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Last Updated: January 01, 2011

This Privacy Policy describes how we handle your personal information for our services on the BestCreativity websites. It applies generally to the BestCreativity.com website and content and other related websites, products and services offered by BestCreativity.

Some Vela Services-branded websites or websites we operate may be governed by separate privacy policies. The policy that applies on any of our domains or subdomains is always the policy that appears in the footer of each website.

1. General Information

In order to manage the BestCreativity Services and reduce the risk of fraud, BestCreativity, must ask you to provide personal information for a data check.

By accepting the Privacy Policy and the User Agreement in registration, you expressly consent to our collection, storage, use and disclosure of your personal information as described in this Privacy Policy.

In this document BestCreativity is giving high priority to the confidentiality of the personal information collected and, therefore, informs you that this data will be used only in accordance with the provisions in this Privacy Policy. BestCreativity. will not transmit or divulge any of the user's personal information or a list of our users to third parties. However, in order to provide the Services to users, continuously improve the quality of services and defend the interests of users, in limited circumstances, as described in more detail below, BestCreativity will share some personal information about users with third parties according to strict limitations.

It is your responsibility to read the privacy policy as this is applied to all BestCreativity Services. By accepting the Privacy Policy and Terms & Conditions during registration on the BestCreativity site, the user gives express consent to the use and disclosure of personal information and authorises BestCreativity to do so, as described in this document. This Privacy Policy is incorporated into these Terms & Conditions and is subject to the terms contained therein. In case of rejection of the terms of our Privacy Policy you should not register for Vela Services LLC and/or use them.

Notification of Changes

BestCreativity may at any time amend or supplement this Privacy Policy ("Change") with the publication of an updated version on the BestCreativity web sites.

Changes will be made unilaterally by BestCreativity and will be deemed accepted by the user once the same has been notified and has not expressed willingness to withdraw from the BestCreativity Services. The change will be effected without prior notice and will come into force immediately when the notification is sent. If the user decides not to accept the change, the user must cancel the account or ask us to close it in the manner specified in the Agreement.

On some pages, the BestCreativity web site contains links to third party web sites. These sites are governed by their own privacy policies and BestCreativity is not responsible for the operations they perform, including, without limitation, the processing of personal data. We recommend that users wishing to send information to or through third-party web sites read their privacy statements before providing personal information.

Special advise about Minors

Minors (people under 18 years of age) are not allowed to use the BestCreativity Service and must refrain from sending personal information to us or using the BestCreativity Services. BestCreativity assumes no responsibility for the misuse of its services by minors.

2. Collected Data

1. The information you provide will be used for the following purposes:

a) Collection, storage and processing for the establishment and operational management and administration of the contractual relationship connected with provision of the service provided on our site; b) Use of the data (especially your e-mail) by BestCreativity to carry out communications relating to: c) performance of the contractual relationship; d) sending advertising e) sending information materials and newsletters; f) Participation in anonymous surveys; g) Participation in thematic forums; h) Collection, storage and processing of data to make statistical analysis in an anonymous and/or aggregate form;

2. The information you provide will be handled electronically using computer systems that provide specific security measures to prevent loss of data, illicit or improper and unauthorized access and serviced only by authorized personnel.

3. The failure to provide the data will make it impossible to access the services mentioned above; we inform you that, in case of no interaction with the services referred to in paragraph 1 for a period exceeding 24 months, we will delete your data, with prior notice by e-mail.

4. The data will be processed for as long as necessary for the proper performance of the stated purposes.

5. The processed data will not be disclosed to other parties, nor will it be circulated.

6. The data controller is BestCreativity, email: privacy@bestcreativity.com

7. At any time, you may exercise your rights with the owner or controller.

Mandatory Information

To open an account and use the BestCreativity Services, you must provide your name, address, telephone number and address.

This information is necessary to BestCreativity for processing transactions, issuing a new password if you forget or lose the previous one, protecting you against fraud and contacting you for administrative and/or management questions regarding the administration of the account and/or BestCreativity Services.

Transaction Information

For sending/receiving a payment to another user of BestCreativity. Services, you may need to provide personal details to the customer in order to complete the transactions. These details can, thus, be transferred from the customer to BestCreativity.

BestCreativity retains all the information for each transaction made through their services and can add this information to the user profile for any future transactions made with BestCreativity, its participating companies and subsidiaries.

BestCreativity also collects the Internet address (IP address) and other identifying information of the computer or device you use to access/use the BestCreativity Services, in order to help detect possible instances of unauthorized transactions.

Although you may terminate your account at any time, without charge, the user continues to be responsible to BestCreativity after the closure of the account for any costs incurred and is responsible for the period prior to the closure of the account; in addition, the user must look at BestCreativity's rights described in the Terms & Conditions.

terzi Information from Third Parties

In order to protect all users against potential fraud, BestCreativity verifies the information provided by comparing it with that in the possession of the banking systems listed in the table in the section "Disclosure to parties other than BestCreativity customers", below. In the course of this review, BestCreativity. receives personally identifiable information about you.

Addional Verification

If BestCreativity is unable to verify the information you provide, you will be asked to fax additional documents proving your true identity or answer additional questions online to verify the information.

Website Traffic Information

Under the standard used for communications on the Internet, when the user logs on or disconnects from the web site, BestCreativity is automatically aware of the web site you came from or to which the user wants to connect. BestCreativity also collects information about web site pages visited by the user, IP addresses, type of browser used and the number of accesses.

This information is used by BestCreativity in order to better identify user preferences and manage the workload of the servers to improve the service offered and the ways it is used.

Cookies

We use cookies, web beacons, and related tools from third parties to provide features and services that improve your buying and selling experience. To help protect your privacy, we limit how these tools can be used on BestCreativity

“Cookies" are small files placed on the hard drive of your computer, that give the possibility to BestCreativity to recognize you as already registered user when you access to the Site, using the same browser.

BestCreativity sends a "session cookie" to your computer if and when you log into your account by entering your address and password or any other means chosen to access the Services.

These cookies allow recognising you if you visit multiple pages in our site during the same session, so that does not need to re-enter your password multiple times. Once you log out or close your browser, these session cookies are deleted from the user's computer and no longer have any effect. BestCreativity also uses longer-lasting cookies for other purposes, such as displaying your e-mail address in the login form, so that you do not have to retype the address each time you log into your account.

These cookies are encrypted so that information can be interpreted only by BestCreativity. You are free to decline our cookies if your browser permits, but this may interfere with site navigation.

BestCreativity may also collect information about your computer or other access devices in order to reduce risks and for fraud prevention purposes. BestCreativity uses cookies to customize the services offered, the content and advertisements, measure the effectiveness of promotions and promote trust and safety. You may encounter cookies from third parties during the use of the BestCreativity Services on web sites not controlled by BestCreativity (for example, when viewing a web page created by a third party or during the use of an application developed by third parties).

Costumer Service Management

All the communications between users and BestCreativity., including all e-mail messages and fax, will be stored by us with all the information and documents related to the user’s account.

We will also retain customer service correspondence and other correspondence sent from BestCreativity to the user.

Such records shall be retained in order to evaluate and improve the efficiency of customer service and to investigate potential fraud and violations of the Terms & Conditions.

If permitted by law, these documents may be deleted in future.

Survey and Account Data Collection

BestCreativity may, from time to time, offer you optional questionnaires and surveys to collect demographic information or assess the user's interests and needs.

The way the information collected is used will be explained in detail in the survey itself. If the questionnaires and surveys require the collection of personal information, you will be advised on how such information is used before taking part in the survey or questionnaire.

3. Use and disclosure of Information by Vela Services

Internal Use

BestCreativity collects, stores and processes personal information on servers in the U.S. and also managed by one of our subsidiaries and on servers in other parts of the world where there are local offices of BestCreativity.

The primary purpose in collecting personal information is to provide you a safe, efficient and personalized experience.

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You agree that BestCreativity may use personal information to:

§ provide the services and customer support you request

§ resolve disputes, collect fees, and troubleshoot problems

§ prevent potentially prohibited or illegal activities and enforce our Terms & Conditions

§ customize, measure and improve our services and content and the layout of the web site

§ send you targeted marketing communications, communicate service updates and promotional offers based on your communication preferences defined in the BestCreativity account (refer to section Contact with BestCreativity customers, below)

§ compare the accuracy of the information and verify it with third parties.

Marketing

We don't sell or rent your personal information to third parties for their marketing purposes without your explicit consent. We may combine your information with information we collect from other companies and use it to improve and personalize our services, content and advertising. If you don't wish to receive marketing communications from us or participate in our ad-customization programs, simply send an e-mail to: privacy@bestcreativity.com.

Disclosure to other users

If the user is registered with BestCreativity, name, address, Skype ID (if available), phone number, date of registration, and any other information necessary for administrative and legal purposes for the completion of transactions and the status of the verified BestCreativity user can be supplied to other BestCreativity users for the completion of the transaction.

If you provide personal information to other users via the BestCreativity Services, BestCreativity cannot be held responsible for various aspects of their activities, including rules relating to the processing of personal data.

Disclosure to third parties

BestCreativity works with third parties (for example, subsidiaries and participating business partners and service companies), with which it may share user information, including, for example, bank details, in order to carry out all management, administrative and financial activities related to the Services offered.

Disclosure to third parties not BestCreativity users

BestCreativity will not sell or disclose personal user information to third parties and discloses this information only in limited circumstances and for the purposes described in this statement.

This includes the transfer of data to countries outside the European Union. Specifically, you authorise BestCreativity to:

§ Disclose information including, without limitation, information relating to transactions, accounts, personal information and the content of communications with the police, law enforcement, government agencies, intergovernmental and supranational authorities, agencies (other than internal revenue agencies), departments and authorities or competent regulatory organizations and self-regulatory authorities (including, without limitation, the agencies listed in the table below in the section "Agents") or third parties with which, at its discretion, it deems appropriate to cooperate with in investigations of fraud or other illegal or potentially illegal activity, or to conduct investigations of violations of our Terms & Conditions.

§ Disclose information in accordance with the rules for using credit cards or in response to the legal collection of data § Disclose information to your agent or legal representative (e.g., a holder of an authorization granted or a guardian appointed for you).

§ Share aggregated statistical data with our business partners or for public relations. For example, BestCreativity may disclose the percentage of our users who live in Manchester. However, this aggregated information is not linked to personal information.

§ As any other company, in the future, BestCreativity could be the subject of merger or acquisition by another company. In this case, you agree that the successor company would have access to information managed by BestCreativity, including information on customer accounts, and that the company will continue to be bound by this Privacy Policy, unless and until the Privacy Policy is changed.

Communication between BestCreativity users

BestCreativity regularly sends you e-mail communications to provide the requested services and communicates by phone to resolve customer complaints or claims submitted by users through BestCreativity services, respond to requests for Customer Service, inform the user about any suspect transactions potentially used for illegal purposes, verify the information on the identity of the user, or the activity the company or account, conduct data collection, customer surveys or investigate suspicious transactions. BestCreativity uses your e-mail address to confirm your opening of a BestCreativity account, send a notice of payments sent or received relating to the Services offered, send information about important changes to the products or services and send notices and other communications required by law.

Users can not choose out of receiving those reports, which, however, are primarily informational in nature rather than promotional.

The e-mail address is also used to send other types of communications that the user can choose whether or not to receive either during registration or subsequently, by logging into your account on the site BestCreativity.com .

In connection with independent audits of the financial statements and operations of BestCreativity, the auditors may try to contact some of our customers to confirm the accuracy of our records. However, these auditors can not use personal information for any secondary purposes.

By accepting the Terms & Conditions, you agree to respect the personal information of other users obtained through the BestCreativity Services Inc, BestCreativity related communications or transactions made through BestCreativity, and to use such information only for: (a) communications related to BestCreativity that are not unsolicited commercial messages, (b) using services offered through BestCreativity, such as insurance, delivery and fraud protection, and (c) any other purpose that such user expressly accepted after adequate communication of the purpose thereof.

In any event, you must provide users with the opportunity to remove themselves from your database and review any information collected. More generally, it is your responsibility to comply with all applicable standards of privacy, especially for sending emails regarding marketing activities. BestCreativity does not allow spam. BestCreativity strictly enforces anti-spamming rules.

To report BestCreativity-related spam or spoof emails to BestCreativity, please forward the email to privacy@bestcreativity.com..

4. Information Security

Information Security

BestCreativity guarantees the highest level of safety in the management of user data by adopting protective measures such as firewalls and encryption of computer data, performing checks of physical access to our buildings and files, and authorising access to personal information only to employees that require it to fulfil their job responsibilities.

Your password is the key to your account. Use unique numbers, letters and special characters, and do not disclose your BestCreativity password to anyone.

If you do share your password or your personal information with others, remember that you are responsible for all actions taken in the name of your account. If you lose control of your password, you may lose substantial control over your personal information and may be subject to legally binding actions taken on your behalf.

Therefore, if your password has been compromised for any reason, you should immediately notify BestCreativity. and change your password.Representatives of BestCreativity will never ask you for your password.

Thus, any e-mail or other communication requesting your password should be considered as unauthorized and suspicious and should be forwarded to privacy@bestcreativity.com.

Right to access personal data and other rights

1. The interested party has the right to know whether or not personal data about him exists, even if not yet recorded, and to receive a copy in intelligible form.

2. You have the right to obtain information:

a) about the origin of the personal data; b) the purposes and methods of its processing; c) the logic applied, in the case of processing by computers; d) the contact information for the holder, managers and representative designated under article 5, paragraph 2; e) the subjects, or categories of subjects, to whom the personal data may be communicated, or that may come to know it in their capacity as designated representative in the territory of the state, managers or appointees.

3. The interested party has the right to:

a) have the information updated, corrected or, when there is an interest, supplemented; b) the deletion, transformation or blockage of data handled in violation of the law, including that which it is not necessary to preserve in relation to the purposes for which the data was gathered or subsequently processed; c) certification that the operations in letters "a" and "b" were brought to the attention, also as regards their content, of those to whom the data was communicated or published, except in the case where such fulfilment is impossible or involves a use of means that is obviously disproportionate to the right protected.

4. The interested party has the right to oppose, in whole or in part:

a) the processing of personal data that regards him, even though pertinent to the purpose for which it was gathered, for legitimate reasons; b) the processing of personal information that regards him for the purpose of sending advertising or direct sales material or for market research or commercial communications.

5. Access and modification of personal information

The user can review the personal information provided at any time and make any changes to such information, or to the settings of your account, by signing in to BestCreativity site and changing your preferences in the Profile page of the "Profile" tab. Through the BestCreativity site, you can also close your account. If you close the account, it will be marked as "Closed" in our BestCreativity database, but the information will remain in the database. This system is a deterrent to fraud, since it prevents persons who try to commit fraud from avoiding detection simply by closing their account and opening a new one. However, if the user closes the account, your personal information will not be used for other purposes, nor sold or shared with third parties, except as necessary to prevent fraud and assist law enforcement or otherwise in accordance with the established by law.

6. Responsibility

The department responsible for checking BestCreativity privacy is responsible for ensuring that the procedures used daily by BestCreativity conform to the Privacy Policy.

If you wish to exercise the right to access your personal information or have any questions about this privacy statement, information practices on BestCreativity or your dealings with BestCreativity, you can contact us by writing to the e-mail address

privacy@bestcreativity.com or if your questions are not answered online, you may write to us