Notice to Organizations Using Cultivate’s On-Premise, Virtual Private Cloud Integration: Your email, chat, and calendar content remains on servers or systems controlled by you. At no time will any such data leave your control, unless as directed by you.

Cultivate Privacy Policy

Modified: November 18, 2020

Cultivate Technology Inc. (“Cultivate”, “we”, “our”, or “us”) offers leadership and coaching tools available online (the “Service”), and websites or online extensions, including but not limited to www.cultivate.com (the “Websites”). This Privacy Policy (the “Policy”) describes how Cultivate collects, uses, and discloses the personal data (or “personal information”) collected/generated through the Service, Websites, or other ways, and what choices you have with respect to such information.

Our path together will require communication, sharing, and mutual trust. Consider this Policy the first promise to pass between us, a pledge to protect the knowledge you have and the information you share.

By accessing or using the Service and Websites, you acknowledge and agree that you have read, understand, and agree to be bound by this Policy. If you do not agree with this Policy, do not access or use the Service, Websites, or any other part of Cultivate’s business.

  1. Which Privacy Terms are Applicable to Me?
  2. Privacy Terms for End Users
  3. Privacy Terms for Website Visitors
  4. Privacy Terms for Other Individuals
  5. Additional Privacy Terms for All Individuals
  6. Privacy Information for Individuals in the EU
  7. Privacy Information for California Residents
  8. Talk to Us

1. Which Privacy Terms Are Applicable to Me?
Cultivate collects information about different types of individuals. Please see the following definitions to determine which type of individual you are. One or all of the privacy terms may be applicable.

End Users. These are individuals who use the Service as part of a paid Cultivate subscription plan.
Website Visitors. These are individuals who use the Websites.
Other Individuals. These are individuals about whom we collect personal data, but are not necessarily End Users or Website Visitors.

2. Privacy Terms for End Users
If you are an End User, the specific terms agreed to between Cultivate and the organization (e.g., your employer or another entity or person, called the “Customer”) that entered into a separate agreement (“Customer Agreement”), governs the collection and processing of information collected from you through the Customer’s instance of the Service (“Account”).  Because the Customer controls the Account used by End Users, if you have any questions about the Customer’s specific Account settings and privacy practices, please contact the Customer whose Account you use.

2.1. Collection/Generation of End User Information

This section explains the information we collect/generate from End Users. We do not require End Users to provide us with information. However, certain information is required to provide you with access to the Service (such as Account Information or authentication information), and other information may be collected automatically as you use the Service.

Account Content. All email and chat messages, and calendar data and other content submitted through the Service is collected, used, and shared by Cultivate in accordance with the Customer’s instructions, including any applicable terms in the Customer Agreement, or as required by applicable law. The Customer, and not Cultivate, determines its own internal policies regarding storage, access, modification, deletion, sharing, and retention of Account Content which may apply to your use of the Service. For example, a Customer may provide or remove access to the Service or enable or disable third party integrations. Please check with the Customer about their policies and settings with respect to the Account Content that is collected when using the Service.

Account Information. To set up your Cultivate account, the Customer will provide us with basic information about you which may include your name, email address, zip code, department, gender and other information.

Service Usage Information. As you access the Service, we collect information about how you use and interact with the Service. Such information includes:

Device information – the type of device you are using, its operating system, device ID and other unique device identifiers.

Log files – web request, browser type and settings, referring/exit pages and URLs, number of clicks, date and time stamp information, language preferences, data from cookies and similar technologies, and other such information.

Metadata – high-level information about the way you work in your Account. For example, we may log the features and embedded Service content you interact with; and what, if any, third party services and integrations you use.

Location information – general information about the location of the device from which you are accessing the Service.

Additional Information. You may provide us with information when you interact with us in other ways, such as when you submit requests or questions to us via forms or embedded chat windows; information you provide in connection with Cultivate research studies in which you choose to participate; and requests for customer support and technical assistance.

Information Collected from Third-Party Integrations. If you choose to use or connect to third-party integrations (e.g., Slack) through the Service, or if you are required or permitted to do so by a Customer, such third parties may allow us to have access to and store additional information about your interaction with those services as it relates to your use of the Service. If you initiate these connections, you also understand that we will share information about you that is required to enable your use of the third-party integration through the Service. If you do not wish to have this information shared, do not initiate these connections. By enabling these connections, you authorize us to connect and access the information provided through these connections, and you understand that the privacy policies of these third parties govern such connections.

Metrics. This is the personalized leadership and coaching metrics generated using Account Content and Service Usage Information.

2.2. How Does Cultivate Use End User Information?

Cultivate may use information collected/generated from and about End Users only as necessary:

  • To provide, maintain, and improve the Service.
  • For internal training and quality control purposes.
  • To protect the Service and our users, and prevent or address technical or security issues.
  • To resolve support requests.
  • To investigate good faith alleged violations of the Customer Agreement or our Terms of Service.
  • In accordance with applicable legal obligations, or to comply with a valid legal subpoena, request, or other lawful process.
  • As otherwise set forth in our Customer Agreement or as expressly permitted by the Customer.

Additionally, Account Information, Service Usage Information, Information from Third Party Integrations, and Additional Information may be also used only as necessary:

  • To help us better understand user interests and needs, and customize the Service for our users.
  • To engage in analysis, research, and reports regarding use of the Service
  • To respond to your requests for information.
  • To communicate with you about important notices and updates regarding the Service, such as to inform you about changes in the Service, our service offerings, or security and fraud issues. You may not opt out of these important Service-related notices and updates.
  • To communicate with you about promotions, offers, and news about Cultivate. You may unsubscribe from promotional communications.

2.3. Sharing of End User Information

We may share the information we collect/generate from End Users as follows:

Customer Agreement. We may share the information in accordance with the Customer Agreement.

Service Providers. We may provide access to or share your information with third parties that use the information only to perform services on our behalf, such as sales, marketing, communications, customer support, technical development/admin, provision of content and features, project management, integration, research, analytics, data storage, data processing, security, fraud prevention, and other services.

Business Transactions. If Cultivate is involved in a merger, acquisition, dissolution, sale of all or a portion of its assets, or other fundamental corporate transaction, or if the ownership of all or substantially all of our business changes, we may transfer your information to the new owner so that the Service can continue to operate. In such case, your information would remain subject to the promises and commitments contained in this Policy until such time as this Policy is updated or amended by the acquiring party upon notice to you. If such transfer is subject to additional mandatory restrictions under applicable laws, Cultivate will comply with such restrictions.

Applicable Law. We may share the information when we believe in good faith that release is necessary to comply with applicable laws, rules or regulations (including any applicable laws, rules or regulations outside your country or state of residence).

Please note that while Cultivate does not proactively display your Metrics to your employer (or another entity or person, called the “Customer”), theoretically, it may be viewable by others within your organization, for example, if your employer takes control of your login credentials.

2.4. Data Subject Rights

Contact your Account owner(s) or administrator(s) to exercise any data subject rights you have under applicable local laws, including your ability to access, delete, rectify, transfer, or object under the GDPR. Alternatively, clicking the “Delete Account” button located in your account’s settings will delete your “Account Content” and “Metrics.”

2.5. Is Cultivate a controller or processor of End User Information?

Pursuant to the EU General Data Protection Regulation (“GDPR”), if you are an End User located in the European Union, the Customer is the data controller with respect to the processing of your Account Content, Account Information, Additional Information, Information Collected from Third-Party Integrations, and Metrics, and Cultivate is the data processor, meaning that we collect and process such information solely on behalf of the Customer. In general, Cultivate is the data controller of Service Usage Information and other information.

2.6. Legal Bases

Pursuant to the GDPR, if you are an End User located in the European Union, we rely on the following legal bases for using the Service Usage Information and other information we collect through your use of the Service:

Legitimate Interests. Where use of your information is necessary for our legitimate interests or the legitimate interests of others, as described in the “How Does Cultivate Use End User Information” section.

Legal Obligation. Where use of your information is necessary to comply with a legal obligation.

3. Privacy Terms for Website Visitors

If you visit the Websites, regardless of whether you are also a user of the Service, the following rules apply to you.

3.1. Collection of Website Visitor Information

When you use the Websites, we collect the following information about you:

Website Usage Information. As you browse the Websites, we collect information about how you use and interact with the Websites. Such information includes:

Device information – the type of device you are using, its operating system, device ID and other unique device identifiers.

Log files – web request, IP address, browser type and settings, referring/exit pages and URLs, number of clicks, date and time stamp information, language preferences, data from cookies and similar technologies, and other such information.

Metadata – high-level information about the way you use the Websites. For example, we may log the features links you interact with.

Location Information – We collect and process general information about the location of the device from which you are accessing the Websites (e.g., country level or geographic location inferred from an IP address).

Contact Information. If you submit a request for information or a question through the Websites, you may be asked to provide us with basic information including your name, email address, address, phone number, and job information. We will also keep records of the communication, the question/request you raised, and how it was resolved. If you choose to participate in a Cultivate research study offered through the Websites, we will also collect basic contact information from you in connection with such activity.

3.2. Cookies and Similar Technologies

To collect the Website Usage Information discussed above, we and our service providers use cookies, server logs, tags, SDKs, tracking pixels, and other similar tracking technologies. A cookie is a small text file that is placed on your computer or mobile device when you visit a site, that enables us to: (i) recognize your computer and login session; (ii) store your preferences and settings; (iii) understand which pages of the Websites you have visited; (iv), enhance your user experience by delivering and measuring the effectiveness of content and advertising tailored to your interests; (v) perform analytics; and (vi) assist with security and administrative functions. A web server log is a file where website activity is stored. An SDK is a section of code that we embed in our applications and software to allow third parties to collect information about how users interact with the Websites. Tracking pixels (sometimes referred to as web beacons or clear GIFs) are tiny electronic tags with a unique identifier embedded in websites, online ads and/or email, and that are designed to provide usage information like ad impressions or clicks, email open rates, measure popularity of the Websites and associated advertising, and to access user cookies. As we adopt additional technologies, we may also gather information through other methods. Please note that you can change your settings to notify you when a cookie is being set or updated, or to limit and even block cookies. Please consult the “Help” section of your browser for more information (e.g., Internet Explorer; Google Chrome; Mozilla Firefox; or Apple Safari). Please note that doing so may limit your use of certain features or functions on our Website and Service. You can also change or withdraw your cookie consent here.

3.3. How Does Cultivate Use Website Visitors Information

3.3.1. We use the information collected from Website Visitors for a variety of purposes including:

  • To provide, maintain, and improve the Websites.
  • For internal training and quality control purposes.
  • To protect the Website and our users, and prevent or address technical or security issues.
  • To investigate in good faith alleged violations of our Terms of Service.
  • In accordance with applicable legal obligations, or to comply with a valid legal subpoena, request, or other lawful process.
  • To help us better understand Website Visitor interests and needs, and customize the advertising and content you see on the Websites.
  • To engage in analysis and research regarding use of the Websites.
  • As otherwise set forth in our Terms of Service or as expressly permitted by you.

3.3.2. Additionally, Contact Information may also be used only as necessary:

  • To respond to your requests for information.
  • To communicate with you about important notices and updates regarding the Website, such as to inform you about changes in the Website, or security and fraud issues. You may not opt out of these important Website-related notices and updates.
  • To communicate with you about promotions, offers, and news about Cultivate. You have the ability to unsubscribe from such promotional communications.
  • For administrative purposes, such as billing, account administration, account integration, or other similar/related purposes.

Imported Contacts or Google User Data. If you provide us with access to your contacts, you acknowledge and agree that we may use such information as part of the service, as described in this Policy, and you confirm that you have the rights and permissions to provide such access to your contacts. Similarly, when you provide us with permissions and access to your Google account, we may access and use your contacts for the purpose of the service. At any time, you may decide to opt-out from enabling us to access your contacts by sending such requests to privacy@cultivate.com.

3.4. Website Analytics and Advertising

Website Analytics. We may use third-party web analytics services on our Websites to collect and analyze usage information through cookies and similar tools; engage in auditing, research, or reporting; and provide certain features to you. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here.

Online Advertising. The Websites may integrate third-party advertising technologies that allow for the delivery of relevant content and advertising on other websites you visit. The ads may be based on various factors such as the content of the page you are visiting, information you enter such as your age and gender, your searches, demographic data, and other information. These ads may be based on your current activity or your activity over time and across other websites and online services and may be tailored to your interests.

Third parties, whose products or services are accessible via the Websites, may also place cookies or other tracking technologies on your computer, mobile phone, or other device to collect information about you as discussed above.

We neither have access to, nor does this Policy govern, the use of cookies or other tracking technologies that may be placed on your device you use to access the Websites, by non-affiliated third parties. For more information about tailored browser advertising and how you can generally control cookies from being put on your computer to deliver tailored advertising, you may visit the Network Advertising Initiative’s Consumer Opt-Out link, the Digital Advertising Alliance’s Consumer Opt-Out link, or Your Online Choices (if you are located in the EU, Switzerland, or the UK) to opt-out of receiving tailored advertising from companies that participate in those programs. To opt out of Google Analytics for display advertising or customize Google display network ads, visit the Google Ads Settings page. We do not control these opt-out links or whether any particular company chooses to participate in these opt-out programs. We are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms.

Please note that if you exercise the opt-out choices above, you will still see advertising on websites, but it will not be tailored to you based on your online behavior over time.

Notice Concerning Do Not Track. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We are committed to providing you with meaningful choices about the information collected on our Websites for third party purposes, and that is why we provide the variety of opt-out mechanisms listed above. However, we do not currently recognize or respond to browser-initiated DNT signals. To learn more about Do Not Track, you can do so here.

3.5. Sharing of Website Visitor Information

We share the information we collect through the Websites with the following:

Terms of Service. We may share the information in accordance with the Terms of Service.

Service Providers. We may provide access to or share your information with third parties that use the information only to perform services on our behalf such as sales, marketing, communications, customer support, technical development/admin, provision of content and features, project management, integration, advertising, analytics, research, data storage, data processing, security, fraud prevention, and other services.

Business Transactions. If Cultivate is involved in a merger, acquisition, dissolution, sale of all or a portion of its assets, or other fundamental corporate transaction, or if the ownership of all or substantially all of our business changes, we may transfer your information to the new owner so that the Websites can continue to operate. In such case, your information would remain subject to the promises and commitments contained in this Policy until such time as this Policy is updated or amended by the acquiring party upon notice to you. If such transfer is subject to additional mandatory restrictions under applicable laws, Cultivate will comply with such restrictions.

Applicable Law. We may share the information when we believe in good faith that release is necessary to comply with applicable laws, rules or regulations (including any applicable laws, rules or regulations outside your country or state of residence).

Consent. We may also disclose your information to third parties with your consent to do so.

3.6. Third Party Links And Services

The Websites may contain links to third-party websites and functionalities. If you choose to use these third party services, you may disclose your information not just to those third-parties, but also to their users and the public more generally depending on how their services function. Because these third-party websites and services are not operated by Cultivate, Cultivate is not responsible for the content or practices of those websites or services. The collection, use, and disclosure of your information will be subject to the privacy policies of the third party websites or services, and not this Policy.

3.7. Is Cultivate a controller or processor of Website Visitor Information

Pursuant to the GDPR, if you are a Website Visitor located in the European Union, Cultivate is the data controller of Website Visitor information.

3.8. Legal Bases

Pursuant to the GDPR, if you are a Website Visitor located in the European Union, we rely on the following legal bases for using the Website Visitor Information and other information we collect through your use of the Website:

Legitimate Interests. Where use of your information is necessary for our legitimate interests or the legitimate interests of others as described in the “How Does Cultivate Use Website Visitors Information” section.

Legal Obligation. Where use of your information is necessary to comply with a legal obligation

Consent. Where we have your consent to process data in a certain way. When we process your personal data based on your consent (i.e. for direct marketing purposes or otherwise), you have the right to withdraw your consent at any time by contacting us. However, this will not affect the lawfulness of the processing based on such consent before your consent was withdrawn.

Contract. Where use of your information is necessary to perform our obligations under a contract with you (for example, to comply with the Terms of Service which you accept by browsing the Websites)

4. Privacy Terms for Other Individuals

Regardless of whether or not you are a Website Visitor or End User, the following terms apply to you if we have collected your personal data, for example from referrals or lead generation, or if someone has provided us with access to their contacts.

4.1. Collection of Information about Other Individuals

We may collect the following information about you:

Contact Information. This is basic information including your name, email address, phone number, postal address and job details.

Biometric Information. We may record some marketing and sales calls, and will obtain appropriate consents where required.

4.2. How Does Cultivate Use Information about Other Individuals?

Contact Information may be used only as necessary:

  • To provide, maintain, and improve the applicable Cultivate service.
  • For internal training and quality control purposes.
  • To protect the applicable Cultivate service and other individuals, and prevent or address technical or security issues.
  • To investigate in good faith alleged violations of our Terms of Service.
  • In accordance with applicable legal obligations, or to comply with a valid legal subpoena, request, or other lawful process.
  • As otherwise set forth in our Terms of Service or as expressly permitted by you.
  • To communicate with you about important notices and updates regarding the applicable Cultivate service, such as to inform you about changes in the applicable Cultivate service, or security and fraud issues. You may not opt out of these important service-related notices and updates.
  • To communicate with you about promotions, offers, and news about Cultivate. You have the ability to unsubscribe from such promotional communications.
  • For administrative purposes, such as billing, account administration, account integration, or other similar/related purposes.

4.3. Sharing of Information about Other Individuals

We share the information we collect about Other Individuals with the following:

Terms of Service. We may share the information in accordance with the Terms of Service.

Service Providers. We may provide access to or share your information with third parties that use the information only to perform services on our behalf such as sales, marketing, communications, customer support, project management, integration, advertising, research, data storage, data processing, security, fraud prevention, and other services.

Business Transactions. If Cultivate is involved in a merger, acquisition, dissolution, sale of all or a portion of its assets, or other fundamental corporate transaction, or if the ownership of all or substantially all of our business changes, we may transfer your information to the new owner so that the Websites can continue to operate. In such case, your information would remain subject to the promises and commitments contained in this Policy until such time as this Policy is updated or amended by the acquiring party upon notice to you. If such transfer is subject to additional mandatory restrictions under applicable laws, Cultivate will comply with such restrictions.

Applicable Law. We may share the information when we believe in good faith that release is necessary to comply with applicable laws, rules or regulations (including any applicable laws, rules or regulations outside your country or state of residence).

Consent. We may also disclose your information to third parties with your consent to do so.

4.4. Is Cultivate a controller or processor of Information about Other Individuals

Pursuant to the GDPR, if you are located in the European Union, Cultivate is the data controller of information about Other Individuals.

4.5. Legal Bases

Pursuant to the GDPR, if you are located in the European Union, we rely on the following legal bases for using information we collect about Other Individuals:

Legitimate Interests. Where use of your information is necessary for our legitimate interests or the legitimate interests of others as described in the “How Does Cultivate Use Information about Other Individuals” section.

Legal Obligation. Where use of your information is necessary to comply with a legal obligation

Consent. Where we have your consent to process data in a certain way. When we process your personal data based on your consent (i.e. for direct marketing purposes or otherwise), you have the right to withdraw your consent at any time by contacting us as provided below. However, this will not affect the lawfulness of the processing based on such consent before your consent was withdrawn.

5. Additional Privacy Terms for All Individuals

The following information about Cultivate’s privacy practices apply to all individuals whose personal data is processed by Cultivate.

5.1 Changes To Our Privacy Policy

We reserve the right to amend this Policy at any time to reflect our data collection and use practices. We will make the revised Policy accessible through the Service and Websites, or by sending you an email to the email address on file. If we make a material change to the Policy, we will comply with applicable legal requirements to provide you with notice and/or consent.

5.2. Is My Personal Data Secure?

We have implemented technical and organizational measures to protect your information against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access. However, no method of transmission over the Internet, and no means of electronic or physical storage, is absolutely secure, and thus we cannot guarantee the absolute security of that information.

Additionally, to facilitate our operations, we may transfer, store and process your personal data in jurisdictions other than where you live including in the United States. Laws in these countries may differ from the laws applicable to your country of residence. For instance, if you are a European Economic Area (EEA) data subject and your personal data is shared with our affiliates, partners, or third-party service providers acting on our behalf outside of the EEA, then it is done so pursuant to necessary means to ensure an adequate level of protection.

5.3. Marketing Practices and Choices

If you receive email from us, we may use certain analytics tools, such as clear GIFs, to capture data such as when you open our message or click on any links or banners our email contains. This data allows us to gauge the effectiveness of our communications and marketing campaigns. You may instruct us not to use your contact information to contact you by email, or phone regarding products, services, promotions and special events that might appeal to your interests by getting in touch with us using the contact information listed “Talk to us” section at the end of this Policy. In commercial email messages, you can also opt out by clicking the “unsubscribe” link located at the bottom of such emails and following the instructions. Please note that, regardless of your request, we may still use and share certain information as permitted by this Policy or as required by applicable law. For example, you may not opt out of certain operational or service-related emails, such as those reflecting our relationship or transactions with you.

5.4. Data Retention

We will retain your information for the period necessary to fulfill the purposes outlined in this Policy unless a longer retention period is required or permitted by law, required to resolve disputes or enforce our agreements, or where the Customer Agreement requires or permits specific retention or deletion periods.

5.5. Combined Information

We may combine the information that we collect through the Service or Websites with information that we receive from other sources, both online and offline, and use such combined information in accordance with this Policy. If, however, the collection of any information about you is governed by a Customer Agreement, information will only be combined and used in accordance with such Customer Agreement and the sections of this Policy applicable to End Users.

5.6. Aggregate/De-Identified Data

We may aggregate and/or de-identify information collected through the Service or Websites so that such information can no longer be linked to you or your device. We may use Aggregate/De-Identified Information for any purpose, including without limitation for research and analytics, and marketing purposes, and may also share such data with any third parties, including advertisers, partners, affiliates, services providers, sponsors, event promoters and others.

6. Privacy Information for Individuals in the EU

6.1. Data Subject Rights

 

Cultivate respects your rights and control over your personal data. You may exercise any of the following rights:

Right of Access: You have the right to be informed of and request access to the personal data we process about you. Upon request, we will confirm whether we hold or are processing personal data that we have collected about you.

Right to Rectification: You have the right to request that we amend or update your inaccurate or incomplete personal data.

Right to Erasure: You have the right to request deletion of your personal data.

Right to Restrict: You have the right to request that we temporarily or permanently stop processing all or some of your personal data.

Right to Object: You have the right, at any time, to object to us processing your personal data on grounds relating to your particular situation; the right to object to your personal data being processed for direct marketing purposes.

Right to Data Portability: You have the right to request a copy of your personal data in electronic format and the right to request that we transmit that personal data for use in another party’s service.

Under certain circumstances we will not be able to fulfill your request, such as if it interferes with our regulatory obligations, affects legal matters, we cannot verify your identity, or it involves disproportionate cost or effort, but in any event, we will respond to your request within a reasonable timeframe and provide you an explanation. In order to make such a request of us, please email us at privacy@cultivate.com.

Please note that for personal data about you that we have obtained or received for processing on behalf of a separate, unaffiliated entity–which determined the means and purposes of processing, all such requests should be made to that entity directly. We will honor and support any instructions they provide us with respect to your personal data.

6.2. Privacy Shield

Cultivate Technology Inc. participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework.  We are committed to subjecting all personal data received from European Union (EU) member countries, the United Kingdom and Switzerland, in reliance on each Privacy Shield Framework, to the Framework’s applicable Principles.  To learn more about the Privacy Shield Frameworks, and to view our certification, visit the U.S. Department of Commerce’s Privacy Shield List.

Cultivate Technology Inc. is responsible for the processing of personal data it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf.  Cultivate Technology Inc. complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, the United Kingdom and Switzerland, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Cultivate Technology Inc. is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.  In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Under certain conditions, more fully described on the Privacy Shield website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

6.3. Additional

For EEA data subjects, our data protection officer is Joshua Pittel, who may be reached at our principal place of business or by emailing privacy@cultivate.com. Our EU Data Protection Representative is DPR Group who may be contacted via the instructions here.

EEA data subjects have the right to lodge a complaint with a supervisory authority concerning Cultivate’s data processing activities.

7. Privacy Information for California Residents

If you are a California resident, California law requires us to provide you with some additional information regarding how we collect, use, and share your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)).

7.1. Categories of personal information we collect

Under the CCPA, we are required to provide you with the “categories” of personal information we collect. The categories we collect are:

Categories

Examples

Identifiers Name, address, email address, phone number, job title, unique personal identifier, online identifier, IP address
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). Name, address, telephone number, employment
Commercial Information Transaction information, records of products or services purchased, obtained, or considered
Biometric Information Recorded demos/sales calls
Internet or other network activity information Website or Service Usage
Geolocation data Country or location based on IP address or time zone
Audio, visual Recorded demos/sales calls
Professional or employment-related information Job title
Inference data about you features we think would be of interest to you, behavior quiz results

7.2 How we use and share these categories of personal information

We use and share the categories of personal information we collect from and about you consistent with the various business purposes we discuss throughout this Policy, and depending on which type of relationship you have with Cultivate. See the relevant section(s) above for more information.

The CCPA sets forth certain obligations for businesses that “sell” personal information to third parties. We do not engage in such activity and have not engaged in such activity in the past twelve months from the effective date of this Policy.

7.3. Your California Privacy Rights

If you are a California resident, the CCPA allows you to make certain requests about your personal information. Specifically you have the:

Right to Know. You may request that we inform you about the categories and specific pieces of personal information we collect about you, the categories of sources of such personal information, the purpose for collecting such personal information, and the categories of third parties with whom we share/disclose such personal information. Such information is also set forth in this Policy.

Right to Access. You may request that we provide access to and/or a copy of certain personal information we hold about you.

Right to Delete. You may request that we delete certain personal information we have about you.

Right to Non-discrimination. You have the right to not be discriminated against for exercising your rights. Certain information may be exempt from such requests.

If you would like to exercise any of your rights under California law with respect to your personal information, please submit your request by completing Cultivate’s CCPA Consumer Rights Form or by contacting us at privacy@Cultivate.com.

We will take reasonable steps to verify your identity before responding to a request, which may include, at a minimum, verifying your name and email address. You are also permitted to designate an authorized agent to submit certain requests on your behalf. We may also follow up with you to verify your identity before processing the authorized agent’s request.

When offering services to Customers, Cultivate acts as a “service provider” under the CCPA and our receipt and collection of any consumer personal information is completed on behalf of our Customers in order for us to provide the services. If you are an End User, please contact your Account owner(s) or administrator(s) for more information about exercising these rights.

Shine the Light Disclosure. The California “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. We do not share your personal information with third parties for their own direct marketing purposes.

Talk to us.

We welcome your comments and questions regarding our Policy. Please contact us at:

Cultivate Technology Inc.
326 Ritch Street
San Francisco, CA 94107
privacy@Cultivate.com

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