CREA, LLC
Privacy Policy
Last Update / Effective Date: April 15, 2026
This Privacy Policy (“Policy”) describes how CREA, LLC and its affiliates (“CREA,” “Company,” “we,” “us,” or “our”) collect, use, disclose, retain, and otherwise process personal information through our websites, portals, communications, and related online and offline interactions (collectively, the “Services”).
Depending on your state of residence, you may have certain rights regarding your personal information, including rights to access, correct, delete, obtain a copy of, or opt out of certain processing of your information.
If you use this website (“Site”), you must comply with our Terms of Use (“Terms”) found https://www.creallc.com/terms-of-use.
1. CATEGORIES OF PERSONAL INFORMATION WE COLLECT
Personal Information is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked to an identified or identifiable individual, subject to applicable legal exclusions (“Personal Information”). Sensitive Personal Information includes categories treated as sensitive under applicable law, such as precise geolocation, account log-in credentials, financial account information in combination with required access credentials, contents of communications where we are not the intended recipient, certain government identifiers, and certain information revealing characteristics such as racial or ethnic origin, citizenship or immigration status, religious beliefs, health information, biometric data, or personal data collected from a known child, where applicable under law.
Depending on how you interact with our Site or Services, we may collect the following categories of Personal Information:
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Identifiers and contact information, such as name, email address, postal address, phone number, online identifiers, IP address, username, and account credentials.
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Commercial or transaction information, such as records of services requested, considered, or obtained.
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Internet or electronic network activity, such as browsing activity, interactions with our Services, device/browser data, and referring/exit pages.
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Geolocation data, such as approximate location derived from IP address and, where enabled, more precise geolocation.
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Professional, employment, and education information, including information in resumes, applications, and related recruiting materials.
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Communications and feedback, including the contents of messages, inquiries, and submissions to us.
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Inferences, such as preferences or interests derived from interactions with our Services.
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Sensitive personal information/sensitive data, only where relevant to the services, recruiting, compliance, security, or other disclosed purposes
We do not collect all categories of personal information from every individual.
This Policy does not apply to any information that is publicly available.
2. CATEGORIES OF SOURCES
We may collect all categories of Personal Information listed above from the following categories of sources:
We Collect Personal Information Directly From You and/or Your Household. We collect Personal Information that you provide directly to us. Personal Information is required to use certain Site features, for example, to contact us via email or phone, submit job application materials, receive or request data from us, and respond to communications from us.
Feedback. When you provide comments or feedback about our Site, the content on the Site, or our products or services ("Feedback"), we will not treat that Feedback as confidential, and we may use that Feedback for any purpose in our sole discretion so long as it does not personally identify you. Feedback will be used without attribution or compensation to you.
Applying to Work with Company. To submit job application materials online to work with Company, you will be redirected from our Site to a website operated by our services provider. You may be required to create an account with that vendor. We encourage you to review the terms and privacy policy posted on that vendor's website since this Policy does not govern your use of that website. If you send us your job application materials directly, we will only use and share those job application materials to evaluate your qualifications to work with Company and its affiliates and communicate with you regarding an employment opportunity.
Business Contracts and Communications with Us. When a business communicates with us or contracts directly with us for the purchase of our services, we may collect the business contact information of those involved. The processing of any information provided in such a business context is governed by the contracts between that business and Company.
We Collect Personal Information Automatically. We automatically collect certain information from you when you access our Site.
Cookies & Other Tracking Technologies.
What types of online tracking mechanisms do we use? We may use cookies, web beacons, pixel tags and other tracking technologies (collectively “Cookies”) on our Site.
What are cookies and web beacons / pixel tags? A cookie is a small text file that our Site saves onto your computer or device when you use the Site that provides us certain information about your activities. Cookies allow the Site to remember your actions and preferences and recognize you or your browser. Web beacons / pixel tags are small graphics on a webpage that monitor your activity when viewing a webpage.
Why do we collect Cookies? We use Cookies to:
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tailor our interactions with you;
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help with our marketing efforts;
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provide us with valuable data and statistics about the usage and effectiveness of our Site and to help us improve our Site; and
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help us improve our services.
What type of information do Cookies collect? The Cookies on our Site may collect information such as:
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the IP addresses assigned to the computers and other devices you use;
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your internet service provider;
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the device ID number;
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approximate geographic location;
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the Site pages visited or clicked on;
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the date and time you visited the Site, and the amount of time spent on the Site;
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your operating system, browser type, search requests, and other similar information;
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the websites you access before and after visiting the Site, and
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data related to how and when you use the Site.
We may combine information from Cookies with Personal Information, including data obtained from other sources.
How long do Cookies last? A Cookie can either be a “session” Cookie or a “persistent” Cookie. Session Cookies exist only for so long as you are visiting the applicable Site and are typically deleted when you exit your web browser. Persistent Cookies exist for a set period of time, for example, up to several months or years. Each time you visit a Site that has implemented a persistent Cookie, the persistent Cookie is renewed, and that Cookie will remain active until its predetermined expiration date. You can manually delete persistent Cookies through your browser settings.
First-party versus third-party Cookies. Cookies may either be “first-party” or “third-party” Cookies. A first-party Cookie allows your web browser to talk to the actual Site that you are visiting (i.e. this Site). A third-party Cookie allows your web browser to talk to a third-party website, such as the source of an ad that appears on the website you are visiting or a third-party analytics provider. We do not have control over how information gathered by third-party Cookies is used by third parties.
How do you manage Cookies or opt-out? Most browsers automatically accept cookies. You can disable this function by changing your browser settings, but disabling cookies may impact your use and enjoyment of the Site. Not all features or functions of the Site may work properly if you disable Cookies. You cannot disable all Cookies, such as Cookies that are essential to the functioning of the Site.
Do Not Track. We do not currently employ a process for automatically responding to “Do Not Track” (DNT) signals sent by web browsers, mobile devices, or other mechanisms. Per industry standards, third parties may be able to collect information, including personal information, about your online activities over time and across different websites or online services when you use the Site.
Global Privacy Control. You can use the Global Privacy Control (“GPC”) through a supported browser to signal certain of your opt-out preferences. You may opt-out of the processing of your Personal Information for purposes of targeted advertising or certain sales of your personal information by broadcasting the Global Privacy Control Signal through a supported browser. If you use the GPC, we will process your request for your browser, but it will not apply outside of that browser to your device. You will need to use the GPC for each browser you use to access the website If you clear your cookies in your browser after using the GPC, you will need to use the GPC again for us to process your opt out for that browser.
Google Analytics. We use Google Analytics to collect and process information about your use of the Site. Google sets cookies on your browser or device, and then your web browser will automatically send information to Google. Google uses this information to provide us with reports that we use to better understand and measure how users interact with our Site.
To learn more about how Google uses data, visit Google’s Privacy Policy and Google’s page on “How Google uses data when you use our partners’ sites or apps.” You may download the Google Analytics Opt-out Browser Add-on for each web browser you use, but this does not prevent the use of other analytics tools. To learn more about Google Analytics cookies, visit Google Analytics Cookie Usage on Websites.
Atlist Maps. The Site contains maps provided by third parties and/or service providers for your convenience. Company and such other parties may collect data about how you interact with the maps. For example, Atlist may collect usage data on maps embedded on the Site. Please see Atlist’s Privacy Policy for more information.
We Collect Personal Information From Third-Party Sources. We obtain data about individuals from various third-party companies and public sources, and we may combine that data with Personal Information or other data we collect, for example through Company Accounts. We utilize a third party to maintain portals for developers and investors. To create an online account, you must submit your name and email address and create a password. This data is used to populate a profile within your account. These accounts are governed by our vendor’s Privacy Policy and Terms.
3. PURPOSE FOR COLLECTING PERSONAL INFORMATION
We may use all categories of Personal Information listed above for the following business purposes:
As Stated or Agreed to at the Point of Collection. We may use Personal Information for the purposes stated or agreed-to (or as is obvious) at the point of collection. For example, we use Personal Information to respond to your questions, comments, or complaints. We may also use Personal Information as requested or consented to by you.
Administration. We use Personal Information for administrative purposes, such as to inform our business strategies, to understand the Site’s demographics and user preferences.
Site Management. We use Personal Information for Site management, such as troubleshooting problems, improving the content and functionality of the Site, statistical and other analyses of the Site, and to customize the Site to you and our users.
Communications and Corporate Updates. We may use Personal Information to notify you of new services, products, business opportunities, programs, or company news updates, to notify you of changes to our Terms or this Policy, and for other similar communications.
To Protect Our Rights. We may use Personal Information to protect our legal rights or interests, or those of other parties, including to bring a legal action against you or anyone who may be causing harm to us, our Site, or to other users of the Site. We may also use Personal Information to seek business, financial or legal advice, and to respond to other legal requests.
We process personal information only as reasonably necessary and proportionate for the purposes described in this Privacy Policy or otherwise disclosed at the time of collection, subject to applicable law.
4. CATEGORIES OF PARTIES WITH WHOM WE SHARE PERSONAL INFORMATION
We may share all categories of Personal Information listed above with the following categories of persons and service providers:
Employees and Affiliates. We may share Personal Information with our employees and affiliates who have a need to know the information for our business purposes.
Service Providers. We may share Personal Information with service providers that provide services for us. We have contracted with our service providers to protect any such Personal Information. For example, we may share Personal Information with service providers to: help us host and manage the Site; market to you; improve the content and functionality of the Site; perform data analysis and statistical analysis; troubleshoot problems with the Site; provide public relations services; provide learning management systems; provide email services; provide data processing; and support or provide the security of the Site.
Government Officials / Law Enforcement. We will cooperate with law enforcement and other governmental agencies, and may disclose Personal Information: (i) if we believe in good faith we are legally required to disclose that Personal Information, (ii) if we are advised to disclose Personal Information by our legal counsel, or (iii) when necessary to identify, contact or bring a legal action against someone who may cause or be causing harm to, or interfering with the legal rights of, Company or any other party.
Professional Advisors. We may share Personal Information with our professional advisors, such as our attorneys, accountants, financial advisors and business advisors, in their capacity as advisors to Company.
Change in Ownership. In the event (a) Company is subject to a change of control, (b) the Site changes ownership, in whole or in part, or (c) of a bankruptcy, receivership or a similar transaction, we may provide Personal Information to the subsequent owner(s), including as part of any due diligence process.
Other. We may share Personal Information with third parties and/or service providers when explicitly requested by or consented to by you, or for the purposes for which you disclosed the Personal Information to us as indicated at the time and point of the disclosure (or as was obvious at the time and point of disclosure).
5. USE AND DISCLOSURE OF DE-IDENTIFIED OR AGGREGATED INFORMATION
Company may collect, use, share, transfer and otherwise process de-identified and aggregated information that it receives or creates for any purposes in its sole discretion, in compliance with applicable laws. Company is the sole and exclusive owner of such de-identified and aggregated information, including if Company de-identifies Personal Information so that it no longer considered Personal Information under applicable laws.
6. CHILDREN
The Site and our Services are not directed at children under 13 years of age. We do not knowingly collect, use, or share Personal Information from children under 13. If a parent or legal guardian learns that their child provided us with Personal Information without his or her consent, please contact us and we will make commercially reasonable attempts to delete such Personal Information.
7. SOCIAL MEDIA
We are active on social media, including Facebook, and LinkedIn (“Social Media”). Anything you post on Social Media is public information and will not be treated confidentially. We may post (or re-post) on the Site and our Social Media pages any comments or content that you post on our Social Media pages.
The Site allows you to connect and share data with Social Media platforms. These features may require us to use cookies, plug-ins, and APIs provided by such Social Media platforms to facilitate those communications and features. The Site may use advertising networks and services offered by Social Media platforms to deliver advertising content. Use of these services requires Social Media platforms to implement cookies or pixel tags to deliver ads to you while you access the Site.
Your use of Social Media is governed by the privacy policies and terms of the providers that own and operate those websites and not by this Policy. We encourage you to review those policies and terms.
8. DATA SECURITY
We use commercially reasonable technical and organizational measures to help secure Personal Information against loss, misuse, and alteration appropriate to the type of Personal Information processed. If a breach of your Personal Information occurs, we will notify you of the breach if required under applicable law.
NO DATA TRANSMISSION OVER THE INTERNET OR DEVICE CAN BE GUARANTEED TO BE 100% SECURE. WHILE WE STRIVE TO PROTECT PERSONAL INFORMATION, WE DO NOT GUARANTEE THE SECURITY OF PERSONAL INFORMATION AND YOU PROVIDE PERSONAL INFORMATION AT YOUR OWN RISK.
9. ACCESS FROM OUTSIDE THE UNITED STATES
If you access the Site from outside the United States, please be aware that Personal Information may be transferred to, stored in, and processed in the United States. Certain governmental authorities may not consider the level of protection of Personal Information in the United States to be equivalent to that required in other jurisdictions.
10. THIRD-PARTY WEBSITES
The Site may link to, or be linked to, websites not owned or controlled by us. We are not responsible for third-parties’ privacy policies or practices. This Policy does not apply to any third-party websites or to any data that you provide to third parties. You should read the privacy policy for each website that you visit.
11. U.S. STATE PRIVACY RIGHTS
Depending on where you live and the laws that apply, you may have certain statutory data protection rights regarding your personal information. These rights may be subject to exceptions and limitations under applicable law.
You may have the right to:
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be informed of what personal data we hold about you and request access to and/or a copy of it;
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request that we correct personal information that is inaccurate or incomplete;
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request that personal information be removed from our systems (deleted), subject to certain exceptions;
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request a portable copy of certain personal information;
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opt out of certain processing of your personal information, including (where applicable) targeted advertising, and the sale or sharing of personal information (as those terms may be defined by applicable law);
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withdraw your consent at any time where we process personal information based on your consent (this will not affect the lawfulness of processing before you withdrew consent);
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not be discriminated against for exercising your rights (where applicable); and
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appeal a decision we make about your request (where applicable under U.S. state law).
Sale/Sharing for targeted advertising: CREA does not sell personal information. CREA does not share personal information for cross-context behavioral advertising (also called targeted advertising) as those terms may be defined under certain U.S. state privacy laws.
Sensitive personal information: CREA uses sensitive personal information only for purposes such as providing services, credentialing, security, fraud prevention, and compliance with law, as described above, and not to infer characteristics about you for targeted advertising.
Non-discrimination: CREA will not discriminate against you for exercising your privacy rights.
If you wish to exercise any of these rights, please contact us by writing to or emailing us at privacy@creallc.com
You may also mail your request to:
CREA, LLC
Attn: Legal Department
30 South Meridian Street, Suite 400
Indianapolis, Indiana 46204
We may need to verify your identity before processing certain requests. We will respond within the time required by applicable law.
Authorized agents (where applicable): In some U.S. states, you may designate an authorized agent to submit a request on your behalf. If you use an authorized agent, we may ask for proof that the agent is authorized, and we may also require you to verify your identity directly with us.
Appeals (where applicable): If we deny your request, you may have the right to appeal our decision. To appeal, please email privacy@creallc.com with the subject line “Privacy Request Appeal” and include your original request and our response. We will review and respond within the time required by applicable law.
Shine the Light. Pursuant to California Civil Code Section 1798.83, if you are a California resident, you have the right to obtain: (a) a list of all third parties to whom we may have disclosed your Personal Information within the past year for direct marketing purposes, and (b) a description of the categories of Personal Information disclosed, by contacting us per the “Contact Us” Section below.
12. CHANGES TO THIS POLICY
We may update this Privacy Policy from time to time. When we make material changes, we will post the updated Privacy Policy and revise the “Last Updated” date. Where required by law, we will provide additional notice and/or obtain consent for materially different processing.
13. CONTACT US
If you have any questions, you may contact us as set forth below:
CREA, LLC
Attn: Legal Department
30 South Meridian Street, Suite 400
Indianapolis, Indiana 46204
1-855-279-2732