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Privacy Policy

Effective date: February 20, 2026 · Last updated: March 18, 2026

Introduction

This Privacy Policy applies to all personal information that DOO Element X Tivat (hereinafter the "Company", "we", "us", or "our") collects in connection with the operation of our online platform called CreometriX. You can read more about CreometriX at https://creometrix.cc.

We provide CreometriX across a number of different countries therefore we may be subject to different privacy and data protection laws depending on the locations of the individuals identified below under 'Who we collect personal information from' (you, your).

We are committed to complying with our obligations under all applicable privacy and data protection laws that apply to the collection, disclosure and processing of your personal information.

The data controller for the service is DOO Element X Tivat. Card data is processed by Stripe, Inc. and its EU entity as an independent controller; we never receive or store full card numbers.

R.camp SIA acts as the Provider’s payment agent and processes billing data — name, email, billing address, VAT number and transaction details — for invoicing, payment execution, accounting and statutory record-keeping. This data is retained for the period required by applicable accounting and tax law.

Who we collect personal information from

We collect personal information from individuals who are users of CreometriX (users). CreometriX is not aimed at persons under the age of 18 and we do not knowingly collect data from or about such individuals.

The personal information we collect and how we use it

Categories of Personal Information

We will only use personal information in a manner that is lawful for us to do so. In most cases, we only use personal information for the purpose for which it was collected, or where we reasonably consider that we need to use the personal information for another reason and that reason is compatible with or related to the original purpose.

If we need to use your personal information for an unrelated purpose, where required by applicable law, we will notify you and explain the legal basis which allows us to do so.

Data Subject: Users

Type of Data:

  1. Identity
  2. Identification
  3. Contact
  4. Payment
  5. Transaction
  6. Technical
  7. Profile
  8. Usage
  9. Marketing and communications

Lawful basis for processing including basis of legitimate interest:

  1. Performance of a contract with you
  2. Necessary for our legitimate interests
  3. With your consent

Purpose/Activities:

  1. To verify your eligibility to use our products/services.
  2. To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.
  3. To use data analytics to improve our products/services and user experiences.
  4. To make suggestions and recommendations to you about our products/services that may be of interest to you.
  5. To respond to your queries, complaints, and/or feedback.
  6. To provide you with technical support.
  7. Payment handling.

Marketing

You may receive marketing communications from us if you have requested information from us or purchased products and/or services from us and you have not opted out of receiving that marketing communication from us.

We may use your identity, contact, technical, usage and profile data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

Aggregated Data

We also collect, use and share Aggregated Data such as statistical or demographic data for our business purposes. Aggregated Data could be derived from personal information but is not considered personal information because it is not capable, directly or indirectly, of revealing a person's identity. However, if we combine or connect Aggregated Data with other information so that it can directly or indirectly identify a person, we treat the combined data as personal information, and will only use it in accordance with this Privacy Policy.

We do not collect any 'special categories of personal information' or 'sensitive personal information' about you. This includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data. Please do not enter any such information into CreometriX.

Consents

Users of CreometriX are required to comply with all applicable privacy laws.

We rely on our users to obtain all relevant privacy consents and authorisations from any person required by law, in order for the personal information that is entered by our users into CreometriX to be collected, disclosed and otherwise processed by us in accordance with this Privacy Policy.

When you provide us with the personal information of any other person, you must ensure that:

  • you are authorised by that person to provide their personal information to us;
  • you have referred them to this Privacy Policy and obtained their express consent to us collecting, using and disclosing their personal information in accordance with this Privacy Policy, where required by applicable law; and
  • you have complied with the applicable privacy legislation in collecting and disclosing to us the personal information.

If you do not provide your personal information

It is not feasible to access CreometriX on an anonymous basis.

Where we need to collect personal information by law, under the terms of a contract we have with a customer, or in order to identify you as a user of CreometriX, and you do not provide that personal information when requested, we may not be able to perform the contract we have in place with the customer. In this case, you will not be able to continue to use CreometriX.

However, in certain cases, you may object to providing us with certain information. For example, if you are providing us with general feedback about CreometriX or making a sales enquiry about CreometriX, you may choose to use a pseudonym.

How we collect your personal information

Our policy is to not collect personal information by means that are unfair or unreasonably intrusive in the circumstances. It is also our policy to collect personal information directly from the data subject about whom the personal information relates, where it is practicable for us to do so.

Direct Interactions

You may provide us with your personal information by completing forms or by corresponding with us by post, phone, email or otherwise. This includes personal information you provide when you:

  • enquire about using our products or services;
  • enter into a business relationship with us;
  • create or login to your CreometriX account;
  • request marketing materials be sent to you;
  • enter a competition, promotion or survey; or
  • give us feedback or contact us.

Automated technologies or interactions

As you interact with our websites and platform, we will automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal information by using cookies, server logs and other similar technologies.

Third parties or publicly available sources

We may receive personal information about you from various third parties, including:

  • analytics providers such as Google Analytics;
  • payment service providers such as Stripe, Inc.;
  • advertising networks such as Google Ads and Facebook Ads; and
  • search information providers such as Google.

Cookies

We may obtain information about your general internet usage by using cookies. A cookie is a small file which is stored on the hard drive of your computer. They help us to improve our websites and platform and to deliver a better and more personalised service.

You may block cookies by activating settings on your browser which allow you to refuse the setting of some or all cookies. If you do choose to block all cookies or essential cookies, you may not be able to access all or some parts of our websites or platform.

We use the following cookies:

  • Strictly necessary cookies: required for the operation of our websites and platform.
  • Analytical/performance cookies: allow us to recognise and count the number of visitors and to see how visitors move around our websites.
  • Functionality cookies: used to recognise you when you return to our websites and enable us to personalise our content for you.
  • Targeting cookies: record your visits to our websites and platform, the webpages visited and links followed.

Disclosures of your personal information

We may share your personal information with the parties set out below. We will require all such third parties to respect the security of your personal information and to treat it in accordance with applicable law.

Marketing provider

In order to analyse, advertise and promote our platform we use our marketing provider R.camp SIA.

Service providers

  • Google Analytics — place of processing: United States. Privacy policy. Opt-out.
  • Stripe, Inc. — place of processing: United States. Privacy policy.
  • Firebase Authentication by Google LLC — place of processing: United States. Privacy policy.

Professional advisers

We may supply personal information to our lawyers, bankers, auditors and insurers who provide consulting, banking, legal, insurance and accounting services.

Regulators and other authorities

We may supply personal information to regulators and other authorities where applicable law requires us to provide the information to them.

Third party buyers

We may supply personal information to actual or potential third parties that we may elect to sell, transfer or merge parts of our business or assets to or with.

Other disclosures

We may also provide your personal information to our lawyers, insurers and professional advisors and any court or administrative body, for one or more of the following purposes:

  • Obtaining professional advice;
  • To obtain or maintain insurance;
  • Prevention, detection, investigation, prosecution or punishment of criminal offences;
  • To protect or enforce our rights or defend claims;
  • Enforcement of our claims against you or third parties;
  • The enforcement of laws relating to the confiscation of the proceeds of crime;
  • The protection of the public revenue;
  • Where disclosure is required to protect the safety or vital interests of employees, users or property.

Data security

We have put in place industry standard security measures to prevent personal information from being lost, used, misused, accessed in an unauthorised way, altered or disclosed.

Although we take all reasonable steps to ensure that personal information is stored in a secure operating environment, we cannot guarantee the absolute security of personal information during its transmission or its storage on our systems.

We have procedures to deal with any suspected or actual personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data storage and retention

Storage locations

We use our internal backend system to host personal information in Georgia.

Retention

We will only retain your personal information for as long as reasonably necessary while we have a business relationship with you (or your company), and thereafter where we have an ongoing business need to retain it, as required under law or to fulfil the purposes we collected it for.

In some circumstances, you can ask us to delete your data: see 'Your legal rights' below for further information.

We may, where permitted by applicable law, de-identify your personal information for research or statistical purposes.

Access to and correction of your personal information

You can request a copy of your personal information by contacting us using the contact details set out below.

Correcting your personal information

We rely on the individuals who provide us with personal information to provide us with accurate, up to date and reliable data, and to update us when personal information that we hold about them is not accurate, up to date or reliable.

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

Third party websites, plug-ins and applications

Our websites or platform may include links to third-party websites, plug-ins and applications. Clicking on those links may allow third parties to collect or share data about you. We do not control these third-party websites, plug-ins or applications and are not responsible for their privacy practices.

Complaints

You have the right to make a complaint about our handling of your personal information by contacting the relevant privacy or information related agency in your jurisdiction:

  • Australia: Australian Information Commissioner — 1300 363 992 — oaic.gov.au
  • United Kingdom: Information Commissioner — 0303 123 1113 — ico.org.uk
  • California, USA: California Privacy Protection Agency — cppa.ca.gov
  • New Zealand: Privacy Commissioner — 0800 803 909 — enquiries@privacy.org.nz
  • EU: Refer complaint to the relevant national Data Protection Authority — edpb.europa.eu

Before you make a complaint to the relevant agency, we would appreciate the opportunity to address your concerns, so please contact us in the first instance. We will endeavour to respond to your complaint as soon as possible and in any event within 30 calendar days.

User Data Deletion Instructions

Users may request deletion of their personal data by contacting ceo@creometrix.cc and using the subject line "Data Deletion Request."

To help us process the request, please provide:

  • your name;
  • your account email;
  • the Facebook or Instagram account used to connect to CreometriX, if applicable.

After verifying the request, we will delete or anonymize the relevant personal data associated with your account, except where we are required or permitted to retain certain information for legal, security, fraud prevention, or compliance purposes.

We aim to respond to verified deletion requests within 30 days.

If you have any questions, contact ceo@creometrix.cc.

Contact

Please feel welcome to contact us if you have any questions about this Privacy Policy:

R.camp SIA
Estonia
Email: support@creometrix.cc
https://creometrix.cc

We may update or replace this Privacy Policy from time to time. We encourage you to periodically review this page for the latest information on our privacy practices.