Privacy Policy

Creative Marketing Concepts (“we”, “us”, or “our”) are the official US merchandise partner of Xero Limited (“Xero”), and therefore act on behalf of Xero and its affiliates.

This Privacy Policy refers to the collection of “personal information” (“PI”) by or on behalf of Creative Marketing Concepts. 

PI is information about a particular individual, or information that identifies an individual or from which the individual’s identity may reasonably be ascertained. PI may be collected by electronic or paper records. Examples of PI we may collect are: name, address, telephone and mobile phone numbers, email address, password (if applicable) and payment details (if applicable). 

We are committed to the protection of your PI and meeting the standards set out in applicable privacy laws, codes, and/or regulations. This policy sets out how we handle your PI and the rights and obligations that we both have in relation to that information.


1.1 Why We Collect Personal Information

We collect your PI solely to provide you with products and services in connection with the Xero store (this website).

1.2 How We Collect Personal Information

We collect PI directly from you through written, electronic and/or verbal means of communication when you interact with us, for example, when you:

(a) send us an email;

(b) submit a general query or place an order for Xero merchandise on this website; and/or

(c) contact us to place an order for Xero merchandise.


2.1 Use

Your personal information may be used for the following purposes:

(a) to provide you with our products or services as requested by you;

(b) to administer our relationship with you within this website;

(c) to process orders;

(d) to respond to comments or queries;

(e) to monitor activity on this website, for the purpose of maintaining the security of this website;

(f) for internal administrative purposes, such as procedural assessments, risk management, staff training, accounting, billing, product and service reviews;

(g) to conduct appropriate checks for credit-worthiness and for fraud; and

(h) as otherwise permitted by law.

2.2 Disclosure

We may provide PI to:

(a) third parties engaged by us to provide functions on our behalf such as processing credit card information; 

(b) third parties authorized by you to receive PI held by us; and

(c) Xero, and you expressly consent to Xero’s use of such PI in accordance with the terms of Xero’s privacy policy (see here: as amended and updated by Xero from time to time by Xero in its absolute discretion.

We may also disclose PI to unrelated third parties (for example, our professional advisers and government authorities or agencies) where that disclosure is reasonably required to obtain advice, prepare legal proceedings, investigate suspected improper conduct or wrongdoing, to assist a lawful authority in the discharge of its duties and/or by law.

If you do not want us to use or disclose your PI for the above purposes, then please contact us at (408) 680-8000 or email us at

To better protect your privacy, we impose strict requirements of security and confidentiality on all third parties as to how third parties handle your PI. Notwithstanding this, we cannot be held responsible for any misuse or unauthorized disclosure of your PI by these third parties. 


If someone visits this website to read, browse or download information, our system may record information such as the date and time of their visit to the website, the pages accessed and any information downloaded. This information is used for statistical, reporting and website administration and maintenance purposes only.

Like many websites, the website may use “cookies” from time to time. Cookies are small text files that the website transfers to a user’s hard drive through their web browser to enable the website's systems to recognize the user’s browser. Cookies may also be used to record non-personal information such as the date, time or duration of a user’s visit, or the pages accessed, for website administration, statistical and maintenance purposes. The default settings of browsers like Internet Explorer always allow cookies, but users can easily erase cookies from their hard-drive, block all cookies, or receive a warning before a cookie is stored. Please note that some parts of this website may not function fully for users that disallow cookies.

When we send emails or other electronic messages, we may record where recipients open the message and click on particular links. This helps us to better understand what information is of interest to those recipients.

The website may use Google Analytics, a web analytics service provided by Google, Inc. (“Google”).  Google Analytics uses cookies to help analyze use of the website. The information generated by the cookies about your use of the website (including the IP address of users’ computers) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating individuals’ use of the websites, compiling reports on website activity for website operators and providing other services relating to website activity and Internet usage.  Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate IP addresses with any other data held by Google. By using the website, individuals consent to the processing of data about them by Google in the manner and for the purposes set out above.

While we take great care to protect PI on the website, unfortunately no data transmission over the Internet can be guaranteed to be 100% secure. Accordingly, we cannot ensure or warrant the security of any information sent to or from the website. This is particularly true for information sent to the website via email. We have no way of protecting that information until it reaches us. Once information is received by email, we protect its security in accordance with this Privacy Policy.

As noted in the Terms of Use, this website may contain links to other websites and/or apps. We are not responsible for the privacy practices or policies of those websites and/or apps.


We take reasonable steps to ensure that the PI we collect, use or disclose is accurate, complete and up to date. If your PI is incorrect or changes, please contact us via email at or call (408) 680-8000 so that we can correct or update your PI and continue providing you with our services.




Your PI is stored in a number of secure computer storage facilities and paper-based files, and in other records. We have taken reasonable security safeguards to protect your PI from misuse, loss and unauthorized access, modification or disclosure. However, we will not be held responsible for the misuse, loss and unauthorized access, modification or disclosure of PI you submit to us, and you do so at your own risk. 

Please also note that the PI you provide to us is stored in the USA on a secure server. 

Once we no longer need your PI, we take reasonable steps to de-identify your PI.


If you have any questions whatsoever on our handling of your PI or the kind of PI we hold about you, please contact us via email at or call (408) 680-8000 and we will endeavor to assist you with your request.


You have the right to access your PI and we will provide you with a copy of any PI we hold on request, if it is readily retrievable. 


Where practical, you may deal with us on an anonymous basis, however, because of the services we provide, if you do not provide us with your PI we may not be able to provide you with the requested product or service.


We will publish this policy on this website and will make copies available by request.


Our Privacy Officer is responsible for monitoring changes in privacy legislation and for reviewing this policy.


If you have any queries about this Privacy Policy, please contact our Privacy Officer by mail at

Privacy Officer

Creative Marketing Concepts

233 Sansome Street, Suite 300

San Francisco, CA 94104

or by email to

Last updated August 2016