THE CREATOR (2021) LTD, trading as theCreator (“theCreator”, “we”, “us” or “our”), is a New Zealand marketing and creative agency.
We respect the privacy of our clients, their customers, website visitors and people who interact with us.
This Privacy Policy explains how we collect, use, store and protect personal information, including information we process on behalf of our clients.
We handle personal information in accordance with the New Zealand Privacy Act 2020 and other applicable privacy and data protection requirements.
THE CREATOR (2021) LTD
Trading as theCreator
99 Ferry Road
Christchurch 8011
New Zealand
Email: studio@thecreator.co.nz
For privacy enquiries, please contact:
Privacy Officer
THE CREATOR (2021) LTD
studio@thecreator.co.nz
This Privacy Policy applies to personal information we handle through:
our website and online forms
enquiries and quote requests
client relationships
marketing and advertising services
website development and hosting
social media management
lead generation
analytics and reporting
email marketing and CRM services
recruitment and employment enquiries
communications with us
information supplied to us by clients so that we can perform services on their behalf.
In some circumstances, we process personal information on behalf of a client rather than for our own purposes. This is explained further below.
The information we collect depends on how you interact with us.
This may include:
your name
email address
phone number
company or organisation
job title
address
information contained in an enquiry or message
project or marketing requirements
account and billing information
communications and correspondence with us
feedback or survey responses
job application information, including CVs and portfolios.
We only seek to collect personal information that is reasonably necessary for the purpose for which it is being collected.
When you visit our website or interact with digital content we manage, certain information may be collected automatically, including:
IP address
device and browser information
approximate location
pages visited
referring website or campaign
time spent on pages
interactions with website content
advertising and conversion information
cookies and similar identifiers.
We may use analytics, advertising and website measurement technologies to understand how our website and marketing perform.
As a marketing agency, clients may provide us with, or give us access to, personal information relating to their customers, prospective customers, leads or other contacts.
Depending on the service, this may include:
names
email addresses
phone numbers
customer or lead status
marketing preferences
purchase or enquiry history
CRM information
campaign attribution information
customer segments
other information reasonably required to provide the agreed services.
Where possible, we minimise the information we receive and only request the fields necessary to perform the particular service.
We generally do not require sensitive personal information, payment card information, passwords, identity documents, health information or other highly sensitive customer information to perform marketing services. Clients should not provide this information unless it is genuinely necessary and has been agreed with us.
We may collect personal information:
directly from you
through our website or online forms
through email, phone, video calls or meetings
through advertising platforms and lead forms
through social media
through analytics and website technologies
from our clients where we are providing services on their behalf
from third-party systems that a client has authorised us to access, such as a CRM, ecommerce platform or advertising account
from publicly available sources where appropriate
through service providers acting on our behalf.
Where we receive personal information indirectly, we will handle it in accordance with applicable privacy requirements and the purpose for which it was provided to us.
We may use personal information to:
respond to enquiries
provide quotations and proposals
provide and manage our services
communicate with clients
manage client projects
invoice clients and administer accounts
improve our services
operate and improve our website
measure website and advertising performance
conduct advertising and marketing
generate and manage leads
create reports and analytics
manage email marketing and CRM activity
provide customer audience and advertising services
troubleshoot technical issues
maintain security
meet legal, regulatory and contractual requirements
recruit team members or contractors
carry out other purposes that have been explained when the information is collected.
We do not sell personal information.
A significant part of our work involves acting as a service provider to our clients.
Where a client provides personal information to us solely so that we can perform services for that client, we will only use that information:
to provide the agreed services
in accordance with the client’s reasonable instructions
for purposes connected with providing those services
as otherwise required by law.
We do not use a client’s customer database for theCreator’s own marketing.
We do not sell client customer data.
We do not intentionally combine one client’s identifiable customer database with another client’s database for our own purposes.
The client remains responsible for ensuring that it has an appropriate basis for collecting the information and instructing us to process it for the relevant purpose.
We will take reasonable steps to minimise the amount of client customer information we receive and, where practical, use direct system integrations rather than manually transferring customer databases.
Where instructed by a client, we may use customer information to provide advertising, audience, exclusion, conversion measurement or customer matching services.
This can include services provided through platforms such as:
Meta, including Facebook and Instagram
Google, including Google Ads
other advertising platforms approved by the client.
Depending on the platform and service, identifiers such as email addresses, telephone numbers or names may be hashed or otherwise processed before or during transfer to the advertising platform.
Where practical, we prefer to:
use the minimum information required
use client-owned advertising accounts
use approved platform integrations or interfaces
use direct CRM-to-platform integrations where appropriate
avoid unnecessary downloading or duplication of customer databases
remove temporary customer files when they are no longer required.
Clients are responsible for ensuring they have the necessary permissions, notices, consents or other lawful basis required for the advertising activity they instruct us to undertake.
We may decline to upload or process customer information where we reasonably believe doing so would be inappropriate, unlawful or contrary to the relevant platform’s requirements.
Our website, and websites we operate or manage for clients, may use cookies, pixels, tags and similar technologies.
These technologies can be used for:
essential website functionality
website analytics
measuring advertising performance
conversion tracking
understanding how visitors use a website
improving user experience
remarketing and advertising
attribution and campaign reporting.
Services used may include technologies provided by companies such as Google, Meta and Microsoft.
For example, Microsoft Clarity may be used to understand how users interact with a website through aggregated behaviour information and session interaction data.
Where required, consent management tools may be used to control whether non-essential analytics or advertising technologies operate.
Browser settings can also be used to restrict or delete cookies, although doing so may affect some website functionality.
We may provide personal information to service providers where this is reasonably necessary to operate our business or provide services.
These can include providers of:
website hosting
cloud storage
CRM systems
project management systems
advertising platforms
analytics
reporting
marketing automation
accounting and payment processing
data integration and workflow automation
IT and security services
professional advice
communications and collaboration tools
AI-assisted and productivity tools.
We take reasonable steps to select service providers appropriate to the nature of the information being processed.
We may also disclose information:
where authorised by the person concerned
where instructed by a client in relation to information we process for that client
where required or permitted by law
to protect our legal rights
in connection with the sale, restructuring or transfer of our business, subject to appropriate confidentiality and privacy safeguards.
We may use artificial intelligence, automation and other technology-assisted tools to support our work.
These tools may assist with activities such as:
drafting
research
analysis
summarisation
reporting
workflow automation
content production
data processing.
We will take reasonable steps to avoid providing unnecessary personal information to these services.
We do not intentionally submit complete client customer databases, payment information or highly sensitive personal information to general-purpose AI tools unless this is necessary for an agreed service, authorised where appropriate, and suitable safeguards are in place.
AI-assisted outputs remain subject to human oversight where appropriate for the service being provided.
Some of the technology providers we use operate or store information outside New Zealand.
This may include providers located in countries such as Australia, the United States, the United Kingdom, countries within the European Economic Area, and other jurisdictions in which our technology providers operate.
Where personal information is stored or processed overseas, we take reasonable steps to ensure it is handled in a manner consistent with applicable New Zealand privacy requirements.
Where we process information solely on behalf of a client using an overseas service provider, we will do so in accordance with our agreement with the client and the requirements applying to that processing.
We take reasonable safeguards to protect personal information against:
loss
unauthorised access
misuse
unauthorised disclosure
alteration
destruction.
Depending on the information and system involved, safeguards may include:
password-protected systems
multi-factor authentication
access controls
restricted staff and contractor access
secure cloud services
device security
appropriate data transfer methods
limiting the information collected and retained.
No method of electronic storage or transmission is completely secure, but we take reasonable steps appropriate to the information we hold.
Clients should avoid sending customer databases or other significant personal information through ordinary email attachments where a more secure transfer method is available.
We retain personal information only for as long as reasonably required for the purpose for which it was collected, or as required for legal, accounting or contractual purposes.
For information processed on behalf of clients, retention may also be governed by our agreement with that client.
Where practical, temporary customer data files created for activities such as advertising audience uploads will be deleted when they are no longer required.
At the end of a client engagement, client information will be returned, deleted, archived or otherwise dealt with in accordance with our agreement with the client and applicable legal requirements.
Some information may remain temporarily in secure backups until those backups are overwritten through normal system processes.
If you receive marketing communications directly from theCreator, you can unsubscribe at any time using the unsubscribe option provided or by contacting us.
Where we send or manage marketing communications on behalf of a client, the relevant client is responsible for its customer relationship and marketing permissions. Requests relating to those communications may need to be directed to that client.
You may ask us whether we hold personal information about you and request access to that information.
You may also ask us to correct personal information if you believe it is inaccurate, incomplete or misleading.
To make a request, contact:
Privacy Officer
THE CREATOR (2021) LTD
studio@thecreator.co.nz
We may need to verify your identity before providing access to personal information.
In some circumstances, information we have access to is held or controlled by one of our clients and we are processing it solely on that client’s behalf. If so, we may refer your request to the relevant client or assist that client in responding to your request.
If we become aware of a privacy or security incident involving personal information, we will assess the incident and take appropriate steps to contain and manage it.
Where information affected by an incident is being processed on behalf of a client, we will notify the affected client as soon as reasonably practicable so that the appropriate response can be coordinated.
Where required by law, we or the relevant client will notify the Office of the Privacy Commissioner and affected individuals.
Our services are primarily intended for businesses and adult users.
We do not intentionally collect personal information from children unless this is appropriate for a particular service and appropriate authority or safeguards are in place.
Clients should tell us before providing personal information relating to children or young people where this information is relevant to a project.
Our website may contain links to third-party websites.
We are not responsible for the privacy practices of third-party websites and encourage you to review their privacy policies separately.
We may update this Privacy Policy from time to time to reflect changes to:
our services
the technologies we use
our business practices
privacy laws or regulatory requirements.
The latest version will be published on our website with the effective date shown at the top.
Where a change materially affects how we use personal information, we will take additional steps to notify affected people where appropriate or required.
If you have any questions, concerns or complaints about how we handle personal information, please contact our Privacy Officer first so we can investigate and respond.
Privacy Officer
THE CREATOR (2021) LTD
99 Ferry Road
Christchurch 8011
New Zealand
You may also contact the Office of the Privacy Commissioner New Zealand if you are not satisfied with our response or wish to make a privacy complaint.
