What Information Do We Collect?
- Non-sensitive/personal Information
As a visitor to our Sites, you can engage in many activities without providing any personal information. However, we do collect and aggregate information pertaining to the web pages visited and general usage patterns through the use of "cookies" and “web beacons”, as described below. Such information is not linked to any sensitive information. The non-sensitive information we collect helps us identify the most popular areas of our Sites, and determines the effectiveness of our promotional activities.
When you download and otherwise use our Application(s), there is some information that is provided automatically by your use of the Application(s), which may include any errors encountered, functions/features used, device type, navigation flow, operating system, usage time for each application screen. Such information is technical information, not linked to any sensitive/personal information and is collected to help us better understand how users engage our Application(s), improve user experience, adapt or develop new features according to users' preferences and determines the effectiveness of our Application(s). Our Application(s) may use Google Analytics which is a web analytics service provided by Google.
- Sensitive/Personal Information
You may have the opportunity to participate in any of the following activities at some Creative Sites , Creative social media sites or Application(s), including but not limited to: account registration, product registration, special offers, promotions, participation in surveys/polls/contests/referral programs, software downloads, online shopping, order fulfillment, newsletter subscription and/or forum participation. These activities or use of our Application(s) may require the collection of your personal information, including but not limited to: your name, postal address, e-mail address, telephone number, , biometric data (which may include head captures (inclusive of face and ears)), credit card details (only for payment obligations to complete your order(s), where so required), and/or information about your interests in the use of Creative's various products, programs and services. Such data collected may be combined with the information you had previously provided (for example, in the event that you had previously registered the ownership of your Creative products). If you opt to log in to your Creative account through available third party platforms, you may need to provide your login credentials or such other information for such platforms. If you opt to make payment through available third party payment gateways, you may need to provide your login credentials or such other information for such payment gateways. Creative is committed to safeguarding your personal information and will only use such information to better understand your needs and to provide you with better service.
To prevent unauthorized access to our database, and to ensure the appropriate use of information, we have put in place electronic and managerial procedures to safeguard sensitive information. We use Secure Sockets Layer (SSL) encryption on web pages where personal information is required.
How We May Use The Information
Creative will not sell, rent, loan or lease your personal information to others unless we have your express permission or are otherwise required by law or related regulations to do so. Creative will not use or share the personally identifiable information that you provide to us online for purposes not consented to by you (if you have given express or deemed consent) or in ways unrelated to those described herein, without offering you a choice to opt out. If you have any problems exercising your choice to opt out, please contact us at http://www.creative.com/contactus or at the contact details provided below. We may use your personal information for purposes consented to by you (if you have given express or deemed consent), to process your orders, to provide you with customer support, to communicate with you, to enable us to keep you updated on our latest products, offerings, promotions, software updates, improve our targeted advertising, content and services and to generally improve our communications and personalize your user experience. (Please note that in the event that you decide to opt out, we may be unable to provide you with certain services and support etc. as the case may be.) We may also use your personal information for our internal purposes - which may include but are not limited to data research, analytics or general audit purposes etc.
Cookies and Web Beacons
Cookies are small text files that a web server can store on a user's device/machines. Cookies allow a web site to store information on a user's machine and retrieve it later. Cookies collect information like IP addresses, operating systems and browser software, but they do not collect any personal information. Cookies enable us to customize your experience and provide greater convenience at our Sites. You have the ability to accept or decline cookies by modifying the settings on your browser; you may wish to refer to the instructions for your file management software to locate the file or directory that stores cookies, for better management of your cookie settings.
A web beacon is a clear or transparent picture file used to keep track of users' navigation through a web site or various web sites. Web beacons are normally used by web sites that use third party traffic monitoring and tracking services. In our case we use Google Analytics, amongst others. Our Sites, whether directly or indirectly, use web beacons in order to enhance the functionalities of our Sites and to gather information on traffic data, analytics etc. and to better understand our users and their use of our Sites and to enable us to purposefully process such content.
Third Party Vendors/ Marketing Agents
We engage third party vendors/marketing agents (including Google LLC ("Google") for online advertising, marketing and/or remarketing service providers for purposes of remarketing, interest-based advertising, age, gender, demographic or location targeting, etc. to better target and serve more relevant ads to our intended audience based on available data. Third-party vendors/marketing agents, including Google, may show our advertisements on websites across the Internet. For more information as to how Google uses data when you use our Sites/Applications please refer to: www.google.com/policies/privacy/partners/ (as may be amended by Google from time to time).
For Sites, as part of our advertising and marketing activities, data analysis, and other activities, we have implemented or may implement Google's Display Advertising features such as Remarketing, Google Display Network Impression Reporting, DoubleClick Campaign Manager Integration or Google Analytics Demographics and Interest Reporting. You may opt-out of Google Analytics for Display Advertising and customize Google Display Network ads at: https://www.google.com/settings/ads We and our third-party vendors/marketing agents (including but not limited to Google) use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on a user's past visits to our website. (Please refer to the section on Web Analytics/ Statistics below for more information.)
Personally Identifiable Information
We do not allow or use or associate personally identifiable information with remarketing lists, cookies, data feeds, or other anonymous identifiers nor associate targeting information (such as demographics or location, with any personally identifiable information collected from the ad or its landing page, or share any personally identifiable information with Google through our remarketing tag or any product data feeds which might be associated with our ads, or send Google precise location information) without first obtaining your consent.
When we or our third party vendor/marketing agents create a remarketing list, we do not use any sensitive information about our customers or visitors to our Sites, whether directly collected or associated with a visitor, based on the visitor's profile or behavior on our Sites or apps.
- Restrictions on list creation may apply to both individual web pages and entire web sites or apps
- Ad content may not imply knowledge of personally identifiable or sensitive information
As an advertiser using interest-based advertising, as far as we are aware, we do not:
- Use interest-based advertising or implement the remarketing tag on any Site or app directed at children under 13 or which stores or solicits age information from people under the age of 13
- Create a remarketing list or create ad content that specifically seeks to reach people in ways that are prohibited
- Create ad content which implies knowledge of personally identifiable or sensitive information about the Site or app visitor, even when the remarketing list has been created without using such information
- Include products which fall into sensitive categories, such as pharmaceutical products, in any data feeds
For the avoidance of doubt, ads that are already prohibited by Google's AdWords content policies, are not used in our campaigns.
Web Analytics/ Statistics
Our Sites use a web analytics service provided by Google called Google Analytics. Google Analytics uses "cookies" (as described above), as well as data from our advertising programs including interest-based and demographics-based advertising, to help better analyse how our users use our Sites. The information stored in the cookie about your use of the Sites (including your IP address) will be transmitted to and stored by Google on servers in the United States or anywhere else as may be determined by Google. Google will use this information for the purpose of evaluating your use of our Sites, compiling reports on web site activity and providing other services relating to activities on our Sites and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google. By entering into and using this web site, you consent to the processing of data about you by Creative and Google in the manner and for the purposes set out hereinabove.
You may access Google Analytics' currently available opt-out options at https://tools.google.com/dlpage/gaoptout/
Social Media Sites
We may from time to time partner or enter into arrangements with another party or other parties to provide specific benefits and/or services to our customers including sending more streamlined and targeted promotions or ads etc. to enhance your overall user experience. We will provide to such partners the information that we believe is reasonably necessary for them to provide such benefits and/or services to you.
Surveys, Contests or Referral Programs
We may from time to time, provide you the opportunity to participate in contests, surveys or referral programs on our Site. If you participate, we will request certain personally identifiable information from you. Participation in these surveys, contests or referral programs is completely voluntary and you have a choice whether or not to disclose this information. The requested information may include contact information (such as name, e-mail address and shipping address) and demographic/geographic information.
We use this information to notify contest winners, award prizes, record store credits, monitor Site traffic or personalize the Site (in the case of anonymous information collected in surveys), and/or send participants email newsletters (as applicable).
We may use third-party service providers to conduct these surveys and/or contests and/or referral programs; if so, that company will be generally prohibited from using our users' personally identifiable information for any other purpose. We will not share the personally identifiable information you provide through a contest, survey or referral program with other third parties unless we give you prior notice and have your consent.
If you choose to use our referral service to tell a friend about our Sites, we will ask you for your friend's name and email address. We will automatically send your friend a one-time email inviting him or her to visit the Site. We will store this information for the sole purpose of sending this one-time email and tracking the success of our referral program.
Retention of Personal Information
We keep your information for no longer than necessary for the purpose(s) for which it is processed. The duration for which we retain your information depends on the purpose(s) for which we collect and use it and/or as required to comply with any applicable laws or regulations.
Our Global Operations
In summary, in order for us to serve you better, we may use your personal information for the following purposes, including but not limited to:
- The Creative Store
To process your order, we will ask you for your personal information such as: name, e-mail address, delivery address, telephone number and credit card information. However, we do not retain your credit card information. We may also contact you, (usually via email or phone) on matters including but not limited to matters relating to your order, order confirmation, shipping and tracking details, shipment delay, change in stock availability, or identity verification.
- Online Registration
You can register your Creative product using an online registration application or via creative.com/register. By registering your Creative product in a timely manner, you will be eligible to receive product support. The level of support available is dependent on the type of Creative product purchased. For more details, visit creative.com/support. Personal information collected from online registration will be used for customer support and to improve our products and services. Creative's internal reports will not contain personal individual data. Where required, we may from time to time contact you on matters relating to your registered product(s). With your permission, we will send you information about new products or services from Creative.
- Surveys/Polls/Contests/Promotions/Referral Programs
From time to time, our Sites may request information from you via surveys/ polls/ contests/ promotions/referral programs and other marketing activities. Participation in these activities is completely voluntary and you have a choice whether or not to disclose any information. Information requested may include contact information; such as your name and your shipping address to notify the winner(s) and demographic information; such as your age, for eligibility purposes. Survey information will be used for the purposes of monitoring or improving the use and satisfaction of our Sites, Products and/or services.
Creative may occasionally send you newsletters, marketing materials or product information via e-mail. Your e-mail address will not be shared with unaffiliated third parties without your consent. Where applicable, we will follow all local requirements, such as having you opt-in, to ensure we do not send you unsolicited e-mails. You have the right to opt-out from receiving such electronic communications from us at any time.
* Overseas transfers
Creative may process personal information on servers in various countries around the world. As a result, we may process your personal information on a server located outside the country where you live. By using our Site and providing us with your personal data, you consent to such transfer of your personal data for any of the purposes stated herein. We use commercially reasonable efforts to ensure that any such personal data transferred to an authorized third party vendor will be subject to appropriate security protection.
Creative will never knowingly collect sensitive information from children under 13 for marketing purposes. If we learn that personal information has been submitted to us by children under 13, we will delete such information from our files. Minors under the age of 13 should ask their parents or guardians for express permission before submitting any personal information to anyone over the Internet.
Third Party Web Sites
You are entitled to ask for a copy of the personal information we hold about you at any time (for which we may charge a small administration fee). We will correct any inaccuracies in your personal information at your request.
Data Privacy (Legal Department)
Creative Technology Ltd
31, International Business Park
#03-01, Lobby C, Creative Resource
We reserve all rights to disclose your personally identifiable information as may be required by law, legal regulations, court orders or legal process and when we believe that disclosure is necessary in the circumstance to protect our rights and/or for the said legal compliance. We shall not be liable under any circumstances including for any loss of data, and/or loss or any inconvenience whether or not caused by viruses and/or other malicious code originating or contracted from our Sites/Application(s) or its use thereof or otherwise. It is solely your responsibility to ensure that your computer/device/table runs on up-to-date anti-virus software at all times and to check regularly for viruses and/or other malicious code. Creative will use reasonable endeavours to ensure that this website does not contain or spread any viruses or other malicious code. SUBJECT TO APPLICABLE LAW, IN NO EVENT SHALL CREATIVE, ITS AFFILIATES, SUBSIDIARIES, INCLUDING ITS DIRECTORS, REPRESENTATIVES, EMPLOYEES OR AGENTS, BE LIABLE WHATSOEVER FOR ANY CLAIM, COST OR DAMAGES INCLUDING WITHOUT LIMITATION ANY CONSEQUENTIAL, INCIDENTAL, INDIRECT, PUNITIVE OR SPECIAL DAMAGES OF ANY NATURE WHATSOEVER, INCLUDING WITHOUT LIMITATION ANY DAMAGES ARISING OUT OF OR IN CONNECTION WITH ANY MALFUNCTIONS, DELAYS, LOSS OF DATA, LOSS OF PROFIT, INTERRUPTION OF SERVICE OR LOSS OF BUSINESS OR ANTICIPATORY PROFITS, ARISING OUT OF YOUR USE OF OUR SITES/APPLICATION(S), INCLUDING PARTICIPATION IN ANY SURVEYS, CONTESTS OR REFERRAL PROGRAMS EVEN IF CREATIVE HAS BEEN APPRISED OF THE LIKELIHOOD OF SUCH DAMAGES OCCURRING.
[Last revised on 8 August 2019]