Date: February 1, 2022
Antifragile Media LLC, dba CreatorML.com (“CreatorML”, “we”, “us” or “our”) respects your privacy and are committed to protecting it through our compliance with this policy.
This policy describes the types of information we may collect from you or that you may provide when you visit the website, https://CreatorML.com (our "Website" or “Site”) and use our web application, together with all associated services, including our free services and subscriptions services that allow you to benefit from our machine learning to optimize video performance on YouTube (our “Services”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.
Information We Collect About You and How We Collect It
We collect several types of information from and about users of our Services, including information:
- By which you may be personally identified, such as name, mailing address, e-mail address, financial information and details related to your YouTube channel ("personal information"); or
- About your internet connection, the equipment you use to access our Services, and usage details.
We collect this information:
- Directly from you when you provide it to us.
- Automatically as you navigate through the Services. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
Information You Provide to Us
The information we collect on or through our Services may include:
- Information that you provide by filling in forms on our Site. This includes information provided at the time of using our free Services for our Shared CTR Model or when subscribing to our Service for a Custom CTR Model, posting or uploading content to our Services, or requesting further services. We may also ask you for information when you report a problem with our Services.
- The text, graphics, images, music, audio, video, works of authorship of any kind, and metrics, information or other materials that you post, upload or otherwise provide or make available to us when you use the Services (“User Content”).
- Records and copies of your correspondence (including email addresses), if you contact us or register an account.
- Your responses to surveys that we might ask you to complete for research purposes.
- Details of transactions you carry out through our Site. You will be required to provide financial information before subscribing to our Services through our Site.
Information We Collect Through Automatic Data Collection Technologies
As you navigate through and interact with our Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and usage patterns, including:
- Details of your visits to our Site, including when you used the Services and for how long, and actions you take and resources that you access within the Services (“Usage Data”).
- Information about your computer and internet connection, including your IP address, operating system, and browser type (“System Data”).
The Usage Data and System Data we collect automatically is only statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Services and to deliver a better and more personalized service, including by enabling us to:
- Estimate our audience size and usage patterns.
- Store information about your preferences, allowing us to customize our Services according to your individual interests.
- Recognize you when you return to our Site.
The technologies we use for this automatic data collection may include:
- Flash Cookies. Certain features of our Services may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Site. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
- Web Beacons. Pages of the Site may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages and for other related website statistics.
Information Provided by Third-Party Services
We may collect the data pertaining to your YouTube channel when you upload videos to the Site to use our Service, including, but not limited to your YouTube Channel name, your name, view counts, video ID, video durations details, YouTube upload date, impression counts and click-thru rate (“Video Data”) as permitted by YouTube's Terms of Service for use by us. By using YouTube Content within our Sites and Services you are agreeing to be bound by YouTube’s Terms of Service.
How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information:
- To provide and improve our Site and Services, including using your Video Data to improve our Shared CTR Model and Custom CTR Models.
- To provide you with information, products, or services that you request from us.
- To provide you with news and newsletters, special offers, and promotions; to contact you about products or information we think may interest you; and for other marketing, advertising, and promotional purposes. We may provide you with such updates and promotional materials via email.
- To analyze how you interact with our Services; to monitor and analyze usage and activity trends; and for other research, analytical, and statistical purposes both on an aggregated and individualized basis including to respond to user desires and preferences.
- To provide you with notices about your subscription, including expiration and payment processing notices.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
- To notify you about changes to our Services.
- Legal Compliance. To comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; to respond to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request, whether formal or informal, from law enforcement or a governmental authority.
- In any other way we may describe when you provide the information.
Disclosure of Your Information
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
- To our subsidiaries and affiliates.
- To contractors, service providers, licensors and other third parties we use to support our business. For example, we use third-party application program interfaces (APIs) to support the functionality of our Services and third-party payment processors to process all fees associated with use of our Services.
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of CreatorML’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Service’s users is among the assets transferred.
- To fulfill the purpose for which you provide it.
- For any other purpose disclosed by us when you provide the information.
- With your consent.
We may also disclose your personal information:
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
- To enforce or apply our Terms of Service and other agreements, including for billing and collection purposes.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of our users, or others.
Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
Accessing and Correcting Your Information
You can review and change your personal information by logging into the Site and visiting your account profile page.
You may also send us an email at [email protected] to request access to, correct or delete any personal information that you have provided to us.
If you delete your User Content from the Site, copies of your User Content may remain viewable in cached and archived pages.
Third Party Links
Our Site and Services may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites.
We may send periodic promotional emails to you. You may opt-out of promotional communications by clicking the unsubscribe link in any such communications or by emailing us at [email protected]. Please note that it may take up to 15 business days for us to process opt-out requests. If you opt-out of receiving promotional emails about recommendations or other information we think may interest you, we may still send you emails about your account or any services you have requested or received from us.
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Site. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained in the Site.
Privacy Rights for California Residents
In this section, we provide additional information to California residents about how we handle their personal information, as required under California privacy laws including the California Consumer Privacy Act (“CCPA”). This section does not address or apply to our handling of publicly available information lawfully made available by state or federal government records or other personal information that is exempt under the CCPA.
A. Categories of Personal Information Under the CCPA (Last Updated: February 1, 2022)
While our collection, use and disclosure of personal information varies based upon our relationship and interactions with you, in this section we describe how we have collected and disclosed personal information about consumers in the prior 12 months (from the Last Updated date above).
We have collected the following categories of personal information (as defined by the CCPA) about California residents:
Identifiers: includes direct identifiers, such as name, user ID, alias, username, account number or unique personal identifier; email address, phone number, address and other contact information; IP address, cookie ID, device ID, and other online identifiers.
Customer Records: includes personal information, such as name, account name, contact information, that individuals provide us in order to purchase or obtain our services.
Commercial Information: customer services purchased, obtained, or considered, or other purchasing or use histories or tendencies.
Usage Data: Includes browsing history, clickstream data, search history, access logs and other usage data and information regarding an individual’s interaction with our websites, mobile apps, and our marketing emails and online ads.
Geolocation Data: Includes precise location information about a particular individual or device.
Inferences: includes inferences drawn from personal information that we collect to create a profile reflecting an individual’s preferences, characteristics, predispositions, behavior, attitudes, intelligence, abilities or aptitudes.
Service Provider Disclosures. We provide the following categories of personal information to the service providers listed below:
Identifiers: may be shared with service providers; our advisors and agents; government entities and law enforcement; our affiliates and subsidiaries; advertising networks; data analytics providers; social networks; internet service providers; operating systems and platforms; our marketing partners.
Customer Records: may be shared with service providers; our advisors and agents; government entities and law enforcement; our affiliates and subsidiaries; advertising networks; data analytics providers; social networks; internet service providers; operating systems and platforms; our marketing partners.
Commercial Information: may be shared with service providers; our advisors and agents; government entities and law enforcement; our affiliates and subsidiaries; advertising networks; data analytics providers; internet service providers; operating systems and platforms; our marketing partners.
Usage Data: may be shared with our service providers; our advisors and agents; government entities and law enforcement; our affiliates and subsidiaries; advertising networks; data analytics providers; internet service providers; operating systems and platforms; our marketing partners.
Geolocation Data: service providers; our advisors and agents; government entities and law enforcement; our affiliates and subsidiaries; advertising networks; data analytics providers; internet service providers; operating systems and platforms; our marketing partners.
Inferences: service providers; our advisors and agents; government entities and law enforcement; our affiliates and subsidiaries; advertising networks; data analytics providers; internet service providers; operating systems and platforms; our marketing partners.
Do We “Sell” Personal Information? Under the CCPA, a “sale” includes disclosing or making available personal information to a third-party in exchange for monetary compensation or other benefits or value. We do not disclose personal information to third parties in exchange for monetary compensation. We may disclose or make available certain categories of personal information to third parties in order to receive certain benefits or services, such as when we make browsing information available to third party ad companies (through third party tags on our Sites) in order to improve and measure our ad campaigns and reach users with more relevant ads and content.
Sources of Personal Information. As described in the above section, we may collect personal information from the following sources:
- directly from the individual
- advertising networks
- data analytics providers
- social networks
- internet service providers
B. California Residents’ Rights
CCPA Rights. In general, California residents have the following rights with respect to their personal information:
Do-not-sell (opt-out): to opt-out of our sale of their personal information. We do not sell personal information about California consumers, including those we have actual knowledge are younger than 16.
Right of deletion: to request deletion of their personal information that we have collected about them and to have such personal information deleted (without charge), subject to certain exceptions.
Right to know: with respect to the personal information we have collected about them in the prior 12 months, to require that we disclose the following to them (up to twice per year and subject to certain exemptions):
categories of personal information collected;
categories of sources of personal information;
categories of personal information about them we have disclosed for a business purpose or sold;
categories of third parties to whom we have sold or disclosed for a business purpose their personal information;
the business or commercial purposes for collecting or selling personal information; and
a copy of the specific pieces of personal information we have collected about them.
Right to non-discrimination: the right not to be subject to discriminatory treatment for exercising their rights under the CCPA.
Submitting CCPA Requests. California residents may submit CCPA requests to opt out of sales, requests to know (access) and requests to delete their personal information by emailing us at [email protected].
When you submit a request to know or a request to delete, we will take steps to verify your request by matching the information provided by you with the information we have in our records. In some cases, we may request additional information in order to verify your request or where necessary to process your request. If we are unable to adequately verify a request, we will notify the requestor. Authorized agents may initiate a request on behalf of another individual by contacting us at the above email address or telephone number; authorized agents will be required to provide proof of their authorization and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.
Privacy Rights for EU Residents
Residents of the European Economic Area (“EEA”) may be entitled to rights under the GDPR. If you qualify, these rights are summarized below.
If you request to exercise your rights under the GDPR, we may require verification of your identity before we respond to any such request. If you are entitled to these rights, you may exercise the following rights with respect to your personal information that we collect and store:
- the right to withdraw consent to data processing at any time;
- the right of access to your personal information;
- the right to request a copy of your personal information;
- the right to correct any inaccuracies in your personal information;
- the right to erase your personal information;
- the right to data portability, meaning to request a transfer of your personal information from us to any other person or entity as chosen by you;
- the right to request restriction of the processing of your personal information; and
- the right to object to processing of your personal information.
The Data Controller of the information collected through the Site and Services is Antifragile Media LLC which is headquartered in the United States. To exercise any rights that you may have with regard to your personal data, you may do so free of charge by contacting us at [email protected]. These rights will be exercisable subject to limitations as provided for by the GDPR. If you are an EEA resident, you have the right to lodge a complaint with a Data Protection Authority about how we process your Personal Information at the following website: https://edpb.europa.eu/about-edpb/board/members_en.
Notice to Non-US Residents
Please be aware that we have offices in the United States. The Site is governed by United States law. If you are using any of our Services from outside of the United States, your information may be transferred to, stored, and processed in the United States where our servers may be located. The United States might not offer the same level of privacy protection as the country where you reside or are a citizen. BY USING THE SITE, COMMUNICATING WITH US VIA MAIL, EMAIL OR TELEPHONE, OR OTHERWISE PROVIDING INFORMATION TO US, YOU CONSENT TO THE TRANSFER TO, AND PROCESSING OF, YOUR INFORMATION IN THE UNITED STATES.
Children Under the Age of 13
Our Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect personal information from children. If you learn that your child has provided us with personal information without your consent, you may contact us [email protected] If we learn that we have collected a child’s personal information in violation of applicable law, we will promptly take steps to delete such information.