Privacy Policy

Effective Date: September 20, 2022

Your privacy is important to us. This Privacy Policy applies to Ateliere Creative Technologies, Inc., and its international subsidiaries and affiliated companies (collectively, “Ateliere”). This Privacy Policy explains how we collect, use, and share the personal information (“Personal Data”) that we gather on the subdomains and websites on https://ateliere.com/ (the “Sites”) or through your use of our products and services.

1. Our Role

Ateliere is the controller or business responsible for your Personal Data when you visit the Sites, use our products and Services, or as otherwise specified in our Privacy Policy.

This Privacy Policy does not apply to the extent we process Personal Data in the role of a processor or service provider on behalf of our customers, including consumer information that is collected, processed, stored, or hosted on behalf of a customer who is using an Ateliere offering (e.g., streaming services or other white-label services provided to an Ateliere customer). To understand how our customers process your information, please refer to the relevant customer’s privacy policy.

2. Processing Activities Covered

This Privacy Policy applies to the processing of Personal Data collected by us when you:

Visit our websites that display or link to this Privacy Policy;
Visit our branded social media pages;
Receive communications from us, including emails, phone calls, texts, or faxes;
Use our SAAS platform and any other analytics software products and services as an authorized user where we act as the entity responsible for your Personal Data; or
Apply for employment opportunities with us.

Third Party Links and Websites. Our Sites may contain links to and from the websites of third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any data to these websites.

3. Information We Collect

Information You Give Us. You may give us information by:

Creating or administering your Ateliere account (and you might have more than one account if you have used more than one email address when using an Ateliere service);
Entering information through our online forms or surveys;
Inputting information while using our services;
Contacting us by phone, email, a support ticket, questionnaire or other information request form for information or customer service;
Registering for or attending an Ateliere event;
Purchasing or using content, products, or services from third-party providers through an Ateliere service;
Offering your content, products, or services on or through the Ateliere Sites and services and other similar venues operated or provided by us;
Employing our notification services, such as newsletters, product updates, or alerts; and/or,
Connecting or sharing with us through social media networks that you use, such as Facebook, Twitter, and Instagram.

The categories of information include:

Contact information, such as name, alias, address, location, company name, email, and telephone number.
Online identifiers, such as Internet Protocol (“IP”) address, cookies, username, and password.
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with our Sites and services.
Professional, employment, or education information, such as copies of your resume or CV and any other information required to verify your qualifications, for recruitment purposes.
Financial information (we use widely accepted third party service providers to collect sensitive Personal Data such as credit card information, for example, if you subscribe to an offering or purchase a product or service online).
Commercial records, such as purchasing histories or products and services you considered purchasing.

Information We Automatically Collect. Like many website operators, we collect information that your browser sends whenever you visit our Sites.

This includes log data, such as your computer’s IP address, browser type, browser version, the pages of our Sites that you visit, the time and date of your visit, the time spent on those pages and other statistics, and whether you reached our page via a social media or email campaign. This information may be collected via several technologies, including cookies, web beacons, clear GIFs, canvas fingerprinting and other means. You can control cookies in your browser to enable or disable them, but this may disable certain features on our services. Learn more in our Cookies section below.

Information We Collect From Third Parties. If you access our Sites through third parties or if you share content from our Sites to a third-party social media service, the third-party service will send us certain information about you if the third-party service and your account settings allow such sharing. The information we receive will depend on the policies and your account settings with the third-party service.

4. How We Use Your Information

We use your Personal Data for the following purposes:

To provide you with the services on our Sites, which includes:
maintaining and servicing accounts,
providing customer service,
processing and fulfilling orders and transactions,
verifying customer information,
processing payments,
providing financing, and
providing advertising or marketing services to you as described further below.
To provide analytic services, such as analyzing customer usage and improving the services offered.
To conduct market research and project planning.
To detect security incidents, protect against fraudulent or other criminal activity, debug and repair errors, and maintain the overall quality and safety of our Sites.
To share your website visitor activity, through website cookies, with third-party marketing partners to market our services on our Sites and other websites that you may visit.
To fulfill our legal and financial obligations.
To provide you with employment opportunities.

Marketing: We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe instructions provided in any email we send, or you can contact us using the contact details provided in the “Contact Information” section below. You will still continue to receive service-related messages concerning products and services you have purchased (unless we have indicated otherwise).

5. How We Share Your Information

Affiliates and Service Providers. We share your information with our third-party service providers and any subcontractors as required to offer you our products and Services. The service providers we use help us to:

Run, operate, and maintain our Sites through third-party platforms and software tools;
Perform content moderation and crash analytics;
Run email campaigns;
Provide analytics, usage, and measurement services and targeted ads on our websites (you can opt out of these services at websites such as http://www.aboutads.info/choices and http://www.youronlinechoices.eu/);
Administer live events, competitions, sweepstakes, and promotions, including registering attendees, managing check-in and attendance, verifying eligibility and prize fulfilment;
Provide payment attribution; and,
Provide technical and customer support.

Some external service providers may also collect information directly from you (for example, a payment processor may request your billing and financial information) in accordance with their own privacy policy. These external service providers do not share your financial information, like credit card number, with us, but may share limited information with us related to your purchase, like your zip code.

Aggregated Data. We may also aggregate or otherwise strip information of all personally identifying characteristics and may share that aggregated, anonymized data with third parties or publish it. This data does not personally identify you and helps us to measure the success of our Sites and its features and to improve your experience. We reserve the right to make use of any such aggregated data as we see fit.

Third Party Marketing and Advertising Organizations. With respect to website cookies, we share your information with third-party marketing and advertising partners to market our services on our Sites and other websites that you may visit. Learn more in our Cookies Section below.

Disclosures Required by Law. We may be required to disclose your data in response to lawful requests by public authorities, including to meet law enforcement requirements. We may be under a duty to disclose or share your Personal Data to comply with any legal obligation, to enforce or apply our terms and conditions and other agreements, to protect our rights, property, or safety, or to protect the rights, property, or safety of others. This includes exchanging information with other companies and organizations for the purposes of fraud protection.

6. How We Respond to ‘Do Not Track’ Signals

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. We do not recognize or respond to browser-initiated DNT signals, as the Internet industry is currently still working toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT.

7. Cookies

To make our Sites and services work properly, we sometimes place small data files called cookies on your device. A cookie is a small text file that a website saves on your computer or mobile device when you visit the site. It enables the website to remember your actions and preferences (such as login, shopping cart, or other preferences) over a period of time, so you do not have to keep re-entering them whenever you come back to the site or browse from one page to another.

Please note that while we use analytics and personalized advertising cookies on our Sites, we do not use third-party analytics and advertising cookies on our customer facing SAAS platform. To the extent we process Personal Data in the role of a processor or service provider on behalf of our customers, including consumer information that is collected, processed, stored, or hosted on behalf of a customer who is using an Ateliere offering (e.g., streaming services or other white-label services provided to an Ateliere customer), our customers may use analytics and personalized advertising cookies on these platforms. To understand how our customers place cookies, please refer to the relevant customer’s privacy or cookie policy.

Google/ Hubspot Analytics. We may use Google and Hubspot Analytics on our Sites. We use the information we get from these analytics companies only to improve the Sites. We do not combine the information collected through the use of analytics with personally identifiable information. Please refer to Google’s Privacy Policy and Hubspot’s Cookie Policy for more information. You may also choose to download the Google Analytics opt-out browser add-on.

You may wish to restrict the use of cookies. Please be aware that some of the features of our Sites may not function correctly if you disable cookies. Most modern browsers allow you to change your cookie settings. You can usually find these settings in the options or preferences menu of your browser. To understand these settings, the following links for commonly used browsers may be helpful:

Personalized Advertising. We may also use targeted advertising cookies on our Sites, to deliver tailored advertising on our Sites and other websites that you may visit. You can learn more about how to control advertising cookies by visiting the Network Advertising Initiative’s Consumer Opt-Out link, the DAA’s Consumer Opt-Out link for browsers, or the DAA’s opt-out link for mobile devices. Please note that electing to opt-out will not stop advertising from appearing in your browser or applications and may make the ads you see less relevant to your interests.

8. Privacy Rights

Marketing Opt-Outs. At any time, you may ask to unsubscribe or opt out from our marketing communications. Please email the unsubscribe or opt out request to the Contact Information below and include the applicable Ateliere service, your name, email address, and request to unsubscribe or opt out. Aggregated information that may have been collected about you or your activities will remain but will no longer be linked to your Personal Data or identifiable with you.

Third Party Marketing. California Civil Code Section 1798.83 permits our customers to request information regarding the disclosure of their Personal Data to third parties for the third parties’ direct marketing purposes. We do not disclose your personal information to third parties for the third parties’ direct marketing purposes.

9. Additional Disclosures for EEA & UK Individuals

Legal Bases for Processing (EEA and UK Individuals). If you are from the European Economic Area (EEA) or United Kingdom (UK), our legal bases for collecting and using your Personal Data is as follows:

The performance of your contract or to enter into the contract and to take action on your requests. For example, the processing of your account registration and to provide our services.
Our legitimate business interests. For example, fraud prevention, maintaining the security of our network and services, direct marketing to you, and improvement of our services.
Compliance with a mandatory legal obligation. For example, accounting and tax requirements, which are subject to mandatory retention periods. We may also collect your Personal Data to record your requests to exercise your rights and to verify your identity for such requests.
Consent you provide where we do not rely on another legal basis. Consent may be withdrawn at any time.
In some limited cases, we may also have a legal obligation to collect Personal Data from you in response to lawful requests by public authorities, including to meet law enforcement requirements, as described above in the “How We Share Your Information” section.

If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Data, please contact us using the contact details provided at the end of this Privacy Policy.

EEA or UK Individuals’ Rights. If you are from the EEA or UK, you have the right, under certain circumstances, to:

Access your Personal Data;
Correct inaccurate information in your Personal Data;
Request erasure of your Personal Data without undue delay;
Request the restriction of, in certain circumstances, the processing of your Personal Data;
Request receiving a portable copy of your Personal Data held by us, and to have that portable copy transmitted to another controller; and
To object to the processing of your Personal Data.

To exercise any of these rights, contact us using the contact details provided at the end of this Privacy Policy, and please specify which privacy right(s) you wish to exercise. We may need to verify your identity to honor your request.

International Transfers of Data. Any data that you provide to us may be accessed, shared, or processed by our offices, located in the United States, and service providers located in the United States, if such data transfer is necessary for the specific purpose for which you submitted your data (such as the provision of goods or services under a written contract).

This may entail a transfer of your Personal Data across international borders. The data protection standards may differ and be lower than the standards enforced in your jurisdiction. We maintain appropriate safeguards as required by applicable law for any Personal Data transferred internationally.

Right to Lodge a Complaint. If you have any issues with our compliance, you have the right to lodge a complaint with an EEA supervisory authority. We would, however, appreciate the opportunity to first address your concerns and would welcome you directing an inquiry to us via the contact information at the bottom of this Privacy Policy.

10. Children’s Privacy

The Sites are not directed at individuals under the age of 16. We do not knowingly collect Personal Data from children under 16. If you become aware that a child has provided us with Personal Data, please contact us using the contact details provided at the end of this Privacy Policy. If we become aware that a child under 16 has provided us with Personal Data, we will take steps to delete such information.

11. Change of Control

Personal Data may be transferred to a third party because of a sale, acquisition, merger, reorganization, or other change in control. If we sell, merge, or transfer any part of the business, part of the sale may include your Personal Data.

12. Data Security

We implement a variety of security measures to maintain the safety of your Personal Data when you enter, submit, or access your Personal Data. However, no website, application, or transmission can guarantee security. Thus, while we have established and maintain what we believe to be appropriate technical and organizational measures to protect the confidentiality, security, and integrity of Personal Data obtained through the Sites, we cannot ensure or warrant the security of any information you transmit to us.

13. Data Retention

We retain information from or about you for so long as necessary to fulfill the purposes outlined in this Privacy Policy. When the information is no longer necessary for these purposes, we delete it or keep it in a form that does not identify you, unless we are required by law to keep this information for a longer period. When determining the retention period, we consider various criteria, such as the type of products and services requested by or provided to you, the nature and length of our relationship with you, possible re-enrolment with our products or services, the impact on the services we provide to you if we delete some information from or about you, mandatory retention periods provided by law and the statute of limitations.

14. Policy Updates

This policy may be periodically updated. We encourage you to periodically review this Privacy Policy to ensure you are familiar with the most current version. Please review carefully before submitting Personal Data to our Sites. The date the Privacy Policy was last updated is indicated at the top of this page.

15. Contact Information

If you wish to contact us or have any questions about or complaints in relation to this Privacy Policy, please contact us here.

CHANGES TO THIS POLICY. We may from time to time make changes to this Privacy Policy. We will post the updated Privacy Policy on each affected ATELIERE Offering and update the Effective Date to reflect the date of the changes. By continuing to use the ATELIERE Offering after the effective date of any such changes, you accept the Privacy Policy as modified.