Effective: 11/11, 2020

This Privacy Policy explains how Creative Union As Corporation (“CU,” “we,” or “us”) collects, uses, and discloses information about you. This Privacy Policy applies when you use our website Globalvirtualsolutions, mobile applications, and other online products and services that link to this Privacy Policy (collectively, our “Services”), contact our customer service team, engage with us on social media, or otherwise interact with us.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy and, in some cases, we may provide you with additional notice (such as adding a statement to our website or providing you with a notification). We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.

CONTENTS

  • Collection of Information
  • Use of Information
  • Sharing of Information
  • Third-Party Embeds
  • Transfer of Information to the United States and Other Countries
  • Your Choices
  • Your Privacy Rights
  • Additional Disclosures for Individuals in Europe
  • Contact Us

COLLECTION OF INFORMATION

Information You Provide to Us

We collect information you provide directly to us. For example, you share information directly with us when we’ll enable to upload your content, fill out a form, submit or post content through our Services, purchase a membership, communicate with us via third-party platforms, request customer support, or otherwise communicate with us. The types of personal information we may collect include your name, display name, username, bio, email address, business information, your content, including your avatar image, photos, posts, responses, and series published by you, and any other information you choose to provide.

In some cases, we may also collect information you provide about others. We will use this information to fulfill your request and will not send communications to your contacts unrelated to your request, unless they separately consent to receive communications from us or otherwise engage with us.

We do not collect payment information through our Services. We rely on third parties to process payments in connection with our Services. Any information you provide to facilitate such a payment is subject to the third-party payment processor’s privacy policy, and we encourage you to review this policy before you provide any information to the payment processor.

Information We Collect Automatically When You Interact with Us

In some instances, we automatically collect certain information, including:

  • Activity Information: We collect information about your activity on our Services, such as your reading history and when you share links, follow users, highlight posts, and clap for posts.
  • Device and Usage Information: We collect information about how you access our Services, including data about the device and network you use, such as your hardware model, operating system version, mobile network, IP address, unique device identifiers, browser type, and app version. We also collect information about your activity on our Services, such as access times, pages viewed, links clicked, and the page you visited before navigating to our Services.
  • Information Collected by Cookies and Similar Tracking Technologies: We use tracking technologies, such as cookies and web beacons, to collect information about you. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular, and count visits. Web beacons (also known as “pixel tags” or “clear GIFs”) are electronic images that we use on our Services and in our emails to help deliver cookies, count visits, and understand usage. We also work with third party analytics providers who use cookies, web beacons, device identifiers, and other technologies to collect information about your use of our Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in mobile apps, and links clicked. This information may be used by Creative Union and others to, among other things, analyze and track data, determine the popularity of certain content, deliver content targeted to your interests on our Services, and better understand your online activity. For more information about cookies and how to disable them, see Your Choices below.

Information We Collect from Other Sources

We obtain information from third-party sources. For example, we may collect information about you from social networks, accounting services providers and data analytics providers. Additionally, if you create or log into your Globalvirtualsolutions account through a third-party platform (such as Apple, Facebook, Google, or Twitter), we will have access to certain information from that platform, such as your name, lists of friends or followers, birthday, and profile picture, in accordance with the authorization procedures determined by such platform.

Information We Derive

We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your location based on your IP address or infer reading preferences based on your reading history.

USE OF INFORMATION

We use the information we collect to provide, maintain, and improve our Services, which includes publishing and distributing user-generated content, personalizing the posts you see and operating our metered paywall. We also use the information we collect to:

  • Create and maintain your Globalvirtualsolutions account, which Is shared by us willingly and Is revocable any time by GVS or Creative Union without notice;
  • Process transactions and send related information, such as confirmations, receipts, and user experience surveys;
  • Send you technical notices, security alerts, and support and administrative messages;
  • Respond to your comments and questions and provide customer service;
  • Communicate with you about new content, products, services, and features offered by Globalvirtualsolutions and provide other news and information we think will interest you (see Your Choices below for information about how to opt out of these communications at any time);
  • Monitor and analyze trends, usage, and activities in connection with our Services;
  • Detect, investigate, and prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of CU and others;
  • Debug to identify and repair errors in our Services;
  • Comply with our legal and financial obligations; and
  • Carry out any other purpose described to you at the time the information was collected.

SHARING OF INFORMATION

We share personal information in the following circumstances or as otherwise described in this policy:

  • We share personal information with other users of the Services. For example, if you use our Services to publish content, post comments or send private notes, certain information about you will be visible to others, such as your name, photo, bio, other account information you may provide, and information about your activities on our Services (e.g., your followers and who you follow, recent posts, claps, highlights, and responses).
  • We share personal information with vendors, service providers, and consultants that need access to personal information in order to perform services for us, such as companies that assist us with web hosting, storage, and other infrastructure, analytics, payment processing, fraud prevention and security, customer service, communications, and marketing.
  • We may disclose personal information if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements. If we are going to disclose your personal information in response to legal process, we will give you notice so you can challenge it (for example by seeking court intervention), unless we are prohibited by law or believe doing so may endanger others or cause illegal conduct. We will object to legal requests for information about users of our Services that we believe are improper.
  • We may share personal information if we believe that your actions are inconsistent with our user agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of Creative Union AS, our users, the public, or others.
  • We share personal information with our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.
  • We may share personal information in connection with, or during negotiations concerning, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
  • Personal information is shared between and among Creative Union AS and our current and future parents, affiliates, and subsidiaries and other companies under common control and ownership.
  • We share personal information with your consent or at your direction.
  • We also share aggregated or de-identified information that cannot reasonably be used to identify you.

THIRD-PARTY EMBEDS

Globalvirtualsolutions does not host some of the content displayed on our Services. Users have the ability to post content that is actually hosted by a third party, but is embedded in our pages (an “Embed”). When you interact with an Embed, it can send information about your interaction to the hosting third party just as if you were visiting the third party’s site directly. For example, when you load a post page with a YouTube video Embed and watch the video, YouTube receives information about your activity, such as your IP address and how much of the video you watch. Globalvirtualsolutions does not control what information third parties collect through Embeds or what they do with the information. This Privacy Policy does not apply to information collected through Embeds. The privacy policy belonging to the third party hosting the Embed applies to any information the Embed collects, and we recommend you review that policy before interacting with the Embed.

TRANSFER OF INFORMATION TO OTHER COUNTRIES

Globalvirtualsolutions is headquartered in Estonia, European Union and we have operations and service providers in other countries. Therefore, we and our service providers may transfer your personal information to, or store or access it in, jurisdictions that may not provide levels of data protection that are equivalent to those of your home jurisdiction. We will take steps to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it.

YOUR CHOICES

Cookies

Most web browsers are set to accept cookies by default. If you prefer, you can usually adjust your browser settings to remove or reject browser cookies. Please note that removing or rejecting cookies could affect the availability and functionality of our Services. If you do not agree with our cookie settings you may choose to stop browsing our website anytime.

Communications Preferences

You may opt out of receiving certain communications from us, such as digests, newsletters, and activity notifications, by following the instructions in those communications or through your account’s Settings page. If you opt out, we may still send you administrative emails, such as those about your account or our ongoing business relations.

Mobile Push Notifications

With your consent, we may send push notifications to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.

Data Retention

We store personal data associated with your account for as long as your account remains active. If you close your account, we will delete your account data within 14 days. We store other personal data for as long as necessary to carry out the purposes for which we originally collected it and for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations.

Threats of violence and incitement

We do not allow content or actions that threaten, encourage, or incite violence against anyone, directly or indirectly.

Hate speech

We do not allow content that promotes violence or hatred against people based on characteristics like race, ethnicity, national origin, religion, disability, disease, age, sexual orientation, gender, or gender identity.

We do not allow posts or accounts that glorify, celebrate, downplay, or trivialize violence, suffering, abuse, or deaths of individuals or groups. This includes the use of scientific or pseudoscientific claims to pathologize, dehumanize, or disempower others. We do not allow calls for intolerance, exclusion, or segregation based on protected characteristics, nor do we allow the glorification of groups which do any of the above.

We do not allow hateful text, images, symbols, or other content in your username, profile, or bio.

 

Harassment

Globalvirtualsolutions exists to share and discuss ideas. We don’t tolerate harassment, which includes:

  • Bullying, threatening, or shaming someone, or posting things likely to encourage others to do so
  • Using digital communication features like responses, private notes, mentions, follows, story requests, or writer requests in a way intended to annoy or harass someone
  • Reviewing businesses or products in a gratuitously harmful or abusive manner

 

Privacy and Reputation

We do not allow the following:

  • Posting copies of private communications between private individuals without the explicit consent of all parties to the communication
  • Doxing, which includes not only private or obscure personal information but also the aggregation of publicly available information to target, shame, blackmail, harass, intimidate, threaten, or endanger
  • Posting intimate or explicit images taken or posted without the subject’s express consent
  • Content that violates others’ privacy, including sensitive or confidential information such as credit card numbers, social security numbers, non-public phone numbers, physical addresses, email addresses, or other non-public information

Restricted categories

We do not allow posts or accounts that engage in the following restricted categories of activity:

  • Promotion of harmful conspiracies
  • Facilitation of gambling or betting
  • Facilitation of buying or selling social media interactions, including off-platform
  • Facilitation of illegal sexual services
  • Facilitation of copyright violation

 

Related conduct

We do not allow posts or accounts that engage in on-platform, off-platform, or cross-platform campaigns of targeting, harassment, hate speech, violence, or disinformation. We may consider off-platform actions in assessing a Globalvirtualsolutions account, and restrict access or availability to that account.

 

Duplicate Content

We do not allow posting duplicate content, whether from a single account or across multiple accounts, either publicly or as an unlisted story.

 

Spam

We do not allow spam on Globalvirtualsolutions. All spam will be immediately removed from Globalvirtualsolutions, without notification. While it is hard to define this content with precision or completeness, here are some representative behaviors we look for that are characteristic of spam:

  • Posting content primarily to drive traffic to, or increase the search rankings of, an external site, product, or service
  • Scraping and reposting content from other sources for the primary purpose of generating revenue or other personal gains
  • Posting duplicate content, whether from a single account or across multiple accounts
  • Stories where the content is clipped with the sole purpose of linking to the rest of the article on a different website
  • Performing a disproportionately large number of interactions, particularly by automated means. This includes bulk, indiscriminate interactions, such as following of other accounts (follow spam) clapping, highlighting, or leaving notes
  • Repeatedly using responses or other interactions as a method of promotion
  • Participating in bounty campaigns or brigades to artificially inflate rankings for posts, accounts, businesses, or products
  • Use or re-use content templates with slight modifications across multiple posts and accounts

For each of these behaviors, when we talk about “content,” we mean not only posts but also any other feature that allows you to add your own text or media. When we talk about “interactions,” we mean any feature that allows one user to interact with another, or with a post.

 

Paid, automatic, bulk, or non-genuine interactions

Globalvirtualsolutions depends on various user behaviors — like follows and likes — to determine what content to feature and make the site work well for everyone. So, we don’t allow artificial behaviors that skew this system and as a result degrade or distort other users’ experiences. This includes:

  • Buying, selling, or trading in accounts or account interactions — including follows, likes, highlights, responses or other traffic
  • Using services, apps, or arrangements that offer you more follows, likes, or other interactions on your Globalvirtualsolutions account or content
  • Registering accounts, posting content, or interacting with users or content automatically, systematically, or programmatically

 

Copyright and trademark infringement

Respect the copyrights and trademarks of others. Unless you’re authorized to use someone else’s copyrighted work or trademark (either expressly or by legal exceptions and limitations like fair use), don’t do it. We respond to notices of alleged infringement as described in our Terms of Service.

 

Deceptive conduct

We do not allow deceptive conduct on Globalvirtualsolutions. This includes:

  • Posting content or impersonating a person or organization in a way likely to deceive people. Parody and satire are fine, but make clear that is what you’re doing. Our Username Policy has specific requirements for parody accounts
  • Using Globalvirtualsolutions for phishing or fraud. Don’t use tags, links, titles, or other metadata in a misleading way. Don’t link to or embed malicious or harmful code or software in your posts
  • Don’t use deception to generate revenue or traffic
  • If you have received compensation, free goods/services or anything of value in connection with the topic of a post, you must make this clear

Ads, Promotions, and Marketing

  • Third-party advertising and sponsorships are not allowed. You may not advertise or promote third-party products, services, or brands through Globalvirtualsolutions posts, publications, or letters. This includes images that indicate brand sponsorship in a post or letter, or as part of a publication name or logo.
  • Images functioning as third-party ads are not allowed. Inline images or embeds that link out and function as banner ads for third-party brands are not allowed.
  • You must disclose affiliate links or payment for a post. Affiliate links, such as link out to Amazon with your code, or any other link out where you will receive a commission or other value, are allowed in posts. But, you must disclose somewhere in the post that it includes affiliate links. If you have received payment, goods or services, or something else of value in exchange for writing a post, you must still disclose this fact in writing within your post (as per FTC Rules and Guides).
  • Multi-level marketing content is not allowed.

 

Embedded Content

In ongoing compliance with the European GDPR, we are restricting the behavior of certain embedded content:

  • Embeds that directly collect data through form fields are not allowed. This includes embeds that facilitate the submission of email addresses and other personally identifying information through forms and the submission of credit card information. If you want to collect information from your readers, you will need to link out from your post on Globalvirtualsolutions to a form hosted elsewhere that makes it clear to a user that they are no longer in the Globalvirtualsolutions network

Cryptocurrency Accounts, Posts, and Publications

Posts and accounts that focus on cryptocurrencies which do not meet the following requirements may be considered spam and are subject to suspension, depending on context. Globalvirtualsolutions does not endorse or verify any coin, token, or similar announcement.

To prevent fraud and abuse, you must:

  • Include a link to your active project domain in your user account bio.
  • Use an email address from that domain as your verified Globalvirtualsolutions account email, and maintain that email account actively. Note that our emails that are registered to GVS can be closed at any time without notice or reason.
  • Link at least one consistently-branded social media account (Facebook or Twitter) to your Globalvirtualsolutions account. That social account should also link out prominently to the same domain as is included in your GVS user bio.
  • Include a prominent about page with up-to-date contact information on your project website.

You may not:

  • Use an anonymous email address which is not linked to your project domain. (e.g., gmail, protonmail, mail.ru, etc.)
  • Advertise or participate in bounty campaigns, pump and dumps, reviewing for reward, or other forms of brigading or inauthentic activity.
  • Include shortened URLs in your posts.

Graphic content

We do not allow pornographic images or videos. We do allow erotic writing and non-graphic erotic images.

We do not allow gratuitously graphic or disturbing media, even if it’s not pornographic.

Exploitation of minors

We do not allow content promoting the sexual or violent exploitation of minors, including the sexualization of fictional minors.

Promotion and glorification of self-harm

We do not allow activities that encourage, promote or glorify acts of self-harm, such as cutting, eating disorders like anorexia or bulimia, and suicide. If you encounter users contemplating or threatening self-harm, please report it to us via the form or email address linked below.

How to report a violation

If you find a post or account on GVS that violates these rules, please flag it. You can use this form to provide more detail or to report other conduct you believe violates our rules. Additionally, you can send us an email to legal@Globalvirtualsolutions.eu.

If you break the rules

We strive to be fair, but we reserve the right to suspend accounts or remove content, without notice, for any reason, particularly to protect our services, infrastructure, users, or community. If you attempt to evade suspension by creating new accounts or posts, we will suspend your new accounts and posts.

Notice

Upon investigating or disabling content associated with your account, we will notify you, unless we believe your account is automated or operating in bad faith, or that notifying you is likely to cause, maintain or exacerbate harm to someone.

Appeals

If you believe your content or account has been restricted or disabled in error, or believe there is relevant context we were not aware of in reaching our determination, you can write to us at legal@Globalvirtualsolutions.eu. We will consider all good faith efforts to appeal.

 

Government Takedown Requests

If Global Virtual Solutions receives a request from a government actor to restrict access to content associated with your account, we will notify you unless we are prohibited by law or believe doing so may endanger others. Where applicable, we will work to limit legally-ordered content restrictions to jurisdictions where we have a good faith belief that we are legally required to restrict the content.

 

We may enforce, or not enforce, these policies at our sole discretion. These policies don’t create a duty or contractual obligation for us to act.

We also may change these rules at any time.

Global Virtual Solutions is committed to providing a transparent, open platform for expression and therefore supports the goals and spirit of The Santa Clara Principles on Transparency and Accountability in Content Moderation as a starting point for further discussion.

Member Content Guidelines

To be eligible for inclusion and potential monetization from member-only content, user posts must meet all Global Virtual Solutions rules as well as the following content requirements. We’ve set these additional guidelines for member-only stories to create a fair environment for writers in our Partner Program and a richer reading experience for members.

  • You may not sell advertising in or on your member-only content.
  • Member stories should not exist with the predominant purpose of driving traffic to an external website, business, or product. All included content must be relevant, substantial and informative.
  • If you have received compensation, free goods/services, or anything of value in connection with the topic of a post, you must make this clear.
  • Do not ask for likes or include other calls to action, including gifs of liking, requests for donations, or other links or embeds for the purpose of capturing user information or soliciting money.
  • Do not use content or images licensed as non-commercial in your Partner Program posts.

If you violate these Member content rules

GVS reserves the right to review posts or accounts at any time and stop payment for any post or to any account, and/or remove from the Member section content that violates these Member Content Guidelines, or GVS’s general rules. In deciding whether something has violated the Rules and Guidelines, we will take into account things like the context, newsworthiness, and nature of the posted information and applicable privacy laws. Repeated violations of the Rules and Requirements will result in permanent ineligibility to participate in the program.

How to report a Member post violation

If you find a member post or account on GVS that violates these rules, please flag it. You can use this form to provide more detail or to report other conduct you believe violates our rules. Additionally, you can send us an email to legal@Globalvirtualsolutions.eu.

If you have questions or feedback about these rules, let us know. You can contact us at legal@globalvirtualsolutions.eu.