Privacy Policy

Effective Date: 01/01/2022
Last Updated: 05/03/2026

C•LAB[Wev], a subsidiary of Twenty 8 State Ltd ("we," "our," or "us"), respects your privacy and is committed to protecting your personal data.

This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application, website, and related services (collectively, the "Services").

By accessing or using our Services, you agree to the terms of this Privacy Policy.

1. Information We Collect

We collect information to operate, secure, and improve our Services.

1.1 Information You Provide

• Personal Data: Name, email address, phone number, mailing address, and other contact details when you create an account, contact us, or use our services.
• Payment Information: Payment card details or other billing information when making a purchase.
• Content: Any information or media content you upload to our Services or platform.

1.2 Information We Automatically Collect

• Device Information: IP address, browser type, device type, operating system, and other technical data.
• Usage Data: Information about your interactions with our Services, such as pages visited, links clicked, and time spent.

1.3 Information From Third Parties

• We may receive information about you from third-party sources, such as payment processors or social media platforms, when you interact with our Services through those platforms.

2. How We Use Your Information

We use your information for the following purposes:

• Provide and operate the Services
• Personalise user experience
• Enable social and messaging features
• Process payments and subscriptions
• Deliver in‑app purchases and virtual goods
• Moderate content and enforce rules
• Detect fraud and security threats
• Improve performance and features
• Communicate service updates and support responses
• Send marketing communications (where permitted)
• Comply with legal obligations
• Enforce our Terms and protect users

3. Legal Bases for Processing (UK GDPR)

We process personal data under the following legal bases:

• Contract: To provide Services you request
• Legitimate Interests: To improve, secure, and grow our platform
• Legal Obligation: To comply with law and regulation
• Consent: For marketing and certain tracking technologies

4. How We Share Your Information

We do not sell personal data.

We may share information with:

• Contract: To provide Services you request
• Legitimate Interests: To improve, secure, and grow our platform
• Legal Obligation: To comply with law and regulation
• Consent: For marketing and certain tracking technologies

4.1 Service Providers

Third‑party vendors supporting:

• Hosting and infrastructure
• Payments
• Customer support
• Analytics
• Moderation tools
• Marketing services

4.2 Platform & App Stores

Where required by Apple App Store and Google Play.

4.3 Legal & Safety

We may disclose data:

• To comply with legal obligations
• To respond to lawful requests
• To protect users and the public
• To enforce our Terms

4.4 Business Transfers

In connection with mergers, acquisitions, or asset sales.

5. User Content & Public Information

Information you post publicly may be visible to other users and searchable online.

We may use user content for:

• Platform display
• Marketing and promotion
• Advertising materials
• Press and public relations

6. Data Retention

We retain personal data only as long as necessary to:

• Provide Services
• Meet legal requirements
• Resolve disputes
• Enforce agreements

Some data may be retained after account deletion where legally required or necessary for safety and fraud prevention.

7. Data Security

We use industry‑standard technical and organisational safeguards. However, no system is completely secure. Use the Services at your own risk.

8. Your Rights

Depending on your location, you may have the following rights regarding your personal data:

• Access your data
• Correct inaccurate data
• Delete your data
• Restrict processing
• Object to processing
• Data portability
• Withdraw consent
• Opt out of marketing

To exercise these rights, please contact us at info@createmoretogether.club.

9. Children’s Privacy

The Services are intended for users aged 18+. Users under 18 may only use the Services with parental or guardian consent.

We do not knowingly collect personal data from children without appropriate consent.

10. International Data Transfers

Your data may be processed outside the UK. Where this occurs, we use lawful safeguards such as adequacy decisions or standard contractual clauses.

11. Automated Systems & Moderation

We may use automated tools and AI systems to:

• Detect harmful content
• Recommend content
• Personalise experiences
• Prevent fraud and abuse

Human review may be used where appropriate.

12. Marketing Communications

We may send:

• Service announcements
• Product updates
• Promotional messages

You can opt out at any time using in‑app settings or unsubscribe links.

13. Changes to This Policy

We may update this Privacy Policy periodically. Changes will be posted with an updated revision date.

10. Contact Us

If you have questions or concerns about this Privacy Policy or your personal data, please contact us at:
Email: info@createmoretogether.club