Privacy Protection & Security

Creaza, October 2020

The purpose of privacy protection is to protect your private life, personal integrity and ensure the quality of personal data is adequate

The processing of personal data in Norway is primarily regulated by the Personal Data Act, but a range of other laws such as the Electronic Communications Act, the Marketing Control Act, and the Accounting Act also provide guidelines for how information that can be connected to a person should be processed.

With the General Data Protection Regulation (GDPR) set to take effect, on May 25th 2018, we want to provide a statement on our work to comply with new regulations and ensure that our customers who use Creaza can continue to do so with confidence.

At Creaza, we have done extensive work to protect the privacy and security of our customers (and of our staff and learners):

• We have Data Processing Agreements (DPAs) with customers that regulate how personal data is defined and how we process this data.

• DPAs also regulate sharing of personal data. We use personal data solely for the purpose of providing the agreed service for the customer and its users. No personal data is disclosed to third parties. Creaza uses the following sub-processors: 

Sub-processors:	Type of processing
Inspera AS (Norway)	Development, maintenance, and service
Expert Software Application srl. (Romania)	Development, software, and service
AWS Amazon (Ireland)	Infrastructure, internet access, hosting, and AWS services
Wevideo Inc (USA)	Video-rendering service. No personal data is being stored.
TrackJS LLC (USA)	Error monitoring of JavaScript bugs. No personal data is being stored.

Information about municipality, county, school, role, name, and email addresses is necessary for the service to work as expected. This information is only used to distinguish users from each other, and for adjustments and workflow.  

Listed below is the personal information Creaza uses:

• Municipality/county
• School
• Name (first and last name)
• Role (teacher/student)
• Email address

THINGS YOU CREATE OR PROVIDE TO US

When you use your Creaza Account, you provide us with personal information. By far, most users log into Creaza using a single sign-on, like Skolfederation, SLI, Skolon, Google, Microsoft, Feide, UNI-login or similar. Upon first login, we receive your name, email, role, school, and municipality. With this information we create your account, were your content is stored. Upon the next login, we receive your unique id to give you access to your content.

Even if you aren’t signed into a Creaza Account, you provide us with information — like an email address to receive updates about our Services. When you upload content such as videos, photos, and audio for use within the services, we collect that content within your account so that you may access it. We also collect comments you make on published works, be they your own or those that others have shared with you.

INFORMATION WE COLLECT AS YOU USE OUR SERVICES

1. Your browsers and devices

We collect information about the browsers and devices you use to access Creaza, which helps us troubleshoot and make improvements to our Services. The information we collect includes the following:

• type of device
• operating system of your device
• browser type
• non-precise geographic location (e.g. zip code and city) derived from IP Address
• technical information about your device, system and App software, and peripherals
• system configuration information
• cookies
• web beacons

We collect this information when your device contacts our servers — for example, when you install a Creaza app on your mobile device or when you connect to our Services through your browser.

Our websites also used so-called cookies. These are small pieces of data stored on your computer or mobile phone by the browser that you use. A cookie belongs to a particular website, and cannot be read by other websites. What is stored in a cookie varies, but ordinarily is ID keys that make it possible to store user settings or to remember a user who has visited the website on a previous occasion.

Our websites use cookies to identify user sessions so that, among other things, you avoid having to enter your username and password for each page view within Creaza.

2. Your activity

We collect information about your activity when using our Services. We process this information to provide you with services, to maintain a reliable quality of our Services, and to provide you with improved Services. Activity that we collect may include:

• Features that you use
• People with whom you communicate or share content with when using our Services
• Information that you provide to us to connect to external services of your choosing with our Services
• date and time of login
• technical eventname
• event context

We do not sell any information that we collect about you or your activity. When we do track, it is done anonymously. We use methods that ensure that no tracking is identified with you, and that it is aggregated and processed in an anonymous manner.

Also our log files use the data described above to connect a user to a certain event. The storage of log files ensures the functional quality of our services.

3. Your location information

We collect information about your location when you use our Services. This helps us offer features that may be localized by knowing the originating country of an IP address. This location information also helps us prevent harm and fraud, comply with law, serve the public interest, and keep Creaza safe and welcoming for everyone.

HOW WE MAY USE PERSONAL INFORMATION

Creaza and our service providers may use personal information for our legitimate business interests, including the following:

• To respond to your inquiries and fulfill your requests, such as sending you newsletters.
• To send administrative information to you, such as information regarding the Services and changes to our terms, conditions, and policies.
• To send you marketing communications that we believe may be of interest to you, such as recommended Creaza based on your general location and your use of the Services, subject to your consent if required by applicable law.
• To personalize your experience on the Services by presenting products and offers tailored to you.

PERSONAL INFORMATION

“Personal Information” is information that identifies an individual or relates to an identifiable person.

We may need to collect and process Personal Information such as:

Name, Email, School, City, Role (Teacher or Student) in order to provide the requested Services to you, or because we are legally required to do so.

If you do not provide the information that we request, we may not be able to provide the requested Services.

If you submit any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

To ensure that the processing of data by us is done in a secure manner, only specially approved persons at Creaza have access to the data you provide us with. The number of employees with such approval is limited. Access to the data is secured by access control mechanisms.

If the data is incorrect or incomplete then you may correct any of it on the Internet. Beyond that you may request that incorrect data is corrected, supplemented, or deleted by contacting our Support Team. You may contact Support for disclosure of what personal data Creaza holds about you. You may also contact Support if you require further information about our processing of personal data.

UPDATES TO THIS PRIVACY POLICY

We may change this Privacy Policy. The “LAST UPDATED” legend at the top of this page indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on the Services. Your use of the Services following these changes means that you accept the revised Privacy Policy.

The responsibility for processing personal data lies with the CEO of Creaza.

CONTACTING US

If you have any questions about this Privacy Policy, please contact us at support@creaza.com

Cort Adelers gate 30

0254 Oslo, Norway