Privacy Notice

This Privacy Notice is issued pursuant to Article 13 of the EU General Data Protection Regulation (GDPR) and applicable national data protection laws. It applies to all personal data collected directly from you — as an Applicant, Participant, newsletter subscriber, or website visitor — in connection with Creative Playground. Please read this Notice carefully before submitting an application or using the Website.

1.  Who We Are — Data Controller

The Operator is the data controller responsible for your personal data. As a German sole trader, he is subject to the EU GDPR directly and to the German Federal Data Protection Act (Bundesdatenschutzgesetz — BDSG).

2.  What Personal Data We Collect and Why

2.1  Application Data

When you submit an Application via the Website, we may collect personal data such as:

• Identity data: first name, last name;
• Contact data: email address, address details, telephone number;
• Demographic data: age range (optional), gender;
• Preference data: Event selection, room preference, room mate preference, daily rhythm preference, how you heard about us; food preferences;
• Health data (special category): may be inferred from dietary preferences (see Clause 3);
• Application responses: your written answers to the open questions in the application form, including information about your creative background, group experience, and personal reflections; and
• Technical data: IP address, browser type, and device data collected automatically when you access the Website (see Cookie Policy).

We use application data to: evaluate your application; conduct the selection interview; communicate with you about your application and, if accepted, about the Event; and administer the booking and payment process.

2.2  Selection Interview Data

Where a selection interview is conducted, we may take notes during or following the call. These notes constitute personal data and are handled as set out in this Notice.

2.3  Participation Data

Following acceptance, we collect and process:

• Payment and financial data: payment records, invoices, and transaction references (not card details — these are handled directly by the payment processor);
• Contractual data: Confirmation of Participation, correspondence, and any variation to participation terms;
• Event logistics data: copies of identification documents, room allocation, room preference, room mate preference, daily rhythm preference, dietary confirmations, emergency contact details (where provided);
• Communications: email correspondence, feedback, and post-event testimonials (where provided with consent).

2.4  Newsletter and Marketing Subscribers

Where you have opted in to receive our newsletter or marketing communication, we process your email address and, where provided, your name, to send you updates about future Events, creative content, and community news.

2.5  Image and Video Data

Where you have provided explicit consent to be photographed or filmed at an Event, we may process images and video recordings in which you are identifiable. This processing is based solely on your freely given, specific, informed consent (see Clause 4.4). Images and video are used for promotional and documentary purposes including on the Website, social media, and marketing materials. You may withdraw your consent at any time by contacting hi@creative-playground.com.

2.6  Testimonial Data

Where you provide a testimonial following an Event and consent to its use for promotional purposes, we process the text or recording of your testimonial and, where you have consented to attribution, your name and relevant details. You may withdraw your consent at any time by contacting hi@creative-playground.com.

2.7  Website and Booking Tool Data

When you visit the Website or book a selection interview via our calendar/booking tool, we collect technical and usage data as described in our Cookie Policy. The booking tool processes your name, email, and calendar/availability data to schedule interview appointments.

2.8 Requirement to Provide Personal Data

Certain personal data is required for the Operator to process your application and deliver the Event. Specifically:

• Application data (name, contact details, application responses) must be provided to evaluate your application. Without it, the Operator cannot assess your suitability or communicate with you about the Event. If accepted, this data is also required to administer your participation and conclude the participation contract.
• Payment and identification data is required to complete the booking process and to comply with applicable commercial and tax law obligations. Without it, the participation contract cannot be concluded.
• Dietary and health data is optional. If not provided, the Operator may not be able to make appropriate catering arrangements for you at the Event.
• Newsletter subscription and consent to the use of images, videos, or testimonials are entirely voluntary. Declining or withdrawing consent for these purposes has no effect on your application or participation.

3.  Special Category Data — Health Information

When you provide us with your dietary preferences, we may process health data, which constitutes special category personal data under Article 9 GDPR. We process this data only on the basis of your explicit consent, given via the dedicated consent checkbox on the application form.

We process health data solely for the following specific purposes:

• To plan and provide appropriate catering that accommodates your disclosed dietary requirements; and
• To communicate your requirements to the venue and catering providers as necessary.

We do not use health data for any other purpose. Health data is shared only with catering and venue providers on a strictly need-to-know basis and is not used for any profiling, marketing, or analytical purpose.

You may withdraw your consent to the processing of health data at any time by contacting hi@creative-playground.com. Withdrawal of consent does not affect the lawfulness of processing prior to withdrawal. Note that if you withdraw consent for health data processing,

4.  Legal Bases for Processing

We rely on the following legal bases under Article 6 GDPR for processing your personal data:

• Article 6(1)(b) — Performance of a contract: Processing necessary to evaluate your application, issue a Confirmation of Participation, administer your booking and payment, and deliver the Event you have contracted for.
• Article 6(1)(a) — Consent: Processing based on your freely given, specific, and informed consent: (i) processing of health data as per Clause 3 (explicit consent pursuant to Article 9(2)(a) GDPR); (ii) marketing and newsletter communications; (iii) use of your image or video for promotional purposes; and (iv) use of testimonials for promotional purposes.
• Article 6(1)(c) — Legal obligation: Processing necessary to comply with applicable legal obligations, including tax and accounting obligations.
• Article 6(1)(f) — Legitimate interests: Processing necessary for the Operator’s legitimate interests, where these are not overridden by your interests or fundamental rights — including: maintaining records of past Events, subject to the retention period outlined in this privacy notice, and participants for programme quality improvement; fraud prevention; and protecting the Operator’s legal rights in connection with disputes or claims. Data subjects may object to this processing at any time pursuant to Art. 21 GDPR by contacting hi@creative-playground.com.

For special category (health) data, we rely on Article 9(2)(a) GDPR — explicit consent — as our legal basis.

5.  How Long We Keep Your Data

We retain personal data only for as long as necessary for the purposes set out in this Notice, or as required by applicable law, including;

• Unsuccessful applicant data: 12 months from the application decision date.
• Successful applicant interview notes: Interview notes for successful Applicants (Participants) are retained for the duration of the participation relationship and for 3 years following the last Event attended.
• Participant data (booking, payment, correspondence): 7 years from the end of the relevant Event, to comply with applicable commercial and tax law retention obligations.
• Marketing/newsletter subscriber data: Until you unsubscribe or withdraw consent.
• Image and video data (with consent): Duration of consent, revocable at any time.
• Testimonial data (with consent): Duration of consent, revocable at any time.
• Website technical / cookie data: As set out in the Cookie Policy.

6.  Who We Share Your Data With

6.1  Data Processors

We engage the following categories of third-party service providers who process personal data on our behalf as data processors, under written data processing agreements:

• CRM / contact management tool (Brevo)
• Calendar / booking tool (Brevo): Used to schedule selection interview calls.
• Payment processing provider (Stripe)
• Email / marketing tool (Brevo)
• Website hosting provider (Hostinger)

6.2  Event Delivery Partners

We share relevant personal data (including dietary requirements) with venue operators and catering providers, on a strictly need-to-know basis, solely for the purpose of delivering the Event. These partners are bound by confidentiality obligations.

6.3  Igniters (Local Artisan Collaborators)

We may share limited Participant data (e.g. first names, group size, dietary summary) with Igniters engaged to deliver Event sessions. Igniters are bound by confidentiality provisions in their freelance agreements with the Operator.

6.4  Legal and Regulatory Disclosure

We may disclose personal data to competent authorities, courts, or regulators where required to do so by applicable law, or to protect the legal rights of the Operator.

6.5  No Sale of Data

We do not sell, rent, or trade your personal data to any third party for commercial purposes. This applies equally to Participants, Applicants, and newsletter subscribers.

7.  International Data Transfers

As a business established in Germany operating within the EU/EEA, we seek to keep your data within the European Economic Area wherever possible. Where we engage service providers based outside the EEA (including providers with servers in the United States), we ensure that appropriate safeguards are in place, which may include:

• Standard Contractual Clauses (SCCs) adopted by the European Commission;
• An adequacy decision by the European Commission in respect of the recipient country; or
• Other appropriate safeguards recognised under GDPR Chapter V.

8.  Your Rights as a Data Subject

Under the GDPR, you have the following rights in relation to your personal data:

• Right of access (Art. 15): You may request a copy of the personal data we hold about you.
• Right to rectification (Art. 16): You may request correction of inaccurate or incomplete personal data.
• Right to erasure (Art. 17): You may request deletion of your personal data in certain circumstances (e.g. where data is no longer necessary for the purpose for which it was collected, or where you withdraw consent).
• Right to restriction (Art. 18): You may request that we restrict processing of your personal data in certain circumstances.
• Right to data portability (Art. 20): Where processing is based on consent or contract and carried out by automated means, you may request your data in a structured, commonly used, machine-readable format.
• Right to object (Art. 21): You may object to processing based on legitimate interests (Art. 6(1)(f)) at any time on grounds relating to your particular situation.
• Right to withdraw consent: Where processing is based on consent, you may withdraw consent at any time without affecting the lawfulness of prior processing.
• Right not to be subject to automated decision-making: We do not use solely automated decision-making (including profiling) that produces legal or similarly significant effects.

To exercise any of these rights, please contact hi@creative-playground.com. We will respond within one month of receipt of your request. We may ask you to verify your identity before processing your request.

9.  Right to Lodge a Complaint

If you believe we have not complied with your data protection rights, you have the right to lodge a complaint with a supervisory authority. The competent supervisory authority for Creative Playground is:

Der Hamburgische Beauftragte für Datenschutz und Informationsfreiheit (HmbBfDI) — the Hamburg Commissioner for Data Protection and Freedom of Information — as the lead supervisory authority in the Operator’s place of establishment in Germany.

You may also lodge a complaint with the supervisory authority of your country of habitual residence within the EU.

10.  California Residents — CCPA/CPRA Addendum

If you are a resident of California (USA), the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA) provides you with additional rights in relation to your personal information. This section supplements the general Notice above.

10.1  Categories of Personal Information Collected

We collect the following categories of personal information (as defined under the CCPA/CPRA): identifiers (name, email, IP address); professional/employment-related information (occupation, background, creative experience); and sensitive personal information (health data as per Clause 3). We do not sell or share your personal information for cross-context behavioural advertising.

10.2  Your California Privacy Rights

As a California resident, you have the right to: (i) know what personal information we collect, use, disclose, and share; (ii) delete personal information we have collected about you (subject to certain exceptions); (iii) correct inaccurate personal information; (iv) opt out of the sale or sharing of personal information (we do not sell personal information, or share personal information except as outlined in section 6 above); (v) limit the use of sensitive personal information; and (vi) non-discrimination for exercising your rights.

To exercise your California privacy rights, please contact hi@creative-playground.com with the subject line ‘California Privacy Request’. We will respond within 45 days as required by law.

11.  Canadian Residents — PIPEDA and Quebec Law 25 Addendum

If you are a resident of Canada, the Personal Information Protection and Electronic Documents Act (PIPEDA) and, where applicable, Quebec’s Act respecting the protection of personal information in the private sector (Law 25) apply to the processing of your personal information.

We collect, use, and disclose your personal information only with your knowledge and consent (where required), and only for the purposes identified in this Notice. You have the right to access personal information we hold about you and to request correction of inaccurate information. You also have the right to challenge our compliance with applicable Canadian privacy law.

To exercise your Canadian privacy rights or to make a complaint, please contact hi@creative-playground.com. If your complaint is not resolved to your satisfaction, you may contact the Office of the Privacy Commissioner of Canada (OPC) at www.priv.gc.ca, or, if you are a Quebec resident, the Commission d’accès à l’information (CAI).

12.  Cookies and Tracking Technologies

The Website uses cookies and similar tracking technologies. Full details of the cookies we use, their purpose, and how to manage your preferences are set out in our Cookie Policy, available at https://creative-playground.com/cookie-policy.

13.  Changes to This Privacy Notice

We may update this Privacy Notice from time to time to reflect changes in our practices or applicable law. We will notify you of material changes by posting a prominent notice on the Website. The date of the most recent version is shown at the top of this Notice. We encourage you to review this Notice periodically.

14.  Contact Us

For any questions, concerns, or requests relating to this Privacy Notice or our data processing practices, please contact:

© 2025–2026 Alessandro Brandolisio trading as Creative Playground.