Privacy Policy
Last Updated on May, 7, 2025
Notice
We (Crelate, Inc) are providing this Privacy Policy to explain how and why we collect data from you in use of our Services, including our platform and public website(s), meetings and events (in-person and virtual), marketing materials, and content, s, in each case that link to, references or otherwise refer to this Privacy Policy (together “Activities” or “Activity”). The following explains our practices regarding the collection, use, disclosure, and protection of personal information. By engaging in such Activities, you understand and agree to our privacy practices. Clients should read this policy in conjunction with our Terms of Service.
For the purposes of this Privacy Policy:
“DPF” or “EU-US DPF” means the EU-U.S. Data Privacy Framework.
“GDPR” means Regulation (EU) 2016/679, the General Data Protection Regulation.
“UK Addendum” means the International Data Transfer Addendum (Version B1.0) issued by the Information Commissioner’s Office under section 119(A) of the UK Data Protection Act 2018, as updated or amended from time to time.
“US Data Protection Law” means all state laws in effect in the United States of America that are applicable to the processing of personal data under this DPA, including, but not limited to, the California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2018 (CCPA), the Virginia Consumer Data Protection Act, the Colorado Privacy Act, the Connecticut Data Privacy Act, and the Utah Consumer Privacy Act.
“Personal Data” means any information that is submitted or made available to Crelate and that is protected explicitly by the Data Protection Laws, to the extent applicable.
“Data Protection Laws” means applicable data protection or privacy laws and regulations directly applicable to a party’s Processing of Personal Data under the Agreement, including the GDPR, UK Addendum, and US Data Protection Law.
“Data Subject” or “you” means people as defined in and subject to Data Protection Laws that have submitted Personal Data via Activities.
Scope
The Privacy Policy does not apply to our Client collection of personal data they collect through Crelate’s services to manage their own recruiting, onboarding, or similar processes. Each Client manages that information in accordance with their own privacy policies, and Crelate acts as a Data Processor on behalf of our Clients.
Crelate is the controller of data that we collect directly via Activities.
Data Privacy Framework
Crelate notifies Data Subjects about its data practices regarding Personal Data received by Crelate in the U.S. from member countries of the European Economic Area, United Kingdom, in reliance on the respective DPF, including the types of Personal Data it collects about them, the purposes for which it collects and uses such Personal Data, the types of third parties to which it discloses such Personal Data and the purposes for which it does so, the rights of Data Subjects to access their Personal Data, the choices and means that Crelate offers for limiting its use and disclosure of such Personal Data, how Crelate’s obligations under the DPF are enforced, and how Data Subjects can contact Crelate with any inquiries or complaints.
Crelate complies with the EU-US DPF and the UK Extension to the DPF as set forth by the U.S. Department of Commerce. Crelate has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-US DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-US DPF. If there is any conflict between the terms in this privacy policy and the EU-US DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.
Recourse, Enforcement, and Liability
The Federal Trade Commission has jurisdiction over Crelate’s compliance with the EU-U.S. DPF, and the UK Extension to the EU-U.S. DPF. In compliance with the EU-US DPF and the UK Extension to the EU-US DPF, Crelate commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU and UK individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-US DPF should first contact Crelate at: [email protected]
For HR related data handled by Crelate, in compliance with the EU-US DPF and the UK Extension to the EU-US DPF, Crelate commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) with regard to unresolved complaints concerning our handling of human resources data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF in the context of the employment relationship.
In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, Crelate commits to refer unresolved complaints concerning our handling of Personal Data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF to the BBB NATIONAL PROGRAMS, an independent, alternative dispute resolution provider based in the U.S. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://bbbprograms.org/programs/all-programs/dpf-consumers for more information or to file a complaint. The services of BBB NATIONAL PROGRAMS are provided at no cost to you.
If your DPF related complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf. Crelate acknowledges the right of EU and UK individuals to access their personal data that Crelate controls, pursuant to the DPF and will grant individuals reasonable access to personal information it received pursuant to these Principles. In addition, Crelate will take reasonable steps to permit individuals to correct, amend, or delete such information that it controls that is demonstrated to be inaccurate or incomplete. An individual may request to access his or her information, or otherwise correct, amend, or delete his or her information pursuant to the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF by contacting us at [email protected]
Crelate agrees to periodically review and verify its compliance with the DPF Principles, and to remedy any issues arising out of failure to comply with the DPF Principles. Crelate acknowledges that its failure to provide an annual self-certification to the U.S. Department of Commerce will remove it from the Department’s list of DPF participants.
Choice
We may require you to provide certain Personal Data in order to receive additional information about our company. We may also ask for your permission for certain uses of your Personal Data, and you may agree to or decline those uses. If you have previously opted in to particular Activities (e.g., an online newsletter), you will be able to unsubscribe at any time by following the instructions included in each communication. If you decide to unsubscribe from an Activity, we will remove your personal information, and reach out to you in case we require additional information or confirmation before we can process your request.
If personal data covered by the Privacy Policy is to be used for a new purpose that is materially different from that for which the personal data was originally collected or subsequently authorized, or is to be disclosed to a third party in a manner not specified in the Policy, Crelate will provide you with an opportunity to choose whether to have your Personal Data so used or disclosed.
Requests to opt out of such uses and disclosures of personal data should be sent to [email protected]
Personal Data Controlled by Crelate
Upon a valid request of a Data Subject where Crelate is the data controller, and the Personal Data is subject to Data Protection Laws, within 30 days or as otherwise required by applicable law, Crelate will provide you with information about whether we hold, or control, any of your Personal Data. In addition, Crelate will take the steps required by the Data Protection Laws to permit Clients to correct, amend, delete, or receive a copy of their Personal Data or to transfer and to restrict the use of their Personal Data, or opt out of transfers of Personal Data. To exercise any of these rights, please contact [email protected].
Personal Data Controlled by our Clients
Crelate acknowledges that Data Subjects have the right to access their Personal Data and to withdraw consent to the use/processing of their Personal Data. You have the right to withdraw your consent under Data Protection Laws. The withdrawal of consent does not affect the lawfulness of the processing carried out on the basis of the consent until the withdrawal. In most situations, Crelate has no direct relationship with the Data Subjects whose Personal Data it processes for customers. We recommend that any individual or EU and UK individuals who seeks access, correct, amend, delete or receive a copy of their Personal Data to direct their query to the Crelate Client who is the controller of that data.
If requested to remove data Client, we will respond within 30 days or as otherwise required by Data Protection Laws.
What data do we collect and how do we use it?
When visiting our website or participate in Activities, we want to optimize your experience, ensure our content is available to you and engage with you via our trusted third-party vendors. To that end, we and our suppliers may place cookies to your browsers to achieve this goal. In addition, the following types of data may be collected for the purposes of targeted advertising, remarketing, analytics, infrastructure monitoring, site optimization, social features, contacting the Visitor: your IP addresses, cookie identifiers, common browser, information provided by the Visitor and device statistics as well as actions you take on our website. If you choose to provide your contact information, engage in sales or support conversation, additional information will be captured to enable those conversations.
Additional data we may collect include:
- Data may be used by third parties: To target advertising on other sites based on your users’ online activity.
- Data from third-parties: This data helps us better understand our audience and deliver ads to you and recognize you across browsers and devices. This may include: pseudonymous advertiser identifiers that some advertisers or other third-party ad platforms choose to share with us – such as your “Customer ID” with an advertiser or other identifiers.
- Email, phone, and contact info, if provided by you via our contact us, landing pages, signup, newsletter, blog or other public forms, may be used to contact you for sales and marketing purposes (such as when you request a demo) or informational purposes (such as when you subscribe to our newsletter). You may request to unsubscribe from any of these communication methods at any time using links provided in those communications. By submitting your phone number or email you consent to be contacted by Crelate via this mechanism. No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. Message frequency varies and standard message and data rates may apply. For help, reply HELP. To opt out, reply STOP.
Other Personal Data collected may be described in other sections of this privacy policy or by dedicated explanation text contextually with our services or via our Terms of Service.
Data Sharing and Use
Crelate does not sell your Personal Data to third parties.
Crelate does not use Personal Data for automated decision-making, including profiling (Art. 22 GDPR)
Crelate limits the collection of Personal Data to information that is relevant for the purposes of processing. Crelate does not process such Personal Data in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by the Data Subject.
Crelate takes reasonable steps to ensure that such Personal Data is reliable for its intended use, accurate, complete, and current. Crelate takes reasonable and appropriate measures to comply with the requirement under the EU-US Data Privacy Framework (EU-US DPF) and the UK Extension to the EU-U.S. DPF to retain Personal Data in identifiable form only for as long as it serves a purpose of processing. Specifically, Personal Data will be retained in accordance with our business purposes and our obligations to comply with legal requirements and professional standards, unless a longer retention period is otherwise permitted by law, and its retention adheres to the DPF Principles.
Given a situation in which we may be compelled to provide data sharing we want to be sure it is clear that we may disclose information about you through data sharing including third-party cookies if the following scenarios are presented:
- Relating to a sale of our business: If a third party acquires some or all of our business or assets, we may disclose your information in connection with the sale.
- With our service providers: We may contract with companies who help with of our business operations. We require that our service providers only use your information in connection with the services they perform for us.
- We may also disclose aggregated, anonymized info with other third-parties.
Accountability
In the event of transfer of Personal Data covered in this Privacy Policy to sub-processors, Crelate remains responsible and liable under the EU-US DPF Principles, and the UK extension to the EU-US DPF if third-party agents that it engages to process the Personal Data on its behalf do so in a manner inconsistent with the Principles of the DPF, unless Crelate proves that it is not responsible for the event giving rise to the damage. We regularly review and enhance our data transfer practices to maintain compliance and uphold the highest standards of data protection.
Cooperation with Law Enforcement
Crelate may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Security
Crelate takes commercially reasonable and appropriate measures to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration, and destruction, taking into due account the risks involved in the processing and the nature of the personal data. All employees of Crelate that have access in the U.S. to Personal Data covered by this Policy are responsible for conducting themselves in accordance with this Policy. Adherence by Crelate to this Policy may be limited to the extent required to meet legal, regulatory, governmental, or national security obligations.
Cookies and Related Technologies
The Crelate website uses cookies, tracking pixels and related technologies enable offerings from our third-party vendors. Cookies are small data files that are served by our platform and stored on your device. They enable our vendors to identify your device when you move between different websites and applications so that we can serve targeted advertising to you.
Third Parties
Crelate uses the following Third-Party Service Providers in conjunction with providing our Services and Activities:
Google AdSense – Google, Inc.
Google AdSense is a web advertising service provided by Google Inc. (“Google”). This service uses the “Doubleclick” Cookie, which tracks use of Visitors behavior concerning ads, products and services offered.
Privacy Policy – Opt Out
Personal Data collected: Cookie, Location and Usage Data.
HubSpot – HubSpot, Inc.
HubSpot is a cloud-based CRM service provided by HubSpot, Inc. (“HubSpot”)
Privacy Policy
Personal Data collected: Various types of data as defined in the privacy policy of the service.
Gong.io – Going.io, Inc.
Gong.io is a cloud-based is a revenue intelligence platform provided by Going.io, Inc. (“Gong”)
Privacy Policy
Personal Data collected: Various types of data as defined in the privacy policy of the service.
Intercom – Intercom, Inc.
Intercom is a cloud-based chat and communication service provided by Intercom, Inc. (“Intercom”)
Privacy Policy
Personal Data collected: Various types of data as defined in the privacy policy of the service.
Other Social, Advertising and Conversion Tracking – Various
Crelate’s Website uses other tracking tools to provide Visitors the ability to share content from our Website on various social networks. Crelate also makes use of tracking pixels and beacons to track conversions and advertising metrics. Services included, but are not limited to Facebook, LinkedIn, Capterra, GetApp, WordPress.com and others.
Google Analytics – Google, Inc.
Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google collects data on how users interact and engage with the Crelate application and website.
Opt Out
Personal Data collected: Cookie, Location and Usage Data.
Hosting and Monitoring
Microsoft Azure – Microsoft Corporation
Azure is a cloud hosting service provided by Microsoft Corporation (“Microsoft”).
Personal Data collected: Various types of data as defined in the privacy policy of the service.
Mailgun – Mailgun Technologies, Inc.
Mailgun is email processing platform provided by Mailgun Technologies (“Mailgun”). Crelate uses Mailgun to send emails on behalf of Subscribers and to process emails between our Subscribers and Individuals.
Personal Data collected: Various types of data as defined in the privacy policy of the service.
Data Protection Officer and Point of Contact
Crelate has appointed a Data Protection Officer, who is responsible for matters related to data privacy and this Privacy Policy. If you have questions, comments or complaints related to Crelate’s Privacy Policy or the handling of Personal Data contact us by email at [email protected].
Changes to this policy
This Privacy Policy may be amended from time to time consistent with the requirements of the DPF. When we make changes to this Policy, we will revise the “updated” date at the top of the page. We encourage you to periodically review this Policy to be aware of updates to our practices.
