Version: CRU-PRIV-COW-2026-09-v1.1
Date: 23 August 2026
Essential principle: Personal data required to provide the service is not processed on the basis of consent. The physical profile card and photograph are optional and require separate authorisation. Refusing this authorisation does not affect access to the coworking service.
1. Controller and contact
Creative Random Universe, Lda., Portuguese company and VAT number 515490849, operating CRU Creative Hub at Rua do Rosário, 211, 4050-524 Porto, is the controller.
Privacy and rights contact: hello@crucreativehub.com.
2. Data processed
CRU may process identification and contact details, tax and invoicing details, subscription plan and history, payment status, access and booking records and operational communications.
During onboarding, the coworker may also voluntarily provide a display name, profession or activity, city and country of origin, topics for “Talk to me about…” and a photograph. Collection is limited to data that is appropriate and necessary for each purpose.
3. Purposes and legal bases
Performance of the agreement: account management, onboarding, provision of a workstation or studio, support, bookings, access control, payments and service communications.
Legal obligations: invoicing, accounting, responding to authorities and retaining records required by law.
Legitimate interests, where applicable and after balancing: security, internal community organisation, fraud prevention, incident management and the establishment or defence of legal claims.
Consent: marketing communications and the optional creation and display of a profile card on the physical community wall. These purposes have separate choices and may be refused without affecting the service.
4. Recipients and platforms
Data may be processed by providers supporting CRU, including Shopify and its subscriptions app, payment providers, Moloni, Notion, booking and access systems, hosting, email and IT support services.
Each provider receives only the data necessary for its purpose and is subject to the applicable contractual and data-protection obligations.
5. International transfers
Some providers may process personal data outside the European Economic Area. Where this occurs, CRU ensures that the transfer is supported by an adequacy decision or appropriate safeguards, such as Standard Contractual Clauses, in accordance with applicable data-protection law.
6. Retention
Data is retained for the duration of the subscription and afterwards for the periods necessary to comply with tax, accounting and legal obligations and to establish or defend legal claims. Data that is no longer necessary is deleted or anonymised.
The physical card is removed from the wall and its production files, including the photograph, are removed from active use after consent is withdrawn or the subscription ends, without prejudice to temporary technical backup copies.
7. Rights
Where applicable, the data subject may request access, rectification, erasure, restriction, portability or objection and may withdraw consent at any time by contacting hello@crucreativehub.com.
Withdrawal of consent does not affect processing lawfully carried out beforehand. A complaint may also be submitted to the Portuguese Data Protection Authority at www.cnpd.pt.
8. Optional physical profile-card authorisation
The card may display the coworker’s chosen name, profession or activity, city and country of origin, topics entered under “Talk to me about…” and, if uploaded, a photograph.
It is intended exclusively for the physical coworker wall at CRU, which is visible to coworkers, staff, visitors and service providers who access the space.
Authorisation is optional, does not limit access to the coworking service and may be withdrawn at any time using the contact above. After withdrawal, CRU will remove the card from the wall as soon as reasonably possible.
Physical profile-card authorisation: ☐ I authorise CRU to create, print and display my profile card on the physical community wall using the data I chose to provide in the onboarding form and, if uploaded, my photograph, under the terms described above.