2. INFORMATION WE COLLECT

3. HOW WE USE YOUR INFORMATION

We use your information for the following purposes:

3.1 Service Delivery (Courses, Digital Products, Community)

• Provide access to Creator Flow Collective courses, digital products, AI Bot Vault, community, and other services

• Create and administer your account, authenticate users, and manage subscriptions

• Deliver purchased content, training materials, resources, and updates

• Customize your experience and provide personalized recommendations

• Facilitate community participation and member interactions

3.2 AI Bot Vault Operations

• Provide, operate, maintain, and support the AI Bot Vault and our custom AI assistants

• Process your prompts/inputs and generate outputs you request

• Save your settings, preferences, and selected outputs (where the feature allows)

• Troubleshoot, monitor performance, and improve model/tool functionality

• Detect and prevent misuse, spam, fraud, and security incidents related to AI tools

3.3 Affiliate Program and Commission Processing

• Track referrals, attribute purchases, and calculate commissions

• Administer affiliate accounts, links, and reporting dashboards

• Process affiliate payouts and handle tax-related compliance where required

• Prevent fraud and abuse of affiliate/referral systems

3.4 Communication

• Send order confirmations, receipts, account notifications, and service updates

• Respond to your inquiries and provide customer support

• Send educational content, newsletters, and promotional materials (you can opt out anytime)

• Notify you about new features, courses, or offerings

• Conduct surveys and request feedback

3.5 Business Operations, Security, and Compliance

• Process payments and manage billing, refunds, disputes, and chargebacks

• Maintain business records for accounting and operational purposes

• Prevent fraud, security threats, and unauthorized access

• Enforce our Terms of Service and protect our legal rights

• Comply with legal obligations and regulatory requirements

• Maintain backup and disaster recovery systems

3.6 Improvement and Analytics

• Analyze usage patterns and user behavior

• Monitor and improve Site performance and functionality

• Develop new features, products, and services (including new AI assistants)

• Conduct research and data analysis

• Test new technologies and capabilities

• Measure the effectiveness of our marketing campaigns

3.7 Marketing and Advertising

• Market our services, including showing ads on our Site and third-party platforms (where permitted)

• Retarget visitors who have shown interest in our services

• Measure advertising effectiveness and ROI

• Build audiences for marketing purposes (where permitted and subject to your choices/consent)

4. LEGAL BASIS FOR PROCESSING (GDPR)

5. HOW WE SHARE YOUR INFORMATION

We do not sell your personal information. We may share your information in the following circumstances:

5.1 Service Providers

We share information with third-party service providers who perform services on our behalf:

• Payment Processors: Stripe, PayPal, and other payment gateways

• Email Service Providers: For delivering newsletters and transactional emails

• Hosting Providers: For website hosting and data storage

• Analytics Services: Google Analytics and similar platforms

• Customer Support Tools: Help desk and communication platforms

• Marketing Platforms: Advertising networks and email marketing services

• AI Technology Providers: Services that power our AI Bot Vault features

5.2 Business Transfers

If we undergo a merger, acquisition, bankruptcy, or sale of assets, your information may be transferred to the successor entity.

5.3 Legal Requirements

We may disclose your information when required by law or to:

• Comply with legal processes, court orders, or government requests

• Enforce our Terms of Service and other agreements

• Protect our rights, property, or safety

• Prevent fraud or security threats

• Protect the rights and safety of our users and the public

5.4 With Your Consent

We may share your information with third parties when you provide explicit consent or direct us to do so.

5.5 Aggregated or De-Identified Data

We may share aggregated, anonymized, or de-identified information that cannot reasonably be used to identify you.

6. DATA RETENTION

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

• Account Information: Retained while your account is active and for a reasonable period afterward

• Transaction Records: Retained for tax and accounting purposes (typically 7 years)

• Communication Records: Retained for customer service and legal purposes

• Marketing Data: Retained until you opt out or withdraw consent

• Usage Data: Retained in aggregated form for analytical purposes

When we no longer need your information, we will securely delete or anonymize it.

7. DATA SECURITY

We implement reasonable administrative, technical, and physical safeguards to protect your personal information from unauthorized access, use, disclosure, alteration, and destruction. These measures include:

• Encryption of data in transit and at rest

• Secure server infrastructure and firewalls

• Access controls and authentication protocols

• Regular security audits and vulnerability assessments

• Employee training on data protection practices

However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

8. YOUR PRIVACY RIGHTS

Depending on your location, you may have the following rights:

8.1 Access and Portability

You have the right to request access to the personal information we hold about you and receive a copy in a portable format.

8.2 Correction

You have the right to request correction of inaccurate or incomplete personal information.

8.3 Deletion

You have the right to request deletion of your personal information, subject to certain exceptions (e.g., legal obligations, pending transactions).

8.4 Restriction and Objection

You have the right to request restriction of processing or object to processing of your personal information for certain purposes.

8.5 Opt-Out of Marketing

You may opt out of receiving marketing emails by clicking the "unsubscribe" link in any promotional email or contacting us directly. Even if you opt out, we may still send you transactional or service-related communications.

8.6 Cookie Preferences

You can manage your cookie preferences through your browser settings (see Section 9).

8.7 Do Not Track

Our Site does not currently respond to "Do Not Track" browser signals.

8.8 Withdrawing Consent

If processing is based on consent, you may withdraw consent at any time without affecting the lawfulness of processing before withdrawal.

8.9 Exercising Your Rights

To exercise any of these rights, please contact us at the information provided in Section 13. We will respond to your request within the timeframe required by applicable law (typically 30 days).

9. COOKIES AND TRACKING TECHNOLOGIES

We use cookies, web beacons, pixels, SDKs, and similar technologies to collect information and improve our services.

9.1 Types of Cookies We Use

• Essential Cookies: Necessary for the Site to function properly (e.g., authentication, security, shopping cart, account access)

• Performance Cookies: Collect information about how you use our Site to improve functionality and reliability

• Functional Cookies: Remember your preferences and settings (e.g., login state, language, saved preferences)

• Analytics Cookies: Help us understand user behavior and Site performance

• Advertising Cookies: Deliver targeted advertisements and measure campaign effectiveness (where permitted)

9.2 Third-Party Cookies and Similar Technologies

We use third-party services that may place cookies or use similar technologies on your device, such as:

• Google Analytics (or similar analytics tools)

• Meta/Facebook Pixel (or similar advertising pixels)

• Google Ads (or similar ad platforms)

• Affiliate/referral tracking platforms

• Payment and checkout providers (for secure transactions)

• Email marketing and CRM tools (for marketing attribution and delivery analytics)

9.3 Managing Cookies

You can control cookies through your browser settings and, where available, through any cookie banner or preference center on our Site. However, disabling certain cookies may limit your ability to use some features of our Site (for example, logging in or completing a purchase).

10. THIRD-PARTY SERVICES

We use third-party companies to help us operate our business and deliver our services. These providers may process personal information on our behalf as service providers/processors, depending on the relationship. Examples include:

• Payment processors and checkout providers (e.g., Stripe, PayPal or similar providers) to process purchases, subscriptions, refunds, and fraud prevention

• Email marketing and CRM providers to send newsletters, deliver course updates, and manage subscriber communications

• Course/community/hosting and storage providers to host content, enable community features, and store data

• Analytics providers to understand Site usage and improve performance

• Customer support tools (e.g., help desk and chat tools) to manage support requests

• Advertising and affiliate tracking partners to measure campaigns, attribute referrals, and manage affiliate commissions

• AI technology providers that support certain AI Bot Vault functionality

These third parties have their own privacy practices. Where required, we take steps to contractually require appropriate privacy and security safeguards.

Our Site may also contain links to third-party websites, services, or resources not operated by us. We are not responsible for the privacy practices of those third parties, and we encourage you to review their privacy policies before providing any personal information.

11. CHILDREN'S PRIVACY

Our services are not intended for children under 18 years of age. We do not knowingly collect personal information from children under 18. If we become aware that we have collected information from a child under 18, we will take steps to delete it promptly.

If you believe we have collected information from a child under 18, please contact us immediately.

12. INTERNATIONAL DATA TRANSFERS

Your information may be transferred to and processed in countries other than your country of residence, including the United States. These countries may have data protection laws that differ from those in your country.

When we transfer information internationally, we implement appropriate safeguards, such as:

• Standard Contractual Clauses approved by the European Commission

• Adequacy decisions by relevant regulatory authorities

• Other legally compliant transfer mechanisms

By using our services, you consent to the transfer of your information to countries outside your country of residence.

13. CALIFORNIA PRIVACY RIGHTS (CCPA/CPRA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA), subject to certain exceptions.

13.1 Categories of Personal Information Collected

In the last 12 months, we may have collected the categories of personal information described in this Privacy Policy, including identifiers (such as name and email), commercial information (such as purchase history), internet or other electronic network activity (such as usage data), approximate location data (based on IP), and inferences drawn from the above.

13.2 Right to Know / Access

You have the right to request information about:

• The categories of personal information we collected about you

• The categories of sources from which we collected it

• The business or commercial purposes for collecting, using, or disclosing it

• The categories of third parties to whom we disclose it

• The specific pieces of personal information we collected about you

13.3 Right to Delete

You have the right to request deletion of your personal information, subject to certain exceptions (for example, to complete a transaction, provide the service, detect security incidents, or comply with law).

13.4 Right to Correct

You have the right to request correction of inaccurate personal information.

13.5 Right to Opt-Out of Sale/Sharing (Targeted Advertising)

We do not sell personal information for money. However, some advertising and analytics activities may be considered “sharing” under California law. Where applicable, you may have the right to opt out of the “sharing” of personal information for cross-context behavioral advertising. If we offer a “Do Not Sell or Share My Personal Information” link or similar mechanism, you can use it to submit your request.

13.6 Right to Limit Use and Disclosure of Sensitive Personal Information

If we collect “sensitive personal information” as defined by California law, you may have the right to limit its use and disclosure, subject to certain exceptions.

13.7 Non-Discrimination

We will not discriminate against you for exercising your California privacy rights.

13.8 Authorized Agents

You may designate an authorized agent to make a request on your behalf. We may require verification of your identity and proof of authorization.

To exercise your California privacy rights, please contact us using the information in Section 15.

14. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will:

• Update the "Last Updated" date at the top of this policy

• Notify you via email or a prominent notice on our Site

• Obtain your consent if required by applicable law

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

15. CONTACT US

If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us:

Giame Digital Design LLC
Doing business as Creator Flow Collective
Website: www.creatorflowcollective.com

Email: support@creatorflowcollective.com

If you are located in the EEA, UK, or Switzerland, you also have the right to lodge a complaint with a data protection authority in your jurisdiction. If we are required to appoint an EU/UK representative or Data Protection Officer for your situation, we will provide that contact information upon request.

By using our Site and services, you acknowledge that you have read and understood this Privacy Policy.