CREA, LLC
política de privacidad

Last Update / Effective Date:  March 16, 2023

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This Privacy Policy (“Policy”) describes the Personal Information collected by or on behalf of CREA, LLC (“Company,” “we,” “us,” or “our”) through this website ("Site") and our interactions with you, and how Personal Information is used, shared and protected. 

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IF YOU ARE A CALIFORNIA RESIDENT, PLEASE SEE SECTION 11 BELOW FOR ADDITIONAL TERMS THAT MAY APPLY TO YOU. 

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We may modify this Policy at any time. All changes will be effective immediately upon posting to the Site. Material changes will be conspicuously posted on the Site or otherwise communicated to you. 

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If you use this Site, you must comply with our Terms of Use (“Terms”) found https://www.creallc.com/terms-of-use.

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1.    CATEGORIES OF PERSONAL INFORMATION WE COLLECT

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We may collect the following categories of Personal Information, which is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“Personal Information”):

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A.    Identifiers: Identifiers such as: a real name, alias, postal address, email address, account name, social security number, internet protocol address (“IP Address”), date of birth, driver’s license number, passport number, or other similar identifiers.

B.    Customer Records: Any of the following types of information: bank account number, telephone number, credit card number, debit card number, physical characteristics or description, and any other financial information.

C.    Protected Classifications: Characteristics of protected classifications under California or federal law such as:  Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

D.    Commercial Information: Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.  
E.    Internet Activity: Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement. 

F.    Geolocation Data: Geolocation data. 
G.    Employment Information: Professional or employment-related information. 

H.    Education Information: Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99). 

I.    Inferences: Inferences drawn from any of the information identified in this section to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

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This Policy does not apply to any information that is publicly available.

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2.    CATEGORIES OF SOURCES

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We may collect all categories of Personal Information listed above from the following categories of sources:

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Source:  We Collect Personal Information Directly From You and/or Your Household. We collect Personal Information that you provide directly to us. Personal Information is required to use certain Site features, for example, to create online accounts, contact us via email or phone, submit job application materials, receive or request data from us, and respond to communications from us.

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Company Accounts.  Company maintains portals for developers and investors. To create an online account with Company, you must submit your name and email address, and create a password. This data is used to populate a profile within your account.  

Feedback.  When you provide comments or feedback about our Site, the content on the Site, or our products or services ("Feedback"), we will not treat that Feedback as confidential and we may use that Feedback for any purpose in our sole discretion so long as it does not personally identify you. Feedback will be used without attribution or compensation to you.

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Applying to Work with Company.  To submit job application materials online to work with Company, you will be redirected from our Site to a website operated by our services provider. You may be required to create an account with that vendor. We encourage you to review the terms and privacy policy posted on that vendor's website since this Policy does not govern your use of that website. If you send us your job application materials directly, we will only use and share those job application materials to evaluate your qualifications to work with Company and its affiliates and communicate with you regarding an employment opportunity.

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Business Contracts and Communications with Us.  When a business communicates with us or contracts directly with us for the purchase of our services, we may collect the business contact information of those involved. The processing of any information provided in such a business context is governed by the contracts between that business and Company.

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Source:  We Collect Personal Information Automatically.  We automatically collect certain information from you when you access our Site.

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Account Activity.  We may collect data about how you use (i) your online account, and (ii) the Site when you are logged into your account. We may combine data automatically collected from you with other Personal Information about you. 

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Cookies & Other Tracking Technologies. 

 

What types of online tracking mechanisms do we use? We may use cookies, web beacons, pixel tags and other tracking technologies (collectively “Cookies”) on our Site.

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What are cookies and web beacons / pixel tags? A cookie is a small text file that our Site saves onto your computer or device when you use the Site that provides us certain information about your activities. Cookies allow the Site to remember your actions and preferences and recognize you or your browser. Web beacons / pixel tags are small graphics on a webpage that monitor your activity when viewing a webpage.

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Why do we collect Cookies? We use Cookies to:

• tailor our interactions with you;

• help with our marketing efforts;

• provide us with valuable data and statistics about the usage and effectiveness of our Site and to help us improve our Site; and

• help us improve our services. 

What type of information do Cookies collect? The Cookies on our Site may collect information such as:

• the IP addresses assigned to the computers and other devices you use;

• your internet service provider;

• the device ID number;

• approximate geographic location;

• the Site pages visited or clicked on;

• the date and time you visited the Site, and the amount of time spent on the Site;

• your operating system, browser type, search requests, and other similar information;

• the websites you access before and after visiting the Site, and 

• data related to how and when you use the Site.

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We may combine information from Cookies with Personal Information, including data obtained from other sources.

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How long do Cookies last? A Cookie can either be a “session” Cookie or a “persistent” Cookie. Session Cookies exist only for so long as you are visiting the applicable Site and are typically deleted when you exit your web browser. Persistent Cookies exist for a set period of time, for example, up to several months or years. Each time you visit a Site that has implemented a persistent Cookie, the persistent Cookie is renewed and that Cookie will remain active until its predetermined expiration date. You can manually delete persistent Cookies through your browser settings.

First-party versus third-party Cookies. Cookies may either be “first-party” or “third-party” Cookies. A first-party Cookie allows your web browser to talk to the actual Site that you are visiting (i.e. this Site). A third-party Cookie allows your web browser to talk to a third-party website, such as the source of an ad that appears on the website you are visiting or a third-party analytics provider. We do not have control over how information gathered by third-party Cookies is used by third parties. 

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How do you manage Cookies or opt-out? Most browsers automatically accept cookies. You can disable this function by changing your browser settings, but disabling cookies may impact your use and enjoyment of the Site. Not all features or functions of the Site may work properly if you disable Cookies. You cannot disable all Cookies, such as Cookies that are essential to the functioning of the Site.

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Google Analytics.  We use Google Analytics to collect and process information about your use of the Site. Google sets cookies on your browser or device, and then your web browser will automatically send information to Google. Google uses this information to provide us with reports that we use to better understand and measure how users interact with our Site.

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To learn more about how Google uses data, visit Google’s Privacy Policy and Google’s page on “How Google uses data when you use our partners’ sites or apps.” You may download the Google Analytics Opt-out Browser Add-on for each web browser you use, but this does not prevent the use of other analytics tools. To learn more about Google Analytics cookies, visit Google Analytics Cookie Usage on Websites.

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Google Maps.  The Site contains maps provided by third parties and/or service providers for your convenience. Company and such other parties may collect data about how you interact with the maps. For example, Google may collect usage data on maps embedded on the Site. Even if you do not interact with the maps, Google may still collect certain information about your interactions with our Site if you are signed into your Google account when accessing our Site. Please see Google's Privacy Policy for more information.   

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Source:  We Collect Personal Information From Third-Party Sources.  We obtain data about individuals from various third-party companies and public sources and we may combine that data with Personal Information or other data we collect.

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3.    PURPOSE FOR COLLECTING PERSONAL INFORMATION

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We may use all categories of Personal Information listed above for the following business purposes:

 

As Stated or Agreed to at the Point of Collection.  We may use Personal Information for the purposes stated or agreed-to (or as is obvious) at the point of collection. For example, we use Personal Information to respond to your questions, comments, or complaints. We may also use Personal Information as requested or consented to by you.

 

Administration.  We use Personal Information for administrative purposes, such as managing accounts, facilitating transactions, to inform our business strategies, to understand the Site’s demographics and user preferences, for evaluating applications, and managing profiles. 

 

Site Management.  We use Personal Information for Site management, such as troubleshooting problems, improving the content and functionality of the Site, statistical and other analyses of the Site, and to customize the Site to you and our users.

 

Communications and Corporate Updates.  We may use Personal Information to notify you of new services, products, business opportunities, programs, or company news updates, to notify you of changes to our Terms or this Policy, and for other similar communications.

 

To Protect Our Rights.  We may use Personal Information to protect our legal rights or interests, or those of other parties, including to bring a legal action against you or anyone who may be causing harm to us, our Site, or to other users of the Site. We may also use Personal Information to seek business, financial or legal advice, and to respond to other legal requests.
 
4.    CATEGORIES OF PARTIES WITH WHOM WE SHARE PERSONAL INFORMATION

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We may share all categories of Personal Information listed above with the following categories of persons and service providers:

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Employees and Affiliates.  We may share Personal Information with our employees and affiliates who have a need to know the information for our business purposes.

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Service Providers.  We may share Personal Information with service providers that provide services for us. We have contracted with our service providers to protect any such Personal Information. For example, we may share Personal Information with service providers to: help us host and manage the Site; market to you; improve the content and functionality of the Site; perform data analysis and statistical analysis; troubleshoot problems with the Site; provide public relations services; provide learning management systems; provide email services; provide data processing; and support or provide the security of the Site.

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Government Officials / Law Enforcement.  We will cooperate with law enforcement and other governmental agencies, and may disclose Personal Information: (i) if we believe in good faith we are legally required to disclose that Personal Information, (ii) if we are advised to disclose Personal Information by our legal counsel, or (iii) when necessary to identify, contact or bring a legal action against someone who may cause or be causing harm to, or interfering with the legal rights of, Company or any other party.

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Professional Advisors.  We may share Personal Information with our professional advisors, such as our attorneys, accountants, financial advisors and business advisors, in their capacity as advisors to Company.

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Change in Ownership.  In the event (a) Company is subject to a change of control, (b) the Site changes ownership, in whole or in part, or (c) of a bankruptcy, receivership or a similar transaction, we may provide Personal Information to the subsequent owner(s), including as part of any due diligence process.

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Other.  We may share Personal Information with third parties and/or service providers when explicitly requested by or consented to by you, or for the purposes for which you disclosed the Personal Information to us as indicated at the time and point of the disclosure (or as was obvious at the time and point of disclosure).

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5.    USE AND DISCLOSURE OF DE-IDENTIFIED OR AGGREGATED INFORMATION 

Company may collect, use, share, transfer and otherwise process de-identified and aggregated information that it receives or creates for any purposes in its sole discretion, in compliance with applicable laws. Company is the sole and exclusive owner of such de-identified and aggregated information, including if Company de-identifies Personal Information so that it no longer considered Personal Information under applicable laws.

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6.    CHILDREN

The Site is not directed at children under 13 years of age. We do not knowingly collect, use, or share Personal Information from children under 13. If a parent or legal guardian learns that their child provided us with Personal Information without his or her consent, please contact us and we will make commercially reasonable attempts to delete such Personal Information.
 
7.    SOCIAL MEDIA

We are active on social media, including Facebook, Twitter, Instagram and LinkedIn (“Social Media”). Anything you post on Social Media is public information and will not be treated confidentially. We may post (or re-post) on the Site and our Social Media pages any comments or content that you post on our Social Media pages.

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The Site allows you to connect and share data with Social Media platforms. These features may require us to use cookies, plug-ins, and APIs provided by such Social Media platforms to facilitate those communications and features. The Site may use advertising networks and services offered by Social Media platforms to deliver advertising content. Use of these services requires Social Media platforms to implement cookies or pixel tags to deliver ads to you while you access the Site.

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Your use of Social Media is governed by the privacy policies and terms of the providers that own and operate those websites and not by this Policy. We encourage you to review those policies and terms.

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8.    DATA SECURITY

We use commercially reasonable technical and organizational measures to help secure Personal Information against loss, misuse, and alteration appropriate to the type of Personal Information processed. If a breach of your Personal Information occurs, we will notify you of the breach if required under applicable law.

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NO DATA TRANSMISSION OVER THE INTERNET OR DEVICE CAN BE GUARANTEED TO BE 100% SECURE. WHILE WE STRIVE TO PROTECT PERSONAL INFORMATION, WE DO NOT GUARANTEE THE SECURITY OF PERSONAL INFORMATION AND YOU PROVIDE PERSONAL INFORMATION AT YOUR OWN RISK.

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9.    ACCESS FROM OUTSIDE THE UNITED STATES

If you access the Site from outside the United States, please be aware that Personal Information may be transferred to, stored in, and processed in the United States. Certain governmental authorities may not consider the level of protection of Personal Information in the United States to be equivalent to that required in other jurisdictions.

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10.    THIRD-PARTY WEBSITES

The Site may link to, or be linked to, websites not owned or controlled by us. We are not responsible for third-parties’ privacy policies or practices. This Policy does not apply to any third-party websites or to any data that you provide to third parties. You should read the privacy policy for each website that you visit.

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11.    TERMS APPLICABLE TO CALIFORNIA RESIDENTS ONLY

This Section 11 provides additional terms that apply to residents of California. In the event of a conflict between this Section and the remainder of this Policy, this Section shall take precedence for California residents.  In this Section only, any capitalized terms not defined in this Policy have the meanings set forth in the California Consumer Privacy Act of 2018 (the “CCPA”).

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We Do Not Sell Personal Information

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In the last 12 months we have not Sold your Personal Information and we currently do not Sell Personal Information. You have the right to opt-out of the Sale of your Personal Information by businesses subject to the CCPA. "Sale" / “Sold” / "Sell" has the definition set forth in the CCPA.

Categories of Personal Information Disclosed For a Business Purpose 

In the last 12 months we disclosed the following categories of Personal Information for our Business Purposes, where “Business Purposes” has the definition set forth in the CCPA. See the section above titled “Categories of Personal Information We Collect” for more detail on the type of Personal Information in each category. 

• Category A: Identifiers

• Category B: Customer Records

• Category C: Protected Classifications

• Category D: Commercial Information

• Category E: Internet Activity

• Category F: Geolocation Data

• Category G: Employment Information

• Category H: Education Information

• Category I: Inferences

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Your Rights to Access and Deletion.  California residents have certain rights under the CCPA, such as the right to request certain information or request deletion of their personal information.  Subject to certain limitations such as (a) exceptions permitted by applicable law and (b) verification of your identity, California residents may exercise the following rights with regard to their Personal Information:

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Right to Access.  You have the right to access any of the following which occurred in the prior 12-month period: (a) the categories of Personal Information we collected from you, (b) the categories of sources from which the Personal Information was collected, (c) the business or commercial purpose for collecting or Selling your Personal Information, (d) the categories of third parties with whom we shared your Personal Information, (e) the specific pieces of Personal Information we collected from you (i.e. "data portability"), and (f) a list of categories of Personal Information we disclosed for a Business Purpose in the last 12 months.

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Right to Deletion.  You have a right to request that we delete Personal Information we collected from you. We will comply with such request, and direct our service providers to do the same, subject to certain exceptions permitted by applicable law. 

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How to Exercise Your Rights of Access and Deletion.  To exercise your California rights described in this Section, you may submit your request to us by contacting us at any of the following:

creallc.com
privacy@creallc.com
855-279-2732

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Verifiable Consumer Request.  In order to verify your request, you must provide sufficient information to allow us to reasonably verify you are the person about whom we collected Personal Information, and you must describe your request with sufficient detail to allow us to properly understand, evaluate, and respond to your request.

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When we receive your request to exercise your rights under the CCPA: (a) we will acknowledge receipt of your request; (b) we will try to match the information you provide in making the request with information we already maintain about you; (c) if required to verify your identity, we may ask you to provide additional information, including personal information; (d) we will consider various factors when determining how to verify your identity, such as the sensitivity and value of the data, the risk of harm, the likelihood of fraud, etc.

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We will only use personal information we collect during the verification process for the purpose of verifying your identity.  If you maintain an account with us, we may use that account to respond to your request and/or verify your identity.  If we are unable to verify your identity as required by applicable laws and regulations, we will decline to comply with your request, and let you know why.  

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When We Will Respond.  We will try to respond to your request for access or deletion within 45 days. If we require additional time, we will inform you of the reason and extension period. Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. For data portability requests, we will select a format to provide your Personal Information to you. We may charge a fee to process or respond to your request if it is excessive, repetitive, or manifestly unfounded.

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Non-Discrimination. California residents have the right to not receive discriminatory treatment for exercising any of their rights under the CCPA. If we choose to offer a financial incentives program in the future, additional terms will apply which may be an exception to this Section.

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Who May Exercise Your Rights? You may only make a request to exercise your rights on behalf of yourself. You also have a right to submit requests to exercise your rights under the CCPA through an authorized agent. You may designate an authorized agent to make a request on your behalf to exercise your rights under the CCPA by doing the following: (1) verify your own identity (per the process stated above) and (2) identity of the authorized agent directly. Alternatively, your authorized agent may provide us with a copy of a power of attorney issued pursuant to California Probate Code sections 4000 to 4465. We may deny a request from an authorized agent if we do not have proof that they are authorized by you to act on your behalf. Furthermore, a parent or legal guardian may make a request on behalf of their child.

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Shine the Light.  Pursuant to California Civil Code Section 1798.83, if you are a California resident, you have the right to obtain: (a) a list of all third parties to whom we may have disclosed your Personal Information within the past year for direct marketing purposes, and (b) a description of the categories of Personal Information disclosed, by contacting us per the “Contact Us” Section below.

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CALIFORNIA’S “DO-NOT-TRACK” REQUIREMENT. WE CURRENTLY DO NOT RESPOND TO “DO NOT TRACK” REQUESTS.

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12.    CONTACT US 

If you have any questions you may contact us as set forth below:

CREA, LLC
Attn: Legal Department
30 South Meridian Street, Suite 400
Indianapolis, Indiana 46239
www.creallc.com 
1-855-279-2732
privacy@creallc.com