Privacy
Welcome to CreateHQ!
CreateHQ is a platform where members can support and engage with creators. This updated Privacy Policy applies to members, creators, and all users of our platform, and is part of our Terms of Use.
CreateHQ is a U.S. based company. By using our platform, you agree that your personal information that you provide directly to us, or that we collect through your use of the platform, may be transferred to and stored in the United States and handled as described in this Policy.
Information You Provide Through Your Account
This is information that you provide to us through text fields, such as your name, payment information and benefits. The information we collect differs depending on if you make an account, become a member, or become a creator.
- First and Last Name
- Email Address
- Username
- Password
- State and Country of Residence
You may also sign up using a Google account. We will ask permission to access basic information from your Google account, such as your name, email, and profile picture. You can choose to stop sharing that information with us at any time by going to Google to remove CreateHQ’s access to that account and your ability to log in.
You also have the option to add more information to your public profile, such as a location, social media links, and an about section, which we store along with any comments or messages you submit on CreateHQ.
Members
A member is someone who joins CreateHQ’s membership platform to support a creator’s membership content. As a member you must provide your payment information to our payment processors. You can see the privacy policy for these payment processors on the Stripe website. At this time, CreateHQ does not receive your full card number. Payment processors provide us with a token that represents your account, your card’s expiration date, card type and the last four digits of your card number. If you are required to provide your name and email address to the payment processor, then they also provide us with that information.
We collect and process information about the creators you support, the level at which you support them, what benefits you receive and how often you support them.
Creators
A creator is someone who creates and provides content for their subscribers through CreateHQ’s platform. To become a creator, you must create a page that describes what you are creating and any benefits you are offering. To receive payouts you have to create an account with one of our payment partner; Stripe. We may also require your bank account information to process payouts. You must also provide us with additional information for tax purposes. Depending on your location you may have to fill out a form with some combination of your:
- First and Last Name
- Address
- Social Security Number or Employer Identification Number
- Country of Citizenship
- Foreign Tax Identification Number
- Date of Birth
- Your Nonprofit Registration Number, if you are a nonprofit business
- Bank Account Information for Payouts
- Phone Number
Additional Information We Collect
Automatically Collected Information
We collect information automatically as you navigate the site or through our third party analytics providers. We may store usage information such as the type of device you use to access CreateHQ, your operating system, browser type, IP address, and device ID, the pages you visit or request, links clicked, referring sites, user interactions and your search terms. We also derive your location from your self-disclosed country, your IP address, and from your payment card.
Forums and Messaging
When you participate in a forum, we collect the comments you make as well as record how many times users visit, the activity on the site, where users have replied, with whom they’ve communicated, private messages, IP address, and from which location the user was last logged in. This means that they may access your information to help provide the forum.
User Surveys
From time to time, we may solicit your participation in user surveys. We may ask you demographic information, including information related to your gender, ethnicity, race, age, earnings, and accessibility to better understand and serve our user base which you may elect to share or not. We collect such information to ensure we provide fair and equal access to our services, and to showcase creators to members for greater discoverability. To the extent that you participate, we will store your survey responses.
Event Information
At in-person and online events, we may request information from you. This is done to better tailor the event experience to those in attendance. This information may include your name, email address, payment details, mobile phone number, demographic information, social media and other online accounts you maintain, details around the types of works you create, and survey or feedback responses.
Blogs
We may collect and store your email address, your comments, and your profile information from our website to better understand your interests and improve our services to you.
Information Collected by Third Parties
Social Media Features and Widgets
We use social media features, such as the Like or Share button or similar interactive mini-programs that run on CreateHQ. If you provide your social media information to us, we may use it to interact with you on these social networks. These features may collect your IP address and other personal data including which page you are visiting on our site and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on CreateHQ. Your interactions with these Features are governed by the privacy policy of the company providing it. For more information on the technologies used by these social networks, please refer to their specific privacy notices. We have provided links to the most used social networks below for easy reference:
- Facebook: https://www.facebook.com/about/privacy/
- Twitter: https://twitter.com/privacy
- YouTube: https://policies.google.com/privacy
- Instagram: https://help.instagram.com/155833707900388
- Twitch: https://www.twitch.tv/p/legal/privacy-notice/
How We Use Your Information
We process your information to:
- verify your identity to comply with US federal, state, and international laws
- allow you to sign in to your account
- allow you to support a creator’s membership program on CreateHQ
- process membership payments and payouts
- send you emails relevant to your usage, as controlled by your email preferences
- reply to your questions
- provide to you existing and enhanced services related to your CreateHQ account
- promote your CreateHQ account for greater discoverability
- spotlight and celebrate creators
- market CreateHQ products and services to you or to audiences similar to you based on your networks and common factors that others have with you, unless you opt out, as controlled by your email preferences
- understand how you use the service, and create better tools for creators to serve members
- conduct research and development to improve CreateHQ and develop future products
- prevent fraud and abuse on CreateHQ
- provide you with reasonable accommodation, if you notify us of a disability
Information We Share with Creators
By becoming a subscriber of a creator, you agree to have the following information shared with that creator:
- your name and email address, and other profile information you’ve provided
- any messages you send creators through CreateHQ
- your physical address, city, state, and country
- your phone number, when you have signed up to support a creator who engages with you via text messages, when you are receiving a benefit that requires shipping, or when you have signed up for event notifications via text
- all information about your pledge, including amount and start date, but not your full payment card information
- some aggregated and anonymized data about how you use CreateHQ that cannot be linked back to you or to any individual user
Creators agree to the terms of our Data Processing Agreement (DPA) when they start their signup with CreateHQ. This DPA is called the Creator Privacy Promise. The Creator Privacy Promise is a creator’s promise to protect the privacy of their members during and beyond their CreateHQ relationship.
Information We Share with Third Parties
We never sell your information to third parties. We will only share data with third parties, other than with creators, under the following circumstances:
- with your consent, to creators’ service providers, to deliver benefits, such as to ship packages to you. You should read these service providers’ privacy policies to see how they use and share your data.
- with our service providers, who are companies that are contractually engaged with us to provide us with services, such as order fulfillment, email management, analyzing data trends, credit card processing, multi currency settlement solutions, increasing our brand awareness and user engagement with marketing initiatives, and fraud detection and prevention. These companies may have access to your data to perform their services, and are obligated by contract to safeguard any of your data they receive from us to the same extent that CreateHQ protects it.
- to protect the security or integrity of CreateHQ, and to protect the rights, property, or safety of CreateHQ, its employees, users, or others, if we believe that disclosure is reasonably necessary to comply with a law, regulation, or other valid legal process (e.g., subpoenas or warrants served on CreateHQ). If we are going to release your data, we will do our best to provide you promptly with notice by email, unless we are prohibited by law from doing so.
- in connection with the sale, merger, bankruptcy, sale of assets or reorganization of our company. We will notify you if a different company receives your data. The promises in this privacy policy apply to any data transferred to a new entity.
- with third party apps used by creators to help run their membership programs. While we try to keep this list up to date, we often experiment with new third party app providers, and this list may not be exhaustive.
Information CreateHQ Collects from Third Party Applications
When you create a CreateHQ account, you can elect to connect your social account(s) with CreateHQ, and we will collect and store some social information from those platforms, such as:
- follower or subscriber counts
- post or upload counts
- view, like, and comment counts
This social information allows us to provide you a better CreateHQ experience, and also helps guide future development of CreateHQ. We use this data to:
- help creators and members find each other on CreateHQ
- assess how to make creators more successful on CreateHQ
- analyze and describe our business
Information We Share with the Public
The following information is publicly accessible:
- your profile, and your social media links and location if you add that information
- by default the creators you support are publicly displayed. If you flag your account as private, we will not display the creators you support
- any posts, likes, or comments you make
- your aggregated or anonymized usage data in blog posts, press releases, or in other ways to share information about CreateHQ’s usage. Aggregated or anonymized data cannot be linked back to any individual CreateHQ user
- monthly pledge value and goals that creators choose to make public
- number of members
Your Preferences and Rights over Data
Choosing Your Preferences
Settings lets you see your account preferences. You can see and adjust your settings by viewing your preferences and, if you wish, by changing your selections.
Marketing Activities
By agreeing to our terms of use, you expressly agree that CreateHQ may:
- provide you with information about your service, service enhancements, or new CreateHQ products, while you are on our web site or using our apps.
- send you messages regarding your existing service, or enhancements related to your existing service, when you are off our platform, via email, or via text, if you have signed up for a service or event notification that uses text messages.
- send you messages related to services we provide which are separate from your existing service via email, from which you may opt out.
- market CreateHQ to you and audiences similar to you based on your networks and common factors that others have with you, unless you opt out.
- send you marketing emails or texts if you don’t have a CreateHQ account but have consented to receiving such messages, from which you may opt out.
- ask for demographic information to spotlight and celebrate creators.
- promote your account for greater discoverability.
- ship physical items to you via mail as part of a promotional activity.
Deleting Your Account
You may self-initiate a deletion of your account under the privacy & security tab when editing your profile.
Additionally, you may delete your account and export all of your personal information by going to the privacy and security tab when editing your profile
Turning off Email Notifications
You can change your email notifications in your email settings. While this allows you to stop many notification emails, we will still send some critical service emails.
Turning off Mobile Notifications
If you download the CreateHQ App you may also receive notifications on your mobile device. These can be disabled in the App settings.
Verification of Requests
Users maintain password protected accounts with CreateHQ. If you submit a request to exercise your privacy rights, you will be asked to verify the request by logging into your CreateHQ account.
If we are unable to verify your request, then for your protection, we reserve the right to deny the request.
Compliance with EU Privacy Laws and Privacy Shield
CreateHQ is an international company that complies with the General Data Protection Regulation (GDPR). We act as Data Controllers, as defined under the GDPR, and process personal data based on our legitimate interests, and for contractual necessity in providing you the Service as described in “How We Use Your Information.” We also process and share personal information based on notification and users’ consent, which our users may revoke at any time.
CreateHQ relies on various legal bases to lawfully execute international transfers of personal information, including the European Union Commission approved standard contract clauses.
CreateHQ complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. CreateHQ has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit: https://www.privacyshield.gov/.
Under limited circumstances, you may invoke binding arbitration before the Privacy Shield Panel. More Information about this arbitration process can be found at: https://www.privacyshield.gov/article?id=G-Arbitration-Procedures.
CreateHQ is responsible for the processing of personal information it receives or subsequently transfers to a third party acting as an agent on CreateHQ’s behalf. CreateHQ complies with the Privacy Shield Principles for all onward transfers of personal information, including the onward transfer liability provisions.
With respect to personal information received or transferred pursuant to the Privacy Shield Frameworks, CreateHQ is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.
Compliance with California Privacy Laws
CreateHQ’s headquarters are located in Sacramento California, USA, and we are subject to the California Consumer Privacy Act.
Effective January 1, 2020, the California Consumer Privacy Act (CCPA) allows California residents to request access to the specific pieces and categories of personal information that the business has collected about the consumer, the categories of sources for that information, the business or commercial purposes for collecting the information, and the categories of third parties with which the information was shared.
Exercising Your Data Rights
Users in certain locations may have certain rights under the General Data Protection Regulation (GDPR) or under the California Consumer Privacy Act (CCPA) regarding data that CreateHQ controls as a Data Controller as defined under the GDPR, including:
- the right of access to their personal data,
- the right to correct or rectify any inaccurate personal data,
- the right to restrict or oppose the processing of personal data,
- the right to erase or delete their personal data,
- the right to personal data portability, and
- the right to opt-out of the sale of personal information.
Account Holders with Disabilities
CreateHQ is committed to accessibility for its account holders with disabilities. If you are having difficulty accessing your account, please email us for assistance.
Contacting our Data Protection Officers
If you have privacy concerns or questions, you can contact our European or US Data Protection Officers (DPOs) via email at support@CreateHQ.com. You may also mail a letter to the DPO with your questions.
For U.S. users, mail to “CreateHQ Team, 3400 Cottage Way, Ste G2 #7967 Sacramento, CA 95825.
Establishing an Authorized Agent
You may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government ID, and the authorized agent’s valid government ID. To protect your information from account takeover, we may decline access to or recovery of your account at our discretion.
Prohibition against Discrimination
We do not discriminate against users who exercise their privacy rights.
Our Data Retention Period
We retain your account information for ten years after your account is last active, unless you delete, or you request us to delete, your account. We may continue to retain some information, even after you delete your account if we are required to do so in order to comply with various laws.
Children
CreateHQ is not directed at children under the age of 13, and children may not create an account or otherwise use CreateHQ.
Changes
We may sometimes make changes to this policy. If we make material changes that adversely affect your rights under this policy, we will let you know by posting an announcement on the site or sending you an email in advance of the changes coming into effect. Continuing to use CreateHQ after a change to this policy means you accept the new policy.