Privacy Policy

Effective Date: **Effective Date: September 22, 2025**

Create Stir (“we,” “our,” “us”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our video-on-demand platform, Brew (the "Platform", “Brew”), website, applications, and related services (collectively, “Services”).

By accessing or using Services, you agree to the terms of this Privacy Policy. If you do not agree, please discontinue use of our Services.

1. Information We Collect

We collect information you provide directly, as well as information automatically when you use Brew.

1.1 Information You Provide

Account Information: When you create an account, we collect your name, email address, phone number, password, date of birth (where required for age verification), and profile information.

Billing and Payment Information: Credit card or debit card details, billing address, and payment history. Payment information is processed via secure third-party payment processors and we do not store complete payment card details on our servers.

Profile and Preferences: Watchlists, favorites, reviews, ratings, viewing preferences, content recommendations settings, and other customization choices you make.

Communication Information: Information you provide when contacting customer support, including support inquiries, feedback, complaints, and any attachments or documents you submit.

Transaction Information: Details about your purchases and rentals, including titles purchased, rental periods, prices paid, transaction dates, and order history.

Marketing Preferences: Your communication preferences and consent for promotional materials.

1.2 Information We Collect Automatically

Device Information: IP address, browser type and version, operating system, device identifiers (such as device ID, advertising ID), mobile network information, device manufacturer and model, screen resolution, and hardware capabilities.

Usage Information: Films and content watched, search queries and results, viewing duration and completion rates, time spent on different sections of our Services, navigation patterns, referral codes used, and features accessed.

Location Information: General geographic location based on your IP address and, with your permission, precise location data from your mobile device.

Performance Information: Information about how our Services perform on your device, including loading times, errors encountered, and crash reports.

Cookies and Tracking Technologies: Information collected through cookies, web beacons, pixel tags, and similar tracking technologies (see Section 5 for more details).

1.3 Information from Third Parties

Social Media Platforms: If you choose to connect your social media accounts, we may receive information from those platforms in accordance with their privacy policies.

Payment Processors: Information necessary to process payments and prevent fraud.

Content Partners: Information from filmmakers and content providers whose content you access through our Services.

Marketing Partners: Information from advertising and marketing partners to help us deliver relevant content and advertisements.

Device Manufacturers: Information about app installations, device capabilities, and usage statistics.

1.4 Optional Information

Promotional Participation: Information you provide when participating in promotions, surveys, contests, sweepstakes, or referral programs.

User-Generated Content: Reviews, comments, ratings, and other content you choose to submit or share.

Research and Feedback: Information you provide when participating in user research, beta testing, or feedback programs.

2. How We Use Your Information

We use your information for the following purposes:

2.1 Service Provision and Operations

Provide Services: Deliver, maintain, and operate our video-on-demand platform and all associated features.

Account Management: Create and manage your account, authenticate your identity, and maintain account security.

Transaction Processing: Process purchases, rentals, and payments, including fraud detection and prevention.

Content Delivery: Stream and deliver Digital Content to your devices in the appropriate format and quality.

Customer Support: Provide technical support, respond to inquiries, and resolve issues.

2.2 Personalization and Enhancement

Content Recommendations: Analyze your viewing history and preferences to recommend relevant content and create personalized experiences.

Platform Customization: Customize the user interface, content offerings, and features based on your preferences and usage patterns.

Search Improvement: Enhance search functionality and results based on user queries and interactions.

Feature Development: Develop new features and improve existing ones based on user behavior and feedback.

2.3 Communications

Transactional Communications: Send essential communications about your account, purchases, rentals, and changes to our Services or policies.

Marketing Communications: With your consent where required, send promotional emails, newsletters, and notifications about new content, features, special offers, and events.

Push Notifications: Send notifications through our mobile applications about new content, recommendations, and account activity.

Customer Service: Communicate with you regarding support requests, feedback, and service-related issues.

2.4 Analytics and Research

Usage Analytics: Analyze how users interact with our Services to understand usage patterns, popular content, and user preferences.

Performance Monitoring: Monitor the performance and reliability of our Services across different devices and platforms.

Market Research: Conduct research to understand market trends, user needs, and content preferences.

Business Intelligence: Generate insights to inform business decisions, content acquisition, and platform improvements.

2.5 Legal and Security

Fraud Prevention: Detect, investigate, and prevent fraudulent activities, unauthorized access, and security breaches.

Policy Enforcement: Enforce our Terms of Service, community guidelines, and other policies.

Legal Compliance: Comply with applicable laws, regulations, legal processes, and governmental requests.

Rights Protection: Protect the rights, property, and safety of Stir Stream, our users, content providers, and the public.

Dispute Resolution: Resolve disputes and investigate potential violations of our terms and policies.

3. Sharing of Information

We may share your information in the following circumstances:

3.1 Service Providers and Business Partners

Payment Processing: Share necessary information with payment processors and financial institutions to process transactions and prevent fraud.

Technology Partners: Share information with cloud hosting providers, content delivery networks, and other technology partners who help us operate our Services.

Analytics Providers: Share aggregated and anonymized data with analytics platforms to help us understand user behavior and improve our Services.

Customer Support: Share relevant information with customer support tools and services to help us provide better assistance.

Marketing Partners: Share information with marketing and advertising partners to deliver relevant promotions and measure campaign effectiveness.

3.2 Content Partners and Creators

Viewing Statistics: Share aggregated and anonymized viewing statistics, audience demographics, and content performance metrics with content providers and filmmakers.

Revenue Reporting: Share necessary transaction information with content creators for revenue sharing and royalty calculations.

Content Insights: Provide content partners with insights about user engagement and preferences to help them create better content.

3.3 Legal and Regulatory Requirements

Legal Compliance: Disclose information when required by law, regulation, legal process, or governmental request.

Law Enforcement: Cooperate with law enforcement agencies in investigations of illegal activities or threats to public safety.

Court Orders: Comply with court orders, subpoenas, warrants, and other legal demands.

Regulatory Authorities: Share information with regulatory bodies when required for compliance purposes.

3.4 Business Transactions

Mergers and Acquisitions: If we are involved in a merger, acquisition, reorganization, or sale of assets, your information may be transferred as part of that transaction.

Due Diligence: Share information with potential buyers, investors, or partners during due diligence processes.

Asset Transfers: Transfer information as part of the sale or transfer of business assets or operations.

3.5 Protection of Rights and Safety

Safety Threats: Disclose information to protect the safety and security of users, employees, or the public.

Rights Enforcement: Share information to enforce our legal rights and protect our property and intellectual property.

Emergency Situations: Disclose information in emergency situations where immediate action is necessary to prevent harm.

3.6 Consent and Authorization

User Consent: Share information for other purposes when you provide explicit consent or authorization.

Public Information: Share information that you have made publicly available through our Services.

We do not sell your personal information to third parties for monetary consideration. We may share aggregated, anonymized, or de-identified information that cannot reasonably be used to identify you.

4. Cookies & Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience and improve our Services.

4.1 Types of Technologies Used

Cookies: Small text files stored on your device that help us recognize you and remember your preferences.

Web Beacons: Small graphic images that help us track user interactions and measure the effectiveness of our communications.

Pixel Tags: Code embedded in web pages and emails that allows us to track user behavior and engagement.

Local Storage: Browser-based storage that allows us to store information locally on your device.

Session Storage: Temporary storage that maintains information during your browsing session.

4.2 Purposes of Tracking

Authentication: Enable secure sign-in and maintain your logged-in status across sessions.

Preferences: Remember your settings, preferences, and customization choices.

Security: Detect and prevent fraudulent activities and unauthorized access attempts.

Performance: Analyze site traffic, monitor performance, and identify areas for improvement.

Personalization: Deliver relevant content recommendations and personalized experiences.

Analytics: Understand how users interact with our Services and measure engagement.

Advertising: Deliver targeted advertisements and measure the effectiveness of marketing campaigns.

4.3 Managing Tracking Technologies

Browser Settings: You may manage cookies and other tracking technologies through your browser settings. Most browsers allow you to block, delete, or restrict cookies.

Opt-Out Tools: You can use industry opt-out tools to limit targeted advertising and tracking.

Mobile Settings: You can control tracking through your mobile device settings, including limiting ad tracking and resetting advertising identifiers.

Platform Controls: Use the privacy controls within our Services to manage data collection and personalization features.

Please note that disabling cookies or other tracking technologies may limit your ability to use certain features of our Services and may affect the functionality and personalization of your experience.

5. Your Rights and Choices

Depending on your location and applicable privacy laws, you may have certain rights regarding your personal information:

5.1 Access Rights

Data Access: Request access to the personal information we hold about you, including the categories of information, sources, and purposes of processing.

Account Information: View and access your account information and transaction history through your account dashboard.

Data Copies: Request copies of your personal information in a commonly used and machine-readable format.

5.2 Correction and Update Rights

Information Updates: Correct or update your personal information through your account settings or by contacting us.

Profile Management: Modify your profile information, preferences, and settings at any time.

Account Corrections: Request correction of inaccurate or incomplete personal information.

5.3 Deletion Rights

Account Deletion: Request deletion of your account and associated personal information, subject to certain legal and operational limitations.

Selective Deletion: Request deletion of specific types of personal information while maintaining your account.

Data Erasure: Exercise your "right to be forgotten" where applicable under local privacy laws.

5.4 Restriction and Objection Rights

Processing Restrictions: Request restrictions on how we process your personal information in certain circumstances.

Objection Rights: Object to certain types of processing, including direct marketing and automated decision-making.

Opt-Out Options: Opt out of non-essential data processing activities where legally permitted.

5.5 Communication Preferences

Marketing Opt-Out: Unsubscribe from promotional emails using the unsubscribe link or through your account settings.

Notification Control: Manage push notifications and other communication preferences through your device or account settings.

Communication Channels: Choose your preferred methods and frequency of communication from us.

5.6 Data Portability

Data Transfer: Request transfer of your personal information to another service provider where technically feasible and legally required.

Export Options: Export your data in structured formats where available through our platform.

5.7 Exercising Your Rights

To exercise any of these rights, please contact us at support@createstir.com or through the contact information provided in Section 11. We will respond to your request within the timeframes required by applicable law, typically within 7 days. We may need to verify your identity before processing certain requests to protect your privacy and security.

6. Data Security

We implement comprehensive technical, administrative, and physical safeguards to protect your information against unauthorized access, alteration, disclosure, and destruction.

6.1 Technical Safeguards

Encryption: Use industry-standard encryption for data in transit and at rest, including SSL/TLS protocols for data transmission and strong encryption algorithms for data storage.

Access Controls: Implement role-based access controls and authentication mechanisms to ensure only authorized personnel can access personal information.

Secure Infrastructure: Maintain secure servers, databases, and network infrastructure with regular security updates and patches.

Monitoring Systems: Deploy continuous monitoring and intrusion detection systems to identify and respond to security threats.

6.2 Administrative Safeguards

Employee Training: Provide regular privacy and security training to all employees who handle personal information.

Access Limitations: Limit access to personal information to employees who need it to perform their job functions.

Background Checks: Conduct appropriate background checks for employees with access to sensitive information.

Incident Response: Maintain detailed incident response procedures to quickly address security breaches or data incidents.

6.3 Physical Safeguards

Facility Security: Secure physical access to our offices and data centers with appropriate access controls and monitoring.

Equipment Protection: Implement controls to protect computers, servers, and other equipment that process personal information.

Secure Disposal: Securely dispose of or destroy personal information when it is no longer needed.

6.4 Third-Party Security

Vendor Assessment: Evaluate the security practices of third-party service providers before sharing personal information.

Contractual Protections: Require third parties to implement appropriate security measures through contractual agreements.

Regular Audits: Conduct regular security assessments and audits of our systems and processes.

6.5 Security Limitations

While we strive to protect your personal information, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security, and you use our Services at your own risk. We encourage you to take steps to protect your own information, such as using strong passwords and keeping your account credentials confidential.

7. Data Retention

We retain personal information for as long as necessary to provide our Services, fulfill the purposes described in this Privacy Policy, and comply with legal obligations.

7.1 Account Information

Active Accounts: We retain account information while your account is active and you continue to use our Services.

Inactive Accounts: We may retain account information for a reasonable period after account closure to comply with legal obligations and resolve disputes.

Account Deletion: When you delete your account, we will delete or anonymize your personal information within a reasonable timeframe, subject to legal and operational requirements.

7.2 Transaction and Billing Records

Financial Records: We retain transaction and billing information for accounting, tax, and legal compliance purposes, typically for seven years or as required by applicable law.

Purchase History: We maintain records of your purchases and rentals to provide ongoing access to content and support services.

7.3 Usage and Analytics Data

Viewing History: We retain viewing history and usage data to provide personalized recommendations and improve our Services.

Analytics Information: We may retain aggregated and anonymized analytics data indefinitely for research and business intelligence purposes.

7.4 Communication Records

Customer Support: We retain customer support communications for quality assurance and to help resolve ongoing issues.

Marketing Communications: We retain records of marketing communications and preferences to comply with anti-spam laws and honor opt-out requests.

7.5 Legal and Security Records

Legal Compliance: We retain information as required by applicable laws, regulations, and legal obligations.

Security Incidents: We maintain records of security incidents and investigations for security improvement and legal compliance purposes.

7.6 Retention Schedule Review

We regularly review our data retention practices and may update our retention periods based on business needs, legal requirements, and industry best practices.

8. International Data Transfers

Your personal information may be transferred to and processed in countries other than your country of residence, including the United States where our primary servers are located.

8.1 Cross-Border Transfers

Global Operations: We operate globally and may transfer your information to countries where we, our affiliates, or our service providers operate.

Data Processing Locations: Your information may be processed in data centers and facilities located in various countries around the world.

Service Provider Locations: Our third-party service providers may be located in different countries and may process your information in those locations.

8.2 Transfer Safeguards

Adequacy Decisions: Where possible, we transfer information to countries that have been deemed to provide adequate protection by relevant authorities.

Standard Contractual Clauses: We use European Commission-approved Standard Contractual Clauses and other appropriate safeguards to protect information transferred internationally.

Binding Corporate Rules: We may implement binding corporate rules or other approved mechanisms to ensure consistent protection across our global operations.

Additional Protections: We implement additional technical, organizational, and contractual measures to protect information during international transfers.

8.3 Legal Frameworks

Privacy Shield: Where applicable, we comply with relevant international data transfer frameworks and agreements.

GDPR Compliance: We ensure compliance with European data protection requirements for international transfers.

Local Laws: We comply with local data protection and privacy laws in jurisdictions where we operate.

8.4 Your Rights

If you are located in the European Union or other jurisdictions with specific international transfer requirements, you have the right to obtain information about the safeguards we use to protect your information during international transfers.

9. Children's Privacy

Our Services are not intended for children under the age of 13 (or the applicable age of digital consent in your jurisdiction, which may be higher).

9.1 Age Restrictions

Minimum Age: Users must be at least 13 years old to create an account and use our Services independently.

Parental Supervision: Users under 18 years of age may use our Services only with the involvement and supervision of a parent or guardian.

Age Verification: We may implement age verification measures to ensure compliance with applicable laws.

9.2 Information Collection from Children

No Intentional Collection: We do not knowingly collect personal information from children under 13 without parental consent.

Discovery Procedures: If we discover that we have collected information from a child under 13, we will delete such information promptly.

Parental Rights: Parents and guardians have the right to review, delete, and control the collection of personal information from their children.

9.3 Parental Controls

Account Oversight: Parents and guardians can oversee their children's use of our Services through parental control features.

Content Restrictions: We provide tools to help parents restrict access to certain types of content based on age ratings.

Communication Controls: Parents can control their children's ability to communicate with others through our Services.

9.4 Reporting and Contact

If you are a parent or guardian and believe that your child has provided us with personal information without your consent, please contact us immediately at support@createstir.com, and we will take steps to remove such information and terminate the child's account if necessary.

10. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or operational needs.

10.1 Notification of Changes

Effective Date: **Policy Updates:** When we make changes to this Privacy Policy, we will revise the "Effective Date" at the top of this document.

Notice Methods: We will notify you of material changes through one or more of the following methods:

  • Posting the updated policy on our website and mobile applications
  • Sending an email notification to the address associated with your account
  • Displaying a prominent notice on our Services
  • Providing in-app notifications or alerts

10.2 Types of Changes

Material Changes: For significant changes that affect how we collect, use, or share your personal information, we will provide advance notice and may seek your consent where required by law.

Minor Updates: For minor changes such as clarifications, formatting improvements, or updates to contact information, we may update the policy without additional notice.

Legal Requirements: We may update this policy immediately to comply with new legal requirements or address security concerns.

10.3 Your Acceptance

Effective Date: **Continued Use:** Your continued use of our Services after the effective date of any changes constitutes your acceptance of the updated Privacy Policy.

Opt-Out Option: If you do not agree with changes to this Privacy Policy, you may discontinue use of our Services and close your account.

Withdrawal of Consent: Where we rely on your consent for processing, you may withdraw your consent at any time, though this may affect your ability to use certain features of our Services.

10.4 Policy History

We maintain records of previous versions of this Privacy Policy for reference and compliance purposes. You may request information about previous versions by contacting us.

11. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us using the following information:

Create Stir Inc.

614 N. DuPont Hwy, Suite 210

Dover, Kent 19901

United States

Email: support@createstir.com

Data Protection Officer: akshat@createstir.com (for EU-related inquiries)

Business Hours: Monday through Friday, 9:00 AM to 6:00 PM EST

Response Time: We strive to respond to all privacy-related inquiries within 48 hours

11.1 Specific Inquiries

General Privacy Questions: Contact support@createstir.com for general questions about our privacy practices.

Data Subject Requests: Submit requests to exercise your privacy rights to akshat@createstir.com.

Security Concerns: Report security issues or data breaches to akshat@createstir.com.

Legal Requests: Send legal process and law enforcement requests to akshat@createstir.com.

11.2 International Contacts

European Union: For users in the EU, you may also contact your local data protection authority if you have concerns about our data practices.

Other Jurisdictions: Users in other jurisdictions may contact their local privacy or data protection authorities as applicable.

11.3 Response Procedures

When you contact us regarding privacy matters, please include:
  • Your full name and email address associated with your account
  • A clear description of your request or concern
  • Any relevant account or transaction information
  • Your preferred method of response

We will verify your identity before responding to requests involving personal information to protect your privacy and security.


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