Privacy Policy

Introduction

Kulturely ("we", "our", or "us") respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our website, platform, products, and services (collectively, the "Service").

Please read this Privacy Policy carefully. If you do not agree with the terms of this Privacy Policy, please do not access or use our Service.

1. Information We Collect

We collect several types of information from and about users of our Service, including:

1.1 Personal Data

Personal Data means data about a living individual who can be identified from that data. While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you, including:

• Contact information (such as name, email address, phone number)
• Account credentials (such as username and password)
• Profile information (such as job title, company, industry, preferences)
• Payment information (such as credit card details, billing address)
• Communications (such as questions, feedback, survey responses)

1.2 Usage Data

We automatically collect certain information when you access and use our Service, including:

• Technical data (such as IP address, browser type, device information)
• Navigation data (such as pages visited, time spent on pages, links clicked)
• Interaction data (such as features used, content accessed, searches performed)
• Location data (such as general geographic location based on IP address)
• Log data (such as error reports, performance data, system activity)

1.3 Cookies and Similar Technologies

We use cookies and similar tracking technologies to track activity on our Service and hold certain information. Please see our Cookies Policy for more details.

2. How We Use Your Information

We use the information we collect for various purposes, including to:

• Provide, operate, and maintain our Service
• Create and manage your account
• Process and complete transactions
• Send administrative information, such as updates, security alerts, and support messages
• Respond to your comments, questions, and requests
• Provide customer support and assistance
• Personalize your experience and deliver content relevant to your interests
• Monitor and analyze usage, trends, and activities related to our Service
• Improve our Service, including functionality, performance, and user experience
• Develop new products, services, features, and functionality
• Communicate with you about promotions, events, and other news about products and services
• Protect against, identify, and prevent fraud and other unauthorized or illegal activity
• Comply with legal obligations and enforce our terms and policies
• For any other purpose with your consent

3. Legal Basis for Processing Personal Data

We process your personal data for the purposes described in this Privacy Policy based on the following legal grounds:

• Performance of a Contract: Processing is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into a contract.
• Legitimate Interests: Processing is necessary for our legitimate interests, provided those interests are not overridden by your rights and freedoms.
• Legal Compliance: Processing is necessary for compliance with a legal obligation to which we are subject.
• Consent: You have given us consent to process your personal data for specific purposes.

4. Disclosure of Your Information

We may share your information in the following situations:

4.1 Service Providers

We may share your information with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf and require access to such information to do that work.

4.2 Business Transfers

We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

4.3 Affiliates

We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy.

4.4 Business Partners

We may share your information with our business partners to offer you certain products, services, or promotions.

4.5 With Your Consent

We may disclose your personal information for any other purpose with your consent.

4.6 Legal Requirements

We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena.

4.7 Protection of Rights

We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person, or as evidence in litigation in which we are involved.

5. International Transfers

Our Service is operated in the United States. If you are located outside of the United States, please be aware that information we collect will be transferred to, processed, and stored in the United States. The data protection laws of the United States may differ from those of the country in which you are located.

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, we ensure that transfers of your personal data to countries outside the EEA, United Kingdom, or Switzerland are subject to appropriate safeguards, such as Standard Contractual Clauses approved by the European Commission, or other legally recognized mechanisms that ensure an adequate level of protection.

6. Data Retention

We will retain your personal data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your personal data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

We will also retain usage data for internal analysis purposes. Usage data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods.

7. Data Security

We implement appropriate technical and organizational measures to protect the security of your personal data during transmission and once we receive it. However, no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security.

8. Your Data Protection Rights

Depending on your location and applicable laws, you may have certain rights regarding your personal data:

• Access: You have the right to request copies of your personal data.
• Rectification: You have the right to request that we correct any information you believe is inaccurate or complete information you believe is incomplete.
• Erasure: You have the right to request that we erase your personal data, under certain conditions.
• Restriction of processing: You have the right to request that we restrict the processing of your personal data, under certain conditions.
• Objection to processing: You have the right to object to our processing of your personal data, under certain conditions.
• Data portability: You have the right to request that we transfer the data we have collected to another organization, or directly to you, under certain conditions.
• Withdraw consent: If we rely on your consent to process your personal data, you have the right to withdraw that consent at any time.

If you would like to exercise any of these rights, please contact us using the contact information provided at the end of this Privacy Policy. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights).

9. Children's Privacy

Our Service is not directed to children under the age of 18. We do not knowingly collect personal data from children under 18. If you are a parent or guardian and you are aware that your child has provided us with personal data, please contact us. If we become aware that we have collected personal data from children without verification of parental consent, we take steps to remove that information from our servers.

10. California Privacy Rights

If you are a California resident, you have specific rights regarding your personal information under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA).

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Additionally, you have the right to request that we delete any of your personal information that we collected from you, subject to certain exceptions.

To exercise your rights under the CCPA/CPRA, please submit a verifiable consumer request to us by using the contact information provided at the end of this Privacy Policy.

11. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last Updated" date at the top.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

12. AI and Automated Processing

Kulturely uses artificial intelligence and automated processing to enhance our services. This includes:

• AI-Powered Simulations: We use AI to generate cultural scenario simulations and provide real-time feedback on your responses.
• Personalized Recommendations: We analyze your learning patterns and preferences to provide customized cultural training content.
• Cultural Insights Generation: AI processes cultural dimension data to generate actionable business recommendations.
• Progress Analytics: Automated analysis of your simulation performance and learning progress.

You have the right to object to automated decision-making and profiling. Contact us to request human review of any automated decisions that significantly affect you.

13. Third-Party AI Services

We use third-party AI service providers to power certain features of our platform:

• OpenAI: For content generation and cultural insights analysis
• Anthropic: For AI-powered simulations and role-play scenarios
• Perplexity: For research and fact-checking cultural information

When you interact with AI-powered features, your inputs may be processed by these providers in accordance with their respective privacy policies. We do not share personally identifiable information with AI providers beyond what is necessary to deliver the service.

14. Cultural Assessment Data

When you complete cultural assessments or simulations, we collect and process:

• Your responses to cultural scenarios and questions
• Performance metrics and scores
• Learning progress and completion rates
• Cultural competency assessment results

This data is used to:

• Provide personalized learning recommendations
• Issue certifications and track professional development
• Improve our simulation scenarios and training content
• Generate anonymized, aggregated research insights

You may request deletion of your assessment data at any time, though this may affect your certification status and learning history.

15. Contact Us

If you have any questions about this Privacy Policy, please contact us:

• By email: privacy@kulturely.com
• By mail: Kulturely, Inc., 123 Main Street, Cheyenne, WY 82001, USA

For data protection inquiries from the European Union, you may also contact our EU representative (to be appointed upon EU market launch).