PRIVACY POLICY AUGUST 2026
This Privacy Policy ("Policy") explains how we (as defined below) collect, share and use any information that alone or in combination with other information, relates to you ("Personal Data") when you ("you" and "your") use our website www.creamarchive.com (the "Website").
This Policy also sets out the rights that you have concerning the Personal Data that we process about you and how you can exercise them.
For the purposes of this Policy, CREAM ARCHIVE ("CREAM" "us," "we," or "our") headquartered in Boston, MA USA acts as the data controller for the Personal Data that is collected via the Website. As a data controller, CREAM is responsible for ensuring that the processing of Personal Data complies with applicable data protection laws, which includes the General Data Protection Regulation.
Please note that the information you provide on our Website may be necessary for contractual purposes and for us to comply with our legal obligations. Without such information, we may not be able to process your order or answer your queries.
We may also collect certain information automatically from your device, such as your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location) and other technical information. We may also collect information about how your device has interacted with our Website, including the pages accessed and links clicked in order to better understand the visitors who come to our Website, where they come from, and what content on our Website is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our Website to our visitors. Some of this information may be collected using cookies and similar tracking technology.
Who does CREAM ARCHIVE share your Personal Data with?
We may disclose your Personal Data to the following:
- group companies for purposes consistent with this Policy, and in particular, so that they may contact you regarding products and services that may interest you where you have given your consent.
- third-party vendors, services providers and partners who provide data processing services to us or who otherwise process Personal Data for purposes that are described in this Policy or notified to you when we collect your Personal Data.
- any competent law enforcement body, regulatory, government agency, court or other third parties where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
- auditors, advisors, legal representatives and similar agents in connection with the advisory services they provide to us for legitimate business purposes and under contractual prohibition of using the Personal Data for any other purpose;
- and/or any other person if you have provided your prior consent to the disclosure.
How we protect your privacy:
We will process Personal Data under the following principles:
Fairness: We will process Personal Data fairly. This means that we are transparent about how we process Personal Data and that we will process it per applicable law.
Lawfulness: We will process Personal Data only on lawful grounds.
Purpose limitation: We will process Personal Data for specified explicit and legitimate purposes and will not process it in a manner that is incompatible with those purposes unless permitted by applicable data protection laws.
Data minimization: We will process Personal Data that is adequate, relevant and limited to what is necessary to achieve the purposes for which the data are processed.
Data accuracy: We take appropriate measures to ensure that the Personal Data that we hold about you is accurate, complete and, where necessary, kept up to date. However, it is also your responsibility to ensure that your Personal Data is kept as accurate, complete and current as possible by informing us promptly of any changes or errors. You should notify us of any changes to the Personal Data that we hold about you (e.g. a change of address).
Data security: We use appropriate technical and organizational measures to protect the personal data we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your Personal Data. In particular, all data is protected according to the varying levels of risks through physical measures, such as secure areas, technical measures, and encryption, and organizational measures such as employee security through vetting and supervision.
Limited Retention: We keep your Personal Data in a form that allows us to identify you for as long as necessary to achieve the purposes for which we are processing your data and do not store your data for longer unless we must comply with applicable laws.
Your data protection rights
a) If you wish to access, correct, update or request deletion of your Personal Data, you can do so at any time by contacting us using the contact details provided below. Please note that deletion requests are subject to certain limitations, for example, we may retain Personal Data as permitted by law, such as for tax or other record-keeping purposes, to maintain an active account, and to process transactions and facilitate customer requests.
b) In addition, in certain circumstances, as stipulated in the applicable data protection legislation, you can object to the processing of your Personal Data, ask us to restrict the processing of your Personal Data or request portability of your Personal Data. You can exercise these rights by contacting us using the contact details below.
c) If we have collected and processed your Personal Data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted before your withdrawal, nor will it affect the processing of your Personal Data conducted in reliance on lawful processing grounds other than consent.
d) You have the right to opt-out of marketing communications we send you at any time. You may unsubscribe from our newsletters or marketing notifications at any time by selecting the unsubscribe link at the bottom of every newsletter email. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided below.
e) If you have a complaint or concern about how we are processing your Personal Data then we will address such concern(s). If you feel we have not sufficiently addressed your complaint or concern, you have the right to complain to a data protection authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
Linking to other websites:
We do not accept any responsibility or liability for the privacy practices of such third party websites and your use of such websites is at your own risk.
Updates to this Policy:
We may update this Policy from time to time in response to changing legal, technical or business developments. When we update our Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Policy changes if and where this is required by applicable data protection laws.
You can see when this Policy was last updated by checking the “last updated” date displayed at the top of this Policy.
How to contact us about your Personal Data:
If you wish to access, correct, update or request deletion of your Personal Data, you can do so at any time by using our email hello@creamarchive.com.