Privacy policy
Creation Capital Management (“CCM,” “we,” “us,” or “our”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website at https://www.creationcm.com (the “Site”). By using the Site, you consent to the practices described in this Privacy Policy.
1. Information We Collect
We may collect the following types of information:
a. Personal Information: Information you voluntarily provide to us, such as your name, email address, phone number, company or organization, or other contact information when you fill out forms, subscribe to updates, or contact us through the Site.
b. Investor and Prospective Investor Information: If you inquire about an investment opportunity or request access to restricted materials, we may collect additional information such as your investor qualification status, jurisdiction, professional background, and any information you choose to share about your investment objectives.
c. Non-Personal Information: Information automatically collected when you visit the Site, which may include your IP address, browser type, device type, operating system, access times, and the pages you have viewed directly before and after accessing the Site.
d. Cookies and Tracking Technologies: We may use cookies, web beacons, and similar tracking technologies to enhance your experience on the Site and gather information about how you use it.
2. How We Use Your Information
We may use the information we collect to:
Provide, operate, and maintain the Site;
Respond to your inquiries or requests;
Evaluate and respond to investor inquiries, including verifying investor status where applicable;
Improve the Site and our services;
Communicate with you about firm updates, insights, or events related to Creation Capital Management (if you have opted in to receive such communications);
Monitor and analyze usage and trends to enhance your experience;
Comply with legal, regulatory, and recordkeeping obligations.
3. How We Share Your Information
We may share your information in the following circumstances:
Service Providers: With third-party vendors who provide services on our behalf, such as website hosting, analytics, email delivery, customer relationship management, or investor administration.
Affiliates: With our affiliated entities, funds, or management companies for the purposes described in this Policy.
Professional Advisors: With our attorneys, accountants, auditors, administrators, and similar professionals in connection with our business.
Legal Requirements: If required by law or in response to valid requests by public authorities or regulators (e.g., a court or government agency).
Business Transfers: In connection with a merger, sale, or transfer of all or a portion of our business.
With Your Consent: For any other purpose disclosed to you and with your consent.
We do not sell your personal information to third parties.
4. Third-Party Links
The Site may contain links to third-party websites and resources. We are not responsible for the privacy practices or content of those sites. We encourage you to review their privacy policies before providing any information.
5. Security
We implement reasonable measures to protect your information from unauthorized access, use, or disclosure. However, no method of transmission over the Internet or electronic storage is 100% secure, and we cannot guarantee absolute security.
6. Data Retention
We retain personal information for as long as necessary to fulfill the purposes described in this Policy, including to maintain business records and to comply with applicable legal, regulatory, tax, and recordkeeping requirements. When information is no longer needed, we take reasonable steps to delete or de-identify it.
7. Children’s Privacy
The Site is not intended for children under the age of 13. We do not knowingly collect personal information from children under 13. If we become aware that we have collected such information, we will take steps to delete it promptly.
8. Your Choices and Rights
Opt-Out: You may opt out of receiving promotional emails from us by following the unsubscribe instructions in those emails.
Cookies: Most web browsers are set to accept cookies by default. You can usually choose to set your browser to remove or reject cookies, but this may affect your experience on the Site.
Access and Deletion: Depending on where you reside, you may have rights to request access to, correction of, or deletion of the personal information we hold about you. To make a request, contact us using the information provided on the Site. We may need to verify your identity before responding.
9. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. Changes will be posted on this page with an updated effective date. Your continued use of the Site after changes constitutes acceptance of the revised policy.
10. Contact Us
If you have any questions about this Privacy Policy or our data practices, please contact us at the contact information provided on the Site.