Effective Date: 22nd April 2025

1. INTRODUCTION

This Privacy Policy sets out how CDR Management Ltd, trading as Creatr UK (“we”, “us”, “our” or the “Company”), collects, uses, stores, discloses, and otherwise processes personal data in the course of its business activities. This includes the management of individuals operating on social media and subscription-based content platforms, and the operation of our corporate website and services.
This policy is issued in accordance with the United Kingdom General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and the Privacy and Electronic Communications Regulations 2003 (PECR).
By accessing our website or providing information to us, you acknowledge that you have read, understood, and accepted the terms of this Privacy Policy.

 

2. DATA CONTROLLER INFORMATION

CDR Management Ltd
Trading as: Creatr UK
Company Registration Number: 14395975
Registered Office: Chandos Business Centre, 87a Warwick Street, Leamington Spa, England, CV32 4RJ
Email for all data protection-related enquiries: [email protected]

 

3. CATEGORIES OF PERSONAL DATA COLLECTED

We collect the following categories of personal data:

From website visitors:

• IP address
• Device type, browser type, and browser settings
• Referrer source, session duration, click paths, and engagement with website elements
• Cookie data and analytics identifiers

From creators, applicants, or affiliates:

• Full name
• Date of birth
• Email address and mobile number
• Location or timezone
• Social media account usernames, profile URLs, and associated performance metrics
• Revenue data derived from content platforms or social media insights
• Identity documents such as passports or driving licences
• Login credentials for social media or content platforms, where explicitly provided for service facilitation
• Communications and submissions made during application or onboarding processes

From marketing subscribers:

• Email address
• Consent preferences
• Newsletter interaction statistics

We do not knowingly collect or process data relating to individuals under the age of 18. If you are under the age of 18, you must not use our website or submit any personal data to us.

 

4. METHODS OF DATA COLLECTION

We collect personal data through the following means:

• Direct submission by the data subject, including via forms hosted on our website or through direct communication
• Automated data collection via analytics tools such as Google Analytics and Meta Pixel, triggered upon visiting our website
• Cookie usage and browser interaction
• Tracking of performance data from managed platforms, subject to contractual consent
• Internal assessments of creator performance for operational purposes

 

5. PURPOSES OF PROCESSING AND LEGAL BASES

We process personal data only where a lawful basis under the UK GDPR applies.

These include:

• To review and assess creator or affiliate applications
  (Lawful basis: Article 6(1)(b) – performance of a contract or pre-contractual steps)
• To verify identity, eligibility, and authenticity of applicants
  (Lawful basis: Article 6(1)(c) – compliance with legal obligation; Article 6(1)(b) – contractual necessity)
• To manage creators’ access credentials and performance metrics
  (Lawful basis: Article 6(1)(b) – contractual necessity)
• To access, manage, and optimise client-linked social media or content platform accounts
  (Lawful basis: Article 6(1)(b) – contractual necessity)
• To send newsletters and promotional content to subscribers
  (Lawful basis: Article 6(1)(a) – consent)
• To operate and enhance our website using cookies, analytics, and pixels
  (Lawful basis: Article 6(1)(a) – consent under PECR and UK GDPR)
• To comply with financial, taxation, record-keeping, and regulatory obligations
  (Lawful basis: Article 6(1)(c) – legal obligation)
• To protect, defend, or enforce our legal rights
  (Lawful basis: Article 6(1)(f) – legitimate interest)

 

6. USE OF COOKIES AND TRACKING TECHNOLOGIES

We use cookies and similar tracking technologies for:

• Functionality and usability of our website
• Traffic analysis and visitor behaviour
• Targeted advertising via external platforms (such as Meta)
  All non-essential cookies are disabled until affirmative consent is received via our website’s cookie management banner. You may withdraw or modify your cookie preferences at any time via the cookie control interface or through your browser settings. For full details, please refer to our Cookie Policy.

 

7. DATA SHARING AND INTERNATIONAL TRANSFERS

We may share your personal data with third-party service providers where necessary to operate our business and provide services.

These may include:

• Cloud storage providers and web hosts
• CRM systems and workflow management tools
• Marketing automation platforms
• Advertising platforms such as Google Ads and Meta Ads
• Professional advisors including legal and accountancy consultants
• Payment processors and banking partners
• Subcontractors engaged to fulfil specific agency-related functions
  Where data is transferred outside the United Kingdom or European Economic Area (EEA), we implement appropriate safeguards in accordance with Chapter V of the UK GDPR. These include:
• Standard Contractual Clauses (SCCs) approved by the ICO
• Technical and organisational controls imposed by contract
• Vendor-specific transfer impact assessments (where applicable)

 

8. DATA RETENTION

We retain personal data for no longer than is necessary for the purposes for which it was collected, subject to applicable legal and regulatory obligations. Our standard retention periods are as follows:

• Creator or affiliate application data: 12 months following last contact if not contracted
• Creator account and contractual records: retained for the duration of the relationship plus six years
• Identity verification and financial records: retained for six years following termination
• Social media access credentials (where held): retained only for the period of the contractual engagement
• Newsletter and marketing subscription data: retained until consent is withdrawn
• Website usage and analytics data: retained for 6 to 24 months depending on the tool and settings

We may retain anonymised or aggregated data for research, benchmarking, or statistical analysis without limitation.

 

9. DATA SUBJECT RIGHTS

Under the UK GDPR, individuals have the following rights in respect of their personal data:

• The right to access a copy of their personal data
• The right to rectification of inaccurate or incomplete data
• The right to request erasure of personal data where it is no longer necessary or lawful to retain it
• The right to restrict processing under certain circumstances
• The right to object to processing carried out under legitimate interest or for direct marketing purposes
• The right to data portability, where applicable
• The right to withdraw consent, where processing is based on consent

To exercise any of the above rights, please contact [email protected]. We will respond within one calendar month. We reserve the right to request additional information to verify identity before complying with any such request.

 

10. MARKETING COMMUNICATIONS

We will only send marketing communications where we have obtained valid consent from the recipient, in accordance with PECR and Article 6(1)(a) UK GDPR. You may withdraw consent at any time by clicking the unsubscribe link in our emails or by contacting [email protected].

 

11. DATA SECURITY

We implement appropriate technical and organisational measures to ensure the security of personal data, including:

• Secure storage of identity documents and access credentials
• Encryption of data in transit and at rest
• Access controls and audit trails for sensitive systems
• Regular internal review and access management procedures
• Staff training on confidentiality and data protection responsibilities

While we strive to ensure robust security, no method of transmission or storage is completely secure. You acknowledge and accept this inherent risk.

 

12. THIRD PARTY LINKS

Our website may include hyperlinks to third-party websites or embedded content. We do not control these websites and are not responsible for their privacy practices. You are encouraged to review the privacy policies of such third parties before providing them with your personal data.

 

13. COMPLAINTS

If you have any concerns or wish to lodge a complaint regarding the way your data is handled, please contact us at [email protected]

You may also lodge a complaint directly with the UK Information Commissioner’s Office (ICO) at:
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Website: www.ico.org.uk
Telephone: 0303 123 1113

 

14. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time to reflect legal, regulatory, operational, or technological developments. Any such changes will be published on our website with an updated effective date. Continued use of our website and services after any such changes shall constitute your acceptance of the updated policy.