Privacy Policy

Updated on: 1st July 2019.
Effective Date: 1st July 2019.

Culturro’s Privacy Commitment

Culturro cares about customer and user privacy with utmost seriousness. We ask for only the least amount of information necessary, gathering only what we believe is essential for doing business, or for the specific transaction at hand. The goal of this policy is to make explicit the information we gather on our customers and users, how we will use it, and how we will not.

Scope of this Privacy Policy

This Privacy Policy applies to all Culturro websites that link to it. It also applies to the products and services provided by Culturro through these websites and applications posted by Culturro on Culturro’s online marketplace and in other third-party online marketplaces. This Privacy Policy does not apply to any of our websites, products or services that have a separate privacy policy.

Part I – Information Culturro collects and controls

What information Culturro collects

We collect information about you only if we need the information for some legitimate purpose. Culturro will have information about you only if

  1. you have provided the information yourself,
  2. Culturro has automatically collected the information, or
  3. Culturro has obtained the information from a third party.

Below we describe the various scenarios that fall under each of those three categories and the information collected in each one.
Information that you provide us

  1. When you sign up for an account to access one or more of our services, we ask for information like your name, contact number, email address, company name and country to complete the account signup process. Your username would be your corporate email address and you’ll also be required to choose a unique password for accessing the created account. You may also provide us with more information such as your photo, time zone and language, but we don’t require that information to sign up for an account.
  2. We record information that you submit when you
    1. register for any event, including webinars or seminars,
    2. subscribe to our newsletter or any other mailing list,
    3. submit a form in order to download any product, whitepaper, or other materials,
    4. participate in contests or respond to surveys, or
    5. submit a form to request customer support or to contact Culturro for any other purpose.
  3. When you buy something from us, we ask you to provide your name, contact information, and payment account information. We also ask you for corporate information as required by tax laws prevalent in India.
  4. When you authorize us to post testimonials about our products and services on websites, we may include your name and other personal information in the testimonial. You will be given an opportunity to review and approve the testimonial before we post it. If you wish to update or delete your testimonial, you can contact us at agnya@culturro.com.
  5. We may record, analyze and use your interactions with us, including email, telephone, and chat conversations with our sales and customer support professionals, for improving our interactions with you and other customers.

Information that we collect automatically

  1. When you visit our websites, we collect information that web browsers, mobile devices and servers make available, such as the internet protocol address, browser type, language preference, time zone, referring URL, date and time of access, operating system, mobile device manufacturer and mobile network information. We may include these in our log files to understand more about visitors to our websites.
  2. We may use temporary and permanent cookies to identify users of our services and to enhance user experience. We may embed unique identifiers in our downloadable products to track usage of the products. We may also use cookies, beacons, tags, scripts, and other similar technologies to identify visitors, track website navigation, gather demographic information about visitors and users, understand email campaign effectiveness and for targeted visitor and user engagement by tracking your activities on our websites.
  3. We collect information about your use of our products, services and mobile applications from application logs and in-house usage analytics tools, and use it to understand how your business use and needs can improve our products. This information may includes clicks, scrolls, features accessed, access time and frequency, errors generated, performance data, storage utilized, user settings and configurations, and devices used to access and their locations.

Information that we collect from third parties

  1. If you log in to Culturro Services using supported federated authentication service providers such as LinkedIn, Microsoft and Google. These services will authenticate your identity and give you the option to share certain personal information with us, such as your name and email address.
  2. If someone has referred any of our products or services to you through any of our referral programs, that person may have provided us your name, email address and other personal information. You may contact us at agnya@culturro.com to request that we remove your information from our database. If you provide us information about another person, or if another person gives us your information, we will only use that information for the specific reason for which it was provided to us.
  3. If you contact any of our reselling partners, or otherwise express interest in any of our products or services to them, the reselling partner may pass your name, email address, company name and other information to Culturro. If you register for or attend an event that is sponsored by Culturro, the event organizer may share your information with us. Culturro may also receive information about you from review sites if you comment on any review of our products and services, and from other third-party service providers that we engage for marketing our products and services.
  4. When you interact or engage with us on social media sites such as LinkedIn, Facebook, Twitter, Google+ and Instagram through posts, comments, questions and other interactions, we may collect such publicly available information, including profile information, to allow us to connect with you, improve our products, or better understand user reactions and issues. We must tell you that once collected, this information may remain with us even if you delete it from the social media sites. Culturro may also add and update information about you, from other publicly available sources.

Purposes for using information
In addition to the purposes mentioned above, we may use your information for the following purposes:

  • To communicate with you (such as through email) about products that you have downloaded and services that you have signed up for, changes to this Privacy Policy, changes to the Terms of Service, or important notices;
  • To keep you posted on new products and services, upcoming events, offers, promotions and other information that we think will be of interest to you;
  • To ask you to participate in surveys, or to solicit feedback on our products and services;
  • To set up and maintain your account, and to do all other things required for providing our services, such as enabling collaboration, providing website and mail hosting, and backing up and restoring your data;
  • To understand how users use our products and services, to monitor and prevent problems, and to improve our products and services;
  • To provide customer support, and to analyze and improve our interactions with customers;
  • To detect and prevent fraudulent transactions and other illegal activities, to report spam, and to protect the rights and interests of Culturro, Culturro’s users, third parties and the public;
  • To update, expand and analyze our records, identify new customers, and provide products and services that may be of interest to you;
  • To analyze trends, administer our websites, and track visitor navigations on our websites to understand what visitors are looking for and to better help them;
  • To monitor and improve marketing campaigns and make suggestions relevant to the user.

Legal bases for collecting and using information
If you are an individual from the European Economic Area (EEA), our legal basis for information collection and use depends on the personal information concerned and the context in which we collect it. Most of our information collection and processing activities are typically based on

  1. contractual necessity,
  2. one or more legitimate interests of Culturro or a third party that are not overridden by your data protection interests, or
  3. your consent.

Sometimes, we may be legally required to collect your information, or may need your personal information to protect your vital interests or those of another person.

Withdrawal of consent:   Where we rely on your consent as the legal basis, you have the right to withdraw your consent at any time, but this will not affect any processing that has already taken place. Legitimate interests notice:   Where we rely on legitimate interests as the legal basis and those legitimate interests are not specified above, we will clearly explain to you what those legitimate interests are at the time that we collect your information.Your choice in information use

You may opt out of receiving newsletters and other non-essential messages by using the ‘unsubscribe’ function included in all such messages. However, you will continue to receive notices and essential transactional emails.
You can disable browser cookies before visiting our websites. However, if you do so, you may not be able to use certain features of the websites properly.
You can choose not to provide optional profile information such as your photo. You can also delete or change your optional profile information. You can always choose not to fill in non-mandatory fields when you submit any form linked to our websites.Who we share your information with

Culturro has access to the information covered above. We do not sell any personal information. We share your information only in the ways that are described in this Privacy Policy, and only with parties who adopt appropriate confidentiality and security measures.

  • Employees and independent contractors of Culturro have access to the information covered above on a need-to-know basis. We require all employees and independent contractors of Culturro group entities to follow this Privacy Policy for personal information that we share with them.
  • We may need to share your personal information and aggregated or de-identified information with third-party service providers that we engage, such as marketing and advertising partners, event organizers, web analytics providers and payment processors. These service providers are authorized to use your personal information only as necessary to provide these services to us.
  • We may share your personal information with our authorized reselling partners in your region, solely for the purpose of contacting you about products that you have downloaded or services that you have signed up for. We will give you an option to opt-out of continuing to work with that partner.

Your rights with respect to information we hold about you as a controller

If you are in the European Economic Area (EEA), you have the following rights with respect to information that Culturro holds about you.

  • You have the right to access (and obtain a copy of, if required) the categories of personal information that we hold about you, including the information’s source, purpose and period of processing, and the persons to whom the information is shared.
  • You have the right to update the information we hold about you or to rectify any inaccuracies. Based on the purpose for which we use your information, you can instruct us to add supplemental information about you in our database.
  • You have the right to request that we delete your personal information in certain circumstances, such as when it is no longer necessary for the purpose for which it was originally collected.
  • You may also have the right to request to restrict the use of your information in certain circumstances, such as when you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. In case the data has already been processed, such processing cannot be undone.
  • You have the right to transfer your information to a third party in a structured, commonly used and machine-readable format, in circumstances where the information is processed with your consent or by automated means.
  • You have the right to object to the use of your information in certain circumstances, such as the use of your personal information for direct marketing.
  • You have the right to complain to the appropriate supervisory authority if you have any grievance against the way we collect, use or share your information. This right may not be available to you if there is no supervisory authority dealing with data protection in your country.

Retention of information

We retain your personal information for as long as it is required for the purposes stated in this Privacy Policy. Sometimes, we may retain your information for longer periods as permitted or required by law, such as to maintain suppression lists, prevent abuse, if required in connection with a legal claim or proceeding, to enforce our agreements, for tax, accounting, or to comply with other legal obligations. When we no longer have a legitimate need to process your information, we will delete or anonymize your information from our active databases. We will also securely store the information and isolate it from further processing on backup discs until deletion is possible.

Part II – Information that Culturro processes on your behalf

Information entrusted to Culturro and purpose

You may entrust information that you or your organization (“you”) control, to Culturro in connection with use of our services or for requesting technical support for our products. This includes information regarding your employees (if you are a controller) or data that you hold and use on behalf of another person for a specific purpose. The service data is also generated on the system when you conduct assessments through our platform. The service data is also generated and stored when you use our integrations on third party platforms (such as Slack, Gsuite etc). All the information entrusted to Culturro is collectively termed “service data”. The data may either be stored on our servers when you use our services, or transferred or shared to us as part of a request for technical support or other services. Our servers may be located in any geographic location in the world depending on our cloud service provider such as Google, Amazon, Heroku.

Ownership and control of your service data
We recognize that you own your service data. We provide you complete control of your service data by providing you the ability to

  1. access your service data,
  2. share your service data through supported third-party integrations, and
  3. request export of your service data.

How we use service data
We process your service data when you provide us instructions through the various modules of our services. For example, when you conduct a Workplace Experience assessment, you generate employee opinions, culture scores, insights, recommendations. This data might be used by you or by Culturro representatives to provide recommendations on culture interventions, in case you avail our services.

Push notifications
If you have enabled notification on our desktop and mobile applications, we will push notifications through a push notification provider such as Apple Push Notification Service, Google Cloud Messaging or Windows Push Notification Services. You can manage your push notification preferences or deactivate these notifications by turning off notifications in the application or device settings. Also, certain integrations such as Slack, Gsuite, Google Hangouts, Skype for Business or similar integrations might generate push notifications on the messages you receive from our platform.

Who we share service data with
In order to provide services and technical support for our products, the information is shared with Culturro representatives. In certain cases, information may be shared with third party partners in order to process data and provide services.
Employees and independent contractors :   We may provide access to your service data to our employees and individuals who are independent contractors of Culturro involved in providing the services (collectively our “employees”) so that they can

  1. identify, analyze and resolve errors,
  2. assess data and provide recommendations
  3. work with respective individuals on behaviour modification, in case you have availed these services.

We ensure that access by our employees to your service data is restricted to specific individuals, and is logged and audited. Our employees will also have access to data that you knowingly share with us for technical support or to import data into our products or services. We communicate our privacy and security guidelines to our employees and strictly enforce privacy safeguards within Culturro.
Third-party integrations you have enabled : Most of our products and services support integrations with third-party products and services. If you choose to enable any third-party integrations, you may be allowing the third party to access your service information and personal information about you. We encourage you to review the privacy practices of the third-party services and products before you enable integrations with them.
Retention of information
We hold the data in your account as long as you choose to use Culturro Services. Once you terminate your Culturro user account, your data may be deleted from active database during the clean-up process. Post that the data may be retained anonymously if it is necessary for Culturro’s products to keep running and functioning properly for other customers. Also, some data may have been processed to improve our products and services. Such processing can not be undone in any case.

Part III – General

How secure is your information

At Culturro, we take data security very seriously. If you have any concerns regarding the security of your data, we encourage you to write to us at agnya@culturro.com with any questions.

Locations and international transfers

We share your personal information and service data within Culturro. By accessing or using our products and services or otherwise providing personal information or service data to us, you consent to the processing, transfer, and storage of your personal information or Service Data within the United States of America, the European Economic Area (EEA) and other countries where Culturro operates.

External links on our websites

Some pages of our websites may contain links to websites that are not linked to this Privacy Policy. If you submit your personal information to any of these third-party sites, your personal information is governed by their privacy policies. As a safety measure, we recommend that you not share any personal information with these third parties unless you’ve checked their privacy policies and assured yourself of their privacy practices.

Blogs and forums

We offer publicly accessible blogs and forums on our websites. Please be aware that any information you provide on these blogs and forums may be used to contact you with unsolicited messages. We urge you to be cautious in disclosing personal information in our blogs and forums. Culturro is not responsible for the personal information you elect to disclose publicly. Your posts and certain profile information may remain even after you terminate your account with Culturro. To request the removal of your information from our blogs and forums, you can contact us at agnya@culturro.com

Social media widgets

Our websites include social media widgets such as LinkedIn “share” buttons and Twitter “tweet” buttons that let you share articles and other information. These widgets may collect information such as your IP address and the pages you navigate in the website, and may set a cookie to enable the widgets to function properly. Your interactions with these widgets are governed by the privacy policies of the companies providing them. Disclosures in compliance with legal obligations.
We may be required by law to preserve or disclose your personal information and service data to comply with any applicable law, regulation, legal process or governmental request, including to meet national security requirements.

Enforcement of our rights

We may disclose personal information and service data to a third party if we believe that such disclosure is necessary for preventing fraud, investigating any suspected illegal activity, enforcing our agreements or policies, or protecting the safety of our users.

Business Transfers

We do not intend to sell our business. However, in the unlikely event that we sell our business or get acquired or merged, we will ensure that the acquiring entity is legally bound to honor our commitments to you. We will notify you via email or through a prominent notice on our website of any change in ownership or in the uses of your personal information and service data. We will also notify you about any choices you may have regarding your personal information and service data.

Compliance with this Privacy Policy

We make every effort, including periodic reviews, to ensure that personal information you provide is used in conformity with this Privacy Policy. If you have any concerns about our adherence to this Privacy Policy or the manner in which your personal information is used, kindly write to us agnya@culturro.com We’ll contact you, and if required, coordinate with the appropriate regulatory authorities to effectively address your concerns.

Notification of changes

We may modify the Privacy Policy at any time, upon notifying you through a service announcement or by sending an email to your primary email address. If we make significant changes to the Privacy Policy that affect your rights, you will be provided with at least 30 days’ advance notice of the changes by email to your primary email address. If you think that the updated Privacy Policy affects your rights with respect to your use of our products or services, you may terminate your use by sending us an email within 30 days. Your continued use after the effective date of changes to the Privacy Policy will be deemed to be your agreement to the modified Privacy Policy. You will not receive email notification of minor changes to the Privacy Policy. If you are concerned about how your personal information is used, you should check back the Privacy Policy periodically.