CultureCode appreciates and acknowledges the vital importance of privacy, security and data protection to our clients and to all data subjects that might have their Personal Data (as defined below) processed through our systems. CultureCode does its utmost to provide adequate protections across all of its operations and implement consistent and rigorous policies and procedures.
SCOPE AND AGREEMENT
By design, the provision of our services per se does not demand the direct collection of personal data, but, rather, entails the processing of data, including Personal Data, which is originally collected and provided to CultureCode by its corporate clients. As such, except for the Personal Data which may be collected when You use our website, as further detailed below, CultureCode will only occasionally collect your Personal Data. If and when your Personal Data is collected for purposes not associated to your visiting of our website (e.g. employment enrollment or general job interest data) you will be duly notified and given the opportunity to exercise your rights to have your Personal Data rectified or erased.
THIRD PARTY SERVICES AND APPLICATIONS
DATA COLLECTED AUTOMATICALLY – COOKIES AND IP
Cookies are text files containing small amounts of information which are downloaded to your device, or more technically, to the browser that you use on that device, when you visit a website. The entity that places cookies on your browser can then read the information on that cookie that it set. Cookies are typically classified as either “session cookies” which do not stay on your device after you close your browser or “persistent cookies” which will usually remain on your device until you delete them or they expire.
When you visit our website, we place information on your computer in the form of a cookie, which is recognized automatically the next time you visit us.
Cookies allow us, for example, to adapt our website to meet your interests. If you do not wish us to recognize your computer again later, please set your web browser to delete cookies from your computer, to block all cookies or to warn you before saving a cookie. Note, however, you may not be able to avail of the full scope of our website functions. In this respect, note that CultureCode uses certain cookies which are unrelated to online advertising: (i) account access security cookies; (ii) functional cookies, which preserve the functionality of navigational elements; and (iii) language or regional setting cookies.
HOW WE USE YOUR PERSONAL DATA
(a) conduct our ordinary business operations, including to verifying your identity, completing transactions and orders of our products or services, administering your account, processing payments and conducting business research and analytics;
(b) improve your customer experiences, by maintaining accurate contact and registration data, offering adequate and improved products, services and features that may interest you and enabling you to participate in contests and surveys;
(c) respond to your comments, questions and complaints;
(d) send you service-related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages;
(e) communicate with you and your referrals about promotions, upcoming events, and news about products and services offered by CultureCode and our business partners;
(f) link or combine information about you with other data we get from third parties, to help understand your needs and provide you with better and more personalized service;
(g) enforce our terms and conditions or protect our business, partners or clients; and
(h) protect against, investigate, and deter fraudulent, unauthorized, or illegal activity.
SHARING OR TRANSFERRING PERSONAL DATA
We do not share Personal Data to third parties unless you have previously agreed to this or it is legally permissible for us to do so.
As any other business, CultureCode relies on service providers to manage and support, on our behalf, certain aspects of our business operations. These service providers may be located in a number of global regions and may provide services such as, data hosting, IT and cloud services, debt-collection, fraud management services, customer support and advertising and marketing activities. Our service providers are required by contract to safeguard any Personal Data they receive from us and are prohibited from using the Personal Data for any purpose other than to perform the services as instructed by CultureCode.
We may also share your Personal Data when we believe, in good faith, that we have an obligation to: (i) comply with any law, regulation or court order; (ii) respond to duly authorized information requests of regulators, law enforcement agencies and other public authorities, including in instances associated to natural security threats; (iii) enforce and/or protect the rights and properties of CultureCode, including to investigate fraud and help prevent security threats or other criminal or malicious activity; or (iv) protect the legitimate interests of third parties, including the personal safety of CultureCode employees.
CultureCode may, for strategic or other reasons, decide to sell, buy, merge or otherwise reorganize its businesses. In such instances, it may be the case that we disclose or transfer your Personal Data to prospective or actual purchasers.
ADVERTISING AND MARKETING
You agree that we can collect, process and use your Personal Data for our own advertising or market research purposes and, in particular, to improve the goods and services offered by us. We can collect, collate and use your data, along with that of other members, in anonymized form in order to improve our services, website and advertisements.
CultureCode also allows that certain third parties, such as analytics companies, advertisers and ad networks, automatically collect information about you through our websites, using cookies, web beacons, and device identifiers, including Personal Data about your online activities over time and across different websites, devices, online channels and applications when you use our websites. Among other things, this may allow ours or other targeted advertising to be shown to you when you are visiting other websites, for example advertising relevant to your age group, your location or to products that you have looked at, recommended, bought or sold (this is known as remarketing, retargeting or behavioral advertising). However, if you see advertising of this sort, it does not mean that we have provided the advertising parties with Personal Data such as your name, address and date of birth.
We will only use your email address for those purposes for which you have provided it (e.g. membership-related messages, sending status emails). You will only receive advertising from us via email if you have agreed to do so or where the law otherwise allows.
If you have expressly agreed to the receipt of marketing emails or newsletters (e.g. when you register or during a later log-in), you thereby agree to receive CultureCode communications containing content chosen by us, or emails with advertising, at the email address that you have supplied to us. CultureCode communications may appear at regular or irregular intervals and, in addition to information pertaining to CultureCode, may contain offers from CultureCode business partners or third parties. You can unsubscribe to CultureCode communications at any time at CultureCode.cc or, when available, via a link in the communication in question.
EXCERCISING YOUR RIGHTS
You have the right to have access granted to any Personal Data that you have provided to us or that we keep about you. Moreover, you have the right to withdraw any consent previously granted or to request amendment, correction, anonymization or deletion of your Personal Data and to request clarification about the processing. In certain cases, your request may be denied on a legitimate basis such as where making information available would reveal Personal Data about another data subject or where CultureCode is legally prevented from disclosing such information.
If most use of your Personal Data is based on your consent, this consent can be revoked at any time; the revocation, however, will only apply to future use of the data. You can revoke this consent by an email to hello@CultureCode.cc. Revocation of your consent and consent may mean that certain services are no longer available or will be limited.
CultureCode retains the right to exercise our data activities on a legal basis at any time.
By subscribing to CultureCode Platform or engaging CultureCode for the provision of services, You provide us access to your production, development or test environment, which may include Personal Data about your employees, customers, partners or suppliers (collectively “End Users”).
CROSS BORDER TRANSFERS
CultureCode follows global data security practices designed to ensure that Services Data is appropriately protected.