creoviva
Draft, pending legal review This is a working draft of creoviva's Privacy Policy. It has not yet been reviewed by qualified UK/EU counsel and is not final. Fields marked TBD are placeholders to be completed before publication.

creoviva Privacy Policy

Draft v1.0 · Effective date: TBD · Last updated: TBD

This Privacy Policy explains how Ember Eagle Ltd processes personal data in connection with creoviva, the platform that hosts each creator's own public page, sessions and videos.

1. Controller

Ember Eagle Ltd, 71-75 Shelton Street, WC2H 9JQ London, United Kingdom, company number TBD, is the data controller for the processing described in this Policy, except where a different role is stated. Privacy contact: TBD.

2. Data we collect

3. Purposes and legal bases

The exact legal basis for each processing activity will be documented in creoviva's internal processing register.

4. User content and illegal-content processing

Because creoviva supports user-generated content and live interactions made available by creators through their own creator pages, we process content and associated metadata for delivery, security, moderation, legal compliance and user protection.

If suspected illegal content or criminal conduct is identified, we may preserve relevant information and disclose it to law enforcement or another competent authority where required or permitted by law. This may justify retention after an account is closed.

5. Sensitive information

Users should not submit health, biometric, criminal-history or other special-category information through ordinary profile fields unless specifically requested for a lawful purpose. Specialist verification providers may process identity or age information under appropriate safeguards.

6. Cookies

We may use necessary cookies for authentication, security and Platform functionality, including a cookie that records whether a visitor has clicked through a creator page's 18+ age gate. Optional analytics or marketing technologies will be used only where applicable consent or another lawful basis exists. A separate Cookie Policy/consent interface may apply.

7. Providers and disclosures

We may use hosting, cloud, content delivery, email, authentication, identity/age verification, security, analytics, support, payment and compliance providers. We may also disclose data to advisers, auditors, regulators, courts and law enforcement where appropriate.

The final published version should include the actual subprocessor/provider list and links.

8. International transfers

Where personal data is transferred outside the UK or EEA, creoviva will use an applicable lawful transfer mechanism and appropriate safeguards, such as adequacy decisions, EU Standard Contractual Clauses, the UK International Data Transfer Agreement/Addendum or another lawful mechanism.

9. Retention

10. Your rights

Requests: TBD. We may verify identity before responding.

11. Children

creoviva is an 18+ service for age-restricted functionality. We do not knowingly permit children to create creator accounts, purchase age-restricted content or participate in age-restricted sessions. If we identify an underage account, we may restrict or remove it and take appropriate safety and data-protection steps.

12. Automated systems

Automated systems may be used for security, fraud prevention, spam detection and content triage. Where applicable law provides rights concerning solely automated decisions with legal or similarly significant effects, creoviva will provide the required safeguards.

13. Security

We use appropriate technical and organisational measures to protect personal data. No online service can guarantee absolute security.

14. Changes

We may update this Policy and will publish the latest version with its effective date.

15. Contact

Privacy: TBD
Safety / illegal content: TBD
Registered office: 71-75 Shelton Street, WC2H 9JQ London, United Kingdom
Company number: TBD