Welcome to CultureTech

CultureTech Inc., a Delaware corporation (“CultureTech”, “we”, “our”, “us”) with mailing address at 244 Madison Avenue #3870, New York, NY 10016, USA and privacy contact email dataprivacy@culture.tech, operates the websites located at the URLs culture.tech, mona.culture.tech, beta.culture.tech, help.culture.tech, referred to together in this Privacy Policy as the (“Website”).

Effective date: September 21, 2021

Scope of Policy

This Privacy Policy explains how we collect, use, disclose and manage your personal information that you provide to us when using the Website or otherwise, as well as our privacy practices. This Privacy Policy applies, without limitation, to any individual or entity that (i) uses the Website, (ii) has  an Account (as defined in our Terms of Service), or (iii) otherwise provides any personal information to us.

WHEN YOU ACCESS OR USE THE WEBSITE, OR OTHERWISE PROVIDE ANY INFORMATION TO US, YOU AGREE TO THIS PRIVACY POLICY, INCLUDING THE MANNER IN WHICH WE USE YOUR INFORMATION, WHETHER OR NOT YOU HAVE AN ACCOUNT WITH CULTURETECH. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, OR TO ANY CHANGES WE SUBSEQUENTLY MAKE TO THIS PRIVACY POLICY, YOU MUST IMMEDIATELY STOP USING THE WEBSITE OR OTHERWISE PROVIDING ANY INFORMATION TO US.

The Website contains links to other websites. This Privacy Policy does not apply to information collected on or through any such third party websites. We are not responsible for the privacy practices of such third parties or the content of their websites. Such third parties have their own privacy policies and you should review those privacy policies to determine their privacy practices.

Information Collected

We collect the following information:

• Contact and Account Information: Your name, addresses, telephone numbers, email addresses, username, password and any other contact and/or Account information that you provide us either through our Website or Application;
• Service Provider Information: Information about the mobile or internet service provider you are using with your device to access the Website and/or send us messages, including name and IP address;
• Messages: The date, time and content of any messages you send to us;
• Payment Information: Credit/debit card and other billing information, including cardholder transaction data, card numbers, expiration dates, billing addresses and CVV codes;
• Interactive Features. We and others who use our Services may collect personal information that you submit or make available through our interactive features (e.g., messaging and chat features, commenting functionalities, forums, blogs, and social media pages). Any information you provide on the public sections of these features will be considered “public,” unless otherwise required by applicable law, and is not subject to the privacy protections referenced herein. Please exercise caution before revealing any information that may identify you in the real world to other users;
• Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities;
• Job Applications. We may post job openings and opportunities on our Services. If you reply to one of these postings by submitting your application, CV and/or cover letter to us, we will collect and use your information to assess your qualifications.
• Technical Information:
  • IP address and other technical information collected from the servers utilized by you or your vendors, such as information and data that is automatically collected upon visiting the Website (i.e., webpage http headers (home server domain names, internet protocol address, operating system type, browser type and language) and information on what pages you access and other information about the way(s) in which you use the Website);
  • Information provided on any application (including the App) or authorization, such as your location, your handset type, your UDID (unique handset code) and any other information you or your mobile device provides to us;
• Other: Other information you provide to us when you use the Website or otherwise interact with us;
• Information listed above which we aggregate and/or anonymize so that it is not linked to you.

How Information is Collected

We collect information through one or more of the following ways:

• The completion of electronic forms found on the Website or on a third party-hosted website, whether via computer or mobile device;
• The completion of paper forms provided to us;
• Surveys;
• Referring websites or third parties, including social media sites such as Facebook, Twitter, Tumblr, Instagram, Pinterest, YouTube and others including by virtue of advertisements placed by us on websites maintained by those third parties;
• The maintenance and analysis of Website server logs;
• “Cookies” (small text files placed by us on your computer(s)), single pixel GIF image files (also called “Web beacons”), Website server log analysis and other similar technological means. See “Use of Web Technologies” Section below.

Location information: We collect information about your location based on:

• derivations made from the IP address from which you connect;

Certain portions of the Website require that you sign in to your Account before being able to access them. On those portions of the Website that require sign in, we collect information to create your account, as well as to determine specific functionality that will be of particular interest to you.

Use of Information Collected

We use the information we collect in the following ways:

• To authenticate and verify individual identities, including requests to exercise your rights under this policy;
• To manage and communicate with you about your account with us, including responding to your questions, feedback and customer or technical support.
• To provide information about our company such as newsletters or other communications; 
• For statistical purposes;
• To publish feedback, personal or company testimonials, and other information on our website;
• To improve our technologies including for the purpose of enhancing your experience on the Website;
• To provide marketing messages and other content which we think will be of specific interest to you, where you have consented (or not opted out, as applicable);
• To process applications if you apply for a job that we post on our Website;
• To manage and secure our operations including for detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity; debugging to identify and repair errors with our Services; and auditing relating to interactions, transactions and other compliance activities;
• To enforce our agreements and policies;
• To comply with our legal obligations.

We store or transfer your credit/debit card data in order to more easily provide services to you. If such credit/debit card and other billing information is collected and/or stored, such credit/debit card and other billing information will be collected and transferred over a secure connection in accordance with applicable regulatory requirements, and is used only for processing underlying transactions.

Where you have consented (or not opted out, as applicable), we add your information to our databases to contact you through future emails regarding site updates, new services and the newsletter. We currently use geolocation only including city, state and country for the purposes of tracking your location when you use the Website, in order to better target service offerings and other information to you.

When you receive an account with us, we will send you a welcome email. We will also communicate with you in response to your inquiries, to provide any services you request, to provide newsletters or other updates that you request and to manage your account. In addition, when you receive an Account with us, you consent to us contacting you by email to receive our email subscriptions and product emails from us. If, at any time, you no longer want us to contact you by email and/or receive our newsletter or product emails, you can contact customer service by email or postal mail at the contact information listed below to assist you with any such changes to your Account.

Use of Web Technologies

Cookies

A cookie is a small text file that is stored on a user’s computer for record keeping purposes. We use cookies on the Website. We link the information we store in cookies to personally identifiable information that you submit while on the Website. We use both session ID cookies and persistent cookies. A session ID cookie expires when a browser is closed. A persistent cookie remains on your hard drive for an extended period of time. Persistent cookies also enable us to track and target the interests of our users to enhance the experience on the Website. You can remove the persistent cookies by following the directions provided in your internet browser’s “help” file. If you reject cookies, you can still use the Website but your ability to use particular areas of the Website will be limited.

Log Files

As is true of most websites, we gather information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data. We use this information, which does not identify individual users, to analyze trends, to administer the Website, to track the movements of users around the Website and to gather demographic information about our user base as a whole.

What types of cookies and other Web Technologies do we use and how do we use them?

The types of cookies and similar technologies used by us and our partners in connection with the Website can be classified into one of five categories, namely ‘essential Website cookies’, ‘functionality cookies’, ‘analytics and performance cookies’, and ‘social media cookies’. Cookies do a lot of different tasks to ensure you enjoy your visit to our Website, for example, they are used to remember your preferences on our Website, to help you navigate between pages more efficiently, to enable you to log into your account more easily. We have set out some further information about each category, and the purposes of the cookies we and third parties set in the following table.

You can block these cookies and similar technologies by changing your browser setting. However, in relation to those that are essential for the operation or improve the functionality of the Website, this may impact your use of the Website.

Type of Cookies	These cookies are essential to provide you with the Website and any services available through this Website and to use some of its features, such as access to secure areas. Without these cookies, services you have asked for, like transactional pages and secure login accounts, would not be possible.
Cookies necessary for essential Website purposes	These cookies are essential to provide you with the Website and any services available through this Website and to use some of its features, such as access to secure areas. Without these cookies, services you have asked for, like transactional pages and secure login accounts, would not be possible.
Functionality Cookies	Functionality cookies record information about choices you’ve made and allow us to tailor the Website to you. These cookies mean that when you continue to use or come back to the Website, we can provide you with our services as you have asked for them to be provided. These cookies allow us to: Save your location preference; Remember settings you have applied, such as layout, text size, preferences, and colors; Show you when you are logged in; and Store accessibility options.
Performance Cookies	We use performance/analytics cookies to analyze how the Website is accessed, used, or is performing in order to provide you with a better user experience and to maintain, operate and continually improve the Website.We use Google Analytics, which is a web analytics tool that helps us understand how users engage with the Website. Like many services, Google Analytics uses first-party cookies to track user interactions, as in our case, where they are used to collect information about how users use our site. This information is used to compile reports and to help us improve our [Website]. The reports disclose website trends without identifying individual visitors. For more information on Google Analytics, see here . You can opt out of Google Analytics without affecting how you visit our site – for more information on opting out of being tracked by Google Analytics across all websites you use, visit this Google page: https://tools.google.com/dlpage/gaoptout. These cookies allow us to:Better understand our Website visitors so that we can improve how we present our content; Test different design ideas for particular pages, such as our homepage; Collect information about Website visitors such as where they are located and what browsers they are using;Determine the number of unique users of the Website; Improve the Website by measuring any errors that occur; andConduct research and diagnostics to improve product offerings.
Advertising and Targeting Cookies	As you use our Website, you will notice that it features advertising. We allow third party companies, including advertising companies, to place cookies on our Website.These cookies enable such companies to track your activity across various sites where they display ads and record your activities so they can show ads that they consider relevant to you as you browse the Internet.Cookies also allow us and third parties to know whether you have seen an ad or a type of ad, and how long it has been since you’ve last seen it. This information is used for frequency capping purposes, to help tailor the ads you see, and to measure the effectiveness of ads.We can use information from one device to help personalize your experience on another device.
Social Media Cookies	On some pages of our Website, third parties that provide applications through our Website will set their own cookies in order to track the success of their applications or customize applications for you. Because of how cookies work, we cannot access these cookies, nor can the third parties access the data in cookies used by us. [Some pages of our [Website] will also contain embedded content, such as video content from YouTube, and these sites will set their own cookies.]These cookies are used when you share an article using a social media sharing button on our Website (e.g., Facebook, Twitter, or Instagram) as the social network that has created the button will record that you have done this. If you are logged in to your account with the third party, the third party will be able to link information about you with your actions via cookies.

In addition to the cookies we use on this website, we also use cookies and similar technologies in some emails and push notifications which enable us to understand whether you have opened the email and how you have interacted with it. If you have enabled images, cookies will also be set on your computer or mobile device and will also be set if you click on any link within the email.

For US Users: Do Not Track

When you use the Website, you may have set your browser or other means used to access the Website to send “do not track” requests to us. We do not respond to “do not track” requests. 

Security

We take reasonable precautions to protect the confidentiality and security of your personally identifiable information by using industry recognized security safeguards. Unfortunately, no method of transmission over the Internet is completely secure. Therefore, while we strive to protect your personally identifiable information within industry standards, we cannot guarantee its absolute security.

We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of your personally identifiable information. Our security procedures mean that we will occasionally request proof of identity before we disclose personal information to you. You are responsible for protecting against unauthorized access to your password and to your computer/mobile device. We ask you not to share your password with anyone.

Our employees are trained and required to safeguard your information. Our internal controls limit access to personally identifiable information based on job functionality.

No Information Collected from Children

The content and services provided by us or our affiliates, sponsors and advertisers, including without limitation the Website, are not intended for anyone under the age of 18 and you should not access such content or services if you are under the age of 18. No information is knowingly collected or retained from children under the age of 13, nor is any such information knowingly used for any marketing or promotional purposes whatsoever, either inside or outside the Website. No part of the Website is designed to attract anyone under the age of 13. Children are not eligible to use any services provided by us and we ask that children under the age of 13 not submit any personal information to us or visit the Website.

Opting Out

If you want to be removed from our marketing list and do not want us to send you email or other messages about our company and services, you can opt out. To do so, please send an email to unsubscribe@culture.tech, with the word “REMOVE” in the subject line.

California Civil Code Section 1798.83 permits California residents to request certain information regarding our disclosure of such residents’ personal information to third parties for such third parties’ direct marketing purposes. To make such a request, please email us at dataprivacy@culture.tech.

Privacy Policy Updates

We reserve the right to change this Privacy Policy at any time, so please review it on a regular basis. Any changes made to this Privacy Policy will be posted here and we will notify you of any material changes. The date stamp at the top of the page represents the last day this Privacy Policy was updated. If you have questions about this Privacy Policy, you can contact us at dataprivacy@culture.tech. By maintaining an Account with us, or by using or accessing any services provided by us or the Website, you will be deemed to have acknowledged our Privacy Policy.

Manage Accurate Information

If your personally identifiable information changes, or if you no longer choose to use our services or the Website, you can contact customer service by email, telephone or postal mail at the contact information listed below to assist you with changes to your Account. To the extent your Account closes or becomes inactive, we will continue to protect your information as described in this Privacy Policy.

International Users

CultureTech is based in the United States, with our servers and offices headquartered in the United States. Please be aware that information you provide to us or that we obtain as a result of your use of the Website, an Account, or any services provided by us will be processed and transferred to, and be subject to the laws of, the United States. The privacy and data protection laws in the United States will be different from similar laws in your country of residence. By using the Website or an Account, or by providing us with your information, you consent to the collection, transfer, storage and processing of information to and within the United States. If our cookies or other software detects IP addresses located in a country outside the United States, we reserve the right to deny access to any and all of our services.

EU Users

If you are in the EU, you have certain additional rights and protections under the law regarding the collection and processing of your personal data.

Legal Basis for Processing

If you are in the EU, we will collect and process your personal data:

• When we have a legitimate interest in collecting and processing your personal data in order for us to run a successful commercial organization (e.g. to communicate with you about updates regarding your subscription, marketing emails and send you updates to this policy);
• Where you have given your consent (e.g. EULA, to use Location Information) – please note that you can withdraw your consent at any time by emailing dataprivacy@culture.tech;
• To comply with our legal or regulatory obligations.

Recipients

We share your information with selected recipients. These categories of recipients include:

• Cloud storage providers including Amazon Web Services located in Virginia, which currently stores your personal data in Virginia, to store the personal data you provide and for disaster recovery services, as well as for the performance of any contract we enter into with you;
• IT Services providers (including Segment, located in the United States), that provide us with SaaS services, who we use to store our customer relationship management information, etc.;
• Provided you have consented, advertisers and advertising networks including Google and Facebook located in California, and which store your personal data in California, that require the data to select and serve relevant information to you and others;
• Analytics and search engine providers including Google located in California and which currently store your personal data in California that assist us in the improvement and optimisation of the website; 

Data Subject Requests

If you are a user in the EU, you have the right to access personal data we hold about you and to have certain personal data corrected or erased. You also have the right to data portability, and to restrict certain processing of your data in certain circumstances. You also have the right to complain to your data protection authority if you have any complaints about how we process your personal information.

You have the right to object to our processing of your personal data at any time, and you can withdraw your consent to marketing at any time.

To make any of these requests please email dataprivacy@culture.tech. We will respond as soon as practicable and no later than one month after receipt of your request. We will request proof of identification to verify your identity.

We reserve the right to deny or restrict fulfillment of your request in certain cases, such as when your access to data places another individual’s privacy rights at risk, or the continued processing or your data is necessary to comply with a legal obligation. If so, we will notify you of the reason(s) for this denial.

Questions or Complaints

In the event that you have a concern about our collection and processing of your data, please contact us first at dataprivacy@culture.tech and we will do our best to fix it. You also have the right to lodge a complaint directly with your local supervisory authority.

Data Retention

• We will retain your information as long as needed to enable you to access the Website or otherwise interact with you, and for as long as you or we can bring a legal claim.

After you have terminated your use of our services, we may store your information in an aggregated and anonymized format.

California Residents

As applicable under the CCPA, from January 1, 2020, if you are a California resident, you may make requests to us as set out below. We will review all requests received and determine the extent to which and how to respond. We will not discriminate against any California resident who makes such requests.

Right to access/know

You may request from us a list of: (i) the personal information that we have collected about you; (ii) the categories of third parties to whom we have disclosed your personal information; and (iii) the categories of third parties to whom we have sold your personal information. You have the right to up to two (2) access requests each twelve (12) months.

Right to delete your personal information

You may request to delete your account and your personal information.

Right to opt-out from the sale of your personal information

You may request, at any time, to direct us to stop “selling” (for the purposes of the CCPA) your personal information.

Making Requests

You may contact us to make the requests described above by email us at: dataprivacy@culture.tech or as otherwise indicated below in the Contact Us section. We will not use the information you provide as part of your request for any other purpose other than to fulfill your request.

To ensure the privacy and protection of individuals, we are required to verify or otherwise authenticate your request(s). To verify your request for access or deletion of your personal information, we may request that you log into your account and additionally send us proof of identification to verify your identity.

If you do not have an account with us, please submit your request by emailing us at: dataprivacy@culture.tech. We will use the information you submit to verify your request prior to completing your request.

You may also submit such requests through an authorized agent. To designate an authorized agent, please send us a notarized power of attorney / notarized letter authorizing said agent. Requests from agents that do not submit such proof that they have been authorized by you to act on their behalf will be denied.

Other Requests

If you are a user of this service and a California resident under the age of 18, you may request to have your information removed by contacting us directly at dataprivacy@culture.tech. Content or information may not be removed from our systems or databases. In certain situations, content or information cannot be removed.

As a California resident, you may contact us with any questions or to request a list of third parties to whom we may disclose your information for such third parties’ marketing purposes and the categories of Information we may disclose.

See the Contact Us section below to make such requests.

Contact Us

If you have any questions or suggestions regarding this Privacy Policy, please contact us as follows:

By mail:

CultureTech
244 Madison Avenue #3870
Attn: Customer Service by email: dataprivacy@culture.tech