Privacy Notice and FAQs

Creative Management Services LLC, d/b/a MC² is committed to protecting your privacy and developing technology that gives you the most powerful and safe online experience. This Privacy Notice (“Privacy Notice”) applies when you interact with us on the MC² website (“Site(s)”) or through your use of our product and service offerings (“Services”). This Privacy Notice governs the collection, use, safeguarding, and disclosure of personal information as defined below. This Privacy Notice also covers personal information we collect about individuals in connection with recruitment and pre-employment activities.

For the purposes of this Privacy Notice, MC² is the controller (i.e., responsible party) for the personal information addressed in this Privacy Notice. When we administer services on behalf of our clients and other third parties, MC² may act as a processor or service provider to such organizations, and you should review the Privacy Notice of such third parties with whom you are dealing directly, as they will be responsible for the handling of your personal information.

By using the MC² Sites or Services, you acknowledge and agree that you have read and understand the data practices described in this Privacy Notice.

Collection of Your Personal Information

The types of personal information MC² collects or receives about you depends on how you interact with us.  “Personal information” (e.g. personal data or other similar terms as defined by applicable law) refers to information that identifies, relates to, describes, or can be associated with an individual or household.

Depending on the Services you use, the following are the categories and specific types of personal information that we may collect, or have collected, in the preceding twelve (12) months:

• Contact Information/Identifiers, including name, email address, postal address, phone number, username, business contact information, or other similar identifiers.
• Information Specific to the Services, including, in certain instances, order history, invoices, and preferences.
• Demographic Information, including age and gender, some of which may include characteristics of protected classifications under state or federal law.
• Device Information and Other Unique Identifiers, device identifier, internet protocol (IP) address, or similar unique identifiers.
• Internet or Other Network Activity, including browsing or search history, and information regarding your interactions with our Sites, emails, or advertisements.
• Payment Information, including credit or debit card number, or other financial information (via third party payment processors).
• Job Applicant Data: Name, gender, age, date of birth, email address, mailing address, telephone number, social media profiles, and in certain instances, identification documents, residency and work permit status, social security number (which may also be considered sensitive personal information) or other taxpayer/government identification number. This data also includes any professional qualifications, prior employment history, education history, additional information included in curriculum vitae, and references, as well as notes collected by interviewers and other professional assessment information. If we offer you a job, we may collect additional background information, such as credit history and eligibility information (as permitted by law).
• Job Applicant Sensitive Personal Information (where permitted and in accordance with applicable law): social security number, driver’s license number, racial or ethnic origin, trade union membership, health and medical information (including where required, drug screening results), sexual orientation, and/or criminal history.

The provision of the personal information listed above is generally voluntary, but in certain instances, we will not be able to process your request for our Services without the requested personal information.

There is also information about your computer hardware and software that is automatically collected by MC². This information can include: your IP address, browser type, domain names, access times and referring Web site addresses.

This information is used by MC² for the operation of the service, to maintain quality of the service, and to provide general statistics regarding use of the MC² Web site.

MC² encourages you to review the privacy statements of Web sites you choose to link to from MC² so that you can understand how those Web sites collect, use and share your information. MC² is not responsible for the privacy statements or other content on Web sites outside of the MC² and MC² family of Web sites.

Sources of Personal Information

We collect your personal information in the following ways, pursuant to applicable law:

• Directly From You, when you use our Site or Services, contact us, sign up to receive emails, text messages, and/or postal mailings.
• Through Our Use of Cookies and Other Automatic Data Collection Technologies, when you visit our Sites, open or click on emails we send you, or interact with our advertisements. We or third parties we work with automatically collect certain information using technologies such as cookies, web beacons, clear GIF, pixels, internet tags, web server logs, and other data collection tools. For more information, please see the “Use of Cookies” section below.
• From Our Third‑Party Partners, including from third parties that we have partnered with to provide you the Services that you have requested from us.
• Other Sources, including publicly available sources.

Use of Your Personal Information

MC² collects and uses your personal information to operate the MC² Sites and deliver the Services you have requested.  We use your personal information for the following business purposes (“Processing Purposes”):

• To provide you the Services.
• To enable you to access and use our Sites.
• To communicate with you and to respond to your requests, questions, comments, and other inquiries.
• To understand what resources you use, if any, and to connect you to additional resources at your request.
• To send marketing and promotional materials, including information relating to our Services, as well as in certain instances those of third parties.
• To administer, maintain, evaluate, and improve our Sites and Services.
• To administer surveys and generally to conduct research and analytics related to our Sites and Services.
• To manage our business operations, perform our obligations and exercise our rights under any agreement that you or your organization has with us.
• For other purposes with your consent, or as otherwise permitted or required by applicable law.
• To consider individuals for employment and contractor opportunities and manage onboarding procedures, as well as to administer and improve our recruitment process.
• To evaluate our progress in achieving our diversity hiring goals, to ensure equal opportunity monitoring and reporting, to meet obligations, including providing workforce accommodations and for disability and workplace safety tracking administration.
• To comply with our legal or regulatory obligations, to establish or exercise our rights, and to defend against a legal claim.

To detect, investigate, prevent, or take action regarding possible malicious, deceptive, fraudulent, or illegal activity, including fraudulent transactions, attempts to manipulate or violate our policies, procedures, and terms and conditions, security incidents, and harm to the rights, property, or safety of MC² and our users, customers, employees, or others.

Legal Basis for Processing Your Personal Information

As required by applicable law, we rely on several different legal bases to collect, use, and disclose your personal information:

• Necessity to Perform Contract with You – We need to process your personal information to provide our Services, ensure Services are working as they should, answer questions and requests from you, manage our business relationship with you, and provide customer support.
• Compliance with Legal Obligations – We need to process your personal information to comply with relevant laws, regulatory requirements and to respond to lawful requests, court orders, and legal process.
• With Your Consent – In certain instances, we ask for your consent to process your personal information for specific purposes. Provision of your consent is voluntary, and you have the right to withdraw your consent at any time.
• Based on Legitimate Interest – We process your personal information to protect your security and the security of the Sites; to detect and prevent fraud; to protect and defend the rights or property of others, or our own rights and interests; and to maintain and improve the user experience.

Use of Cookies

The MC² Sites and Services use various technologies to collect and store information, including cookies, pixel tags, web beacons, local storage, such as browser web storage or application data caches, databases, and server logs set by us or third parties (collectively for purposes of this section, “cookies”).

Among other things, a cookie helps MC² to recall your specific information on subsequent visits.  This simplifies the process of recording your personal information, such as billing addresses, shipping addresses, and so on.  When you return to the same MC² Sites, the information you previously provided can be retrieved, so you can easily use the MC² features that you customized.

We differentiate between cookies that are essential for the technical features of the Sites, analytics, and advertising cookies.  For more information, please see our Cookie Policy.

Generally, we deploy non-essential cookies with your consent.  To set your cookie preferences, please utilize our Cookie Preference Manager. If you disable cookies, your ability to use some features of the website may be limited. Any choices concerning cookies are browser and/or device specific. If you clear your cookies from your browser on any of your devices, your choices will need to be reset.

Opt-Out Preference Signals. An opt-out preference signal is a signal that is sent by a platform, technology or mechanism on your behalf that communicates your choice to opt-out of the sharing for browser-level targeted advertisements. You can learn more about implementing opt-out preference signals by visiting, https://globalprivacycontrol.org/, or by exploring other legally recognized device or browser-based universal opt-out mechanisms. We recognize Global Privacy Control signals as valid requests to opt-out of browser-level targeted advertising. We do not currently recognize “Do Not Track” signals.

Disclosures of Your Personal Information

In addition to the specific situations discussed elsewhere in this Privacy Notice, we may disclose information in the following situations, as permitted by applicable law:

• MC² Affiliates: We may disclose your personal information with our affiliates (g., parent company, sister companies or subsidiaries, and other companies under common control) for the purposes described in this Privacy Notice.
• Service Providers: We may disclose your personal information with service providers that provide Services on our behalf or help us operate the Sites.
• Government agencies, regulators, and professional advisors: Where permitted or required by applicable law, we may disclose your personal information to government agencies and regulators (e.g., tax authorities, courts, and government authorities) to comply with our legal obligations, and to external professional advisors as necessary to defend our legal interests.
• Corporate Transactions: In the event of a merger, reorganization, dissolution, or similar corporate event, or the sale of all or substantially all of our assets, we expect that the information that we have collected, including personal information, may be disclosed to the surviving entity in a merger or the acquiring entity. Such information will be disclosed in accordance with applicable law.
• Other Disclosures with Your Consent. We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this Privacy Notice.
• Social Media Platforms and Networks: Some of our Sites have features such as, plugins, widgets, or and other tools made available by third parties that may result in information being collected or disclosed between us and the third party. The third party’s use of your information is not governed by this Privacy Notice.
• De-identified or Aggregate Information. We may aggregate and anonymize information you provide to us in such a way as to ensure it will no longer be identifiable to you. This data may be used for statistical, analytic, and administrative purposes, including analyzing our website traffic and trends, tailoring our Services, or conducting product analysis.  We may disclose anonymized or aggregated data at our discretion, in accordance with applicable laws. We will not attempt to re-identify de-identified information and maintain safeguards to prevent such re-identification.

Security of Your Personal Information

No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts designed to protect your personal information from unauthorized access, use, or disclosure, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of any unauthorized access to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

Retention of Your Personal Information

We apply a general rule of keeping personal information only for so long as is required to fulfil the purpose for which it was collected.  However, in some circumstances, we will retain your personal information for longer periods of time.  We will retain personal information for the following purposes: (i) as long as it is necessary and relevant for our operations and to provide the Service, e.g. so that we have an accurate record of your dealings with us in the event of any complaints or challenge; and (ii) to comply with applicable laws, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigation, and take other actions as permitted by law.

Your Rights

You may have certain rights regarding your personal information.  Your rights will vary depending on where you are located (e.g., the EU, UK and California).  Specifically, you may have the following rights:

• Access: You may have the right to know and access the personal information we have collected about you, including the categories of personal information, the business or commercial purpose for collecting and processing your personal information, the categories of third parties to whom we disclose personal information, the categories of personal information that may be disclosed to those third parties, and, in some instances, a list of third parties to whom we have disclosed your personal information. You may have the right to receive the personal information we process about you in a format, to the extent technically feasible, that is portable, usable, and allows you to transmit the personal information to a person without impediment.
• Correction: You have the right to request correction of inaccurate personal information we have about you. Depending on the purposes of the processing, you may have the right to have incomplete personal information completed, including by means of providing a supplementary statement.
• Deletion (erasure): You have the right to request that we delete your personal information. If required by law, we will grant your request to delete information. However, when we delete personal information it will be removed from our active database, but it may remain in archives where it is not practical or possible to delete it.  In addition, we may keep your personal information as needed to comply with our legal obligations, resolve disputes, and/or enforce any of our agreements.
• Withdraw Consent: Where we rely on your consent to process your personal information, you have the right to withdraw that consent at any time with future effect. Such a withdrawal will not affect the lawfulness of the processing prior to the consent withdrawal.
• Data Portability: Under certain circumstances, you have the right to receive the personal information about you that you have provided to us, in a structured, commonly used, and machine-readable format.
• Opt-Out of the “Sale” or “Sharing” of Personal Information: You have the right to direct a business that sells or shares personal information to third parties to not sell or share your personal information. However, we do not and have not in the preceding 12 months, sold or shared (in this context, share means use of your personal information for cross-contextual behavioral advertising) your personal information without your consent.
• Automated Processing: Under certain circumstances, you have the right to opt-out of the use of automated decision-making technology when it is used for significant decisions concerning you or for extensive profiling. We do not currently use automated decision-making technology for these purposes.
• Right of Non-Discrimination/Retaliation: We do not discriminate against individuals who exercise any of their rights described in this Privacy Notice, nor do we retaliate against individuals who exercise these rights.
• Right to Opt Out of our Use of your Sensitive Personal Information. You have the right to request the restriction of processing of your sensitive personal information. Where applicable, the respective sensitive personal information will be marked accordingly and may only be processed by us for certain purposes. At the current time, however, we do not use or disclose sensitive personal information for purposes other than those expressed in this Notice or otherwise permitted by applicable law, and these uses cannot be limited under applicable law.

Please note that many of the above rights are subject to exceptions and limitations.  Your rights and our responses will vary based on the circumstances of the request. If you choose to assert any of these rights under applicable law, we will respond within the time period prescribed by such law.  In some cases, we may limit or deny your requests to access or delete your information.  This may occur because the law permits or requires us to do so, or if we are unable to adequately verify your identity. In certain jurisdictions, a person authorized to act on your behalf may make a verifiable request related to your personal information.  If you designate an authorized person to submit requests to exercise certain privacy rights on your behalf, we will require verification that you provided the authorized agent permission to make a request on your behalf.

In any circumstances, your request must: (i) provide sufficient information that allows us to reasonably verify that you are the person about whom we collected personal information or an authorized representative of that person; and (ii) describe the request with sufficient detail that allows us to properly understand, evaluate, and respond to it.  We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

To submit a request to exercise any such rights (if they apply to you), please use the contact information provided for in the “Contact Information” section of this Privacy Notice. Current and former California employees of MC² can contact Human Resources for more information about their rights.

Transfers to Other Countries

As permitted by applicable law, MC² may transmit the personal information we collect to representatives, global affiliates, and service providers in the United States or other countries where we do business that may be outside your home country, and may have different standards of data protection than your home country.  We provide appropriate protections for cross-border transfers as required by law, including information transferred to third parties.  With respect to such transfers from the European Economic Area (“EEA”) or the United Kingdom (“UK”) to the United States and other non-EEA jurisdictions, we may rely on the European Union (“EU”) Standard Contractual Clauses (“EU SCCs”) and the United Kingdom (“UK”) Addendum to the EU SCCs.  As permitted by applicable law, you may request details about the suitable safeguards we have in place by contacting us as described below in the “Contact Information” section.

Links to Third Party Websites

Occasionally, MC² Sites may provide links to the websites of third parties.  In these situations, we are not responsible for the content or privacy practices they employ and encourage you to read their own privacy disclosures.

Children’s Privacy

Our Site and Services are not intended for persons under 16 years of age.  If we learn that we have collected personal information from persons under 16 through our Site or Services, we will take appropriate steps to delete this information.  MC² does not knowingly collect or sell personal information from children under the age of 16.

Changes to This Privacy Notice

MC² will occasionally update this Privacy Notice from time to time to reflect MC² and Service changes.  MC² encourages you to periodically review this Privacy Notice to be informed of how MC² is protecting your information.  We will post the updated version of the Privacy Notice on our Sites, and ask for your consent to material changes if legally required to do so.

Contact Information

MC² welcomes your comments regarding this Privacy Notice. If you have any questions regarding this Privacy Notice or to submit a request to exercise any data subject rights (if they apply to you), please use the below contact information:

Email: webmaster@mc-2.com.

If you are in the EU, or the UK, you may also have a right to lodge a complaint with a supervisory authority.

This Privacy Notice includes an “effective” and “last updated” date.  The effective date refers to the date that the current version took effect.  The last updated date refers to the date that the current version was last substantively modified.

Effective Date. May 27, 2026

Last Updated Date. May 29, 2026