This privacy policy sets out how Creative Media Systems Limited uses and protects any information that you provide us when you use this website.

Creative Media Systems Limited is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement.

Creative Media Systems Limited may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes.

This is our updated Privacy Policy going into effect on May 25, 2018. Your privacy is critically important to us. At Creative Media Systems, we have a few fundamental principles:

We are thoughtful about the personal information we ask you to provide and the personal information that we collect about you through the operation of our services.

We store personal information for only as long as we have a reason to keep it.

We aim to make it as simple as possible for you to control what information on your website is shared publicly (or kept private), indexed by search engines, and permanently deleted.

We help protect you from overreaching government demands for your personal information.

We aim for full transparency on how we gather, use, and share your personal information.

Below is our Privacy Policy, which incorporates and clarifies these principles.

We are the folks behind a variety of products and services designed to help entrepreneurs and more established companies conceptualise, design and commercialise new products. Our mission is to support entrepreneurs and enterprise teams globally through our online services and local partners. This Privacy Policy applies to information that we collect about you when you use:

Our websites, specifically www.cms360.org, www.r3framework.com, www.r3framework.app and www.milliondollarscaleup.com

Our mobile applications (including apps for Android and iOS);

Our coaching, consulting and mentoring services whether delivered in person, online via conference calls or via our website.

Throughout this Privacy Policy we’ll refer to our website, mobile applications and other products and services collectively as “Services.” Below we explain how we collect, use, and share information about you, along with the choices that you have with respect to that information.

We only collect information about you if we have a reason to do so–for example, to provide our Services, to communicate with you, or to make our Services better. We collect information in three ways: if and when you provide information to us, automatically through operating our Services, and from outside sources. Let’s go over the information that we collect.

It’s probably no surprise that we collect information that you provide to us. The amount and type of information depends on the context and how we use the information. Here are some examples:

Basic Information: We also ask for basic information from you in order to communicate with you and, where relevant, for the purposes of setting up an account. For example, we require individuals who sign up for a CMS360.org account to provide a username and email address. We may request additional information–like your name–in order to personalise our communication with you.

Public Profile Information: If you have an account with us, we collect the information that you provide for your public profile. For example, if you have a CMS360.org account, your username is part of that public profile, along with any other information you put into your public profile, such as a photo or an “About Me” description. Your public profile information is just that–public–so please keep that in mind when deciding what information you would like to include.

Transaction and Billing Information: If you buy something from us–a course, membership subscription or coaching service through the site–you will provide additional personal and payment information that is required to process the transaction and your payment, such as your name, credit card information, and contact information. In some cases we will invoice manually for our services and will require your name, company information, and contact details in order to correctly address the invoice and collect payment.

Communications With Us: You may also provide us information when you respond to surveys, communicate with our team about a support question, or post a question in our membership only and public forums.

We also collect some information automatically:

Log Information: Like most online service providers, we collect information that web browsers, mobile devices, and servers typically make available, such as the browser type, IP address, unique device identifiers, language preference, referring site, the date and time of access, operating system, and mobile network information. We collect log information when you use our Services.

Usage Information: We collect information about your usage of our Services. We also collect information about what happens when you use our Services (e.g., page views, support document searches, and information about your device (e.g., screen size, name of cellular network, and mobile device manufacturer). We use this information to, for example, provide our Services to you, as well as get insights on how people use our Services, so we can make our Services better.

Location Information: We may determine the approximate location of your device from your IP address. We collect and use this information to, for example, calculate how many people visit our Services from certain geographic regions. We may also collect information about your precise location via our mobile apps (when, for example, you post a photograph with location information) if you allow us to do so through your mobile device operating system’s permissions.

Information from Cookies & Other Technologies: A cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. Pixel tags (also called web beacons) are small blocks of code placed on websites and emails. We use cookies and other technologies like pixel tags to help us identify and track visitors, usage, and access preferences for our Services, as well as track and understand email campaign effectiveness and to deliver targeted ads. For more information about our use of cookies and other technologies for tracking, including how you can control the use of cookies, please see our Cookie Policy.

We may also get information about you from other sources. For example, if you create or log into your CMS360.org account through another service (like Google) or if you connect your website or account to a social media service (like Twitter), we will receive information from that service (such as your username, basic profile information, and friends list) via the authorization procedures used by that service. The information we receive depends on which services you authorize and any options that are available. We may also get information, such as a mailing address, from third party services about individuals who are not yet our users (…but we hope will be!), which we may use, for example, for marketing and advertising purposes like postcards and other mailers advertising our services.

We use information about you as mentioned above and for the purposes listed below:

To provide our Services–for example, to set up and maintain your account or charge you for any of our paid Services;

To further develop and improve our Services–for example by adding new features that we think our users will enjoy or will help them to develop their business ideas;

To monitor and analyze trends and better understand how users interact with our Services, which helps us improve our Services and make them easier to use;

To measure, gauge, and improve the effectiveness of our advertising, and better understand user retention and attrition–for example, we may analyze how many individuals purchased a plan after receiving a marketing message or the features used by those who continue to use our Services after a certain length of time;

To monitor and prevent any problems with our Services, protect the security of our Services, detect and prevent fraudulent transactions and other illegal activities, fight spam, and protect the rights and property of Creative Media Systems and others, which may result in us declining a transaction or the use of our Services;

To communicate with you, for example through an email, about offers and promotions offered by Creative Media Systems and others we think will be of interest to you, solicit your feedback, or keep you up to date on Creative Media Systems and our products; and

To personalize your experience using our Services, provide content recommendations, target our marketing messages to groups of our users (for example, those who have a particular plan with us or have been our user for a certain length of time), and serve relevant advertisements.

A note here for those in the European Union about our legal grounds for processing information about you under EU data protection laws, which is that our use of your information is based on the grounds that: (1) The use is necessary in order to fulfill our commitments to you under our Terms of Service or other agreements with you or is necessary to administer your account–for example, in order to enable access to our website on your device or charge you for a paid plan; or (2) The use is necessary for compliance with a legal obligation; or (3) The use is necessary in order to protect your vital interests or those of another person; or (4) We have a legitimate interest in using your information–for example, to provide and update our Services, to improve our Services so that we can offer you an even better user experience, to safeguard our Services, to communicate with you, to measure, gauge, and improve the effectiveness of our advertising, and better understand user retention and attrition, to monitor and prevent any problems with our Services, and to personalize your experience; or (5) You have given us your consent–for example before we place certain cookies on your device and access and analyze them later on, as described in our Cookie Policy.

Broadly speaking Legitimate Interests means that we can process your personal information if we have a genuine and legitimate reason and we are not harming any of your rights and interests.

So, what does this mean? When you provide your personal details to us we use your information for our legitimate business interests to carry out our work developing Services for you and other businesses. Before doing this, though, we will also carefully consider and balance any potential impact on you and your rights. Some typical examples of when we might use the approach are for preventing fraud, direct marketing, maintaining the security of our system, data analytics, enhancing, modifying or improving our services, identifying usage trends and determining the effectiveness of our campaigns and fundraising.

Creative Media Systems will use various ways to achieve our mission and to support our objectives: we believe that people who share our values would love to know how to support us. We will process the personal information you have supplied to us to conduct and manage our business to enable us to give you the most appropriate marketing, information, service and products and provide the best and most secure experience. These are what we consider to be our ‘Legitimate Interests’.

Our Interests: The following are some examples of when and why we would use this approach in our work helping businesses:

Direct Marketing: We may send postal and email marketing asks which further the aims and objectives of CMS360. We will also make sure our marketing is relevant for you, tailored to your interests.

Ordering online: In order for us to process an order, payment has to be taken and contact information collected, such as name, delivery address and telephone number, provided. The seller would also need to record the transaction.

Your best interest: Processing your information to protect you against fraud when transacting on our website, and to ensure our websites and systems are secure.

Personalisation: Where the processing enables us to enhance, modify, personalise or otherwise improve our services/communications for the benefit of our supporters.

Analytics: To process your personal information for the purposes of customer analysis, assessment, profiling and direct marketing, on a personalised or aggregated basis, to help us with our activities and to provide you with the most relevant information as long as this does not harm any of your rights and interests.

Research: To determine the effectiveness of promotional campaigns and advertising and to develop our products, services, systems and relationships with you.

Due Diligence: We may need to conduct investigations on service providers, potential customers and business partners to determine if those companies and individuals have been involved or convicted of offences such as fraud, bribery and corruption.

We will also hold information about you so that we can respect your preferences for being contacted by us.

Your interests: When we process your personal information for our legitimate interests, we will consider and balance any potential impact on you and your rights under data protection and any other relevant law. Our legitimate business interests do not automatically override your interests – we will not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

We do not sell our users’ private personal information. We share information about you in the limited circumstances spelled out below and with appropriate safeguards on your privacy:

Employees, and Independent Contractors: We may disclose information about you to our employees, and individuals who are our independent contractors that need to know the information in order to help us provide our Services or to process the information on our behalf. We require our subsidiaries, employees, and independent contractors to follow this Privacy Policy for personal information that we share with them.

Third Party Vendors: We may share information about you with third party vendors who need to know information about you in order to provide their services to us, or to provide their services to you or your site. This group includes vendors that help us provide our Services to you (like payment providers that process your credit and debit card information, fraud prevention services that allow us to analyze fraudulent payment transactions, postal and email delivery services that help us stay in touch with you, customer chat and email support services that help us communicate with you, those that assist us with our marketing efforts (e.g. by providing tools for identifying a specific marketing target group or improving our marketing campaigns), those that help us understand and enhance our Services (like analytics providers), and companies that make products available on our websites, who may need information about you in order to, for example, provide technical or other support services to you. We require vendors to agree to privacy commitments in order to share information with them. Other vendors are listed in our more specific policies (e.g. our Cookie Policy).

Legal Requests: We may disclose information about you in response to a subpoena, court order, or other governmental request.

To Protect Rights, Property, and Others: We may disclose information about you when we believe in good faith that disclosure is reasonably necessary to protect the property or rights of Creative Media Systems, third parties, or the public at large.

Business Transfers: In connection with any merger, sale of company assets, or acquisition of all or a portion of our business by another company, or in the unlikely event that Creative Media Systems goes out of business or enters bankruptcy, user information would likely be one of the assets that is transferred or acquired by a third party. If any of these events were to happen, this Privacy Policy would continue to apply to your information and the party receiving your information may continue to use your information, but only consistent with this Privacy Policy.

With Your Consent: We may share and disclose information with your consent or at your direction. For example, we may share your information with third parties with which you authorize us to do so, such as social media services that you connect to our site through.

Aggregated or De-Identified Information: We may share information that has been aggregated or reasonably de-identified, so that the information could not reasonably be used to identify you. For instance, we may publish aggregate statistics about the use of our Services and we may share a hashed version of your email address to facilitate customized ad campaigns on other platforms.

Published Support Requests: And if you send us a request (for example, via a support email or one of our feedback mechanisms), we reserve the right to publish that request in order to help us clarify or respond to your request or to help us support other users.

We generally discard information about you when we no longer need the information for the purposes for which we collect and use it–which are described in the section above on How and Why We Use Information–and we are not legally required to continue to keep it. See also the Choices section below for further information related to your choices in relation to the information we keep.

While no online service is 100% secure, we work very hard to protect information about you against unauthorized access, use, alteration, or destruction, and take reasonable measures to do so, such as monitoring our Services for potential vulnerabilities and attacks.

You have several choices available when it comes to information about you:

Limit the Information that You Provide: If you have an account with us, you can choose not to provide the optional account information, profile information, and transaction and billing information. Please keep in mind that if you do not provide this information, certain features of our Services–for example, paid, premium content–may not be accessible.

Opt-Out of Electronic Communications: You may opt out of receiving promotional messages from us. Just follow the instructions in those messages. If you opt out of promotional messages, we may still send you other messages, like those about your account and legal notices if you previously registered with us.

Set Your Browser to Reject Cookies: At this time, our websites do not respond to “do not track” signals across all of our Services. However, you can usually choose to set your browser to remove or reject browser cookies before using our website, with the drawback that certain features of our websites may not function properly without the aid of cookies.

Close Your Account: While we’d be very sad to see you go, if you no longer want to use our Services 🙁 🙁 🙁 :(, you can close your account. Please keep in mind that we may continue to retain your information after closing your account, as described in How Long We Keep Information above–for example, when that information is reasonably needed to comply with (or demonstrate our compliance with) legal obligations such as law enforcement requests, or reasonably needed for our legitimate business interests.

If you are located in certain countries, including those that fall under the scope of the European General Data Protection Regulation (AKA the “GDPR”), data protection laws give you rights with respect to your personal data, subject to any exemptions provided by the law, including the rights to:

Request access to your personal data;

Request correction or deletion of your personal data;

Object to our use and processing of your personal data;

Request that we limit our use and processing of your personal data; and

Request portability of your personal data.

You can usually access, correct, or delete your personal data using your account settings and tools that we offer, but if you aren’t able to do that, or you would like to contact us about one of the other rights, scroll down to How to Reach Us to, well, find out how to reach us. EU individuals also have the right to make a complaint to a government supervisory authority.

Creative Media Systems and CMS360.org Services are worldwide. Creative Media Systems is the controller of your personal data which is the company that entered into the contract with you under the Terms of Service for the product or service you use. In addition, Creative Media Systems is the controller for the processing activities across all of our Services worldwide.

If you have a question about this Privacy Policy, or you would like to contact us about any of the rights mentioned in the Your Rights section above, please contact us.

You may request details of personal information which we hold about you. A small fee will be payable. If you would like a copy of the information held on you please write to Suite 112, Heddington Grove, Islington, London, N7 9SZ, UK.

If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible, at the above address. We will promptly correct any information found to be incorrect.

Other Things You Should Know (Keep Reading!)

Because Creative Media Systems’ Services are offered worldwide, the information about you that we process when you use the Services in the EU may be used, stored, and/or accessed by individuals operating outside the European Economic Area (EEA) who work for us or third party data processors. This is required for the purposes listed in the How and Why We Use Information section above. When providing information about you to entities outside the EEA, we will take appropriate measures to ensure that the recipient protects your personal information adequately in accordance with this Privacy Policy as required by applicable law. These measures include:

In the case of US based entities, entering into European Commission approved standard contractual arrangements with them, or ensuring they have signed up to the EU-US Privacy Shield; or

In the case of entities based in other countries outside the EEA, entering into European Commission approved standard contractual arrangements with them.

You can ask us for more information about the steps we take to protect your personal information when transferring it from the EU.

Ads appearing on any of our Services may be delivered by advertising networks. Other parties may also provide analytics services via our Services. These ad networks and analytics providers may set tracking technologies (like cookies) to collect information about your use of our Services and across other websites and online services. These technologies allow these third parties to recognize your device to compile information about you or others who use your device. This information allows us and other companies to, among other things, analyze and track usage, determine the popularity of certain content, and deliver advertisements that may be more targeted to your interests. 

Please note this Privacy Policy only covers the collection of information by Creative Media Systems and does not cover the collection of information by any third party advertisers or analytics providers.

Although most changes are likely to be minor, Creative Media Systems may change its Privacy Policy from time to time. We encourage visitors to check this page frequently for any changes to our Privacy Policy. If we make changes, we will notify you by revising the change log below, and, in some cases, we may provide additional notice (such as adding a statement to our homepage) or sending you a notification through email or your dashboard. Your further use of the Services after a change to our Privacy Policy will be subject to the updated policy. That’s it! Thanks for reading.

This policy has been adapted from a Privacy Policy available under a Creative Commons Sharealike license. The original was developed by Automattic, the creator of the WordPress technology which is used to drive some of our web sites.