Last updated on April 2, 2020.

1 – What Information does Creative Therapy collect?

When you use a Creative Therapy website, service, application, or product we collect information relating to you and your use of our services from a variety of sources. These are listed below. The sections afterward describe what we do with this information.

Information we collect directly from you

  1. Registration Information: You need a Creative Therapy account to use Creative Therapy software and products. When you register for an account, we collect your email address.
  2. Billing Information: If you make a payment to Creative Therapy, we require you to provide your billing details, such as a name, address, company, VAT number,  email address and other relevant contact details. If you provide a billing address, we will regard that as the location of the account holder.
  3. Physiologic Data: Creative Therapy devices record your raw data, as well as any information you voluntarily enter into Creative Therapy software and applications. This information is transmitted to a Creative Therapy managed server. UNDER NO CIRCUMSTANCES IS CREATIVE THERAPY RESPONSIBLE FOR ANY PERSONALLY IDENTIFIABLE INFORMATION (PII) SUBMITTED BY THE USER THROUGH THE APPLICATION OR ANY OTHER ROUTES. ALTHOUGH WE TAKE ALL REASONABLE MEASURES TO SECURE YOUR DATA, WE STRONGLY ADVISE AGAINST SUBMITTING ANY PII THROUGH THE APPLICATION.
  4. Other Intentionally Shared Data: We may collect your personal information or data if you submit it to us in other contexts. For example when you subscribe to receive communications from us or contact us in any way.

Our servers are located depending on our service providers, and therefore subject to change.

Information we collect about you indirectly or passively when you interact with us

  1. Usage Data: We collect usage data about you whenever you interact with our services. This may include webpage visits, what you click on, when you performed those actions, and so on. Additionally, like most websites and applications today, our web servers keep log files that record data each time a device accesses those servers. The log files contain data about the nature of each access, including originating IP addresses, internet service providers, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system versions, and timestamps.
  2. Device Data: We collect data from the devices (including but not limited to Creative Therapy produced devices) and applications you use to access our services, such as your IP address, relevant device and experiment identifiers, operating system version, device type, system and performance information, and browser type. We may also infer your geographic location based on your IP address.
  3. Referral Data: If you arrive at a Creative Therapy  website from an external source (such as a link on another website or in an email), we record information about the source that referred you to us.
  4. Information from Third Parties: We may collect your personal information or data from third parties if you give permission to those third parties to share your information with us.
  5. Information from Page Tags: We use third party tracking services that employ cookies and page tags (also known as web beacons) to collect aggregated and anonymized data about visitors to our websites. This data includes usage and user statistics. Emails sent by Creative Therapy or by users through our services may include page tags that allow the sender to collect information about who opened those emails and clicked on links in them. We do this to allow the email sender to measure the performance of their email messaging and to learn how to improve email deliverability and open rates.

2 – What does Creative Therapy with your Information?

  1. This includes providing you with customer support, which requires us to access your information to assist you (such as technical troubleshooting).
  2. In order to provide you with useful options to use the services together with other applications, we may give you the option to export information to third party applications and websites. We do not own or operate the applications or websites that you connect with, and you should review the privacy policies and statements of such websites to ensure you are comfortable with the ways in which they use the information you share with them.
  3. We process your raw data to provide you with additional insights. CREATIVE THERAPY DOES NOT MAKE ANY DIAGNOSTIC CLAIMS NOR IS CREATIVE THERAPY RESPONSIBLE FOR ANY DIAGNOSTIC CLAIMS BASED ON PERMITTED USAGE OF THE APPLICATION.

To manage our services

We internally use your information for the following limited purposes:

  1. To monitor, maintain, and improve our services and features: We internally perform statistical and other analysis on information we collect to analyze and measure user behavior and trends, to understand how people use our services, and to monitor, troubleshoot and improve our services, including to help us evaluate or devise new features. We may use your information for internal purposes designed to keep our services secure and operational, such as for troubleshooting and testing purposes, and for service improvement, marketing, research and development purposes.
  2. To prevent potentially illegal activities
  3. To create new services, features, or content
  4. To contact you about your service or account: We can occasionally send you communications of a transactional nature (e.g. service-related announcements, billing-related matters, changes to our services or policies, a welcome email when you first register).
  5. To contact you for marketing purposes: We may use your data to advertise a new feature, new product or application. Anytime you would like to stop receiving information from feature, products or others, you can unsubscribe.

We are committed to handling your personal information and data with integrity and care. However, regardless of the security protections and precautions we undertake, there is always a risk that your personal data may be viewed and used by unauthorized third parties as a result of collecting and transmitting your data through the Internet. If you have any questions about the security of your personal information, contact customer support at info@mycreativetherapy.com

To respond to legal requests and prevent harm

If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.

3 – When might we Disclose your Data to Third Parties?

Service Providers

We use service providers who help us to provide you with our services. We give relevant persons working for some of these providers access to your information, but only to the extent necessary for them to perform their services for us. We also implement reasonable contractual and technical protections to ensure the confidentiality of your personal information and data is maintained, used only for the provision of their services to us, and handled in accordance with this privacy policy. Examples of service providers include payment processors, hosting services, email service providers, and web traffic analytics tools.

Account Details to Billing Contact

If your details (as the account holder) are different to the billing contact listed for your account, we may disclose your identity and account details to the billing contact upon their request (we also will usually attempt to notify you of such requests). By using our services and agreeing to this privacy policy, you consent to this disclosure.

When Required or Permitted by Law

We may disclose your information as required or permitted by law, or when we believe that disclosure is necessary to protect our rights, protect your safety or the safety of others, and/or to comply with a judicial proceeding, court order, subpoena, or other legal process served on us.

Change in Business Ownership or Structure

If ownership of all or substantially all of our business changes, or we undertake a corporate reorganization (including a merger or consolidation) or any other action or transfer between Creative Therapy entities, you expressly consent to Creative Therapy transferring your information to the new owner or successor entity so that we can continue providing our services. If required, Creative Therapy will notify the applicable data protection agency in each jurisdiction of such a transfer in accordance with the notification procedures under applicable data protection laws.

4 – Consent

When you provide us with personal information to register and use one of our services, complete a transaction, verify your credit card, place an order, arrange for a delivery or return a purchase, we assume that you consent to our collecting it and using it for that specific reason only. If we ask for your personal information for a secondary reason, like marketing, we will ask you directly for your consent.

If after you opt-in, you change your mind, you may withdraw your consent for us to contact you, for the continued collection, use or disclosure of your information, at anytime, via the provided opt-out links or by contacting us at info@mycreativetherapy.com.

5 – Security

To protect your personal information, we take reasonable precautions and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed.

Creative Therapy BVBA, located at Saghermansstraat 1B, 9000 Ghent, Belgium is the data controller for all data we collect from users in the EU.

6 – Safety of Children

Our services are not intended for and may not permissibly be used by individuals under certain age depending on the laws of the governing country. Creative Therapy does not knowingly collect personal data from persons under the age of 18 or allows them to register. If it comes to our attention that we have collected personal data from such a person, we may delete this information without notice. If you have reason to believe that this has occurred, please contact customer support.

7 – Cookies

We and our partners use cookies and similar technologies on our websites. Cookies are small bits of data we store on the device you use to access our services so we can recognize repeat users. Each cookie expires after a certain period of time, depending on what we use it for. We use cookies and similar technologies for several reasons:

  • To make our site easier to use: We may store your username in a cookie to make it quicker for you to sign in whenever you return to Creative Therapy.
  • For security reasons: We use cookies to authenticate your identity, such as confirming whether you are currently logged into Creative Therapy.
  • To provide you with personalized content: We may store user preferences, such as your default language, in cookies to personalize the content you see.
  • To improve our services: We use cookies to measure your usage of our websites, as well as to occasionally display different versions of content to you. This information helps us to develop and improve our services and optimize the content we display to users.
  • Google Analytics: In addition to the above, we have implemented on our websites and other services certain Google Analytics features to measure our products and services in order to improve our offer and value for our clients.

Please be aware you can still choose to remove or disable cookies via your browser. Please note that doing this may adversely impact your ability to use our services. Enabling cookies ensures a smoother experience when using our websites. By using our websites and agreeing to this privacy policy, you expressly consent to the use of cookies as described in this policy.

8 – Your Rights

You can:

  1. Update your account details
  2. Access and correct your personal information: As an account holder, you may access and correct certain personal information that Creative Therapy holds about you. In all cases, requests to exercise these rights may be directed to our customer support team at info@mycreativetherapy.com
  3. Delete your data: Deleting data will not permanently delete data immediately. As long as you maintain an account with us, we may retain your deleted data for a limited time in case you delete something by accident and need to restore it (which you can request by contacting customer support at info@mycreativetherapy.com). To the extent permitted by law, we will permanently delete your data if you request to cancel your account (“Right to be forgotten”).
  4. Cancel your account: To cancel and delete your account, please contact customer support at info@mycreativetherapy.com. We will respond to any such request, and any appropriate request to access, correct, update, or delete your personal information within the time period specified by law (if applicable) or without excessive delay. We will promptly fulfill requests to delete personal data unless the request is not technically feasible or such data is required to be retained by law (in which case we will block access to such data, if required by law).
  5. Portability: Taking into account that Creative Therapy product offers data in a structured, commonly used and machine-readable format, you as a client, already have the right to transmit those data to another company if desired (“right to data portability”).

9 – Your Responsibilities

By using our services, you agree to comply with applicable data protection requirements when collecting and using your data, such as requirements to inform respondents about the specific uses and disclosures of their data.

10 – For how Long do we Retain your Data?

We generally retain your data for as long as you have an account with us, or to comply with our legal obligations, resolve disputes, or enforce our agreements. Data that is deleted from our servers may remain as residual copies on offsite backup media for up to approximately 6 months.

11 – Changes to this Privacy Policy

We may modify this privacy policy at any time, but if we do so, we will notify you by publishing the changes on this website. If we determine the changes are material, we will provide you with additional, prominent notice as is appropriate under the circumstances, such as via email or in another conspicuous manner reasonably designed to notify you. If, after being informed of these changes, you do not cancel your subscription and continue to use our services beyond the advance-notice period, you will be considered as having expressly consented to the changes in our privacy policy. If you disagree with the terms of this privacy policy or any updated privacy policy, you may close your account at any time.