Creatives' Tool | Privacy Policy

As the publisher of the electronic invoicing tool CREATIVES' TOOL ("CREATIVES' TOOL") accessible from the following URL: creativestool.com, respect for privacy and personal data is a priority for the company NV IMAGE, registered with the Paris Trade and Companies Register under number 932351570 and domiciled at 41 rue du Disque 75013 Paris ("NV IMAGE" or "we"). Consequently, we always process personal data in compliance with the regulations in force.

In this respect, the purpose of this document is to inform you of the means we implement to collect and process your personal data when you use CREATIVES' TOOL or the Services, in compliance with Law No. 78-17 of 6 January 1978 on information technology, data files and civil liberties as well as Regulation No. 2016-679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data ("the Policy").

The Policy may be amended at any time, in particular in order to comply with any regulatory, case-law, editorial or technical developments. We therefore recommend that you refer, before any use of CREATIVES' TOOL or of the Services, to the latest version of the Policy.

Article 1 Definitions

The terms defined in our General Terms and Conditions apply to this Policy.

Furthermore, the terms used in the body of the Policy and beginning with a capital letter, whether used in the singular or the plural, shall have the meaning given to them below:

Personal data or Data: any information relating to an identified or identifiable natural person.
Controller: the person who determines the means and purposes of the processing of Personal data.
Joint controllers: mean the persons who jointly determine the means and the purposes of the processing of Personal data.
Processor: the person who processes personal data on behalf of the controller.
Processing: any operation or set of operations carried out in the context of the use of CREATIVES' TOOL and of the Services applied to personal data (examples: collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or any other form of making available, alignment or combination, restriction, erasure or destruction of Personal data).

Article 2 Who is this Policy for?

This policy is addressed to any adult natural person who uses CREATIVES' TOOL ("User(s)" or "you") or who has subscribed to our Services ("the Subscribers" or "you").

Article 3 What is NV IMAGE's role?

We may have the role of Controller and of Processor:

We act as Controller when we process the Personal data of Users and of Subscribers on our own behalf; this is the case for example when you subscribe to our newsletter or when a Subscriber creates an Account in order to benefit from the Services of CREATIVES' TOOL.
Lastly, we act as joint Controllers, together with the company IOPOLE, when we process the Personal Data of FR/BE Subscribers to allow them to use certain Services of CREATIVES' TOOL, namely in particular when we verify their identity upon connection to their Account.
We act as Processor when the Subscriber uses the Services of CREATIVES' TOOL in the course of their professional activities for electronic invoicing or the use of indicators relating to invoicing. In that case, it is the Subscriber who has the role of Controller of the Personal data provided within their Documents (invoices and quotes) which they create, modify, issue and/or import on CREATIVES' TOOL; this includes the Personal data concerning them and, where applicable, the Personal data concerning their own Clients.

The purpose of this Policy is to provide you with information on the processing of Personal data that we carry out in our capacity as Controller and joint Controller.

Article 4 The terms of the processing carried out in our capacity as controller

Reasons for which we collect your Personal data	Categories of Personal data processed	Legal bases	Retention periods
To send you our newsletter when you have subscribed to it	Contact details (email)	Your consent	Until the withdrawal of your consent or up to 3 years from the collection of your consent
To respond to your contact request when you have completed our contact form accessible on CREATIVES' TOOL	Identity (surname and first name); Contact details (email); Data relating to your contact request (content of your message)	Performance of pre-contractual measures with a view to a contract concluded between the Subscriber and NV IMAGE	Up to 6 months from the last contact
To create an Account allowing Subscribers to benefit from the Services of CREATIVES' TOOL	Identity (surname and first name); Professional information (company name, status, country of domiciliation, year of experience, fields of expertise, registration number with the Trade and Companies Register); Contact details (email and telephone number)	Performance of the contract in application of the GTC concluded between the Subscriber and NV IMAGE	For the whole duration of the contractual relationship
To train the CREATIVES' TOOL algorithm making it possible to offer Subscribers a service of supplying invoicing price indicators and statistics	Statistical Data	NV IMAGE's legitimate interest in training its algorithm in order to offer a service of supplying invoicing price indicators and statistics	For the period strictly necessary for the process of anonymising the Personal Data, which is then reprocessed in the context of the Service offered to Subscribers
For commercial and payment management with the Subscriber who benefits from the Services of CREATIVES' TOOL and the technical support service.	Bank details; VAT no.; SIRET no.; Identity (surname and first name); Contact details (email and telephone number); Data relating to your support request	Performance of the contract in application of the GTC concluded between the Subscriber and NV IMAGE	For the whole duration of the contractual relationship, and for a period of 5 years from the end of the contractual relationship, the statutory limitation period in the event of a dispute
For the management of after-sales service with the Subscriber	Identity (surname and first name); Contact details (email); Data relating to your complaint	Performance of the contract in application of the GTC concluded between the Subscriber and NV IMAGE	For the whole duration of the contractual relationship and for a period of 5 years from the end of the contractual relationship, the statutory limitation period in the event of a dispute
To manage our administrative and accounting needs	Identity (surname and first name); Professional information (company name, status, country of domiciliation, year of experience, fields of expertise); Contact details (email and telephone number); Bank details; VAT no.; SIRET no.	Compliance with our legal obligations	Statutory retention periods (10 years from collection)
To ensure the proper functioning of CREATIVES' TOOL (essential cookies) and to produce anonymous statistics on the use of CREATIVES' TOOL in order to make it easier for Subscribers to use (non-essential cookies)	IP address	Our legitimate interest in ensuring the proper functioning of CREATIVES' TOOL (essential cookies); Your consent (non-essential cookies)	For a maximum of 13 months

Article 5 The terms of the processing carried out in our capacity as joint controller with the company IOPOLE

The joint controllers have concluded an agreement defining their respective obligations regarding the protection of the data of FR/BE Subscribers.

The main lines of that agreement are described in this section.

The Processing of personal data implemented in the context of the electronic invoicing Service is carried out jointly by:

NV IMAGE in its capacity as publisher of the electronic invoicing tool
IOPOLE, in its capacity as supplier of the electronic invoice dematerialisation solution, compliant with the regulations.

Within the framework of their joint controllership agreement, NV IMAGE is principally responsible for:

the initial collection of the Data from the Subscriber,
the management of the relationship with its Subscribers on electronic invoicing services,
certain identity verification operations (in the case of manual processing)

IOPOLE intervenes in particular for:

the technical operation of the electronic invoicing solution;
automated identity verification (including, where applicable, via biometric devices subject to consent);
the management of the electronic invoicing directories and of the associated exchanges;
the technical processing of the data necessary for the functioning of the service.

Reasons for which we or IOPOLE collect your personal data	Categories of Personal data processed	Legal bases	Retention periods
To allow the implementation of electronic invoicing and compliance with the associated legal obligations; To verify the identity of Subscribers and their capacity (legal representative, agent or delegate) upon access to the Services; To ensure the registration and the updating of the information in the electronic invoicing directories (in particular the central directory and/or the Peppol network); To guarantee the security of the systems, prevent fraud and retain the evidence necessary in the event of a dispute; To manage requests to exercise rights and any data breaches.	The categories of Personal data processed jointly by NV IMAGE and IOPOLE are the following: Identity Photograph Contact details Professional information In the event of failure of the identity verification by IOPOLE: data extracted from the identity document Electronic invoicing data Timestamp data	Compliance with our legal obligations, in particular that of verifying the Subscriber's identity The legitimate interest of the joint controllers in ensuring the maintenance and the internal security of CREATIVES' TOOL or of IOPOLE The legitimate interest of the joint controllers in retaining evidence in the event of an audit or a dispute	For the statutory limitation periods. At the end of those periods, the Personal data will be archived and then deleted, according to the periods compliant with the legislation in force.

Reasons for which we or IOPOLE collect your personal data

Categories of Personal data processed

Legal bases

Retention periods

To allow the implementation of electronic invoicing and compliance with the associated legal obligations;
To verify the identity of Subscribers and their capacity (legal representative, agent or delegate) upon access to the Services;
To ensure the registration and the updating of the information in the electronic invoicing directories (in particular the central directory and/or the Peppol network);
To guarantee the security of the systems, prevent fraud and retain the evidence necessary in the event of a dispute;
To manage requests to exercise rights and any data breaches.

The categories of Personal data processed jointly by NV IMAGE and IOPOLE are the following:

Identity
Photograph
Contact details
Professional information
In the event of failure of the identity verification by IOPOLE: data extracted from the identity document
Electronic invoicing data
Timestamp data

Compliance with our legal obligations, in particular that of verifying the Subscriber's identity
The legitimate interest of the joint controllers in ensuring the maintenance and the internal security of CREATIVES' TOOL or of IOPOLE
The legitimate interest of the joint controllers in retaining evidence in the event of an audit or a dispute

For the statutory limitation periods.

At the end of those periods, the Personal data will be archived and then deleted, according to the periods compliant with the legislation in force.

You may exercise your rights (access, rectification, erasure, restriction, objection, portability) with IOPOLE as the single point of contact on this Processing, at the following address: gdpr@iopole.com, or with NV IMAGE at the address indicated in this policy.

Article 6 Terms of the processing carried out in our capacity as processor of the Subscriber

Where the Subscriber provides personal data of their Clients or their own personal data relating to their professional activity within their Documents (invoices and quotes) in the CREATIVES' TOOL tool, NV IMAGE is liable to act as processor of the Subscriber for the following Processing: hosting, storage, access to or modification of the Documents, with the exception of the processing relating to the management of electronic invoicing.

The processing relationships are governed by the contract concluded between the Subscriber and NV IMAGE in the General Terms and Conditions.

Article 7 Who are the recipients of the Personal data?

Some of the Personal data that we process is communicated:

To the authorised members of the NV IMAGE team;
To the providers we call upon:
- Newsletter provider: the company SENDINBLUE, a SAS domiciled in France, which publishes the website brevo.com;
- Payment provider: the company Stripe Payments Europe, Ltd. domiciled in Ireland;
- Approved provider for electronic invoicing: the company IOPOLE, a SAS domiciled in France;
- Hosting provider for CREATIVES' TOOL: Clever Cloud SAS, domiciled in France;
- Provider processing the Documents on the basis of an AI technology: DAIJOBU AI SAS, domiciled in France;
- Audience measurement provider: the company Google Ireland Limited, through Google Analytics, domiciled in Ireland;
- Advertising performance measurement provider: the company Meta Platforms Ireland Ltd., through Meta Pixel, domiciled in Ireland.

These two recipients act solely for audience measurement and advertising performance on the CREATIVES' TOOL site, by means of non-essential cookies placed with your prior consent. They under no circumstances receive the Personal data contained in your Documents — invoices and quotes — nor the billing data relating to them.

In the event that we transfer personal data outside the European Economic Area through our recipients, we undertake to preserve your right to respect for Personal data, in application of adequacy decisions, standard contractual clauses approved by the European Commission or binding corporate rules approved by the competent supervisory authorities.

Article 8 What are your rights?

As a person concerned by the processing of your Personal data, you have the following rights:

Right of access: the right to request confirmation as to whether or not your personal data is being processed and, where applicable, access to the said data and to information relating to its processing.
Right to portability: under certain conditions, the right to receive certain personal data that we have collected directly from You and to transmit it to another controller.
Right of rectification: the right to request the rectification of any error in the personal data concerning You.
Right to object: under certain conditions, the right to object to the processing of personal data carried out by CREATIVES' TOOL for reasons relating to your particular situation.
Right to erasure: under certain conditions, the right to request the erasure of your personal data processed.
Right to restriction of processing: the right to request the restriction of the processing of your personal data.
The right to give general and specific directions on the fate of personal data after your death.
Where applicable, the right to withdraw any consent given on CREATIVES' TOOL.

To exercise your rights, We invite You to send us an email to this address: contact@creativestool.com. In case of doubt as to your identity, proof of identity may be requested from You in order to protect us against any fraudulent request.

For any complaint, You may contact the CNIL, online or by post at the following address: 3 Place de Fontenoy – TSA 80715 – 75334 PARIS CEDEX 07 or via the website: cnil.fr.

Article 9 Questions?

For any questions relating to the processing of personal data on CREATIVES' TOOL or in connection with our Services, please contact us at the following email address: contact@creativestool.com.

See also the General Terms and Conditions and the General Terms of Use.