Privacy Policy


Last Modified December 8, 2020.


The Service is operated by Creative Labs Management Inc., 142 – 757 West Hastings Street, Vancouver, BC V6C 1A1 (“We,” or “Creative Labs”). This Privacy Policy describes the information collected through your (“Your”) use of the Service, how We use it, how We share it, how We protect it, and the choices You can make about Your information.

ATTENTION: PLEASE READ OUR PRIVACY POLICY CAREFULLY BEFORE ACCESSING OR USING THE SERVICE. ACCESSING OR USING THE SERVICE INDICATES THAT YOU ACCEPT AND AGREE TO BE BOUND BY THIS PRIVACY POLICY IN FULL. IF YOU DO NOT ACCEPT THIS PRIVACY POLICY, DO NOT ACCESS OR USE THE SERVICE. You acknowledge (a) that You have read and understood this Privacy Policy; (b) that this Privacy Policy shall have the same force and effect as a signed agreement; and (c) that by agreeing to this Privacy Policy, You consent to receive notifications regarding security incidents to the email address We have on file for You.

Unless explicitly stated otherwise, any new features that augment or enhance the current Service shall be subject to this Privacy Policy.

Please review the Privacy Policy each time You use the Service. BY USING THE SERVICE, YOU AGREE TO BE BOUND BY THE MOST RECENT VERSION OF THE PRIVACY POLICY. If We materially change this Privacy Policy, We will let You know by showing it to You again when You access the Service, via inclusion in our next App update that is submitted to Apple’s App Store or Google Play (as applicable), or by sending an email notifying You of the changes to the email address We have on file for You.

I. Your Consent to Collection, Use and Disclosure

We collect, use and disclose Your personal information with Your consent or as permitted or required by law.  How We obtain Your consent (i.e. the form We use) will depend on the circumstances, as well as the sensitivity of the information collected.  Subject to applicable laws, Your consent may be express or implied, depending on the circumstances and the sensitivity of the personal information in question.  If You choose to provide personal information to us, We assume that You consent to the collection, use and disclosure of Your personal information as outlined in this Privacy Policy.

Typically, We will seek Your consent at the time Your personal information is collected. Where We want to use Your personal information for a purpose not previously identified to You at the time of collection, We will seek Your consent prior to our use of such information for this new purpose.

You may withdraw Your consent to our collection, use or disclosure of Your personal information at any time by contacting us using the contact information in the “How to Contact Us” section below.  However, before We implement the withdrawal of consent, We may require proof of Your identity. In some cases, withdrawal of Your consent may mean that We will no longer be able to provide the Service to you.

If You provide personal information about another individual to us, it is Your responsibility to obtain the consent of that individual to enable us to collect, use and disclose his or her information as described in this Privacy Policy.

II. Information We Collect

We collect information from You when You use the Service, contact or interact with us, and voluntarily provide us with Your comments and other content in connection with using the Service, including photos or other content that You have posted to social media and authorize us to repost on our social channels for marketing purposes with Your express permission.

When You use the Website to pre-register for the Service, We collect Your email address.

When You use Your email address to sign up for the Service and create a profile on the App, We collect Your first name, last name, email address, and password. When You sign up for the Service using Your Facebook account, We collect Your first name, last name, email address, and profile picture. 

When You join a Path, start a workout, share to an individual Path feed, or otherwise use or interact with the App, We may collect information related to Your current fitness level, when You prefer to exercise, Your number of workouts, exercises completed, suit streak, most common exercise, reps completed, active time, total workout time, Your path, Your achievements, how You would like to receive notifications, and any other content You choose to upload, including photographs and comments.

When You contact us with a comment, question, or complaint, We may collect information such as Your name or email address, along with any additional information We may need to help us answer Your question or respond to Your comment or complaint.

We may also collect information about You from third-party sources, including social media providers. The Website provides links to our Facebook, Instagram, and Twitter accounts. If You connect with these websites through the Website, We may receive personal information about You, including information related to actions You take within social plugins, such as share buttons. 

  • Facebook Login (Formerly Facebook Connect).  We use Facebook Login/ Facebook Connect to facilitate single sign-on for our users.  When You use Facebook Login/ Facebook Connect, We may be able to retrieve Your name, Instagram username and bio, profile photo, and email address. For more details on the information that Facebook collects, please visit Facebook’s data policy:
  • Sign in with Apple.  We use Sign in with Apple to facilitate single sign-on for our users. When You sign in with Apple, We may receive Your name, email address, and a unique identifier that enables You to sign in with Your Apple ID. For more information, please visit the Apple privacy policy at:

You may use some portions of the Service without providing any personal information, though We automatically collect information regarding each user of the Service, including device IDs or identifiers (including mobile advertising identifiers), connection information, statistics of page views, ad data, referral URLs, IP address, general geographic location, the domain name of Your Internet service provider, the Service features You use and the time of Your use, page requests, browser type, information related to Your device information (e.g., device model, software, and operating system version), and aggregated information that cannot be used to specifically identify You when You use the Service. Additional information collected is described in the Analytics and Cookies sections below.

We may combine all of the information We collect from or about You and use it in the manner described in this Privacy Policy.

III. How We Use Your Information

We use the information that We collect for several purposes, including:

  • The purposes for which You provided it and marketing purposes as permitted by law, including marketing purposes which You have expressly authorized where required by law;
  • To recommend the best workouts for You and help You find your Path;
  • To track Your progress;
  • To send You inspiration;
  • To provide information and services to You;
  • To process and respond to Your inquiries and comments;
  • To display relevant advertising of third party products and services and/or targeted advertising of Creative Labs’ products and services across third-party websites or service offerings. Note: If at any time You would like to opt out of this activity, please contact us using the contact information in the “How to Contact Us” section below;
  • To administer, operate, and improve the Service;
  • To personalize and enhance Your experience using the Service;
  • To send periodic emails relating to Creative Labs’ products and services. If You choose, the email address You provide may be used to send You occasional newsletters, updates, related product or service information, etc. Note:  If at any time You would like to unsubscribe from receiving future emails, We include detailed unsubscribe instructions at the bottom of each email. Please note that if You opt out from receiving marketing-related emails, We may still need to send You communications about Your use of our products or services, or other matters;
  • To generate and review reports and data about our user base and Service usage patterns;
  • To analyze the accuracy, effectiveness, usability, or popularity of the Service;
  • To compile aggregate data for internal and external business purposes;
  • To prevent fraud and abuse of the Service and to otherwise protect users and visitors and our business;
  • To investigate legal claims;
  • To assist law enforcement and respond to subpoenas; and
  • To perform other business activities as needed, or as described elsewhere in this Privacy Policy.
  • As explained elsewhere in this Privacy Policy, personal information We collect may be processed by our partners in providing services related to the Service (such as administration services, technical services relating to the maintenance, servicing, and upgrading of software, hosting services, customer service, data migration services, and analytical services, among others).
  • We may also use Your personal information and other information for purposes for which We have obtained Your consent, and for such other purposes as may be permitted or required by applicable law.

IV. How Your Information is Disclosed

Information may be disclosed to third parties in accordance with our Privacy Policy. If We otherwise intend to disclose Your personal information to a third party, We will identify that third party and the purpose for the disclosure, and obtain Your consent. Please note that a user may choose not to share certain information as described in the Analytics section below.

A. Third Party Service Providers and Business Partners. We may use third-party service providers and business partners to perform functions in connection with the Service, such as marketing, website hosting, site analytics, relationship management, functions related to analyzing and improving the Service usefulness, reliability, user experience, and operation, storing data, and as otherwise described in this Privacy Policy. Any third party with which the App shares Your data will provide the same or equal protection of Your data as stated in this Policy.  Our third-party business partners and service providers may only use and disclose Your personal information for the limited purposes for which it is provided. When our business partners and service providers no longer need Your personal information for those limited purposes, We require that they dispose of the personal information.  In some circumstances, We may permit our service providers to retain aggregated, anonymized or statistical information that does not identify You.    

  • Facebook Login. We use Facebook Login/ Facebook Connect to facilitate single sign-on for our users. When You use Facebook Login/ Facebook Connect, We may disclose information related to Your device, the websites You visit, the purchases You make, the advertisements You view, and information regarding Your activities on the Service. For more details on the information that Facebook receives, please visit Facebook’s privacy policy:
  • Instagram. By clicking on the Instagram button on the Website, You will be automatically transported to the official Instagram Page for fit52,
  • Mailchimp. We use Mailchimp to disseminate newsletters and other marketing materials. Mailchimp may collect Your name, email address, mailing address, telephone number, device information, IP address, operating system, browser information, email client type, information related to Your browsing activities (such as the pages You view and the emails You open), information related to whether You have subscribed to the App, and information related to interactions with our emails (such as whether a sent email has been delivered and opened, dates and times when emails were accessed, and whether links within the email were clicked). For more information, please visit Mailchimp’s privacy policy:
  • RevenueCat. We use RevenueCat to manage user subscriptions to the App. RevenueCat may collect Your in-app purchase receipts. RevenueCat may also collect information related to country, device type, operating system, RevenueCat Purchases SDK version, the last time a user used the App, and App User ID. For more information on the information RevenueCat collects, please visit the RevenueCat privacy policy at:
  • Sprout Social. We use Sprout Social for social media management and reporting. If You follow our social media channels, Social Sprout may collect Your name, username, social media handle, profile picture, biography, follower counts, website URL, and Your messages or communications with us. Sprout Social may also collect Your IP address, device type, unique device identification numbers, browser type, information related to location, information related to third-party webpages accessed through the Sprout Social service, and information related to Your interactions with the Sprout Social service, such as the content You access. For more information related to the information Sprout Social collects, please visit the Sprout Social privacy policy at:
  • Twitter. By clicking on the Twitter button on the Website, You will be automatically transported to the official Twitter Page for fit52,
  • Leanplum. We analyze the usage of the fit52 app by using the services of Leanplum, Inc, 1550 Bryant Street, Suite 545, San Francisco, CA 94103, USA. Leanplum uses the collected data to create reports about user behavior, which help us to provide a better product. Furthermore we use Leanplum to send you in-app messages about news or offers on our app. Leanplum is using the Firebase Cloud Messaging component of Google LLC, 1600 Amphitheatre Parkway, Mountain View, California 94043, United States for this purpose. You can find Leanplum’s Privacy Policy here. To disable the collection of your data by Leanplum please send an email to

B. Other Path Members.  If You choose, information related to Your workouts, successes, name, and profile picture (including any photos or comments You may choose to post) may be shared with other Path members.

C. Apple or Google.  We may share Your information with Apple or Google, to be used in accordance with their respective privacy policies.

Specifically, We offer users the option to sign into the App with Apple or Google. The first time You sign in with Apple or Google, Apple or Google generates a unique token associated with each user, and stores the email address that You shared with us. Using this information, Apple or Google facilitates secure authentication, and enables You to manage and view Your account details. Subsequent visits to the App do not require sharing additional information with Apple or Google.

We also use App Store Connect and Google Play to manage all in-app purchases. We also use App Store Connect and Google Play to offer promo-codes to VIPs. We further use App Store Connect and Google Play to manage the marketing materials that You see in the App Store and our Beta test program through an Apple Product TestFlight. Finally, We use App Analytics (offered through App Store Connect and Google Play) for analytics and sales/financial reporting. App Store Connect and Google Play may collect session and crash data, unique device identifiers, device make and model, and time of install. For more information, please visit the Apple privacy policy at: and the Google privacy policy at:

You also have the option to transmit the data collected by the Service via interfaces provided by Apple and Google, such as Apple HealthKit and Google Fit, to track Your progress and to help motivate You to keep going and stay the path. When You track Your progress by saving workout data in Apple HealthKit or Google Fit, We read the following data securely from Apple Health and Google Fit: steps, calories burned, and calories consumed. We write the following information related to workouts: total time, start time, finish time, and source. This will only happen if You explicitly agree to share Your data. You can change the permissions You grant the App at any time, using either the in-app settings or Apple Health or Google Fit. Data gathered from Apple HealthKit or Google Fit may not be used (including by third parties) for marketing, advertising, or use-based data mining.

Finally, We enable You to share photos post-workout using Apple or Google native sharing functionality, which will allow You to share pictures including by posting them to Your social media account. 

D. Fit in 52, LLC.  We may share Your information with Fit in 52, LLC, the company with which We are working to deliver the Service to You. 

E. Business Changes. If We become involved in a merger, acquisition, sale of assets, joint venture, securities offering, bankruptcy, reorganization, liquidation, dissolution, or other transaction, or if the ownership of all or substantially all of our business otherwise changes, We may transfer Your information to a third party or parties in connection therewith.

F.  Affiliates. We may also share Your information with our affiliates for purposes consistent with this Privacy Policy. Our affiliates will be required to maintain that information in accordance with this Privacy Policy.

G. Investigations and Law. We may disclose information about You to third parties if We believe that such disclosure is necessary to:

  • Comply with the law or guidance or cooperate with government or law enforcement officials or private parties, including responding to requests from government or law enforcement officials or private parties outside your country of residence;
  • Protect our operations, rights, privacy, safety, or property, or those of any of our affiliates or subsidiaries, including pursuing available legal remedies or limiting the damages that We may sustain;
  • Investigate, prevent, or take action regarding suspected illegal activities, suspected fraud, the rights, reputation, safety, and property of us, users, or others, or violations of our policies or other agreements with us;
  • Respond to claims and legal process (for example, subpoenas); and/or
  • Protect against legal liability.

H. Aggregated Information. We may share aggregated information relating to users of the Service with affiliated or unaffiliated third parties. This aggregated information does not contain personal information about any user.

I. Analytics. We use third-party analytics tools to better understand who is using the Service and how people are using it. These tools may use cookies and other technologies to collect information about Your use of the Service and Your preferences and activities. These tools collect information sent by Your device or the Service and other information that assists us in improving the Service. This information may be used to analyze and track data, determine the popularity of certain content, and better understand Your online activity, among other things.

We use Google Analytics to better understand who is using the Website and how people are using it. Google Analytics uses cookies to collect and store information, such as Website pages visited, places where users click, time spent on each Website page, Internet Protocol address, type of operating system used, language preference, location-based data, device ID, search traffic, gender, and age. We use this information to improve the Website and as otherwise described in this Privacy Policy. Please see: for information about how Google Analytics uses this information, and visit: for information about the Google Analytics Opt-out Browser Add-on. Google may track activity over time and across websites.

We may deliver advertisements to You. We may also work with third-party advertising companies that help deliver these advertisements. To learn more about third-party online advertising and to opt out of certain types of advertising, please see:

We also use Google Firebase Performance Monitoring and Google Analytics for Firebase to collect application usage information to help us gather and analyze information on the App’s performance and how users engage with it to evaluate and improve the App experience. Firebase Performance Monitoring may collect information related to general device information (such as model, operating system, and orientation), RAM and disk size, CPU usage, carrier (based on mobile country and network code), radio/network information (i.e., WiFi, LTE, 3G), country (based on IP address), locale/language, signal strength, jailbroken or rooted status of device, battery level and battery-charging state, App version, App foreground or background state, App package name, App-instance identifier, network URLs (and the corresponding information: response codes, payload size in bytes, and response times), and duration times for automated traces. Google Analytics for Firebase collects information related to Your interactions with the App, including information related to advertisements and Your interactions with advertisements, information related to Your interaction with the App and App data, information related to the performance of the App and updates to the App, and information related to Your in-App purchases. Google Analytics for Firebase may also collect information related to Your age, gender, interests, language, App-instance ID, App version and store, country, device brand, category, and model, information related to when You open the App, and operating system version.  You can opt out of the Google Analytics for Firebase features We use by contacting us at: For more information, please visit the Google privacy policy at:

J. Cookies and Other Tracking Technologies

We, along with third parties, use cookies, local storage objects, Web beacons, mobile advertising identifiers and other technologies. These technologies are used for tracking, analytics, and personalization and optimization of the Service.

Cookies are small files that are transferred to and stored on Your computer through Your Web browser (if You allow it) that enable the website’s or service provider’s system to recognize Your browser and capture and remember certain information. You can instruct Your browser to stop accepting cookies. But, if You do not accept cookies, You may not be able to use all portions of all functionality of the Website.

  • Persistent cookies remain on the visitor’s computer after the browser has been closed.
  • Session cookies exist only during a visitor’s online session and disappear from the visitor’s computer when he/she closes the browser software.

Flash cookies (also known as local shared objects) are data files that can be created on Your computer by the websites You visit, and are a way for websites to store information for later use. Flash cookies are stored in different parts of Your computer from ordinary browser cookies. You can disable the storage of flash cookies. For additional information about managing and disabling flash cookies, please visit:

Web beacons are small strings of code that provide a method for delivering a graphic image on a web page or in an email message for the purpose of transferring data. You can disable the ability of web beacons to capture information by blocking cookies.

We use cookies and other tracking technologies to help us understand and save Your preferences and interests, so We can personalize Your future visits and compile aggregate data about Service traffic and Service interaction to offer better Service experiences and tools in the future.

We use standard and dynamic remarketing features in Google Ads and Google Analytics to show customized ads to users who have previously interacted with the Website. We and our third-party vendors, including Google, use cookies and device identifiers to inform, optimize, and serve ads based on Your past visits to our Website. Google, and other third-party vendors, show our ads on websites across the Internet. Google may collect information about the Website pages You view (including the referring page URL), and information related to specific actions You take on the Website. Please visit Google’s Ads Settings to opt out of Google’s use of cookies or device identifiers. You can also opt out of a third-party vendor’s use of cookies by visiting the Network Advertising Initiative’s opt-out page (, and You can use Your device settings to control the use of device identifiers.

We also use cross-device linking in conjunction with our Google Ads campaigns. As part of those campaigns, We share unique anonymous identifiers with third parties to facilitate reporting and advertising across user browsers and devices.

We also use the Facebook Pixel to analyze user activity on our Website for remarketing and behavioral targeting. The Facebook Pixel is triggered to establish a connection with the Facebook servers when You perform certain activities on the Website. Facebook links the information with Your personal Facebook user account, and allows us to display Facebook ads to Facebooks users who have visited our Website. Facebook (and other third parties) may use cookies, web beacons, and other storage technologies to collect information from the Website (and elsewhere on the Internet), and use that information for the purposes of ad targeting and providing measurement services. Facebook may additionally track Your activity over time and across websites. For more information about the data Facebook collects, please visit Facebook’s data policy at:  For specific information about Facebook Pixel, please visit: If You are logged into Facebook, You can opt out of the collection and use of Your information for targeted advertising by visiting: You can also exercise Your choice to opt out at:

We may use mobile advertising identifiers (such as IDFA for Apple mobile devices), which function similarly to cookies on mobile devices and allow us to track and attribute mobile advertising activities.  You may reset your mobile advertising identifiers in the settings on your mobile device.

Some of our business partners, such as our analytics providers and advertising networks, also use cookies and other tracking technologies on our Service, some of which may track users across websites and over time.

V. Security

We implement a variety of security measures to protect the safety of Your personal information when You enter, submit, or access Your personal information.  Please keep Your account password secure to help ensure the safety of Your personal information. 

While We take reasonable measures to protect the information You submit via the Service against loss, theft, and unauthorized use, disclosure, or modification, We cannot guarantee its absolute security. No Internet, email, or mobile application transmission is ever fully secure or error free. Email or other messages sent through the Service may not be secure. You should use caution whenever submitting information through the Service and take special care in deciding with which information You provide us.

We cannot guarantee that transmissions of Your personal information will be fully secure and that third parties will never be able to defeat our security measures or the security measures of our partners.  WE ASSUME NO LIABILITY FOR DISCLOSURE OF YOUR INFORMATION DUE TO TRANSMISSION ERRORS, THIRD-PARTY ACCESS, OR CAUSES BEYOND OUR CONTROL.

If You have reason to believe that Your interaction with us is no longer secure (for example, if You feel that the security of any information that You provided to us has been compromised), please contact us immediately using the contact information in the “How to Contact Us” section below.

Any information collected through the Service is stored and processed in the United States. If you use the Service outside of the United States, You consent to having Your data transferred to the United States. While Your information is stored and processed outside of Your country, it is subject to the laws of the country in which it is located, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country.

fit52 operates in multiple jurisdictions, some of which are not located in the European Union or European Economic Area (EEA). The personal information that we collect from users will be stored in the United States of America and might also be shared with third party data recipients (e.g. customer support providers) that are not located in the EEA. Therefore, the personal information that you provide to us may be transferred internationally to countries other than the country in which you initially provided your data.

VI. Data Retention Policy, Managing Your Information

We will retain Your information for as long as You use the Service and for a reasonable time thereafter, or as permitted by law. We may maintain anonymized or aggregated data, including usage data, for analytics purposes. We may retain and use Your information as necessary to comply with our legal obligations, resolve disputes, and/or for the period required by laws in applicable jurisdictions. Please note that some or all of the information We have collected may be required for the Service to function properly.

Your rights to your data are outlined in VIII. Your Choices Regarding Your Information.   

VII. Links to Other Websites or Applications

This Privacy Policy applies only to the Service. The Service may contain links to other websites or apps or may forward users to other websites or apps that We may not own or operate and to which this Privacy Policy does not apply. The links from the Service do not imply that We endorse or have reviewed these websites or apps. The policies and procedures We describe here do not apply to these websites or apps. We neither can control nor are responsible for the privacy practices or content of these websites or apps. We suggest contacting these websites or app providers directly for information on their privacy policies. Nonetheless, We seek to protect the integrity of the Service and welcome any feedback about these linked websites and mobile applications.

VIII. Your Choices Regarding Your Information

You have choices regarding the use of information by the Service.

  • Changing Your Information – You may request to update, or have deleted, any personal information collected from You through the Service.  Just send us an email at asking to update Your personal information, or to have us delete Your personal information.  However, We reserve the right to retain personal information as necessary for our business purposes, and to comply with laws. 
  • Closing Your Account – You may close Your account by contacting us at  If the email account associated with Your email address is not active, We may close Your account without notice.

IX. Choices Regarding Your Information for app users who are EU/EEA residents

Residents of the European Union or European Economic Area also have the following choices regarding the user of information by the Service.

  • Request information about whether we hold personal information about you, and, if so, what that information is and why we are holding/using it;
  • Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it;
  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected;
  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below);
  • Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes;
  • Object to automated decision-making, including profiling, that is not to be subject of any automated decision-making by us using your personal information or profiling of you;
  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it;
  • Request transfer of your personal information in an electronic and structured form to you or to another party (commonly known as a right to “data portability”). This enables you to take your data from us in an electronically useable format and to be able to transfer your data to another party in an electronically useable format; and
  • Withdraw consent. In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes to which you originally agreed, unless we have another proper and legitimate basis for doing so.

If you wish to exercise your rights related to your personal information (including the rights set out above), please contact us using the details in XII – How to Contact Us. While you will generally not be required to pay a fee to access your personal information or to exercise any of your other statutory rights, we may charge a reasonable fee if your request for access is clearly completely unfounded or excessive or decline to comply with such requests where permitted by applicable data privacy laws.

You also have certain options with respect to the use of cookies and other tracking technologies on our site, including for the purposes of online interest-based advertising.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it and to prevent unauthorized modification of your personal information.

You also have the right to lodge a complaint about our processing of your personal information with the body regulating data protection in the country or state / province in which you live.

X. Information Collected From Other Websites and Mobile Applications and Do Not Track Policy

Your browser or device may offer You a “Do Not Track” option, which allows You to signal to operators of websites, web applications, mobile applications, and services (including behavioral advertising services) that You do not wish such operators to track certain of Your online activities over time and/or across different websites or applications. The Service does not support Do Not Track requests at this time, which means that We or our analytics providers or other third parties with which We are working may collect information about Your online activity both during and after Your use of the Service. If at any time You would like to opt out of online tracking or behavioral advertising, please contact us using the contact information in the “How to Contact Us” section below.

XI. Children

The Service is not intended for children under 18 years of age. We do not knowingly collect personal information from an individual under age 18. If You are under the age of 18, please do not submit any personal information through the Service. If You have reason to believe that We may have accidentally received personal information from an individual under age 18, please contact us immediately at

XII. Changes to Privacy Policy

We reserve the right to update or modify this Privacy Policy at any time and from time to time without prior notice. Please review this Privacy Policy periodically, and especially before You provide any information. This Privacy Policy was made effective on the date indicated above.

When changes are made to this Privacy Policy they will become immediately effective when published in a revised Privacy Policy posted on the Website and in the App, unless otherwise noted.  By submitting Your personal information to us, by registering for or using any of the services We offer, by using the Website, or by voluntarily interacting with us after We publish or communicate a notice about the changes to this Privacy Policy, You consent to our collecting, using and disclosing Your personal information as set out in the revised Privacy Policy.

XIII. How to Contact Us

Please feel free to contact us by email at, or by writing us at Creative Labs Management Inc., 142 – 757 West Hastings Street, Vancouver, BC V6C 1A1, if you have any questions about this Privacy Policy, or if You have any comments, questions, concerns, or complaints regarding Your personal information or our privacy practices.

XIV. Your California Privacy Rights

Section 1798.83 of the California Civil Code permits California residents to request from a business, with whom the California resident has an established business relationship, certain information about the types of personal information the business has shared with third parties for those third parties’ direct marketing purposes, and the names and addresses of the third parties with whom the business has shared such information during the immediately preceding calendar year. You may make one request each year by emailing us at, or by writing us at Creative Labs Management Inc., 142 – 757 West Hastings Street, Vancouver, BC V6C 1A1.

XV. Your Nevada Privacy Rights

Senate Bill No. 220 (May 29, 2019) amends Chapter 603A of the Nevada Revised Statutes to permit a Nevada consumer to direct an operator of an Internet website or online service to refrain from making any sale of any covered information the operator has collected or will collect about that consumer. You may submit a request pursuant to this directive by emailing us at  We will provide further information about how We verify the authenticity of the request and Your identity.

XVI. Your Canadian Privacy Rights

We will take steps to ensure that Your personal information is kept as accurate, complete and up-to-date as reasonably necessary.  We will not routinely update Your personal information, unless such a process is necessary.  We expect You, from time to time, to supply us with updates to Your personal information, when required.

You may make a written request to review any personal information about You that We have collected, used or disclosed, and We will provide You with any such personal information to the extent required by law.  You may also challenge the accuracy or completeness of Your personal information in our records. If You successfully demonstrate that Your personal information in our records is inaccurate or incomplete, We will amend the personal information as required.

We may require that You provide sufficient identification to fulfill Your request to access or correct Your personal information.  Any such identifying information will be used only for this purpose. To access or correct Your personal information, please email our Privacy Officer at, or write to our Privacy Officer at Creative Labs Management Inc., 142 – 757 West Hastings Street, Vancouver, BC V6C 1A1.

XVII. Your Australian Privacy Rights

For the purposes of the Australian Privacy Act 1988, you can contact our Privacy Compliance Officer at: