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.

For the purposes of this Privacy Policy, “You” means, in the case of an individual accepting this Privacy Policy on his or her own behalf, such individual, or in the case of an individual accepting this Privacy Policy on behalf of a company or other legal entity, the company or other legal entity for which You are accepting this Privacy Policy, and Affiliates of that company or legal entity.

You are deemed to have accepted this Privacy Policy whenever You navigate our website, subscribe to and/or use CultureCode Platform, whether it is a trial or beta version thereof, and enter into the Platform Subscription Agreement, as applicable.

This Privacy Policy informs you of our privacy practices and of the choices you can make about the way we collect and use information about you, including information that may be collected from your online activity and which may be processed as a consequence of our services.

For the purposes of this Privacy Policy, personal data (“Personal Data”) means any information relating to an identified or identifiable natural person (you); whenever you can be identified, directly or indirectly, in particular by reference to an identifier such as your name, an identification number, location data, an online identifier or to one or more factors specific to your identity.

This Privacy Policy describes the collection and use of Personal Data when you visit and use the services offered by CultureCode. By agreeing to this Privacy Policy, you declare and agree that CultureCode may use your Personal Data accordingly.

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.
Moreover, this policy does not apply to Personal Data to which we may have access in order to provide services to you (“Services Data”), which is detailed in our Services Privacy Policy below.

This Privacy Policy does not apply to third-party applications, products, services, websites or social media features that may be accessed through links we provide for your convenience and information. Accessing those links will cause you to leave our environment and may result in the collection or sharing of information about you by a third-party. We do not control, endorse or make any representations about those third-party websites or their privacy practices, which may differ from ours. We encourage you to review the privacy policy of any website you interact with before allowing the collection and use of your Personal Data.

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.

CultureCode may also track IP addresses for purposes of system administration, to report aggregate information, site tracking, to prevent our servers from being abused and for other uses described in this Privacy Policy.

We use your Personal Data for the purposes described in this Privacy Policy and to manage our relationship with you and provide you with better services, including by personalizing your interaction and experience with us. For example, we may use your information to:

(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.

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.

We may transfer Personal Data to other CultureCode entities. To ensure that your Personal Data is secure, CultureCode entities are contractually bound to comply with this Privacy Policy and our internal privacy guidelines. Those, in turn, are communicated regularly to our employees, as part of our specific compliance program. By accessing this website you consent to the transfer and sharing of your Personal Data among CultureCode entities.

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.

We may also share your Personal Data with: (i) credit reference and fraud prevention agencies; (ii) debt collection agencies (for outstanding debts with us); (iii) other third parties, such as our business partners, with the appropriate notice and consent. If you choose to provide Personal Data to these other companies, that Personal Data will be handled according to the privacy policy of those companies, which may differ from CultureCode policies and practices

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 or, when available, via a link in the communication in question.

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.

As technology and our services advance, we will also adapt our Privacy Policy. When this happens, we will post the revised statement here, with an updated revision date. If necessary, ask you for a fresh agreement. All the same, you should view this page on a regular basis in order to find out about the current status of our Privacy Policy.

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 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.

If you have any questions or concerns about this Privacy Policy, our collection and use practices or regarding a possible data or privacy breach you can contact us via e-mail to


This CultureCode Services Privacy Policy (“Services Privacy Policy”) is an addendum to our Privacy Policy and is offered to You in order to clarify that the use of information to which we may be provided access in order to provide services to our clients, including Personal Data, is more limited than set forth in the Privacy Policy.

For the purposes of this Services Privacy Policy, “You” means, in the case of an individual accepting this Services Privacy Policy on his or her own behalf, such individual, or in the case of an individual accepting this Services Privacy Policy on behalf of a company or other legal entity, the company or other legal entity for which You are accepting this Services Privacy Policy, and Affiliates of that company or legal entity.

You are deemed to have accepted this Services Privacy Policy whenever You navigate our website, subscribe to and/or use CultureCode Platform, whether it is a trial or beta version thereof, and enter into the Platform Subscription Agreement, as applicable.

We may collect information from your use of CultureCode websites and your interactions with us offline (“Your Data”). We deal with Your Data according to the terms of the Privacy Policy.

Conversely, the data that resides on CultureCode Platform, Your or third-party systems, and to which CultureCode is provided access specifically to enable it to perform services (“Services Data”) is treated according to the terms of this Services Privacy Policy, and as confidential data in accordance with the terms of the Platform Subscription Agreement.

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”).

CultureCode follows global data security practices designed to ensure that Services Data is appropriately protected.
Please note that Services Data may be transferred, accessed and stored globally as necessary in accordance with this Services Privacy Policy and the Platform Subscription Agreement.

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