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Creative Technology Ltd and its subsidiary and affiliated companies (or "Creative", "we" "our" and "us") value your privacy and adhere strictly to good privacy practices to ensure that your privacy is respected and personal information you provide to us is kept in accordance with applicable laws and the policies and practices as described in this Privacy Policy. For certain jurisdictions, this Privacy Policy is supplemented by Creative's Personal Data Protection Policy (GDPR) or Personal Data Protection Policy (please see ‘Important Note for European Visitors' and ‘Important Note for Singapore Visitors' below), as applicable.

Our privacy policy, together with our Personal Data Protection Policy (GDPR) or Personal Data Protection Policy (where applicable), discloses our privacy practices for handling online personal and non-personal information. Please read this Privacy Policy, together with our Personal Data Protection Policy (GDPR) or Personal Data Protection Policy (where applicable) carefully before you use any of Creative's web sites ("Site(s)") and/or Creative's PC/mobile applications (“Application(s)”). By using or accessing the Sites and/or Application(s), you are accepting this Privacy Policy. We reserve the right to change our Privacy Policy, Personal Data Protection Policy (GDPR)and our Terms of Use at any time and from time to time, and may do so without any notice to you. We encourage you to refer to this Privacy Policy on an ongoing basis so that you are aware of the current terms.

• * Important Note for European Visitors
  For visitors from the European Economic Area, please note that Creative may transfer your personally identifiable data outside the European Economic Area for use for any of the purposes described herein. Please refer to our Personal Data Protection Policy (GDPR).
• * Important Note for Singapore Visitors
  For visitors from the Republic of Singapore, please refer to our Personal Data Protection Policy.

What Information Do We Collect?

• Non-sensitive/personal Information
  

  As a visitor to our Sites, you can engage in many activities without providing any personal information. However, we do collect and aggregate information pertaining to the web pages visited and general usage patterns through the use of "cookies" and “web beacons”, as described below. Such information is not linked to any sensitive information. The non-sensitive information we collect helps us identify the most popular areas of our Sites,and determines the effectiveness of our promotional activities.

  When you download and use our Application(s), there is some information that is provided automatically by your use of the Application(s), including any errors encountered, functions/features used, device type, navigation flow, operating system, usage time for each application screen. Such information is technical information, not linked to any sensitive/personal information and is collected to help us better understand how users engage our Application(s), improve user experience, adapt or develop new features according to users' preferences and determines the effectiveness of our Application(s). Our Application(s) use Google Analytics which is a web analytics services provided by Google.

• Sensitive/Personal Information
  

  You may have the opportunity to participate in any of the following activities at some Creative Sites or on Creative social media sites, including but not limited to: product registration, special offers, promotions, participation in surveys/polls/contests, software downloads, online shopping, technical support, newsletter subscription and/or forum participation. These activities may require the collection of your personal information including: your name, postal address, e-mail address, telephone number, fax number, credit card details (only for payment obligations to complete your order(s), where so required), and/or information about your interests in the use of Creative's various products, programs and services. Such data collected may be combined with the information you had previously provided (for example, in the event that you had previously registered the ownership of your Creative products). Creative is committed to safeguarding your personal information and will only use such information to better understand your needs and to provide you with better service.

  Please note that your credit card payment will be handled by third party financial institutions and we do not store any credit card information on our servers.

  To prevent unauthorized access to our database, and to ensure the appropriate use of information, we have put in place electronic and managerial procedures to safeguard sensitive information. We use Secure Sockets Layer (SSL) encryption on our entire website to safeguard the personal information that you submit to us.

How We May Use The Information

Creative will not sell, rent, loan or lease your personal information to others unless we have your express permission or are otherwise required by law or related regulations to do so. Creative will not use or share the personally identifiable information that you provide to us online in ways unrelated to those described herein, without (i) first letting you know and (ii) offering you a choice to opt out. If you have any problems exercising your choice to opt out, please contact us at http://www.creative.com/contactus or at the contact details provided below. We may use your personal information to enable us to keep you updated on our latest products, offerings, promotions, software updates, improve our targeted advertising, content and services and to generally improve our communications and personalize your user experience. (Please note that in the event that you decide to opt out, we may be unable to provide you with certain services and support etc. as the case may be.) We may also use your personal information for our internal purposes - which may include but are not limited to data research, analytics or general audit purposes etc. Creative may process personal information on servers in various countries around the world. We may process your personal information on a server located outside the country where you live.

Cookies and Web Beacons

Cookies are small text files that a web server can store on a user's device/machines. Cookies allow a web site to store information on a user's machine and retrieve it later. Cookies collect information like IP addresses, operating systems and browser software, but they do not collect any personal information. Please note that in some circumstances, dynamic IP addresses (which changes every time a person connects to a network) may result in personal identifiable information being created if they are combined with other information. Cookies enable us to customize your experience and provide greater convenience at our Sites. You have the ability to accept or decline cookies by modifying the settings on your browser; you may wish to refer to the instructions for your file management software to locate the file or directory that stores cookies, for better management of your cookie settings.

You may refuse the use of cookies by selecting the appropriate settings on your browser. However, please note that if you do this, you may not be able to use the full functionality of our Sites.

A web beacon is a clear or transparent picture file used to keep track of users' navigation through a web site or various web sites. Web beacons are normally used by web sites that use third party traffic monitoring and tracking services. In our case we use Google Analytics, amongst others. Our Sites, whether directly or indirectly, use web beacons in order to enhance the functionalities of our Sites and to gather information on traffic data, analytics etc and to better understand our users and their use of our Sites and to enable us to purposefully process such content.

Third Party Vendors/ Marketing Agents

We engage third party vendors/marketing agents (including Google, Inc. ("Google") for online advertising, marketing and/or remarketing service providers for purposes of remarketing, interest-based advertising, age, gender, demographic or location targeting, etc. to better target and serve more relevant ads to our intended audience based on available data. Third-party vendors/marketing agents, including Google, may show our advertisements on Sites across the Internet. For more information as to how Google uses data when you use our Sites/Applications please refer to: www.google.com/policies/privacy/partners/ (as may be amended by Google from time to time).

For Sites, as part of our advertising and marketing activities, data analysis, and other activities, we have implemented or may implement Google's Display Advertising features such as Remarketing, Google Display Network Impression Reporting, DoubleClick Campaign Manager Integration or Google Analytics Demographics and Interest Reporting. You may opt-out of Google Analytics for Display Advertising and customize Google Display Network ads at: https://www.google.com/settings/ads We and our third-party vendors/marketing agents (including but not limited to Google) use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on someone's past visits to our website. (Please refer to the section on Web Analytics/ Statistics below for more information.)

We also work with the following third party vendors (subject to change from time to time and may be done without prior notice):

Awin/The Affiliate Gateway/ ClixGalore/ FlexOffers/ TradeDoubler
These are networks where we (as advertisers) provide the ads of products that we want to promote, and publishers (e.g. coupon sites, blogs etc) can choose to promote our products by publishing our ads on their websites. The publishers earn a commission for every sale that occurs through their website. A tracking code is placed on our site to collect order information such as transaction ID, purchased product, order quantity, order amount, click date, and order date. This information is needed to validate orders and ensure that the commission amount paid to publishers is correct.

Personally Identifiable Information

We do not allow or use or associate personally identifiable information with remarketing lists, cookies, data feeds, or other anonymous identifiers nor associate targeting information (such as demographics or location, with any personally identifiable information collected from the ad or its landing page, or share any personally identifiable information with Google through our remarketing tag or any product data feeds which might be associated with our ads, or send Google precise location information) without first obtaining your consent.

When we or our third party vendor/marketing agents create a remarketing list, we do not use any sensitive information about our customers or visitors to our Sites, whether directly collected or associated with a visitor, based on the visitor's profile or behavior on our Sites or apps.

• Restrictions on list creation may apply to both individual web pages and entire web sites or apps
• Ad content may not imply knowledge of personally identifiable or sensitive information

Interest-Based Advertising

As an advertiser using interest-based advertising, as far as we are aware, we do not:

• Use interest-based advertising or implement the remarketing tag on any Site or app directed at children under 13 or which stores or solicits age information from people under the age of 13
• Create a remarketing list or creating ad content that specifically seeks to reach people in ways that are prohibited
• Create ad content which implies knowledge of personally identifiable or sensitive information about the Site or app visitor, even when the remarketing list has been created without using such information
• Include products which fall into sensitive categories, such as pharmaceutical products, in any data feeds

For the avoidance of doubt, ads that are already prohibited by Google's AdWords content policies, are not used in our campaigns.

Web Analytics/ Statistics

Our Sites use a web analytics service provided by Google called Google Analytics. Google Analytics uses "cookies" (as described above), as well as data from our advertising programs including interest-based and demographics-based advertising, to help better analyse how our users use our Sites. The information stored in the cookie about your use of the Sites (including your IP address) will be transmitted to and stored by Google on servers in the United States or anywhere else as may be determined by Google. Google will use this information for the purpose of evaluating your use of our Sites, compiling reports on web site activity and providing other services relating to activities on our Sites and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google. By entering into and using this web site, you consent to the processing of data about you by Google in the manner and for the purposes set out hereinabove.

You may access Google Analytics' currently available opt-out options at https://tools.google.com/dlpage/gaoptout/

More information on Google tools (subject to change from time to time and may be done without prior notice):

Google Tag Manager
Google Tag Manager (GTM) is a script/tag management service which we use to manage our various third party tracking codes, including that of Google Analytics. Using this tool, we can install/uninstall scripts and tags into our web sites without having to directly modify its source code.

AdWords
Google AdWords is an advertising platform which allows advertisers to use different types of ads to reach their target customers. Ways that we can target customers:

• Bidding on keywords that customers use to search in search engines.
• Targeting by customer interests and demographics.
• Re-targeting visitors who have previously visited Creative's website.

Please note that customer interests/demographics are collected/profiled by Google, not advertisers. Google will present these options in the AdWords platform for advertisers to select for advertising.

Additional information such as product id and order value may be collected by us when visitors visit our website so that we can retarget them (by showing them the product ads of the pages which they previously visited) through AdWords.

Tracking code provided by Google is placed on our websites to track various metrics.

We also make use of the following site(s) to collect site visitor information (subject to change from time to time and may be done without prior notice):

CrazyEgg
This is used to collect site user interaction data anonymously to optimize user experience for site navigation.

Site visitors are tracked and their site interaction data is collected and processed to understand general usage behavior of all our users. No personal identifiable information is transmitted nor can the transmitted data be reversed to re-identify the individuals.

We may disclose certain or all of the information (described above) that we collect, as stated above and in accordance with the terms set forth in this section. We do not reveal personally identifiable information about you to third-parties for their independent use unless: (1) you request or authorize; (2) in connection with our Sites as described above; (3) the information is provided to comply with applicable laws, regulations, search warrants, subpoenas or court orders, enforce an agreement we have with you, or to protect our rights, property or safety, or the rights, property or safety of our employees or others; (4) the information is provided to our agents, vendors or service providers who perform functions on our behalf; (5) the information is to address emergencies or acts of God or to address disputes or claims, or to persons holding a legal or beneficial interest. We may also gather aggregated data about our customers and Site visitors and disclose the results of such aggregated data (but not personally identifiable information) to our partners, service providers, advertisers and/or other third parties for marketing or promotional purposes.

Social Media Sites

Our Sites interface with social media sites including Facebook, Twitter and other social media sites. In the event that you do decide to "like" or share information from our Sites through these services, you must also review the privacy policy of each of the linked social media sites accordingly. If you are a member of a social media site, the interfaces may allow the social media site to connect your site visit to your personally identifiable information.

We may from time to time partner or enter into arrangements with other party or parties to provide specific benefits and/or services to our customers including sending more streamlined and targeted promotions or ads etc to enhance your overall user experience. We will provide to such partners the information that we believe is reasonably necessary for them to provide such benefits and/or services to you. In the event that you do not wish to receive marketing communications from us, please do let us know (in writing) of your preference to not be contacted by sending us a letter or e-mailing our offices at the contact information below informing us of your preference.

We make use of the following social media sites (subject to change from time to time and may be done without prior notice):

Facebook
Used to keep our customers informed on the latest happenings and product offerings from Creative.

Facebook provides general, non-personal, non-identifiable data in their insights tool. While we do not collect any personal data, emails from our database (such as newsletter subscribers) are uploaded into the Facebook Custom Audience tool to match Facebook users with our subscribers. From time to time, we run advertising campaigns to target these matched users and also include Facebook tracking pixels on our websites for conversion and re-marketing purposes.

Twitter
Engage and interact with the community via tweets or direct messages.

We do not collect any personal information of our users via Twitter. Occasionally, emails from our database (such as newsletter subscribers) will be uploaded to the Twitter Ad Tool for ads targetting. Tracking pixels are also uploaded onto our website to track ads conversions and to facilitate re-marketing. Twitter Insights Tool also provides us with non-personal, non-identifiable data like gender, age and location.

Instagram
This is used to reach out to various demographics through imagery and video stories. No personal data are collected but Instagram provides non-personal, non-identifiable data in its insight tool which includes gender, age and location.

YouTube
This is used to provide branding, informational and product demo videos regarding our products. While we do not collect individual user information, YouTube provides non-personal, non-identifiable data in the channel insights tool. Some examples of data include gender, age and location.

Surveys or Contests

We will from time to time, provide you the opportunity to participate in contests or surveys on our Site. If you participate, we will request certain personally identifiable information from you. Participation in these surveys or contests is completely voluntary and you have a choice whether or not to disclose this information. The requested information typically includes contact information (such as name, e-mail address and shipping address) and demographic/geographic information.

We use this information to notify contest winners and award prizes, to monitor Site traffic or personalize the Site (in the case of anonymous information collected in surveys), to send participants an email newsletter.

We may use third-party service providers to conduct these surveys and/or contests; If so, that company will be generally prohibited from using our users' personally identifiable information for any other purpose. We will not share the personally identifiable information you provide through a contest or survey with other third parties unless we give you prior notice and have your consent.

Tell-A-Friend

If you choose to use our referral service to tell a friend about our Sites, we will ask you for your friend's name and email address. We will automatically send your friend a one-time email inviting him or her to visit the Site. We will store this information for the sole purpose of sending this one-time email and tracking the success of our referral program.

Our Global Operations

As Creative operates globally, we may need to share your personal information with our worldwide business units as well as our business partners, if required to fulfill our business obligations. We will share your information with other Creative entities (including subsidiaries and affiliates) and/or business partners who are acting on our behalf to provide the necessary service or information requested by you, to consolidate data storage, or to simplify the management of customer information and as referred to above where necessary. Such Creative entities and/or business partners are governed by their respective privacy policies with respect to the use of this data and are bound by appropriate confidentiality and data protection agreements, if required.

In summary, in order for us to serve you better, we may use your personal information for the following purposes, including but not limited to:

• The Creative Store

  To process your order, we will ask you for your personal information such as: name, e-mail address, delivery address, telephone number and credit card information. We may also contact you, (usually via email or phone) on matters including but not limited to matters relating to your order, order confirmation, shipping and tracking details, shipment delay, change in stock availability, or identity verification.

• Online Registration/After-Sales Services

  You can register your Creative product using an online registration application or via creative.com/register. By registering your Creative product, you will be eligible to receive product support. The level of support available is dependent on the type of Creative product purchased. For more details, visit creative.com/support. Personal information collected from online registration will be used to improve our products and services. Creative's internal reports will not contain personal individual data. Where required, we may from time to time contact you on matters relating to your registered product(s). With your permission, we will send you information about new products or services from Creative. We may also use your personal information to provide after-sales services (including but not limited to technical support) whether or not the Creative product has been registered with us.

• Surveys/Polls/Contests/Promotions

  From time to time, our Sites may request information from you via surveys/ polls/ contests/ promotions and other marketing activities. Participation in these activities is completely voluntary and you have a choice whether or not to disclose any information. Information requested may include contact information; such as your name and your shipping address to notify the winner(s) and demographic information; such as your age, for eligibility purposes. Survey information will be used for the purposes of monitoring or improving the use and satisfaction of our Sites.

• Newsletters

  Creative may occasionally send you newsletters, marketing materials or product information via e-mail. Your e-mail address will only be used for these purposes and will not be shared with unaffiliated third parties without your consent. Where applicable, we will follow all local requirements, such as having you opt-in, to ensure we do not send you unsolicited e-mails. You have the right to opt-out from receiving such electronic communications from us at any time.

Children's Information

Creative will never knowingly collect sensitive information from children under 13 for marketing purposes. If we learn that personal information has been submitted to us by children under 13, we will delete such information from our files. Minors under the age of 13 should ask their parents or guardians for express permission before submitting any personal information to anyone over the Internet.

Students

Creative Student Store
Students can enjoy special sales promotions and fulfill their product orders via our Creative Student Store.

Verification of students' status is carried out using their student email address or through a third party platform such as Student Beans, for the purpose of accessing student promotions. Other data collected will be used for order fulfilment.

Data typically collected: Name, Email Address, Student Email Address, School, Telephone Number, Billing address, Shipping address, Date of Birth

• Student Beans
  Student Beans provides assistance in student status verification for our Creative Student Store.

  Data such as Name, Email, Date of Birth, Country and School are typically collected from Student Beans for the purpose of creating a store account and order fulfilment. No personal identifiable information is transmitted back to Student Beans.

Third Party Web Sites

Please note that our Privacy Policy only applies to Sites controlled by Creative. Links to third party web sites are provided solely as a convenience to you. You are advised to check the privacy policies and terms of use of those sites before providing your personal information to them. Creative has not reviewed these third party web sites, does not control and is not responsible for any of these sites, their contents or their privacy policies and/or terms of use. Creative does not endorse or make any representations about these other sites, or any information, products or other materials that may be found there. Access to and use of such other web sites is at the user's own risk and subject to any terms and conditions applicable to such access/use.

Information requests

You are entitled to ask for a copy of the personal information we hold about you at any time (for which we may charge a small administration fee). We will correct any inaccuracies in your personal information at your request.

Contacting Us

We value your opinions. If you have any questions or comments about our Privacy Policy or questions or concerns about the use of your personal information, please contact us. You can send your request to:

Asia, Europe, Oceania, Middle East & Africa:
Data Privacy (Legal Department)
Creative Technology Ltd
31, International Business Park
#03-01, Lobby C, Creative Resource
Singapore 609921
Singapore

Americas:
Data Privacy (Legal Department)
Creative Labs, Inc.
1901 McCarthy Blvd.
Milpitas, CA 95035
USA

Disclaimers

We reserve all rights to disclose your personally identifiable information as may be required by law, legal regulations, court orders or legal process and when we believe that disclosure is necessary in the circumstance to protect our rights and/or for the said legal compliance. We shall not be liable under any circumstances including for any sort for any loss of data, and/or loss or any inconvenience caused by viruses and/or other malicious code originating or contracted from our Sites/Application(s) or its use thereof or otherwise. It is solely your responsibility to ensure that your computer/device/table runs on up-to-date anti-virus software at all times and to check regularly for viruses and/or other malicious code. Creative will use reasonable endeavours to ensure that this website does not contain or spread any viruses or other malicious code. IN NO EVENT SHALL CREATIVE, ITS AFFILIATES, SUBSIDIARIES, INCLUDING ITS DIRECTORS, REPRESENTATIVES, EMPLOYEES OR AGENTS, BE LIABLE WHATSOEVER FOR ANY CLAIM, COST OR DAMAGES INCLUDING ANY CONSEQUENTIAL, INCIDENTAL, INDIRECT, PUNITIVE OR SPECIAL DAMAGES OF ANY NATURE WHATSOEVER, INCLUDING WITHOUT LIMITATION ANY DAMAGES ARISING OUT OF OR IN CONNECTION WITH ANY MALFUNCTIONS, DELAYS, LOSS OF DATA, LOSS OF PROFIT, INTERRUPTION OF SERVICE OR LOSS OF BUSINESS OR ANTICIPATORY PROFITS, ARISING OUT OF YOUR USE OF OUR SITES/APPLICATION(S), INCLUDING PARTICIPATION IN ANY SURVEYS OR CONTESTS EVEN IF CREATIVE HAS BEEN APPRISED OF THE LIKELIHOOD OF SUCH DAMAGES OCCURRING.

[Last revised in May 2018]