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In compliance with the European Union General Data Protection Regulation (“GDPR”), Creative Technology Ltd and its subsidiaries and affiliated companies (or "Creative", "we", "our" and "us") value your personal data and will do what we can, to ensure that your personal data is respected and protected, in line with applicable laws and the policies as described in this Policy. This Policy supplements our Privacy Policy and should be read in conjunction with the latter. With regards to GDPR matters, this Policy takes precedence.
This Policy seeks to help you better understand how we collect, use, disclose and protect your personal information.
Please read this Policy carefully before you use any of Creative's web sites ("Site(s)") or when you provide us with your personal data. By using or accessing our Sites or when you provide us with your personal data, you consent to and accept Creative's collection, use and disclosure of your personal data in accordance with the terms of this Policy. We reserve the right to amend, change or modify this Policy (or any part hereof) at any time and from time to time, without any notice to you. We encourage you to refer to this Policy on an ongoing basis so that you are aware of the current terms.
What is Personal Data?
The GDPR refers to ‘personal data” as meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier. This includes unique identifiers (e.g. passport number); as well as any set of data (e.g. name, age, address, telephone number, occupation, etc), which when taken together would be able to identify the individual. (For more information, please refer to https://gdpr-info.eu/)
How We Collect Your Personal Data
We collect your personal data in a variety of ways. Some of the ways include occasions when you take part in our contests, lucky draws, surveys etc, when you subscribe to our newsletter, when you register a Creative product online, contact us for support or when you buy products from our online stores.
When you are submitting your personal data to us (for whatever the purpose may be), please ensure that the data you provide us is accurate, complete, correct and true or we may not be able to contact you for the reasons for which you submitted the data.
The Information We Collect
3.1. The information we collect depends on the products you bought, or the contests or activities you signed up for or subscribed to. You may have the opportunity to participate in any of the following activities at some Creative Sites including but not limited to: contests, product registration, special offers, promotions, participation in surveys, polls, software downloads, online shopping, newsletter subscription and/or forum participation.
3.2. These activities may require the collection of your personal information including: your name, postal address, e-mail address, telephone number, fax number, 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).
How We Use Your Information; Legal Basis for Processing Your Information
We will use your information for general administrative purposes including processing of orders and/or payments, personalizing your user experience, activating or deactivating accounts, responding to queries, technical support, audit purposes, to meet any governmental, legal or regulatory requirements, to enable us to keep you updated on our latest products, offerings, promotions, software updates etc.
Legal Basis of using Your Information (under the GDPR):
For product orders, we have to use your Information in order to fulfill our contractual obligations to process your order(s).
For technical support, we have to use Your Information in order to fulfill our legal obligations (including our warranty obligations) towards you.
For your enquiries, we would be using your Information to meet both our legitimate interests of answering your enquiries.
For newsletters, updates on new products and special offers, and marketing activities (including but not limited to lucky draws and competitions) we would be meeting both our legitimate interests of keeping you updated on such new products, special offers and marketing activities.
How We Disclose Your Information
We may disclose certain or all of the information (described above) that we collect, as stated above and in accordance with the terms and the purposes as set forth in this Policy. We do not reveal personally identifiable information about you to third-parties for their independent use, save as follows: (1) unless you request or authorize us; (2) in connection with our Sites as described above; (3) the information is required to be provided in compliance with applicable laws, regulations, search warrants, subpoenas or court orders, enforce an agreement we have with you, or to protect our rights, property or safety, or the rights, property or safety of our employees or others; (4) the information is provided to our agents, vendors or service providers who perform functions on our behalf, where such information may be processed on servers located outside the country where you live (please see clause 6 below); or (5) the information is to address emergencies or acts of God or to address disputes or claims, or to persons holding a legal or beneficial interest. By entering into and using this web site, you consent to the processing of data about you by our third party vendors and marketing agents for the purposes set out hereinabove.
If you wish to opt-out, please contact us at the contact details provided in clause 9 below. We shall, under no circumstance, be liable or responsible to you in any way for the data protection policies, privacy policies, security or other policies of these third party vendors/social media/marketing agents or otherwise. Subject to the provisions and exceptions as provided in the GDPR, we may disclose or share your information with our subsidiaries or affiliated companies within the Creative Group, or our service providers as necessary.
Protection of Your Personal Data
To prevent unauthorized access to our database systems, and to ensure the appropriate use of information, we have used commercially reasonable efforts to put in place electronic and managerial processes and procedures to help safeguard your personal information. Such safeguards include, but are not limited to, ensuring that online transfers of personal data are carried out via secure (encrypted) means.
Your personal data might be stored outside the European Economic Area in countries such as Singapore and the United States, with third party vendors known as “data processors” under the GDPR.
We have identified such data processors and have ensured that we have entered into agreements with such data processors in compliance with the GDPR. Such agreements require that the parties rely on any of the following: (i) EU Model Clauses, (ii) Binding Corporate Rules, or (iii) Privacy Shield framework, for the protection of your personal data. Such data processors have implemented security procedures to protect your personal data, have certified that their systems are compliant to industry standards such as ISO 27001, and conduct annual audits on their security systems to verify that they meet such industry standards.
Access and Correction of Personal Data
Users who are resident within the European Economic Area (EEA), have the following rights under the GDPR:
For other rights that you may have, please refer to https://gdpr-info.eu/
PLEASE DO NOTE THAT IF WE PERFORM SOME OF THE REQUESTS ABOVE, FOR EXAMPLE, WITHDRAWAL OF CONSENT, RIGHT OF ERASURE, OBJECTION TO PROCESSING, ETC, WE MAY NO LONGER BE ABLE TO PROVIDE YOU WITH CERTAIN SERVICES WHICH MAY INCLUDE ANY REQUESTS FOR TECHNICAL SUPPORT, WARRANTY OR OTHERWISE. OUR LEGAL RIGHTS ARE HEREBY EXPRESSLY RESERVED.
You may contact us (details are as provided in clause 9 below) for the above requests. Please give us at least thirty (30) days to process each request.
Please be aware that you have the right to lodge a complaint with an applicable supervisory authority, for example, residents of the Republic of Ireland can contact the Data Protection Commissioner at https://www.dataprotection.ie/docs/Making-a-Complaint-to-the-Data-Protection-Commissioner/18.htm
Feedback and Comments
If you have comments or feedback on the matters referred to in this Policy, please drop us a line at the contact details provided in clause 9 below:
Contact Us
Last updated: May 2018