PRIVACY POLICY

SUMMARY

When you use or interact with a website, mobile application or other Digital Service (each referred to as a “Digital Service”) operated or owned by CREAMODITE (“CREAMODITE”) or when you fill out a digital form to subscribe to our Database or newsletter, enter a contest or provide your information for an event (“Forms”), we and third parties obtain certain information about you. In this summary section we provide a general overview of our privacy practices related to the Digital Services and Forms. Please review our full Privacy Notice, set forth below, for a detailed explanation of our practices.

Information We Collect

Information you provide when you use the Digital Services or request related content, products or services, including, for example, signing up to receive newsletters, or creating or registering a membership application through the Digital Services or through Forms. This may include contact, payment or demographic information.
Information you submit when you choose to participate in a survey, sweepstakes, contest, promotion, event or similar initiative.
Information obtained through cookies and similar technologies. Such information includes information about your device and browser, including your IP address or mobile advertising identifiers, as well as information about how you and others use, interact with or respond to the Digital Services. This type of information collection takes place while you are using a Digital Service or while such Digital Service is running in the background of your device. Our Cookie Policy contains detailed information about our use of cookies and similar technologies.
Precise location information from your device when location-based services are active.
Information we obtain from other sources, such as business partners, data providers and social media platforms.

How we use the information and legal basis for doing so

To process your requests or subscriptions and provide you with the Digital Services. Please note that we use your payment information (for example your credit card number or credit card expiration date) for limited purposes, such as to process your transaction (including recurring payments, if applicable), to provide you with the requested products or services, and to protect our rights or the rights of third parties.
To obtain information about users of the Digital Services and to analyze how you and others interact with and respond to the Digital Services.
To communicate with you and send you marketing and promotional communications.
For advertising and marketing purposes, including sending interest-based advertisements, for cross-device linking and to analyze the results of advertising and marketing activities.
To protect our rights and the rights of third parties.
We process personal information for various purposes on the following legal bases: to fulfill our contract with you, to defend our legitimate interests, to fulfill our legal obligations, as well as for other reasons, with your consent or at your direction.

With whom we share information

With service providers who perform services or transactions on our behalf.
With advertisers, advertising and marketing related service providers, and companies that help us understand how you and others interact with our content.
With social networks and similar services, including those you use when you interact with our Digital Services that integrate tools and services provided by social networks.
With business partners, such as where we partner with a third party to offer products or services in the case of a brand linking strategy.
With another party, when required by law or when necessary to protect our rights, and in the context of corporate transactions.
With your consent or, where appropriate, at your direction.

Your choices, including the ability to opt-out of interest-based marketing communications and advertisements.

You can take steps to limit the use of your information for interest-based advertising in your browser or on your mobile device.
You can unsubscribe from our marketing or promotional emails by clicking on the “Unsubscribe” link in the email or by emailing info@workef.com.

Additional Information

We use a variety of security technologies and procedures to help protect information from unauthorized access, use or disclosure.
Your data is deleted when it is no longer needed for legitimate business activity or for legal reasons.
We implement appropriate security mechanisms to protect your data when it is transferred to, stored or processed in, a country that does not maintain data protection laws similar to those of the European Union or the United Kingdom.
The Digital Services are not intended for use by children under the age of 14.

Contacting Us

If you have any questions about this Privacy Notice you may contact us at gisela@workef.com.

INTRODUCTION

This Privacy Policy describes how CREAMODITE (identified as “we,” “us,” “our,” “our” or “CREAMODITE”) collects and processes personal information about you, how it uses and protects such information, and sets forth what your rights are with respect to such information. This Privacy Policy applies to personal information about you that we collect or process on the websites, mobile applications or other Digital Services (each a “Digital Service”) linked to this Privacy Policy or when you fill out a digital form to subscribe to our newsletters and other publications, enter a contest or give us your details for an event (“Forms”).

If you have any questions about this Privacy Policy or our data practices, you can find more information in the “Contact Us” section below.

This Privacy Policy describes the privacy practices of CREAMODITE only and does not cover the practices of other companies, including those that advertise or sponsor the content, products or services incorporated in the Digital Services, as described in the “With whom we share information” section, also discussed below.

INFORMATION WE COLLECT

When you use a Digital Service, we collect various types of information about you and your use of that Digital Service. This includes information that directly identifies you, for example, your name, address or contact information, as well as information regarding online identifiers and cookie data, which may identify you. The information we collect generally consists of:

1. Information We Collect Directly From You

When you use certain parts of the Digital Services, we ask you for information about yourself. For example, to subscribe to one of our newsletters, you are required to provide us with an e-mail address. You may not be able to use certain features if you choose not to submit the required information.

The information you provide to us includes details such as:

Contact information (e.g., name, mailing address, email address or phone number).
Demographic, interest or household information (e.g., age, gender or education).
Information about payments made or purchases made through the Digital Services (e.g., credit card number, credit card expiration date, and billing information).
Comments, photos, videos and other content or information that you choose to post on the Digital Services or otherwise share with us.
Information you provide when you participate in surveys, sweepstakes, contests, promotions (including information about your participation in activities that generate loyalty or reward points) or events.
Location information, including precise location information when you allow the Digital Services to access the location of your device. To prevent the collection of precise device location information, please refer to the instructions provided by your cell phone service provider or the manufacturer of your device.
Other information that you allow us to access through your device’s permission settings, such as your contacts or address book.
Transactional and activity information.

2. Information you provide about third parties

You may provide us with information about other people, such as another person’s name and email address. You should not provide information about third parties unless you are authorized to do so or unless those third parties have given you their permission. We will use your information for the purposes described in this Privacy Policy.

3. Information Collected Automatically

The Digital Services automatically record certain information about visits to the Digital Services, such as the number and frequency of users, technical information about the browsers and devices used to access the Digital Services, and information about malfunctions and other technical issues. In addition, in accordance with preferences expressed by you, we and other involved parties obtain, automatically and by automated means, certain information about your activities during the time you spend logged on to the Digital Services or to third party sites, applications or other means. The tools that obtain this information vary across the Digital Services and include technologies such as cookies, web beacons, tags, scripts, pixels, local shared objects (including HTML5 cookies) and software development kits (SDKs) (collectively referred to as “Cookies and similar technologies”).

4. Information we obtain from other sources

We receive information about you from other sources and, in certain circumstances, combine it with other information about you. For example, we may obtain data from:

Operators of third party sites or applications, content delivery channels and platforms, voice-activated assistants or other devices and technologies when you interact with our content, products, services or advertisements available on those channels and platforms. The information we receive includes information about the content you visit or access, as well as your demographic and interest information.
Third-party data providers, such as data aggregators, data resellers, public databases and business partners. They all provide demographic information, information about your purchases and information that helps us learn about you and other users of the Digital Services.
Social Media Platforms and Similar Services (“Social Media Platforms”). When you access our content or advertisements on social media platforms, or when you interact with tools on the Digital Services with content or features provided in turn by social media platforms (e.g., by logging into or registering for features or tools that allow you to share our content with others on social media platforms), we may obtain information from those social media platforms, including your user name, user ID and demographic information, subject to the applicable platform’s privacy settings and practices. We may obtain such information directly from the platform or through plug-ins, integrations or applications. Please note that social media platform operators also collect information about your use of the Digital Services and their features and tools. We are not responsible for their practices.

HOW WE USE THE INFORMATION WE COLLECT

If you make a purchase or request an order through or in connection with a Digital Service or Forms, we use payment information (e.g., your credit card number and expiration date) to process the transaction (including recurring payments, if applicable), to provide you with the requested products or services, and to protect our rights or the rights of third parties, as described below.

With respect to information about you other than payment information, we use such information:

1. To provide you with the Digital Services or Other Services you request. This includes:

Processing your requests regarding the Digital Services, products or services, or your participation in a survey, sweepstakes, contest, promotion, event or similar initiatives.
Providing customer service or technical support.
Personalized content, providing recommendations and improving the quality of and your overall experience with the Digital Services, taking into account maintaining your user preferences in the most effective manner for the browser or device you use to access the Digital Services.
Maintaining, operating, improving and developing the Digital Services and related content, products or services, including developing new products and features based on users’ interaction with the Digital Services.
Improving knowledge about users of the Digital Services and analyzing how you and others interact with and respond to the Digital Services, including measuring and optimizing usage, reliability and performance, developing market research, analyzing trends, and supporting our operations (e.g., accounting, auditing, financing, legal and other matters).

2. To communicate with you. This includes:

Sending you informational messages about the Digital Services (e.g., to confirm your subscription or notify you of changes to a Digital Service).
Sending you marketing or promotional communications, including offers or promotions about our or third parties’ products, services or other initiatives.
Responding to your inquiries or fulfilling your requests.
Communicating with you regarding surveys, sweepstakes, contests, promotions or events.

3. For advertising and marketing purposes, including interest-based advertising.

Depending on your preferences, considering those regarding the use of cookies and similar technologies, it may include:

Developing, managing and executing advertising and marketing campaigns, promotions and offers, such as those relating to our content, products and services or the products, services and other initiatives of third parties.
Interest-based advertising (also known as targeted or personalized advertising or ads) is based on your interests, inferred from your activities over time on the Digital Services and online services operated by third parties as well as information from other sources. Interest-based ads consist of text, image, animation or video ads and are delivered to you based on a variety of factors, including the context of the site or app in which they appear (e.g., sports or travel sections), information you have provided to the site or app operator (e.g., when you created an account), your activities on the site or app (e.g., pages visited, searches performed or ads opened), and information such as your demographics, interests or household information.
We, our service providers or other involved parties use automated means, including cookies and similar technologies on the Digital Services and third party sites, applications or other means to (a) obtain information for interest-based advertising or (b) serve you interest-based ads. When you accept the use of cookies and similar technologies on the Digital Services, specific identifiers may be associated with your device to support interest-based advertising.
The online and offline information we collect about you, including your personal information, is used by us for the purposes of interest-based advertising. We aggregate the information we collect in order to create audiences that are more likely to respond to ads based on demographic, interest and household information.
Interest-based ads may be delivered to you by third parties, such as ad networks or so-called Ad Exchanges.
You can take steps to limit the collection of information about you through cookies and similar technologies and the use of your information for interest-based advertising; these steps vary across web and mobile app environments and are browser and device specific. For more information about these choices see “Your Choices, Including Opting Out of Interest-Based Marketing Communications and Ads” below and our Cookie Policy.
Cross-device Linking. If you access the Digital Services from multiple browsers or devices, we, our service providers and other involved parties may attempt to establish connections and link the different browsers and devices you use to access the Digital Services and our content and advertisements served elsewhere in certain circumstances. This helps us to provide you with a seamless experience with the browsers and devices you use and to serve you the most relevant content and advertisements (e.g., so that we do not show you the same item twice). Please see our Cookie Policy for information on steps you can take to limit cross-device linking.
Analyzing and measuring the performance, effectiveness and reach of our advertising (including interest-based ads) and our marketing initiatives on the Digital Services and elsewhere.

4. To protect our rights or the rights of third parties. This includes:

Detecting, preventing and responding to fraud or potentially illegal activities, misuse of the Digital Services, intellectual property related infringements or other violations of law, this Privacy Policy and our Terms of Use or other BeuP policies.
Conducting inspections, assessments and testing or troubleshooting activities.
Strengthening our systems (including disaster recovery measures) and improving the overall security of the Digital Services.
Compliance with and enforcement of applicable industry and legal requirements (including legal processes such as judgments, orders and subpoenas) and fulfillment of contractual obligations.

LEGAL BASIS FOR THE USE OF INFORMATION

We process personal information for various purposes on the following legal bases:

To fulfill our contractual obligations to you. We and our service providers process your information to fulfill our contractual obligations to you when we use your information to provide you with the Digital Services and related content, products or services and to communicate with you. We also send you informational communications on this basis, including notifying you of a change to a Digital Service. Failure to provide the required information may contravene or delay the performance of our contractual obligations.
To meet our legitimate interests. We process your information to fulfill our legitimate interests in using it to provide you with Digital Services and related content, products or services, to communicate with you, and for our advertising and marketing purposes. For example, our legitimate interests include making improvements, personalizing and understanding how you interact with the Digital Services and related content, products or services, and sending you communications about products and services that we think may be of interest to you. To satisfy our legitimate interests, we may share your information with our subsidiaries and affiliates, and our service providers and business partners (including for advertising and marketing purposes) and in the context of a corporate transaction. We maintain appropriate security measures to protect the information we process, ensuring that our legitimate interests are safeguarded.
To comply with our legal obligations. We process and share your information as necessary to comply with our legal obligations when we use your information to protect our rights or the rights of others and when we share it with others where required to do so by law, or where it is necessary to protect our rights. For example, we are required to obtain certain information from you to process your payment for a subscription, for tax or financial control purposes.
With your consent. We obtain your consent to process your information when required to do so by law. In connection with cookies and similar technologies, we obtain your consent as described in our Cookie Policy. If consent is the legal basis on which we process your personal information, you may withdraw such consent at any time by contacting us as set out in the “Contact Us” section.

WITH WHOM WE SHARE INFORMATION

We share the information we collect with:

Service Providers. In connection with the operation and delivery of the Digital Services and Forms, and fulfilling requests for our products or services, we rely on third parties to provide services or handle transactions on our behalf, for example in connection with payment processing, email distribution, list distribution, list processing, postal mailings, cloud computing, analytics, performance measurement of digital content or paper subscriptions, ad serving, and sweepstakes, contest, promotion or event management. These service providers use the information we provide to them as they deem necessary or appropriate for the provision of their services.

Advertisers, advertising and marketing related service providers. We sometimes provide your information to advertisers, advertising agencies, ad networks, advertising exchanges, marketing companies, technology marketers and other entities that create, deploy and analyze advertising or marketing campaigns, including those that incorporate interest-based advertising.

Social Networking. If you interact with social media widgets, share content on social media, or access features of the Digital Services with content or features provided by social media, those platforms collect information. You should review the privacy guidelines of the social media platforms you interact with to learn about their privacy practices, which we do not control.

Business Partners. In certain circumstances, we provide information about you to business partners, including, without limitation, joint marketing partners, content sponsors or event organizers, for various purposes. For example, we may partner with another entity to offer products on a brand tie-in, co-sponsorship or co-promotional strategy basis, which involves information sharing. These initiatives take place in Digital Services or other media. A business partner’s participation in a particular initiative is communicated to you through the inclusion of the relevant business partner’s products, services or brands.
Other parties when required by law or when necessary to protect our rights. We share your information when we believe it is necessary or appropriate to protect, enforce or defend our legal rights, the privacy or safety of our employees, users of the Digital Services, or other persons and entities or to comply with or enforce industry standards, laws or legal proceedings, such as judgments, court orders and subpoenas, and other requirements of public and governmental authorities.

Corporate Transactions. We may transfer any information we have about you in order to proceed with the consideration, negotiation or completion of a sale or transfer of all or a portion of our business or assets to a third party, in the event of a merger, acquisition or other corporate transaction, or in connection with a reorganization, dissolution or liquidation in bankruptcy.
With your consent or otherwise at your direction. In addition, we share your information with third parties when you consent or request that we do so.
Because we operate as part of a global entity, the recipients of the above information will sometimes be located outside of the jurisdiction in which you are located (or in which we provide the Digital Services or Other Services to you). Please see the “International Data Transfer” section below for more information.

YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION

In certain circumstances, you have the right to access or object to the use of personal information held about you (including for direct marketing purposes). You may also instruct us to correct, update, delete, limit or share with another company, in an appropriate format, your information. Such requests are governed by the relevant legal framework.

Please do not hesitate to contact us to correct your information if it changes, or if the personal information we hold about you is inaccurate.

If you wish to discuss or exercise such rights, please contact us as set out in the “Contact Us” section below. We will contact you if we need additional information to fulfill your requests.

YOUR CHOICES, INCLUDING THE RIGHT TO OPT-OUT OF INTEREST-BASED MARKETING COMMUNICATIONS AND ADVERTISEMENTS

Opt-out of direct marketing:

Email Marketing. You may unsubscribe from receiving marketing or promotional emails sent by us or by third parties (where you have opted-in to receive third party and other communications from us, as required by law) by clicking on the “unsubscribe” link contained in such emails.
Text Message Marketing. If at any time you have opted-in to a text message marketing campaign or promotion offered in connection with a Digital Service or Other Service, you may opt-out of receiving further text messages by following the instructions contained in such messages (e.g., by typing the word STOP or UNSUBSCRIBE), or in the instructions provided to you at the time you agreed to receive text message marketing.

Direct mail. If you opt-in to receive offers by postal mail related to a Digital Service (provided that such opt-in is required under applicable law), you may request that we stop sending you offers by postal mail by notifying us of your request in writing at the address specified below in the “Contact Us” section. Please indicate in the correspondence the name of the Digital Service, Other Service or publication to which your request relates

Third Party Marketing. We provide contact information about you to third parties to use for their own marketing purposes where you have given us your consent to do so. If you wish to withdraw your consent to such sharing in the future, you may notify us in writing at the address specified below in the “Contact Us” section. Please indicate in the correspondence the name of the Digital Service, Other Service or publication to which your request relates.

Offers with linked brands, co-sponsorship or co-promotion with business partners. If at any time you opt-in to a linked branded, co-sponsored or co-promotional offer campaign, the sponsor or other business partners involved in such offers may use information about you for their own purposes, including those related to advertising and marketing, in line with our business partner privacy policy. To exercise your opt-out choices regarding the business partner’s use of your information, you should contact the business partner directly.
Opting out of receiving interest-based advertisements

Depending on your preferences regarding the use of Cookies and similar technologies, the ads you receive on the Digital Services may be interest-based ads. This means that such ads are customized based on information that we and others obtain about you and involve the use of cookies and similar technologies. We outline in our Cookie Policy the steps you can take to limit the tracking of your activities and the delivery of interest-based ads on the browsers and mobile applications you use to access the Digital Services. Please note that even if you opt-out of interest-based ads, you will continue to receive ads, but they will not be based on your interests or preferences. On the other hand, if you take the steps outlined in the Cookie Policy, certain automated means of obtaining information about your interactions with the Digital Services will still be used for the other purposes described in this Privacy Notice (e.g., remembering user preferences or activating specific functionality).

The technologies used to deliver advertisements on the websites and mobile applications are diverse. Please also note that “opt-out” links are specific to different browsers and devices.

Additional options

Device Configuration Settings. In the corresponding Digital Services, you can review and adjust your preferences by updating your device settings (e.g., allowing us to obtain precise information about your location).

Push Notifications. If push notifications for a particular Digital Service are enabled on your device, you can review and update your preferences about them by adjusting your device settings. For example, you can select the relevant app under “Notifications” (for iOS devices) or “App Notifications” (for Android devices) and turn off alerts as appropriate.

HOW WE PROTECT AND STORE YOUR INFORMATION

We use various technologies and procedures to help protect information from unauthorized access, use or disclosure.

We will keep your information for as long as we maintain a relationship with you. Once that relationship ends, we will retain your personal information for a period that allows us to:

Maintain business records for analysis, market trend research and/or inspection measures and to improve our Digital Services.
To comply with record retention obligations under relevant laws, or other relevant legal or regulatory requirements.

Defend, raise, exercise or analyze existing or potential legal actions.

Take fraud detection and prevention actions.

Address any complaints regarding the Digital Services and other products and services.

We will delete your personal information when it is no longer needed for such purposes. If there is any information that, for technical reasons, we are unable to delete from our systems, we will take appropriate measures to prevent any further processing or use of the data.

INTERNATIONAL TRANSFER OF DATA

In certain circumstances, your personal information may be transferred to, stored and processed in, countries outside the European Union and the United Kingdom, which do not have data protection laws similar to those in the European Union or the United Kingdom.

In such circumstances, we will put in place appropriate safeguards to protect your data, including contractual commitments. For more information about such mechanisms, please contact us by the means detailed below.

PRIVACY RIGHTS FOR CHILDREN

The Digital Services are not intended for use by children, especially children under the age of 14, and we do not knowingly collect personal information from persons under the age of 14.

LINKS TO THIRD-PARTY WEBSITES, MOBILE APPLICATIONS OR OTHER SERVICES.

Certain Digital Services contain links to websites, mobile applications or other services operated by companies not affiliated with Hearst. In addition, the Digital Services may be made available to you through other platforms (such as app stores or social media) or other channels. We are not responsible for the privacy practices of any websites, mobile applications or other services and channels not operated by CREAMODITE, so you should review the privacy policies or notices of the relevant third parties.

CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our privacy practices or in applicable law. Where changes to this Privacy Policy will have a material impact on the nature of the information processing or on you, we will notify you in advance so that you can exercise your rights (e.g., by objecting to the processing of the information). We will publish the updated version of the relevant Digital Services and indicate at the beginning of the Privacy Policy the date of its last update. Your use of Digital Services will be governed by the most current version of the Privacy Notice.

CONTACT US

CREAMODITE, as the controller of the Digital Services and Forms that you are using or accessing, is the data controller of the personal information that we collect and process in connection with each Digital Service or Form. The details of the data controller and its publications, together with the corresponding contact information, are set out below.

You may contact our Data Protection Officer at: moda@prensademoda.com.

We are committed to working with you to reach a satisfactory resolution should you have any privacy-related issues or complaints. If, however, you feel that we have not been able to help you with your problem or complaint, you have the right to file a complaint with the data protection regulators.