Privacy Policy Updated June 2026
Article 1 Introduction
As the publisher of the electronic invoicing tool CREATIVES' TOOL ("CREATIVES' TOOL"), accessible at the following URL: creativestool.com, the protection of privacy and personal data is a priority for the company NV IMAGE, registered with the Paris Trade and Companies Register under number 932351570 and located at 41 rue du Disque, 75013 Paris ("NV IMAGE" or "we"). Consequently, we always process personal data in compliance with applicable regulations.
In this regard, this document is intended to inform you of the means we implement to collect and process your personal data when you use CREATIVES' TOOL or the Services, in accordance with French Law N°78-17 of 6 January 1978 relating to Information Technology, Data Files and Civil Liberties, as well as EU General Data Protection Regulation No. 2016/679 of 27 April 2016 ("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 to the latest version of the Policy before any use of CREATIVES' TOOL or the Services.
Article 2 Definitions
The terms defined in our General Terms and Conditions available at the following link: General Terms and Conditions shall apply to this Policy.
In addition, the terms used in this Policy and beginning with a capital letter, whether used in the singular or plural, shall have the meanings given below:
- Controller: the person which determines the purposes and means of the processing of Personal Data.
- Joint Controllers: the persons which jointly determine the purposes and means of the processing of Personal Data.
- Personal Data or Data: any information relating to an identified or identifiable natural person.
- Processing: any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
- Processor: a person which processes Personal Data on behalf of the Controller
Article 3 Who is this Policy addressed to?
This Policy applies to any adult natural person who uses CREATIVES' TOOL ("User(s)" or "you") or who has subscribed to our Services ("Subscriber(s)" or "you").
Article 4 What is NV IMAGE's role?
We may act as Controller and as Processor:
- We act as Controller when we process the Personal Data of Users and Subscribers on our own behalf. This is the case, for example, when you subscribe to our newsletter or when a Subscriber creates an Account to benefit from CREATIVES' TOOL's Services.
- We act as Joint Controllers, together with the company IOPOLE, when we process the Personal Data of FR/BE Subscribers in order to enable them to use certain Services of CREATIVES' TOOL, including when we verify their identity upon logging into their Account.
- We act as Processor when the Subscriber uses CREATIVES' TOOL's Services in the context of their professional activities for electronic invoicing or the use of indicators related to invoicing. In this case, the Subscriber acts as Controller of the Personal Data contained in their Documents (invoices and quotes) that they create, modify, issue and/or import on CREATIVES' TOOL, including their own Personal Data and, where applicable, the Personal Data of their own Clients.
This Policy is intended to provide you with information on the Personal Data processing activities that we carry out in our capacity as Controller and Joint Controller.
Article 5 Processing activities as Controller
The table below summarises the main processing activities for which NV IMAGE acts as Controller:
| Purposes | Categories of Personal Data | Legal bases | Retention periods |
|---|---|---|---|
| To send you our newsletter when you have subscribed to it | Contact information (email address) | Your consent | Until you withdraw your consent or for up to 3 years from the date your consent was obtained |
| To respond to your contact request when you have completed our contact form available on CREATIVES' TOOL | Identity (first name and last name); contact information (email address); data relating to your contact request (content of your message) | Performance of pre-contractual measures in view of a contract between the Subscriber and NV IMAGE | For up to 6 months from the last contact |
| To create an Account enabling Subscribers to benefit from the Services of CREATIVES' TOOL | Identity (first name and last name); professional information (company name, legal status, country of establishment, years of experience, areas of expertise, registration number); contact information (email address and phone number) | Performance of the contract under the Terms and Conditions concluded between the Subscriber and NV IMAGE | For the entire duration of the contractual relationship |
| To train the CREATIVES' TOOL algorithm to provide Subscribers with a service offering pricing indicators and statistics | Statistical Data | NV IMAGE's legitimate interest in training its algorithm to provide a service offering pricing indicators and statistics | For the period strictly necessary to anonymize the Personal Data |
| For commercial management and payment processing with the Subscriber benefiting from the Services of CREATIVES' TOOL, as well as for technical support services | Bank details; VAT number; SIRET number; identity (first name and last name); contact information (email address and phone number); data relating to your support request | Performance of the contract under the Terms and Conditions concluded between the Subscriber and NV IMAGE | For the entire duration of the contractual relationship, and for a period of 5 years following the end of the contractual relationship, corresponding to the French statutory limitation period in the event of a dispute |
| For sales service management with the Subscriber | Identity (first name and last name); contact information (email address); data relating to your complaint | Performance of the contract under the Terms and Conditions concluded between the Subscriber and NV IMAGE | For the entire duration of the contractual relationship, and for a period of 5 years following the end of the contractual relationship, corresponding to the French statutory limitation period in the event of a dispute |
| For the management of our administrative and accounting needs | Identity (first name and last name); professional information (company name, legal status, country of establishment, years of experience, areas of expertise); contact information (email address and phone number); bank details; VAT number; SIRET number | Compliance with our legal obligations | Statutory retention periods (10 years from the date of collection) |
| To ensure the proper functioning of CREATIVES' TOOL (essential cookies), to generate audience statistics via Google Analytics and to measure the performance of our advertising campaigns via Meta Pixel / Facebook Pixel (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 period of thirteen (13) months |
Article 6 Joint controllership with IOPOLE
The Joint Controllers have entered into an agreement defining their respective obligations regarding the protection of the Personal Data of FR/BE Subscribers.
The main aspects of this agreement are described in this section.
The processing of Personal Data carried out as part of the electronic invoicing service is jointly performed by:
- NV IMAGE, as publisher of the electronic invoicing tool,
- IOPOLE, as provider of the electronic invoicing dematerialization solution, in compliance with applicable regulations.
Within the framework of their joint controllership agreement, NV IMAGE is primarily responsible for:
- the initial collection of Data from the Subscriber,
- the management of the relationship with its Subscribers regarding electronic invoicing services,
- certain identity verification operations (in the case of manual processing).
IOPOLE is notably responsible for:
- the technical operation of the electronic invoicing solution,
- automated identity verification (including, where applicable, via biometric devices subject to consent),
- the management of electronic invoicing directories and related exchanges,
- the technical processing of data necessary for the operation of the service.
The following table summarises the main aspects of processing carried out as Joint Controllers:
| Purposes | Categories of Personal Data | Legal bases | Retention periods |
|---|---|---|---|
| To enable the implementation of electronic invoicing and compliance with the related legal obligations; to verify the identity of Subscribers and their capacity (legal representative, agent or delegate) when accessing the Services; to ensure registration and updating of information in electronic invoicing directories (including the central directory and/or the Peppol network); to ensure system security, prevent fraud and retain the evidence necessary in the event of a dispute; to manage requests for the exercise of rights and any data breaches. | Identity; photograph; contact information; professional information; in the event of failure of identity verification by IOPOLE: data extracted from the identity document; electronic invoicing data; timestamp data | Compliance with our legal obligations, in particular the obligation to verify the identity of the Subscriber; the legitimate interest of the Joint Controllers in ensuring the maintenance and internal security of CREATIVES' TOOL or IOPOLE; the legitimate interest of the Joint Controllers in retaining evidence in the event of an audit or dispute. | For the French statutory limitation periods. At the end of these periods, the Personal Data will be archived and then deleted, in accordance with the time limits set out by applicable legislation. |
You may exercise your rights (access, rectification, erasure, restriction, objection and portability) with IOPOLE, acting as the single point of contact for these processing activities, at the following address: gdpr@iopole.com, or with NV IMAGE at the address indicated in this Policy.
Article 7 Processing as Processor of the Subscriber
Where the Subscriber provides Personal Data relating to its Clients or its own Personal Data relating to its professional activity within its Documents (invoices and quotes) through CREATIVES' TOOL, NV IMAGE may act as a Processor on behalf of the Subscriber for the following processing activities: hosting, storage, access to or modification of the Documents, excluding processing activities relating to the management of electronic invoicing.
The Processor relationship is governed by the contract entered into between the Subscriber and NV IMAGE under the General Terms and Conditions.
Article 8 Recipients of Personal Data
Some of the Personal Data we process is disclosed to:
- Authorized members of the NV IMAGE team.
- The service providers we engage:
- Newsletter service provider: the company SENDINBLUE, domiciled in France, which operates the website brevo.com.
- Payment service provider: the company Stripe Payments Europe Ltd., domiciled in the USA.
- Approved electronic invoicing service provider: the company IOPOLE, domiciled in France.
- Hosting service provider: the company Clever Cloud SAS, domiciled in France.
- Document processing service provider based on AI technology: the company DAIJOBU AI SAS, domiciled in France.
- Audience measurement and statistical analysis provider: Google LLC, through Google Analytics, domiciled in the United States. Google Analytics places cookies on your device in order to measure traffic on CREATIVES' TOOL and analyze your browsing. The data collected (anonymized IP address, pages visited, session duration) is transferred to Google servers in the United States under the standard contractual clauses approved by the European Commission. These cookies are only placed with your prior consent.
- Advertising performance measurement provider: Meta Platforms Ireland Ltd., through Meta Pixel (Facebook Pixel), domiciled in Ireland. Meta Pixel places cookies on your device in order to measure the effectiveness of our advertising campaigns on Meta platforms (Facebook, Instagram) and to offer you targeted advertising. The data collected (browsing data, conversions) may be transferred to servers in the United States under the standard contractual clauses approved by the European Commission. These cookies are only placed with your prior consent.
In the event that we transfer Personal Data outside the European Economic Area through our recipients, we undertake to preserve your right to the protection of personal data, by virtue of adequacy decisions, standard data protection clauses adopted by the Commission, or binding corporate rules approved by the competent supervisory authorities.
Article 9 Your rights
As a data subject whose Personal Data is being processed, you benefit from 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 said data and information relating to its processing.
- Right to data 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 to rectification: the right to request the correction of any inaccuracy in your Personal Data.
- Right to object: under certain conditions, the right to object to the processing of your Personal Data carried out by CREATIVES' TOOL on grounds relating to your particular situation.
- Right to erasure: under certain conditions, the right to request the erasure of your Personal Data.
- Right to restriction of processing: the right to request the restriction of the processing of your Personal Data.
- Instructions after death: the right to issue general and specific instructions regarding the fate of your 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 at the following address: contact@creativestool.com. In case of doubt regarding your identity, proof of identity may be requested in order to protect 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 10 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 General Terms and Conditions and Terms of Use.