At ConCreates, Inc. (“ConCreates” together with “we,” “us,” and “our”), we value transparency and we’re committed to being upfront about our privacy practices, including how we treat your personal information. This policy explains our privacy practices for concreates.com (which we’ll refer to as the “Site”), our social media accounts, marketing services and our other services provided by ConCreates. We’ll refer to the Site, social media accounts, marketing services, and our other services as the “Services” or “Site.” This policy does not apply to the practices of third parties who may also collect or receive data in connection with your use of the Services.

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1. Our Privacy Policy

2. Information Collected or Received

3. Messages from ConCreates

4. Information Uses, Sharing, & Disclosure

5. Security

6. Retention

7. Your Rights & Choices

8. Privacy Policy Changes

9. Contact

 

1. Our Privacy Policy

We collect general analytics on our website. We may process your personal information to run our business. By going to our website you are accepting our Terms of Use and in some jurisdictions, by acknowledging this policy), you confirm that you have read and understand this policy. We are not responsible for the content or the privacy policies or practices of any of our third-party websites and apps.

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Our Site is not directed toward children under 13 and we will not knowingly collect information for any child under the age of 13. If you are the parent of a child under the age of 13 and have a concern regarding your child’s information on our site, please contact us at info@concreates.com.

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We do not knowingly “sell,” as that term is defined under applicable law, including the California Consumer Privacy Act, the personal information of ConCreates users.

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By using the Site, you acknowledge that ConCreates will use your general information in the United States and any other country where ConCreates operates. Please be aware that the privacy laws and standards in certain countries, including the rights of authorities to access your personal information, may differ from those that apply in the country in which you reside.

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2. Information Collected or Received

In the course of providing our Services, we may collect or receive your personal information in a few different ways. We obtain the categories of personal information listed below from the following sources: directly from you, for example, from forms you complete or during registration, or directly emailing us at info@concreates.com; indirectly from you based on your activity and interaction with our Services, or from the device or browser you use to access the Services; from our vendors and suppliers that help provide ConCreates services you may interact with (such as, for example, for payments and customer support), and from our third party advertising and marketing partners. Often, you choose what information to provide, but sometimes we require certain information to provide you the Services. ConCreates uses the personal information it receives and collects in accordance with the purposes described in this policy.

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Automated Information

ConCreates automatically receives and records information from your browser or your mobile device when you visit the Site or use the Services, such as your IP address or unique device identifier, cookies, and data about which pages you visit and how you interact with those pages in order to allow us to operate and provide the Services. This information is stored in log files and is collected automatically. We may combine this information from your browser or your mobile device with other information that we or our advertising or marketing partners collect about you, including across devices. This information is used to prevent fraud and to keep the Services secure, to analyze and understand how the Services work for clients and visitors, and to provide advertising, including across your devices, and a more personalized experience for clients and visitors.

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We also automatically collect device-specific information when you access or use our Services. This information can include information such as the hardware model, operating system information and debugging information, browser information, IP address, and device identifiers.

 

Data from Third-Party Vendors and Suppliers

We also receive information from our vendors and suppliers about you. This information can include customer service interactions and payments information.

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Data from Advertising and Marketing Partners

As described below, ConCreates receives information from our advertising and marketing partners about you. This information can include attribution information via cookies and UTM tags in URLs to determine where a visit to ConCreates comes from, responses to marketing emails and advertisements, responses to offers, and audience information from partners who you have given consent to share that information with us. A cookie is a string of information that a website stores on a visitor computer, and that the visitor browser provides to the website each time the visitor returns. ConCreates uses cookies to help ConCreates identify and track visitors, their usage of the ConCreates Websites, and their website access preferences. ConCreates visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using ConCreates Websites, with the drawback that certain features of ConCreates Websites may not function properly without the aid of cookies.

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Location Information

We collect information about your use of the Services for advertising, for analytics, to serve content, and to protect the Services. This can include your IP address, browser information (including referrers), device information (such as iOS IDFA, IDFV for limited non-advertising purposes, Android AAID, and, when enabled by you, location information provided by your device).

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We obtain location information you provide in your IP address. With your consent, we may also determine location by using other information from your device, such as precise location information from GPS or information about wireless networks or cell towers near your mobile device. We use and store information about your location to provide features and to improve and customize the Services, for example, for ConCreates’ internal analytics and performance monitoring; localization, regional requirements, and policies for the Services. If you have consented to share your precise device location details but would no longer like to continue sharing that information with us, you may revoke your consent to the sharing of that information by emailing us at info@concreates.com. Certain non-precise location services, such as for security and localized policies based on your IP address or submitted address, are critical for the Site to function.

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Analytics Information

We use data analytics software to ensure Site functionality and to improve the Services. This software records information such as how often you use the Site, what happens within the Site, aggregated usage, performance data, Site errors and debugging information. We do not link the information we store within the analytics software to any personally identifiable information that you submit within the mobile application.

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3. Messages from ConCreates​

On occasion, ConCreates will need to contact you. Primarily, these messages are delivered by email or by push notifications for a variety of reasons, including marketing, transactions, and service update purposes. If you no longer wish to receive push notifications, you can disable them at device level. You can opt out of receiving marketing communications via email or Messages by following the unsubscribe link in any marketing email you receive. To ensure you properly receive notifications, we will need to collect certain information about your device, such as operating system and user identification information. ConCreates may also contact you by telephone to provide member support or for transaction-related purposes if you request that we call you. Additionally, and with your consent where required by applicable law, ConCreates may send you an SMS (or similar) message, or reach out to you by telephone, in order to provide you with customer support, for research or feedback, or to provide you with information about products and features that you may find of interest.

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Some messages from ConCreates are service-related and necessary for ConCreates clients. You understand and agree that ConCreates can send you non-marketing emails, messages, such as those related to transactions, security, or product changes. Examples of service-related messages include an email address confirmation/welcome email, modification of key features or functions, relaying Messages and correspondence with ConCreates’ Support team (including by chat interface or the other methods of communication as described above).

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When you subscribe to a newsletter or provide us with your email address or phone number you receive notice of and agree (in some jurisdictions and situations, by an additional unambiguous consent) to receive marketing emails and messages from us. You can unsubscribe at any time from marketing emails or messages through the opt-out link included in marketing emails or messages. Clients can also control which marketing emails or messages they receive from ConCreates by unsubscribing or emailing us at info@concreates.com.

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4. Information Uses, Sharing, and Disclosure

We respect your privacy. ConCreates will not disclose your name, email address, or other personal information to third parties without your consent, except as specified in this policy. You can control your privacy by emailing us at info@concreates.com. Please note that some changes to your privacy settings may take a few days to take effect.

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Legal Bases

When you access or use the Services, we collect, use, share, and otherwise process your personal information for the purposes described in this policy. We rely on a number of legal bases to use your information in these ways. These legal bases include where:

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• Necessary to perform the contractual obligations in our Terms of Use and in order to provide the Services to you;

• You have consented to the processing, which you can revoke at any time;

• Necessary to comply with a legal obligation, a court order, or to exercise or defend any impending or asserted legal claims;

• Necessary for the purposes of our or a third party’s legitimate interests, such as those of visitors, clients, or partners (described in more detail below);

• Necessary in the public interest, such as to prevent crime; and

• Occasionally necessary to protect your vital interests or those of others (in rare cases where we may need to share information to prevent loss of life or personal injury).

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We principally rely on consent (which can be withdrawn at anytime) (i) to send marketing messages, (ii) for third-party data sharing related to advertising, and, to the extent applicable, (iii) for the use of location data for advertising purposes.

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Where we process your information on the basis of legitimate interests, we do so as follows:

Providing and Improving our Services: We use your information to improve and customize our Services, including sharing your information for such purposes, and we do so as it is necessary to pursue our legitimate interests of improving our Services for our users. This is also necessary to enable us to pursue our legitimate interests in understanding how our Services are being used, and to explore and unlock ways to develop and grow our business. It is also necessary to allow us to pursue our legitimate interests in improving our Services, efficiency, interest in Services for users, and obtaining insights into usage patterns of our Services.

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Providing Marketing Communications

We rely on our legitimate interest to send you marketing messages (where permitted independent of consent) and for ConCreates’ advertising programs (including ConCreates’ on-site advertising and marketing).

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Keeping our Services Safe and Secure: We use your information for safety and security purposes, which can include sharing your information for such purposes, and we do so because it is necessary to pursue our legitimate interests or those of a third party in ensuring the security of our Services, preventing harm to individuals or property, or crime, enforcing or defending legal rights, or preventing damage to ConCreates’ systems, or those of our users or our partners. This includes enhancing protection of our community against spam, harassment, intellectual property infringement, crime, and security risks of all kinds. We use your information to provide and improve the Services, for billing and payments, for identification and authentication, and for general research and aggregate reporting.

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Affiliated Businesses

ConCreates is affiliated with a variety of businesses and works closely with them for a variety of purposes, including assisting us to perform and improve the Services. These businesses may sell items or services to you through the Services or, with your consent, offer promotions to you. ConCreates also provides services or sells products jointly with affiliated businesses, including providing you with the opportunity to sign up with such partners and allow them to more effectively market to you. When an affiliated business assists in facilitating your transaction, we may need to share information related to the transaction with that affiliated business in order to facilitate your transaction, and this forms part of the Services we provide in accordance with our Terms of Use. We rely on consent (which can be withdrawn at any time) to send marketing messages and for third-party sharing relating to advertising. As part of this, we may work with advertising partners such as Facebook or Google, and we may use analytics aggregated from usage information including, for example, search keywords, favorites, browsing history, and purchase history.

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Service Providers

ConCreates also needs to engage third-party companies and individuals (such as research companies, and analytics and security providers) to help us operate, provide, and market the Services. These third parties have only limited access to your information, may use your information only to perform these tasks on our behalf, and are obligated to ConCreates not to disclose or use your information for other purposes. Our engagement of service providers is often necessary for us to provide the Services to you, particularly where such companies play important roles like helping us keep our Service operating and secure. In some other cases, these service providers aren’t strictly necessary for us to provide the Services, but help us make it better, like by helping us conduct research into how we could better serve our users. In these latter cases, we have a legitimate interest in working with service providers to make our Services better.

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Business Reorganization

In some cases, ConCreates may choose to buy or sell assets. Such transactions may be necessary and in our legitimate interests, particularly our interest in making decisions that enable our business to develop over the long term. In these types of transactions (such as a sale, merger, liquidation, receivership, or transfer of all or substantially all of ConCreates’ assets), member information is typically one of the business assets that is transferred. If ConCreates intends to transfer information about you, ConCreates will notify you by email or by putting a prominent notice on the Site, and you will be afforded an opportunity to opt out before information about you becomes subject to a different privacy policy.

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5. Security

The security of your personal information is important to us. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and after it is received. Unfortunately, no method of transmission over the internet or method of electronic storage is 100% secure. Therefore, while we strive to protect your personal information, we cannot guarantee its absolute security.

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6. Retention

ConCreates will retain your information only for as long as is necessary for the purposes set out in this policy, for as long as your contract is active (i.e., for the lifetime of your ConCreates client account), or as needed to provide the Services to you. ConCreates will retain and use your information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your information to comply with applicable tax/revenue laws), resolve disputes, enforce our agreements, and as otherwise described in this policy. We also retain log files for internal analysis purposes. These log files are generally retained for a brief period of time, except in cases where they are used for site safety and security, to improve site functionality, or we are legally obligated to retain them for longer time periods.

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7. Your Rights & Choices

Certain privacy laws around the world, including the European General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA), provide users with rights related to their personal information. Consistent with those laws, ConCreates gives you the choice of accessing, editing, or removing certain information, as well as choices about how we contact you, even though we do not fall under the GDPR because we do not collect information from users in Europe and we do not fall under CCPA because we are within the exemptions of the CCPA. However, you may change or correct your ConCreates information by emailing us at .  You may also remove certain optional information that you no longer wish to be publicly visible through the Services, such as your name. Depending on your location, you may also benefit from a number of rights with respect to your information. While some of these rights apply generally, certain rights apply in limited cases.

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• Right to Access & Portability: You can request a copy of your personal information in an easily accessible format and information explaining how that information is used.

• Right to Correction: You have the right to request that we rectify inaccurate information about you. Please email us at info@concreates.com.

• Right to Restrict Processing: In certain cases where we process your information, you may also have the right to restrict or limit the ways in which we use your personal information.

• Right to Deletion: In certain circumstances, you have the right to request the deletion of your personal information, except information we are required to retain by law, regulation, or to protect the safety, security, and integrity of ConCreates.

• Right to Object: If we process your information based on our legitimate interests as explained above, or in the public interest, you can object to this processing in certain circumstances. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons. Where we use your personal data for direct marketing purposes, you can object using the unsubscribe link in such communications.

• Right to Withdraw Consent: Where we rely on consent, you can choose to withdraw your consent to our processing of your information using specific features provided to enable you to withdraw consent, like an email unsubscribe link. If you have consented to share your precise device location details but would no longer like to continue sharing that information with us, you can revoke your consent to the sharing of that information by emailing us at info@concreates.com.

 

The CCPA provides California residents with the following additional rights:

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• Right to Know: California residents may request disclosure of the specific pieces and/or categories of personal information that the business has collected about them, the categories of sources for that personal information, the business or commercial purposes for collecting the information, the categories of personal information that we have disclosed, and the categories of third parties with which the information was shared.

• Right to Opt-Out: California residents are entitled to opt-out of the “sale” of data at any time (see below for more information). ConCreates does not “sell” personal information (as that term is defined under the CCPA).

 

If you would like to manage, change, limit, or delete your personal information, you can do so by emailing ConCreates at info@concreates.com. Once you contact us to exercise any of your rights, we will confirm receipt of your request.

Limiting use of, or deleting, your personal information may impact features and uses that rely on that information. However, we will not discriminate against you for exercising any of your rights, including otherwise denying you goods or services, providing you with a different level or quality of services, or charging you different prices or rates for services. If you need further assistance, you can contact ConCreates through one of the channels listed below under “Contact”. We will respond to your request within a reasonable timeframe.

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Please note that we may verify your identity before we are able to process any of the requests described in this Section, and in our discretion, deny your request if we are unable to verify your identity. As a part of this process, government or other identification may be required. You may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government issued identification, and the authorized agent’s valid government issued identification, and we may verify the authenticity of the request directly with you.

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Email & Messages

You may also control the receipt of certain types of communications from ConCreates. ConCreates may send you messages about the Services or your activity. Some of these messages are required, service-related messages for clients (such as transactional messages or legal notices). Other messages are not required, such as newsletters. You can control which optional messages you choose to receive by emailing us at info@concreates.com.

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Cookies

We use both technically necessary (for the functioning and security of the Services) and non-technically necessary cookies and similar technologies.

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Additional Disclosures for California Residents

Notice of Collection

In addition to the Rights & Choices described above, the CCPA requires disclosure of the categories of personal information collected over the past 12 months. While this information is provided in greater detail in the Information Collected or Received Section above, the categories of personal information that we have collected – as described by the CCPA – are:

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• Identifiers, including name, email address, IP address, and an ID or number assigned to your client account.

• Other individual records such as phone number, billing address, or credit or debit card information. This category includes personal information protected under pre-existing California law (Cal. Civ. Code 1798.80(e)), and overlaps with other categories listed here.

• Demographics, such as your age or gender. This category includes data that may qualify as protected classifications under other California or federal laws.

• Commercial information, including purchases and engagement with the Services.

• Internet activity, including your interactions with our Services and what led you to our Services.

• Geolocation data provided through location enabled services such as WiFi and GPS.

 

The Purposes for Our Collection

We collect and use these categories of personal information for our business and commercial purposes described in the “Information Uses, Sharing and Disclosure” Section above, including providing and improving the Services, maintaining the safety and security of the Services, processing purchase and sale transactions, and for advertising and marketing services.

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Third Party Marketing and Advertising and Your Rights (Opt-Out of “Sale”)

ConCreates does not sell personal information to third parties for monetary value. However, the term “sale” is defined broadly under the California Consumer Privacy Act. To the extent that “sale” under the CCPA is interpreted to include interest based advertising or other data uses described in the “Information Uses, Sharing and Disclosure” Section above, we will comply with applicable law as to those activities.

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Do Not Track Signals

Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.

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Shine the Light

California law entitles residents to ask for a notice describing what categories of personal information we share with third parties for their own direct marketing purposes. ConCreates does not share any personal information to third parties for their own direct marketing purposes. If you have questions about these practices, you can contact us through one of the channels listed in the “Contact” Section below.

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Accessibility

If you have a disability and would like to access this policy in an alternative format, please contact us using one of the channels listed in the “Contact” section below.

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8. Privacy Policy Changes

We may amend or update this policy from time to time. If we believe that the changes are material, we’ll let you know by doing one (or more) of the following: (i) posting the changes on or through the Services, (ii) sending you an email or message about the changes, or (iii) posting an update in the version notes. We encourage you to check back regularly and review any updates.

 

9. Contact

If you have any questions, send an email to info@concreates.com.

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Last Updated on January 1, 2023