Your activities on our Websites, including Your use of, or interest in, our products, Services, or content, or those offered by third parties; (iv) provide customer support and manage Your account; (v) provide You with information via e-mail, postal mail, telephone and/or mobile devices about products or Services offered by us or third parties; (vi) monitor surveys, discussion boards, forums and/or chat rooms provided to You on our Websites from us or a third party; (vii) verify Your eligibility and deliver prizes in connection with contests; (viii) develop and provide content and advertising customized to Your interests from us or third parties; (ix) contact Your friends for whom You have provided us a name and an email address; (x) enforce this Privacy Policy, the Terms of Use and any other applicable terms and conditions; (xi) manage our business; and (xii) perform functions and activities as otherwise described to You at the time of collection of information.

4. Correspondence.

We will occasionally send You information on products, Services, special deals, and promotions. We may also use Your name and email address to send newsletters to You. Out of respect for Your privacy, we present the option not to receive these types of communications. Please refer to Section 8 below for further information regarding opting out.

We will send You strictly Services-related announcements on rare occasions when it is necessary to do so. For instance, if our Services is temporarily suspended for maintenance, we may send You an email. Generally, You may not opt-out of these communications, which are not promotional in nature. If You do not wish to receive such service-related communications, You have the option to deactivate Your account.

5. Customer Service.

We will communicate with You in response to Your inquiries, to provide the Services You request, and to manage Your account. We will communicate with You by email or telephone, in accordance with Your stated preferences.

6. Profile.

We store information that we collect through cookies, log files, web beacons, and/or third party sources to create a “profile” of Your preferences. We may tie Your personally identifiable information, and Your purchasing history, to information in the profile, in order to provide tailored promotions and marketing offers and to improve the content of the Websites for You.

We may purchase marketing data from third parties and add it to our existing user database, to better target our advertising and to provide pertinent offers in which we think You would be interested. To enrich our profiles of individual customers, we may tie the marketing data from third parties to the personally identifiable information You have provided to us. We may share Your profile with third parties for promotional purposes, but will not share such profiles in any way that would personally identify You.

7. Conditions Under Which We Share Information.

(a) Aggregate Information (Non-Personally Identifiable).

We share aggregated demographic information about our user base with our partners and advertisers. We may combine non-personal information we collect with additional non-personal information collected from other sources. We also may share aggregated information with third parties, including advisors, advertisers and investors, for the purpose of conducting general business analysis. This information does not personally identify individual users and may be used to develop the Websites’ content and Services and to target content and advertising, such that we may provide content and Services that You and other users may find of interest. We do not link aggregated user data with personally identifiable information.

(b) Third Party Advertisers.

The advertisements appearing on the Websites are delivered to users by our advertising partners. We share information about the Websites’ traffic and users with our advertising partners for the purpose of targeting our advertisements on the Websites.

Our advertising partners may use cookies and web beacons on the Websites, which allow them to recognize a user’s cookie when a user visits the Websites and to measure advertising effectiveness. The information that our advertising partners collect and share through this technology is not personally identifiable.

For more information about our third-party advertisers, please contact us via the following link: www.createnu.com/contact.

(c) Personally Identifiable Information.

Except as discussed below, we do not share personally identifiable information with third parties:

(i) Other Users

We may share Your information, including personally identifiable information, with other users or visitors of the Websites. For example, we may display Your name, email address, biographical info and picture as part of Your public profile on the Websites, which other users could view.

(ii) Service Providers

We may share Your personal information with our authorized service providers that may be associated with us to perform functions on our behalf. These functions may include processing credit card payments, providing customer service, performing business and marketing analysis, supporting and improving the functionality of our Websites or the Services, and providing or maintaining contests, surveys and other features offered through our Websites. These service providers may have access to information about You, including personally identifiable information, that they need to perform their functions, but they are not permitted to use such information for any other purpose other than the purpose we authorize, and they cannot disclose or share such information for any other purposes.

(iii) Business Partners

We may partner with third parties to offer You surveys, contests, products and Services on our Websites or through our Services. When You participate in such surveys or contests, or purchase such products and Services, You authorize us to share information about You, including personally identifiable information, with such third parties. If You have any questions or concerns regarding how such third parties use Your information, please consult the applicable third party’s privacy policy. You agree that we will not responsible or liable for any loss or damage incurred in connection with our partnership with such third parties, their activities on our Websites, and the sharing of Your information with such third parties.

(iv) Legal

We reserve the right to, and You acknowledge and agree that we may, disclose Your personally identifiable information as required by law and when we believe, in our sole discretion, that disclosure is reasonable to protect our or a third party’s rights; to comply with a judicial proceeding, court order, or legal process served on us or the Websites; to assist in investigation, prosecution, prevention, or taking other action regarding illegal activity, fraud or other wrongdoing, or suspected illegal activity, fraud or other wrongdoing; to protect a user’s or a third party’s health or safety, such as when harm or violence against any person (including You) is threatened; or in connection with an actual or proposed corporate transaction, such as a merger, acquisition, consolidation, asset sale, divestiture, or insolvency proceeding involving all or part of our business or assets.

(v) Abuse Victims

Notwithstanding any other provision of this Privacy Policy or our Registration Agreement, we reserve the right, but have no obligation, to disclose any of Your information, including personally identifiable information, if in our sole discretion, we suspect or have reason to suspect, that the information involves a victim of physical, psychological or other abuse, including without limitation elder abuse, child abuse, spousal abuse, neglect, or domestic violence. If we deem appropriate, in our sole discretion, that some information should be disclosed to authorities, we reserve the right to do so. You hereby acknowledge and agree that we have the right to make such disclosure in our sole discretion.

8. Choice/Opt-out

If You no longer wish to receive our newsletter and promotional communications, You may opt-out of receiving them by following the instructions included in each newsletter or communication or by emailing us at membership@createnu.com.

If You do not wish for Your personally identifiable information to be used as contemplated by this Privacy Policy, then you should not provide it to us. Our Services may depend on Your provision of such information, so You may not be able to participate in our Services if You choose not to disclose certain information.

9. Links to Other Websites

The Websites may contain links to other sites that are not owned or controlled by CreateNU. Please be aware that we are not responsible for the privacy policies or the content of such other sites or of any third-party advertisers.

We encourage You to be aware when You leave the Websites and to read the privacy policies of each and every web site that collects personally identifiable information.

This Privacy Policy applies only to information collected by the Websites.

10. Changes to Personally Identifiable Information

If Your personally identifiable information changes, You may correct or update it by making the change on Your member information page on the Websites.

11. Age Restrictions

We do not knowingly collect personal information from children under the age of 18, and in compliance with the Children’s Online Privacy Protection Act, any information we may receive from users we know to be under the age of 18 will be purged from our database.

12. Outside the United States

Any information we collect may be transferred to, stored and processed in servers located in the United States and other countries around the world. This Privacy Policy is intended to cover collection of information on our Websites from residents of the United States. If You are visiting our Websites from outside the United States, You hereby acknowledge that Your information may be transferred to, stored and processed in the United States or in other countries around the world where our servers may be located. Other countries may have more comprehensive data protection and privacy laws than those of the United States. By using the Websites and our Services, You understand that Your information may be transferred to our facilities and those third parties with whom we share it as described in this Privacy Policy.

13. Security

The security of Your personal information is important to us. When You provide us sensitive information (such as a credit card number), we encrypt that information using secure socket layer technology (SSL). We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. You acknowledge, however, that no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect Your personal information, we do not guarantee its absolute security.

If You have any questions about security on our Websites, You may email us at membership@createnu.com.

14. Changes in this Privacy Policy

We reserve the right to modify this Privacy Policy at any time, so please review it frequently. If we make changes that materially affect our uses or disclosures of personally identifiable information that we have previously collected, we will notify You by email or by means of a notice on our Websites homepages.

If we decide to modify our Privacy Policy, we will post the changes to this Privacy Policy on our Websites’ homepages and on such other pages we deem appropriate so that You are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.

Your continued use of any portion of our Websites following posting of the updated Privacy Policy will constitute Your acceptance of the changes.

15. Acceptance of Privacy Policy

Your use of our Websites or our Services, including any dispute concerning privacy, is subject to this Privacy Policy and the applicable Terms of Use. BY USING OUR WEBSITE OR SERVICES, YOU ACCEPT THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY AND THE APPLICABLE TERMS OF USE.

Effective Date: 03/01/2020