Privacy Policy

Introduction

Creative Pathworks LLC and Rook Creek LLC (the “Company”, “we” or “us”) owns and operates the Creative Pathworks platform, located at https://www.creativepathworks.com (the “Website”). The Website provides a platform for the public to participate in writing retreats or workshops, purchase books, and build a community of creative writers (collectively, the “Services”).

This Privacy Policy explains how we collect, process, and store your personal information when you use or access the Website or our Services (collectively, the “Platform”). Specifically, this Privacy Policy will address:

Age Restrictions
What Information We Collect About You
Collection within the United States and Abroad
How We Use the Information We Collect
How We Share the Information We Collect
How We Retain and Protect Your Information
Third-Party Sites
Mobile Devices
Accessing and Correcting Your Information
Your Data Rights
Changes to This Privacy Policy
Contact Us

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the bottom of the policy, and in some cases, we may provide you with additional notice.

BY USING OR ACCESSING OUR WEBSITE OR SERVICES, YOU AFFIRM YOUR CONSENT TO THE PRACTICES AND POLICIES SET OUT IN THIS PRIVACY POLICY AND THE APPLICABLE TERMS OF SERVICE (the “Terms”). Your use of the Website or the Services, and any dispute arising out of or in any way related to privacy, will be subject to this Privacy Policy and the Terms, which are incorporated into this Privacy Policy by reference. If you do not agree to this Privacy Policy or the Terms, please do not use the Website or our Services.

We reserve the right to revise our Privacy Policy at any time. If we modify our Privacy Policy, we will post those changes to this Privacy Policy page (and revise the date at the top) and, in some cases, we may provide you with additional notice that we deem appropriate (such as adding a statement to our homepage or sending you a notification). Your continued use of or access to any portion of our Website or Services following the publication of the updated Privacy Policy on this website will constitute your assent to the updated Privacy Policy. We encourage you to review the Privacy Policy whenever you access the Services or otherwise interact with us to stay informed about our information practices and the choices available to you.

Age Restrictions

The Platform is not intended for persons under 18 years of age. No one under age 18 may provide any personal information to or on the Platform. We do not knowingly collect personal information from persons under 18 years of age. If you are under 18, do not use or provide any information on the Platform or on or through any of its features/register on the Platform, make any purchases through the Platform, use any of the interactive or public comment features of the Platform or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a person under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a person under 18, please contact us at info@creativepathworks.com.

What Information We Collect About You

We collect several types of information from and about users of the Platform, including information:

by which you may be personally identified, such as name, e-mail address, or any other identifier by which you may be contacted online or offline (“personal information”);
that is about you but individually does not identify you; and/or
about your internet connection, the equipment you use to access the Platform, and usage details.

We may collect this information:

directly from you when you provide it to us (e.g., when you sign up for a blog or to watch a video); and/or
automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.

Information You Provide to Us

The information we collect on or through the Platform may include:

Information that you provide by filling in forms on the Platform. This includes information provided (i) at the time of registering to use the Platform or requesting Services, (ii) when you sign up for a blog, (iii) at the time you request to view certain Content. We may also ask you for information when you report a problem with the Platform.
Records and copies of your correspondence (including email addresses), if you contact us.
Details of transactions you carry out through the Platform and of the fulfillment of those transactions. You may be required to provide financial information before placing an order through the Platform.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with the Platform, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

Details of your visits to the Platform, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Platform.
Information about your computer and internet connection, including your IP address, operating system, and browser type.
We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Please contact us at info@creativepathworks.com for information on how you can opt out of behavioral tracking on this website and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.

The information we collect automatically is statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve the Platform and to deliver a better and more personalized service, including by enabling us to:

estimate our audience size and usage patterns;
store information about your preferences, allowing us to customize the Platform according to your individual use; and/or
recognize you when you return to the Platform.

The technologies we use for this automatic data collection may include:

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of the Platform. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to the Platform.
Flash Cookies. Certain features of the Platform may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on the Platform. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
Web Beacons. Pages of our Platform and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

We do not collect personal information automatically, but we may tie this information to personal information about you that we collect from other sources or you provide to us.

Collection within the United States and Abroad

The Company is based in the United States and we process and store information in the U.S. Therefore, we and those that perform work for us may transfer your personal information to, or store or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. By using our Services, you consent to the processing of your information in the U.S. We will take steps to ensure that your personal data receives an adequate level of protection in the jurisdictions in which we process it.

The Platform may be accessed in the United States and abroad. In such cases, certain data and information will be transferred to the United States. For personal information protection purposes, the Company is the controller and, unless otherwise noted, is also the processor of the personal information. User account information remains in your account until you choose to delete it. If you are using the Platform outside of the United States, your data and the information collected may be subject to the data protection laws of the country in which you are located, regardless of whether or not your data is transferred to the United States. To the extent permitted by applicable law, if you would like to request to review, correct, restrict, or delete personal information that you have previously provided to us, object to the processing of personal information, or if you would like to request to receive an electronic copy of your personal information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), please contact us at info@creativepathworks.com. We will respond to your request in accordance with the applicable law that governs the collection, us, and deletion of your data and information. The requested deletion will be as comprehensive as possible but is always subject to issues outside of our control, including applicable regulations and laws, your actions and the actions of third parties. It is important to note that we may retain a copy of the information for archival purposes and to avoid identity theft or fraud. Certain users may have additional personal information rights and choices based on where they live. Please see the “Your Data Rights” section below for more information.

How We Use The Information We Collect

We use the information we collect to provide, maintain, and improve our Website and Services, such as to provide additional resources, continuing education, seminars and webinars, and other ancillary services. We may also use the information we collect to:

Present the Platform and its contents to you;
Administer your account, send you technical notices, updates, security alerts, and support and administrative messages, to respond to your comments, questions, and customer service requests;
Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
Notify you about changes to the Platform or any products or services we offer or provide through it;
Communicate with you about products, services, offers, and events offered by us and others, and provide news and information we think will be of interest to you (see the “Your Data Rights” section below for information about how to opt out of these communications at any time);
Monitor and analyze trends, usage, and activities in connection with our Services;
Detect, investigate, and prevent fraudulent transactions and other illegal activities and protect the rights and property of the Company and others;
Personalize and improve the Services;
Target advertisements to you on third-party platforms and websites (for more information and to opt-out, see the “Your Data Rights” section below);
Create de-identified, anonymized, or aggregated information;
Facilitate contests, sweepstakes, and promotions and process and deliver entries and rewards; and
Carry out any other purpose described to you at the time the information was collected.

How We Share The Information We Collect

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy in the following ways:

with vendors, consultants, contractors, and service providers who need access to such information to provide services to us, such as companies that assist us with web hosting, shipping and delivery, payment processing, fraud prevention, customer service, and marketing and advertising;
with our contractors and service providers so that they can better tailor their content to you;
if we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property, and safety of the Company or others;
in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company;
between and among the Company and our current and future parents, subsidiaries, and other companies under common control and ownership;
for any other purpose disclosed by us when you provide the information; and/or
with your consent.

We may also disclose your personal information:

to comply with any court order, law, or legal process, including to respond to any government or regulatory request;
to enforce or apply our terms of use and other agreements, including for billing and collection purposes; and/or
if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

We may also engage others to provide analytics, serve advertisements, and perform related services across the web and in mobile apps. These entities may use cookies, web beacons, SDKs, device identifiers, and other technologies to collect information about your use of our Services and other websites and mobile apps, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in mobile apps, links clicked, and conversion information. This information is used to deliver advertising targeted to your interests on other companies’ sites or mobile apps and to analyze and track data, determine the popularity of certain content, and better understand your activity. Some of our advertising partners enable us to translate your email address or phone number into an identifier that cannot be used to identify you personally.

Our advertising partners then use that unique identifier to show ads that are more relevant to you across the web and in mobile apps. Some of the activities described in this section may constitute “targeted advertising,” “sharing,” or “selling” under some laws. To learn more about the choices available to you with respect to these practices, see the “Your Data Rights” section below. You can also learn more about interest-based ads, or opt out of having your web browsing information used for behavioral advertising purposes by companies that participate in the Digital Advertising Alliance, by visiting www.aboutads.info/choices, or, if you reside in the European Union, by visiting www.youronlinechoices.eu.

How We Retain and Protect Your Information

We store personal data associated with your account for as long as your account remains active. We store other personal data for as long as necessary to carry out the purposes for which we originally collected it and for other business purposes explained in this Privacy Policy.

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted using SSL technology.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of the Platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to the Platform. Any transmission of personal information is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on the Platform.

Third-Party Sites

The Platform may, from time to time, contain links to and from the Platform of our partner networks, advertisers and affiliates. If you follow a link to any of these external websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these websites or their policies. Please check these policies before you submit any personal data to these external websites.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative at http://thenai.org/opt-out/.

Accessing and Correcting Your Information

You can review and change your personal information by logging into the Platform and visiting your account profile page.

You may also send us an email at info@creativepathworks.com to request access to, correct, or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Certain users may have additional personal information rights and choices based on where they live. Please see the “Your Data Rights” section below for more information.

Your Data Rights

We may process personal information to serve you advertisements on non-Company properties. Some of these activities may be considered “sales” or “sharing” of personal information or “targeted advertising” under the law that applies to you. To opt out of targeted advertising, sharing, and sales of your personal information, please contact us at info@creativepathworks.com.

You may have the right to object to certain processing, withdraw your consent where we process your information on that basis, and the right to request we restrict certain processing. In addition to requesting the deletion of any such information, you can request that we stop processing this data. To exercise any of these rights, please contact us at info@creativepathworks.com.

You may opt out of receiving promotional emails from the Company by following the instructions in those emails or by contacting us at info@creativepathworks.com. If you opt-out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.

The laws in certain jurisdictions require us to provide users, to the extent those laws apply to such users, with certain rights and information. This means that certain users may have additional personal information rights and choices based on where they live, and with respect to those users, to the extent this portion of the Privacy Policy conflicts with any other portion of this Privacy Policy, this portion of the Privacy Policy shall supersede and control. We have tried to provide links to websites that provide more information below. If you feel that this list does not cover your rights, please immediately notify us at info@creativepathworks.com.

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit https://oag.ca.gov/privacy.

If you are a resident of the European Union or European Economic Area (the “EU”), the General Data Protection Law (“GDPR”) may provide you with additional rights regarding our use of your personal information. To learn more about your GDPR privacy rights, visit https://eugdpr.org/the-regulation/. A list of European Union data protection authorities is available at: http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080 .

If you are a Canada resident, Canadian law may provide you with additional rights regarding our use of your personal information. To learn more about your Canada privacy rights, visit https://www.priv.gc.ca/en/.

For example, certain users (such as users in California or the EU) may have the following rights with respect to their personal information:

The right to know what information the Company collects from you, why it is collected, and how it is shared.
The right to have access to your personal information in a portable format, to the extent technically feasible.
The right to have your personal information deleted by the Company and its service providers (see below) and to be notified when such deletion has been completed, colloquially known as the “right to be forgotten”.
The right to have incomplete or inaccurate personal information rectified and to be notified upon rectification.
Withdraw your consent to the processing of your personal information.
The right to request information about the categories of information that are sold and/or to opt out of the sale of personal information. (Note: what is covered as a “sale” under California law is not yet clear, but we currently do not “sell” your information, as we understand it.)

Below is a list of our service providers with whom we may share user information and the services they generally provide.

Payment processing

The rights and options described above are subject to limitations and exceptions under applicable law. In situations in which the Company processes personal data on behalf of a user, the Company may refer the request to the relevant user and cooperate with their handling of the request, subject to any special contractual arrangement with that user.

If you are using the Platform outside of the United States, your data and information is collected in the country in which you are located and are transferred to the United States or another country where our servers are located.

If you would like to request to review, correct, restrict, or delete personal information that you have previously provided to us, object to the processing of personal information, or if you would like to request to receive an electronic copy of your personal information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), please contact us at info@creativepathworks.com. We will respond to your request in accordance with the applicable law that governs the collection, use, and deletion of your data and information. The requested deletion will be as comprehensive as possible but is always subject to issues outside of our control, including applicable regulations and laws, your actions, and the actions of third parties. It is important to note that we may retain a copy of the information for archival purposes and to avoid identity theft or fraud.

You also have the right to lodge a complaint with the supervisory authority of your habitual residence, place of work or place of alleged infringement, if you consider that the processing of your personal data infringes applicable law. However, we encourage any such user to contact us first at info@creativepathworks.com, and we will do our very best to promptly address such user’s issue(s) and resolve the concern(s).

Changes to This Privacy Policy

We reserve the right to change this Privacy Policy from time to time, so please be sure to check back here periodically.

Contact Us

If you have questions about our Privacy Policy or practices, or if you would like to make a complaint, please contact us at info@creativepathworks.com.

Last updated: September 17, 2023

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