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Cultr Privacy Policy

Last updated: March 15, 2018

1. Introduction

Cultr provides a culture change tool through a Software as a Service (SaaS) model. At Cultr the privacy and security of our clients, users and visitors are of paramount importance. Cultr is committed to protecting the data you share with us. This privacy policy explains how Cultr processes information that can be used to directly or indirectly identify an individual (“Personal Data”) collected through use of its website and platform.

For the purposes of this policy, Cultr defines the term “Client” as an entity with which Cultr has an established relationship, the term “User” as any individual who uses our apps/platform or who is included as a user in a Client’s account and the term “Visitor” as an individual that visits our websites (for example cultr.works or www.cultrworks.com).

Any information stored on Cultr’s platform is treated as confidential. All information is stored securely and is accessed by authorized personnel only. Cultr implements and maintains appropriate technical, security and organisational measures to protect Personal Data against unauthorized or unlawful processing and use, and against accidental loss, destruction, damage, theft or disclosure.

2. Collection and use

2.1 General

The following sections cover the specifics of each of the three groups from which data is collected: website Visitors, Users and Clients.

2.2 Website Visitors

If you are a Visitor to our website only, and not a user of our app or platform, then this section is relevant for you.

By visiting this website, you consent to the collection and use of your Personal Data as described herein. If you do not agree with the terms set out herein, please do not visit our websites. If required by applicable law, we will seek your explicit consent to process Personal Data collected on our websites or volunteered by you. Kindly note that any consent will be entirely voluntary. However, if you do not grant the requested consent to the processing of your Personal Data, the use of our websites may not be possible.

Cultr may collect, record and analyze information of Visitors to our websites. We may record your IP address and use cookies. Cultr may add information collected by way of pageview activity. Furthermore, Cultr may collect and process any Personal Data that you volunteer to us in our websites’ forms, such as when you register for events or sign up for information and newsletters. If you provide Cultr with your social media details, Cultr may retrieve publicly available information about you from social media.

Such Personal Data may comprise your IP address, first and last name, your postal and email address, your telephone number, your job title, data for social networks, your areas of interest, interest in Cultr products, and certain information about the company you are working for (company name and address), as well as information as to the type of relationship that exists between Cultr and yourself.

Cultr gathers data about visits to our websites, including numbers of Visitors and visits, geo-location data, length of time spent on the site, including pages clicked on or where Visitors have come.

2.2.1 Purpose of processing Visitor’s Personal Data

Cultr uses the collected data to customize content for Visitors, to communicate with Visitors, to send information about product, to show ads on other websites to Visitors, and to improve its website by analyzing how Visitors navigate its website.

2.2.2 Sharing Visitor’s Personal Data

Cultr may also share such information with service vendors or contractors in order to provide a requested service or transaction or in order to analyze the Visitor behavior on its website.

2.2.3 Cookies

Cookies are small pieces of information sent by a website to a Visitor’s hard disk. Cookies cannot be used to run programs or deliver viruses to your computer. By continuing to visit the website, you agree to the placement of cookies on your device. If you choose not to accept our cookies, we cannot guarantee that your experience will be as fulfilling as it would otherwise be. We may also place cookies from third parties for functional and marketing purposes. 

2.2.4 Links to other sites

Please be aware that while visiting our site, Visitors can follow links to other sites that are beyond our sphere of influence. Cultr is not responsible for the content or privacy policy of these other sites.

2.3 Users

If you are a user of our app or platform, then this section is relevant for you.

By using our app or platform, you consent to the collection and use of your Personal Data as described herein. If you do not agree with the terms set out herein, please do use our app or platform. Users should be aware that in using the Cultr app or platform, they will be disclosing information that will make them personally identifiable to the Cultr Client who has provided an account for the User.

2.3.1. User account

In order to offer our service and provide an individualized experience while using our apps/platform, we create a personal account for each user added to a Client’s Account. The Client may transfer to us or register in the platform information about the user:

  • Email Address
  • Full Name
  • Title
  • Department
  • Office location
  • Images of user
  • Gender
  • Birth Date

2.3.2. Collection of Users’ Personal data while using the app/platform

While using the app/platform with the account the Client have provided for you, you may see the challenges, missions, quizzes and other content that the Client has selected for you. You may also see messages from other users. By interacting with the content or with other users, you may provide your Personal Data in the form:

  • Full name
  • Title
  • Additional work-related information
  • Pictures
  • Comments
  • Likes and follows
  • Messages

We will use this information to:

  • carry out our obligations arising from the agreement with the Client that has provided an account for you. This includes providing the platform for the Client that have provided an account you;
  • It also includes providing the Client with reports and analysis summarising information provided during your use of the Platform;
  • contact you for your feedback on our services and to help us evaluate and improve our services, for example by acting on any information you have provided to us;
  • notify you about changes to the Platform and any other services of ours that you use, including informing you about new versions of the Platform and about new features, functionality and service offerings; or
  • deal with any enquiries, correspondence, concerns or complaints you have raised, or that have been raised by or concerning third parties (such as your Client) involving you and any issues caused by your use of the Platform.
  • We also keep a log of your activity on our Platform, that we use to improve our service, and to generate reports to Client on the activity on the Platform.

Your Personal Data is disclosed to the Client that has provided the account for you. The Client is responsible for using the collected User data as consented by User in Cultr’s Terms of Use or agreed separately between User and Client, and in accordance with applicable laws.

2.3.3. Request of access, rectification and erasure of Personal Data

If you wish to inquire about your Personal Data, or request access, rectification or erasure of your Personal Data, please contact the admin of the Client which has provided an account for you. Cultr is a Processor, it does not control the Personal Data used or stored, but processes it on behalf of its Client.

2.4 Clients

2.4.1. General

In order to provide services to its Clients, Cultr collects certain types of data from them. Furthermore, Cultr’s Clients collect information from Users when they use the app or platform. This section will describe how these two types of data are collected and used by Cultr as well as geographical differences that effect this policy.

2.4.2 Collection of Client Admin data

During a Client’s registration and later on Cultr’s platform, the Client provide information such as name, company name, email, address, telephone, payment information and other relevant data. This information is used by Cultr to identify the Client and provide them with support, services, mailings, sales and marketing actions, billing and to meet contractual obligations.

Cultr Clients can at any time access and edit, update or delete their contact details by logging in with their username and password to Cultr’s platform. Cultr Client admin users may create more users with different privilege levels within the Client’s account. It is the responsibility of the Cultr Client admin user, to choose the level of access each Client should have. Once these new users log into the Cultr app or platform, they meet the definition of User in this policy. Cultr will not retain Client data longer than is necessary to fulfil the purposes for which it was collected or as required by applicable laws or regulations.

2.4.3 Collection of Users’ Personal data

Campaigns of challenges, missions and quizzes, are created, selected or acquired by Clients who make them available to relevant users. It is the Client’s responsibility to ensure that collection and processing of data is done in accordance with Client’s agreements with its Users and applicable law. Cultr will not process Users’ Personal Data for other purposes than as described in Cultr’s Terms of Use.

Users’ Personal Data includes data that Users uploaded about themselves or about about other users, or provided by the Client to the Cultr platform, or sent to Cultr for entry into the Platform. Users’ Personal Data may include information such as email address, name, title, other personal descriptions. It may also include content provided by users through the use of the app or platform such as pictures, comments, likes, etc. In addition, User’s activity in the platform may be logged.

Cultr collects User Data for the purpose of performing the Platform for the Client, and for improving the service. The Clients’ purpose of collecting Users’ Personal Data will vary on the Client’s objective for using Cultr. Cultr provides its Platform to a wide group of customers and businesses, the purpose may vary greatly. For Clients in the EEA, or for Clients providing campaigns to Users in the EEA, the Client will be the “controller”, as defined in the Directive and the GDPR. The purpose will consequently be defined by Cultr’s Client, and the Client is responsible for informing its Users about its purpose of using the Platform.

2.4.4.1 Processing in the European Economic Area (EEA)

For Clients with accounts located in Cultr’s European Data Region, all processing of Personal Data is performed in accordance with privacy rights and regulations following the EU Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995 (the Directive), and the implementations of the Directive in local legislation. From May 25th, 2018, the Directive and local legislation based on the Directive will be replaced by the Regulations (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, known as the General Data Protection Regulation (GDPR), and Cultr’s processing will take place in accordance with the GDPR.

2.4.4.1.1 Controller

Cultr processes Personal Data both as a Processor and as a Controller, as defined in the Directive and the GDPR:

The Cultr entity which you as a Client entered an agreement with when using Cultr’s platform, will be the Controller for Client data, as outlined above in “Collection of Client Admin data” section. For Users’ Personal data, as outlined in the “Collection of Users’ Personal data” section, the Client will be the Controller in accordance with Directive and GDPR, and Cultr will be the Processor. Cultr adheres to the Directive of 1995 and the GDPR from May 25th, 2018. Consequently, Cultr processes all data provided by its Clients with accounts in its European Data Region, in the European Economic Area (EEA) only.

All data collected by Cultr Clients through the Cultr Platform will be stored exclusively in secure hosting facilities provided by Amazon Web Services. Cultr has a data processing agreement in place with its provider, ensuring compliance with the Directive. All hosting is performed in accordance with standard security regulations. All transfers of data internally in the EEA is done in accordance with this data processing agreement.

3. Retention and deletion

Cultr will not retain data longer than is necessary to fulfil the purposes for which it was collected or as required by applicable laws or regulations. For Users’ Personal Data, Cultr’s Clients have control of the purpose for collecting data, and the duration for which the Users’ Personal data may be kept. For Users’ Personal data, Clients with an active account will therefore have the responsibility to delete data when required. When a Client’s account is terminated or expired, all Users’ Personal data collected through the platform will be anonymized or permantely deleted within 30 days or retained only if required by applicable laws.

If you are a user who wishes to request access, correction or deletion of your Personal Data, please contact the admin of the Client which has provided an account for you.

4. Acceptance of these Conditions

We assume that all Visitors of our website, Users of the Cultr apps and platform and Clients of Cultr’s platform have carefully read this document and agree to its contents. If someone does not agree with this privacy policy, they should refrain from using our websites, apps or platform. We reserve the right to change our privacy policy as necessity dictates. Continued use of Cultr websites, apps or platform after having been informed of any such changes to these conditions have been made implies acceptance of the revised privacy policy. This privacy policy is an integral part of Cultr’s Terms of Use

5. Cultr’s Data Protection Officer

Cultr has a “Data Protection Officer” who is responsible for matters relating to privacy and data protection. This Data Protection Officer can be reached at the following address:

Wellevue S.á. r.l.

Attn: Cultr Data Protection Officer
681 Rue de Neudorf
L-2220 Luxembourg
Luxembourg
dataprotectionofficer@cultr.works