THE CREATOR OF CHANGE, LLC PRIVACY POLICY
This Privacy Policy applies to personal and other information that may be collected when you interact with The Creator of Change, LLC (hereinafter “The Creator of Change”).
Protecting the privacy and security of your personal information is a priority at The Creator of Change, and we believe that a single, comprehensive privacy policy that is straightforward and clear is in the best interests of our customers and our businesses. Personal information is sometimes referred to as personal data in certain jurisdictions.
The Creator of Change reserves the right to modify or amend this Privacy Policy at any time. You will be notified of any material changes to this Privacy Policy which are less protective of customer information prior to such changes becoming effective. We may notify you of these changes by email reminders, by notice on this site, or by other acceptable means. Such modifications will only apply to information collected on, or after, the date of the modification.
Below you will find answers to the following frequently asked questions about how we collect, use and share your personal information:
- What is the personal information that we collect?
- Why do we collect personal information?
- How do we collect your personal information?
- How do we use personal information?
- With whom do we share personal information?
- How do we secure personal information?
- How do we respect your choices about your personal information?
- The Creator of Change does not sell or share your personal information.
- Whom do I contact if I have questions or concerns?
- What other information about The Creator of Change’s Privacy Policy would I want to know?
- What is the personal information that we collect?
Depending on how you choose to interact with The Creator of Change, we may collect personal information from you, for example your name, email address, billing address, shipping address, phone number, credit card or bank account information, date of birth and other persistent identifiers that can be used to personally identify you. We may also collect other personal information regarding your interaction with The Creator of Change Websites, Devices and Apps, including usage information, the items that you browse, purchase, download, read, watch and otherwise access, and your geographic location, and your communications with The Creator of Change.
- Why do we collect personal information?
We collect your personal information in an effort to provide you with a superior customer experience and, as necessary, to administer our business. It allows us to provide you with easy access to our products and services, with a particular focus on the items and programs that may be of most interest to you. For more information as to why we collect personal information, please see the section below entitled: "How do we use your personal information?"
Your personal information also allows us to communicate with you about special offers, promotions, and other marketing programs and news that may be of interest to you. You always have the opportunity to unsubscribe from promotional emails by following the instructions included in each marketing email or by changing your preferences in your account. You may unsubscribe from mobile notifications by changing your settings in the Apps or on your The Creator of Change or third-party device.
- How do we collect your personal information?
(a) Information that you provide to us
As a general matter, you can browse in our stores and on The Creator of Change Websites without submitting your personal information to us, although we may receive and collect certain personal information automatically, as outlined in Section 3(b) of this Privacy Policy, including site analytics regarding our websites, information your Internet browser automatically sends when you visit our websites, and information collected by cookies.
However, there are a number of circumstances in which you may need to provide us with your personal information.
The most common of these circumstances include:
Making a purchase or placing an order
Creating an account or joining The Creator of Change Member Programs
Enrolling in the Paper Source Marketing Program
Using The Creator of Change Websites, Devices and Apps
Contacting customer service
Entering a sweepstakes or contest
Interacting with social networking sites
Signing up for promotional communications
For your convenience, we have provided a summary description of each of these circumstances below:
Making a purchase or placing an order
When you make a purchase or place an order in our online store, you may need to submit personal information to us.
Creating an account or joining The Creator of Change Member Programs
In order to use Devices, certain Apps and features of The Creator of Change Website, or to purchase or access Digital Content, you may be required to create a password-protected user account and provide us with personal information when you do so. Similarly, when you enroll in our The Creator of Change Premium Membership Program, The Creator of Change Rewards, The Creator of Change Educator Program, or Paper Source Marketing Program, we will ask you to submit personal information as part of your member profile. We will store and use this information to administer the programs and services in which you choose to participate, and as permitted by this Privacy Policy.
Using The Creator of Change Websites, Devices and Apps
The Creator of Change Websites, Devices, and Apps may provide you with the ability to enter (either directly, or by authorizing The Creator of Change to access the information from a third-party such as a social networking site or application) certain information such as your contacts, calendar entries or photos, or images you may submit to us to help us locate products for you.
Contacting Customer Service
When you contact customer service, we may ask you to provide, or confirm, personal information so that we can better serve you.
Entering a sweepstakes or contest
If you enter a sweepstakes or contest we offer, we may ask you to provide personal information so that we can consider your entry and, if you win, so that you may redeem your prize.
Interacting with social media sites
Our Devices and Apps may provide you with the ability to enter (directly, or by authorizing us to download the information from a third-party such as a social media site or application) personal information such as contacts or lists of friends. These or related applications may also allow you to provide information directly to social media sites including information about your purchases, physical location, or comments.
Signing up for promotional communications
If you sign up to receive promotional communications or notifications from us, we may ask you to provide personal information so that we can provide these to you.
(b) Information automatically collected
There are circumstances in which we automatically receive and collect information from you. The most common sources of this information include:
Web server logs
Cookies
Pixel tags or clear GIFs
Third-party web analytics services
Targeted advertising
Your Device or Apps you use
Geolocation, including general and precise location information
Social media sites
Business partners, contractors, and other third parties
For your convenience, we have provided a summary description of each of these circumstances below:
Web server logs
When you visit a The Creator of Change Website, our web servers may automatically log information that your browser sends us. For example, we may receive and collect: the name of the domain and host from which you access the Internet; the Internet Protocol (IP) address of the computer you are using; the date and time you access the The Creator of Change Website; and the Internet address of the website from which you linked directly to the The Creator of Change Website. We may also collect information regarding search queries run on the The Creator of Change Website. We use this information to monitor the usage of the The Creator of Change Websites and as necessary for our business.
Cookies
Like many online retailers, we and/or our third-party providers use cookies to recognize you as you use or return to the The Creator of Change Websites. This is done so that we can personalize and enhance your browsing and shopping experience. "Cookies" are small files that are placed in your browser to collect information about your activities on a The Creator of Change Website. Cookies help us to: (1) speed navigation, keep track of items in your shopping bag and provide you with content that is tailored to you; (2) remember information you gave us so that you do not have to re-enter it; (3) determine the effectiveness of some of our marketing efforts and communications; and (4) monitor the total number of visitors, pages viewed, and the total number of ads displayed.
Browsers are typically set to create cookies automatically. You can choose to have your browser notify you when cookies are being written to your computer or accessed, or you can disable cookies entirely. To learn more about the types of cookies that we use and how to manage your cookie settings please click here to access our Cookie Policy.
Pixel tags or clear GIFs
We may use sensing technologies that use pixel tags or clear GIFs (which are also called web beacons). These technologies allow us to determine the effectiveness of our email and advertising and marketing efforts. For this purpose, we tie the pixel tags and clear GIFs to personally identifiable information. We may also collect information regarding the links within such marketing materials that you click on and purchase statistics regarding items you buy following receipt of such marketing.
Third-party web analytics services
We work with third-party service providers, including but not limited to Adobe Analytics, Google Analytics, and Localytics to help us better understand how you use the The Creator of Change Websites. These third-party service providers will place cookies in your browser to collect information such as how you were referred to the The Creator of Change Website, how you navigate around the The Creator of Change Website, what you purchase and what traffic is driven by various marketing methods. This information will help us to better serve you and provide you with more personalized information and product offerings. We do not allow third-party service providers to collect your credit card information, email address, or password information. These third-party service providers may only use your personal information to perform services for us and may not share your personal information with anyone else, or use it for any other purpose, except on an aggregated, non-personally identifiable basis.
To learn more about the privacy practices of Adobe, you may review its privacy policy located here. To exercise your choice with respect to their collection of information on The Creator of Change Websites, please click here.
To learn more about the privacy practices of Google, you may review its privacy policy located here. To disable the Google Analytics cookie and other third-party web analytics service provider cookies, you can choose to have your browser notify you when cookies are being written to your computer or accessed, or you can disable cookies entirely.
Targeted advertising
We may partner with third-party advertising networks that collect IP addresses, unique device identifiers (UDIDs), browser type, operating system, time zone, country, referring pages, and other information through the use of cookies, web server logs and pixel tags on The Creator of Change Websites, Apps, emails and on third-party websites and emails. They use this information to provide you with advertisements that are customized to your particular preferences, including for companies that are not affiliated with us. You may see these advertisements on The Creator of Change Websites and third-party apps and websites, and across different devices you use. The Creator of Change does not control these third-party cookies. We may use this process to help us manage and improve the effectiveness of our marketing efforts. If you would like to learn more about the third-party advertisers that may be aware of the fact that you visit The Creator of Change Websites or use our Apps, and to understand your opt-out choices, please visit the website of the National Advertising Initiative here. Please note this does not opt you out of being served advertising. You will continue to receive generic ads.
Some of the activities described in this section may constitute “targeted advertising,” “sharing,” or “selling” under certain laws. Depending on where you reside, you may, have the right to opt out of targeted advertising, sharing, and sales of your personal information. You can do so by following the prompts here. To learn more about the choices available to you with respect to these practices, see below.
Your Device or Apps you use
When you use a Device or our Apps, we automatically collect information through the Device or App when it is connected to the Internet. For example, we may receive and collect information concerning device registration, operating system, settings, usage, firmware version, signal strength, search queries, network interaction, the name of the network from which you access the Internet, the Internet Protocol (IP) address of the device you are using, unique device identifiers (UDIDs), downloads, sideloaded content, configuration, or service information relating to any malfunction of the Device or App. This may include information regarding your activity on such Devices or Apps, such as books opened, date and time of use, time elapsed, page turns, bookmarks, annotations, or customer reviews.
Geolocation
In addition, to provide location-based services on Devices or through Apps, The Creator of Change and third-party application providers may automatically collect real-time geographic location information or other location-based information about you and your Device or other mobile device on which the App is installed. This information may be used to provide certain device or application functionality or to offer, provide and improve products and services (e.g. proximity to local The Creator of Change Stores).
Social media
We may provide you the ability to sign into a The Creator of Change Website or App using a social media account such as a Facebook, Twitter, Instagram, Snapchat, or Google account, or use your social media accounts to share information from The Creator of Change Websites, Devices or Apps. In these cases, as well as when you use a The Creator of Change app on a social media site or choose to join (or "like") a The Creator of Change page on a social media site, the social media site may provide us with certain information about you, including but not limited to your contacts and other "likes". In addition, we may share your information, including personal information, with third-party vendors to facilitate your choice to sign into a The Creator of Change Website or App using a social media account. Please see the privacy policy for the applicable social media site to learn more about how these sites use and share your personal information.
Business partners, contractors, and other third parties
We may collect personal information and other information about you from business partners, contractors and other third parties. This includes, but is not limited to, instances in which you affirmatively authorize third parties to provide us with information. Such information may be collected via, but not limited to, software applications that you download or use on your Device or that otherwise allow you to interact with the The Creator of Change enterprise.
- How do we use your personal information?
The Creator of Change uses your personal information across our enterprise to provide you with a superior customer experience and, as necessary, to administer our businesses. For example, we use your personal information to:
Provide you with products, services and information across the The Creator of Change enterprise, including product and subject recommendations and other information in The Creator of Change retail stores, through emails from our businesses, and on the The Creator of Change Websites and online interactive communities, your Devices, Digital Content, Apps and software, and display associated content and advertising;
Administer our programs;
To protect against deceptive and fraudulent activity;
Provide customer service in stores, by telephone and online;
Conduct research and perform analysis in order to measure, maintain, protect, develop and improve our products and services;
Administer sweepstakes, contests, promotions or surveys and provide appropriate notifications;
Communicate with you about special offers, events, or new products or services that may be of interest to you;
Customize and enhance the The Creator of Change Websites and advertising;
Make communications necessary to notify you regarding security, privacy, and administrative issues; and
Manage our business.
- With whom do we share personal information?
Protecting the privacy and security of your personal information is a priority at The Creator of Change. Except as described in this Privacy Policy, The Creator of Change will not provide your personal information to third parties without your consent. The Creator of Change shares your personal information with:
Other entities within The Creator of Change enterprise. The Creator of Change owns and operates other operations and businesses and we may share your personal information with our other business units and operations, even if such business units or operations are sold.
Service providers, subcontractors and agents who perform services on our behalf. We provide personal information to third-party service providers, subcontractors, and agents that work under contract on our behalf to provide certain services. These include third-party service providers who help facilitate any communications you may have with The Creator of Change on its website—those communications may be recorded and shared with these third parties to assist The Creator of Change in providing this service. These third parties do not have the right to use personal information we provide to them in any way that is not authorized by The Creator of Change. They are contractually obligated to use such information only as necessary to assist us and to maintain the confidentiality and security of such information.
Providers of products and services. These are third parties that provide products and services you may purchase or request from or through us. These providers of products or services do not have the right to use personal information we provide to them in any way that is not authorized by The Creator of Change. They are contractually obligated to use such information only as necessary to assist us and to maintain the confidentiality and security of such information.
Credit card companies. Credit card transactions are handled by third-party financial institutions and their vendors and contractors who receive credit card numbers and other personal information from us to verify the credit card numbers and process transactions. Although The Creator of Change’s treatment of this information is governed by this policy, the use of your information by the third-party financial institutions and their vendors and contractors will be subject to their own privacy policies.
Law enforcement officials and as required by law. The Creator of Change may release personal information to third parties when we determine, in our judgment, and without your consent, that it is necessary to (a) comply with the law, regulation, legal process, or enforceable governmental request; (b) enforce or apply the terms of any of our policies or user agreements; (c) establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies, (d) protect the rights, property or safety of The Creator of Change, our employees, our customers, users, or others; or (e) to comply with your request for the shipment of products to or the provision of services by a third-party intermediary.
Co-branded offerings. In some instances, we may offer a service or feature that is co-branded by The Creator of Change and a third-party company. If you provide information in connection with such co-branded service or feature, that information may be shared between The Creator of Change and the third-party. Although The Creator of Change’s treatment of the information is governed by this policy, the third-party’s treatment of your information will be subject to the third-party’s privacy policy.
Other websites operated by The Creator of Change. In some instances, we may operate a The Creator of Change Website on behalf of a third-party. If you provide information in connection with a The Creator of Change Website operated by The Creator of Change on behalf of a third-party, that information may be shared between The Creator of Change and the third-party. Although The Creator of Change’s treatment of the information is governed by this policy, the third-party’s treatment of your information will be subject to the third-party’s privacy policy.
Certain Digital Content providers. In certain cases, we may be required to forward your name, email address, IP address, and shipping or billing address to certain content providers in connection with your order. The content providers may share this information with the applicable publisher and circulation auditors, and may use this information to fulfill your order and for other purposes. In these cases, the terms of the privacy policy of the publishers whose content you have purchased or downloaded will apply to you. If you do not wish to receive marketing communications from these publishers, you must contact the publisher directly.
Sales, mergers, and acquisitions. If The Creator of Change becomes involved in a merger, acquisition, restructuring, reorganization, or any form of sale or other disposition of some or all of its assets, personal information and your transaction history may be provided to the entities and advisors involved subject to a confidentiality agreement, and we will provide notice to you at your email address on file before any personal information is finally transferred and becomes subject to a different privacy policy. Such a transaction may involve us (i) retaining the right to continue to use transferred personal information in addition to the right of the transferee to use such information, and (ii) engaging in additional transfers of personal information (including new personal information) with the transferee from time to time following such a transaction.
Your Consent. We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this policy.
- How do we protect personal information?
No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use commercially reasonable efforts to protect your personal information from unauthorized access, use, or disclosure, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of a breach to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.
Some of our websites permit you to create a The Creator of Change account. When you do you will be prompted to create a password. You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else that has obtained your password, whether or not such access or use has been authorized by you. You should notify us of any unauthorized use of your password or account. For more information, please visit the The Creator of Change Terms and Conditions of Use.
- How do we respect your choices about your personal information?
You may choose to opt out from receiving marketing and promotional communications from The Creator of Change at any time by following the instructions below.
For The Creator of Change account Holders: Any account holder can opt-out of the receipt of any promotional communications by logging onto their Account and following the instructions under "Communication Preferences". If you do not have a The Creator of Change account, you may opt out of the receipt of such communications by selecting the link at the bottom of any promotional email communication and following the instructions.
For The Creator of Change Member programs: Any participant can opt out of the receipt of any Member program promotional communications by logging on to their The Creator of Change account and following the instructions under "Change Your Communication Preferences." If you do not have a The Creator of Change account, you may opt-out of the receipt of such communications by selecting the link at the bottom of any promotional email communication and following the instructions.
- The Creator of Change does not sell or share your personal information.
We do not provide your name, phone number, address, email address or other personally identifiable information to third parties in exchange for money.
However, under certain state privacy laws, sharing information for advertising purposes may be considered a “sale” or “sharing” of “personal information.” “Sale,” broadly means scenarios in which we have disclosed personal information with partners in exchange for valuable consideration. “Sharing” means that we make available or otherwise disclose your information to third parties for cross-contextual behavioral advertising, such as targeting advertising to you based on your personal information obtained from your activity across businesses, websites, apps, and services other than our Services.
You have the right to opt out of the “sale” or “sharing” of personal information, and we’ve made it possible for you to stop the information transfers that might be considered such a “sale” from our website or applications by visiting the following link: Do Not Sell My Personal Information. We will not discriminate against you for exercising your privacy rights.
Analytics
You may choose to opt out of collection of automatically collected information, including cookies, Adobe Analytics, Google Analytics, and Localytics, by following the instructions given in Section 3(b) above, or by using the functionality in your browser to reject cookies.
Targeted Advertising
You may choose to opt out of targeted advertising, by following the instructions given in Section 3(b) above, or by using the functionality in your browser to reject cookies. You may also opt out of the sharing of your personal information for targeted advertising purposes by visiting the following link: Do Not Sell My Personal Information or by visiting our Services with a legally-recognized opt-out preference signal enabled (such as the Global Privacy Control).
Online Community Users
The Creator of Change provides you with the ability to access, correct, change or request deletion of the personal information in your community profile(s) at any time by following the instructions below. However, you cannot currently change your profile name although you may re-register and choose a new name. To review or modify your profile information, please click here. Please be advised that The Creator of Change may archive information it collects on its community and visitors. Additionally, by participating in the The Creator of Change online interactive community, including but not limited to, the submission of customer reviews, participation in The Creator of Change’s other various interactive offerings, you agree to receive communications from The Creator of Change, other users, and moderators related to the provision of these services.
Your Privacy Rights and Choices
You have the right to ask us not to use your personal information for direct marketing purposes. You have the right to request a copy of the personal information that we hold about you and to have any inaccuracies rectified. You have the right to request that we delete your personal information. If required by law we will grant a request to delete information, but you should note that in many situations we must keep your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our business purposes.
Please address written requests and questions about your rights on our Contact form. You may submit a request for a copy of the personal information that we hold about you through our online portal.
Note that, as required by law, we will require you to prove your identity. We may conduct an identity verification by phone call or email. Depending on your request, we will ask for information such as your name, the last item you purchased from us, or the date of your last purchase from us. We may also ask you to provide a signed declaration confirming your identity. Following a request, we will use reasonable efforts to supply, correct or delete personal information about you in our files.
If we deny your request, you may appeal our decision by contacting us at email. Please include all prior communications with us concerning your request. If you have concerns about the results of an appeal, you may contact the attorney general in the state where you reside.
- Whom do I contact if I have questions or concerns?
If you have any questions about this Privacy Policy, please contact us on our Contact Form.
- What other information about The Creator of Change’s Privacy Policy would I want to know?
Policies for Minors, including children under the age of 16
The Creator of Change is committed to complying with all applicable laws and regulations regarding the collection, storage and use of personal information of Minors under the age of 16, including the Children’s Online Privacy Protection Act of 1998.
Except as noted below: (i) our products and services are marketed for and directed towards purchase by adults or with the consent of adults; (ii) Individuals under the age of 18 ("Minors") are not permitted to use The Creator of Change Websites or Apps without the supervision of a parent or legal guardian; (iii) we do not knowingly collect or solicit personal information from children under the age of 16 or knowingly allow such persons to register for an online account or to post personal information on the The Creator of Change Websites; and (v) should we learn that someone under the age of 16 has provided any personal information to or on any of the The Creator of Change Websites, we will remove that information as soon as possible.
We do not knowingly sell or share personal information about consumers under the age of 16.
If we direct certain Devices features or Apps to Minors who may be under the age of 16, we require the parent or legal guardian to provide verifiable consent to such Minor’s use of our products and services and our collection of personal information in connection with such use. In these cases, we require validation of credit card information already on file with us and we will then email the master account holder to give notice that we have received such consent. If no credit card information is on file, or if the credit card is invalid, we will not register that you have consented. With your consent, we may collect, use and share information regarding Minors under the age of 16 consistent with this Privacy Policy. Please see the sections above for detailed information on how we do so.
If you are a parent or guardian who believes that your Minor under the age of 16 has submitted personal information or other information to us without your consent, please contact us on our Contact Form. Once we verify that you are the parent or legal guardian, at your request, we will promptly provide to you information regarding what, if any, personal information we have collected about your child and how it has been used or shared. We will, at your request, remove personal information about your child from its database and instruct our affiliates to do the same.
If you are a Minor under the age of 18, you may request and obtain removal of certain content or information posted on The Creator of Change Websites and Apps by contacting us on our Contact Form with “Privacy Rights for Minors” in the subject line. Please be advised that our removal of your post(s) does not ensure complete or comprehensive removal of the content or information you have posted on The Creator of Change Websites or Apps.
Data retention policy
We will retain your information for as long as your account is active or as needed to provide you with services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Otherwise, personal information associated with expired or deactivated accounts will be deleted within two (2) years of inactivity or deactivation.
Authorized Agent policy
You may use an authorized agent to submit a request to access your information, delete your information, or opt out of the sale of your information. To designate an agent for these purposes:
You must provide us with a copy of a written and signed permission given to your authorized agent; and
You must verify your own identity directly with us.
Additional Disclosures for Individuals In California
The California Consumer Privacy Act, as amended by the California Consumer Privacy Rights Act (“CPRA”) requires us to explain some information using certain definitions and categories. If you reside in California, this section applies to you and describes our data practices today and in the preceding 12 months.
Personal Information Collected and Shared
California laws and regulations require us to disclose what categories of information we have collected in the last twelve months and what categories of information we have “shared” or “sold” as those terms are defined under California law. You can find a list of the categories of information that we have collected and shared or sold, as those terms are defined under the CPRA here. Please note that because these lists are comprehensive, they may refer to types of information that we share about people other than yourself. If you would like more information concerning the categories of personal information (if any) we share with third parties or affiliates for those parties to use for direct marketing please submit a written request to us using the information in the “Contact Information” section below. We do not discriminate against California consumers who exercise any of their rights described in this policy. You can find additional information regarding the number of requests The Creator of Change received and responded to under the California Consumer Privacy Act here.
Do Not Track Disclosure
Certain web browsers may provide an option by which you may ask your browser to inform websites you visit that you do not wish your activities to be tracked by cookies or other persistent identifiers, commonly called "Do Not Track Signals". Although The Creator of Change Websites are currently unable to respond to Do Not Track Signals, you may opt out of tracking activities by following the instructions in this Privacy Policy to opt out of web analytics and behavioral advertising.
Shine the Light
California law permits residents of California to request certain details about how their information is shared with third parties for direct marketing purposes. Under the law, a business must either provide this information or permit California residents to opt in to, or opt out of, this type of sharing. We qualify for this alternative option. To opt out of having information about you shared with third parties for direct marketing purposes, please visit the following link: Do Not Sell My Personal Information.
Important information about third-party devices, ISPs, websites and applications
This Privacy Policy applies solely to information collected by the The Creator of Change enterprise. Whenever you click on links and banners on any The Creator of Change Website that take you to a third-party website or you use, download or install third-party software applications onto your Device, your use of those third-party websites and/or software will be subject to the third-party’s privacy policies, not The Creator of Change’s. Additionally, please note that when using The Creator of Change Websites or Apps, third-party mobile device manufacturers and internet service providers (ISPs) may collect personal information about you and your use of such third-party products and services will be subject to the third-party’s privacy policies.
In addition, our website includes links to other websites whose privacy practices may differ from those of The Creator of Change. If you submit personal information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit.
Notice of Financial Incentive and Bona Fide Loyalty Programs
We provide price discounts, coupons, services and other benefits for (1) members of our The Creator of Change Premium Membership Program, The Creator of Change Rewards, The Creator of Change Educator Program, Paper Source Marketing Program, Cafe and other customer programs; (2) large volume customers; (3) members of our mailing list; and (4) The Creator of Change Account Holders (collectively “Programs”). Through these offerings, customers provide us with the necessary personal information (e.g., names, emails, phone numbers, educator credentials) when they opt-in to our programs. There is no obligation to opt-in and customers may opt-out at any time. The details of each Program are contained in the terms and conditions for each Program. We offer these Programs, among other things, to enhance our relationship with you so you can enjoy more of our products/services at a lower price. We invest heavily in our marketing and brands, in part, so we can provide Programs to our customers. The value to our business of customers’ personal information is dependent on specific facts such as whether and to what extent they, in the aggregate, take advantage of any offerings and whether and to what extent they opt-out of any offerings. Our ability to create any value from the Programs is heavily based on our ability to leverage said intellectual properties. We do not calculate the value of customer data in our accounting statements. To the extent we create overall value from our Programs to our business that could be directly or reasonably related to the value of customer data in the aggregate, the method for calculating same would include: the costs associated with (1) our intellectual property; (2) enhancing customer data by our marketing team’s efforts; (3) leveraging our significant investments in understanding you as our existing and future customers; (4) all other costs reasonably related to the programs and (5) for each program, and in the aggregate, whether the sales generated by the program(s) exceed the cost to us of offering them. We estimate that the value of these Programs is at least equal to the value of the information you provide when you participate in them.
You can opt-in to, or opt-out of, our Programs at any time through the same means they are offered, or by contacting us on our Contact Form.
To see what personal information we have collected or shared in the last twelve months, click here.
Information collected from visitors from outside the United States
Certain jurisdictions outside the United States require that we have a lawful basis to justify our processing of your personal information. Where applicable, the lawful bases that The Creator of Change relies upon to justify a particular processing activity may differ from the lawful basis used to justify a different processing activity. The Creator of Change relies on the following lawful bases to process personal information, as permitted under applicable law:
Processing necessary for the negotiation, execution, or performance of contracts;
Processing to comply with legal and regulatory obligations and as necessary for the establishment, exercise, or defense of legal claims;
Processing in furtherance of our legitimate interests, including our interests to conduct legitimate business activities (such as improving our products and services, to communicate with you, to secure our systems, among other legitimate interests);
Processing for employment purposes;
Processing based on your consent; and
We may obtain your consent to collect and use certain types of personal information when we are required to do so by law. If we ask for your consent to process your personal information, you may withdraw your consent at any time by contacting us using the details at the end of this Policy. Withdrawing your consent will not affect the lawfulness of processing based on consent before its withdrawal.
You can contact us on our Contact Form for more information about our processing of your personal information.
Some jurisdictions outside the United States have provided individuals with certain rights in relation to the processing of their personal information. This may be the case, for example, if you are located in the European Union or United Kingdom. These rights are not available to everyone, and they do not necessarily apply in all contexts. You may have a right under your jurisdiction’s data protection law to the following with respect to some or all of your personal information:
To request access to your personal information;
To request that we rectify or erase your personal information;
To request that we restrict or block the processing of your personal information;
To provide your personal information directly to another, i.e., a right to data portability; and
When we previously obtained your consent, to withdraw consent to processing.
To exercise these rights, please contact us through our online portal. We may, after receiving your request, require additional information from you to honor the request and verify your identity. Please be aware that we may be unable to afford these rights to you under certain circumstances, such as if we are legally prevented from doing so.
If you are concerned about how your personal information is used, please contact us on our Contact Form.
Terms of Use
Any dispute between you and us regarding the privacy of your personal information is subject to this Privacy Policy and the terms of use or terms of service applicable to our product or service you use, including limitation on damages, resolution of disputes, and application of the law of the State of New York.
Contact Information
If you have questions or concerns about this Privacy Policy or our privacy practices, you may contact us on our Contact Form. You may also mail inquiries and concerns to: Chief Privacy Officer, The Creator of Change Inc., 15455 Manchester Rd #13, Ballwin, MO 63011.
Effective Date: March 12, 2024