Privacy Policy

Your privacy is important to us.  Cultura Technologies (“Cultura”) is committed to protecting your privacy and maintaining the integrity of any identifiable information (“Personal Information”) we collect about you.  The purpose of this Privacy Policy is to outline the steps we take to keep your Personal Information confidential, to inform you about how and why we collect Personal Information, and to provide you with our contact information in case you have any questions or concerns arising out of our Privacy Policy. 

Protecting your privacy and maintaining the integrity of Personal Information means that: we will keep your information and the business you do with us in confidence; we will not sell, rent, or loan your information to third parties; we will respect your privacy when we may contact you from time to time concerning various products and services which we make available to you; you will have control over how we obtain, use, and under circumstances give out information about you; and you will have access to the information that we have about you. 

Why Cultura May Collect Personal Information

Cultura collects Personal Information and uses it in order to:

  • Establish identity;
  • Perform necessary identity and security verifications;
  • Process transactions and conduct business;
  • Deliver products and services;
  • Provide customer support and services;
  • Provide ongoing service delivery;
  • Provide you with information;
  • Improve products, services, and service delivery;
  • Better understand your needs, interests, and suitability for various products and services;
  • Recommend specific products and services that may meet your needs;
  • Respond to issues, questions, and queries;
  • Protect you and us against errors or fraud; and
  • Co-operate with law enforcement and legal authorities, where required, to comply with applicable laws and with court orders.

Cultura will collect, use, and may disclose personal information only for purposes that a reasonable person would consider appropriate in the circumstances; and endeavors to collect as little information as possible as may be necessary under the circumstances. 

Please note that aggregated statistics and information, where the identity of a specific individual cannot be identified, is not Personal Information.  Cultura reserves the right to use aggregated information in any manner it determines, in its discretion, to be appropriate.  Use of such aggregated information may include, but not be limited to, the preparation of aggregated user statistics and information summaries to improve efficiencies, more effectively describe our product and service offerings, and assist in the marketing of our products and services.  Aggregated statistics and information will not contain Personal Information.

What Type of Personal Information Cultura May Collect

Cultura collects various types of Personal Information.  During the course of doing business or interacting with Cultura, or receiving products and services from or through Cultura, you may, depending on the nature of the circumstances, be asked to provide Cultura with:

  • Geographic (physical) addresses;
  • Demographic information;
  • E-mail addresses;
  • Phone numbers or other contact information;
  • Names (first, and last or whatever the family identifying name is);
  • Shipping information;
  • Billing information; 
  • Transaction history;
  • Website usage preferences;
  • Feedback regarding our business, services, website, and public relations;
  • Source IP addresses;
  • Times and dates of access to website servers;
  • Language;
  • Personal preferences;
  • Product and service preferences;
  • Browsers types and configurations; and
  • Miscellaneous administrative and computer traffic information.

Certain forms of information, such as government issued or private sector issued licenses, permits, certificates, and cards, in the nature of driver’s licenses, social insurance/security number, passports, insurance cards, voucher numbers, and the like, although convenient for identification, is voluntary.  It is up to you whether you want to provide this, or other suitable identification, subject to any legal requirements.

How Does Cultura Collect Personal Information

Cultura will only collect Personal Information that you have voluntarily provided to us or have agreed to provide to us.  Cultura will not collect any Personal Information about you without advising you accordingly (either by way of this Privacy Policy or by way of providing you with some other form of notice at the time we are requesting or collecting Personal Information) regarding why and how that Personal Information is being collected and how such Personal Information will be used or disclosed.  Cultura may collect Personal Information through a variety of means:

  • using our website;
  • using our services;
  • in the course of communications with us (face-to-face, by e-mail, by phone, mail, or otherwise);
  • in the course of feedback to us regarding our business, services, website, and public relations;
  • when registering with us for services or, where relevant, accounts, or, where relevant, for the download of our software;
  • customer, membership, recipient, or service lists that have been lawfully acquired from third parties;
  • through the completion of manual or electronic forms;
  • website cookies – Cookies are identifiers that can be sent from a website via your browser to be placed on your computer’s hard drive. You may elect not to accept cookies by changing the designated settings on your web browser; however, not utilizing cookies may prevent you from using certain functions and features of websites.  Information collected from the use of cookies is used to improve Cultura services;
  • web beacons – Web beacons are small, graphic images that allow a website operator to collect certain information and monitor user activity on its website. A web beacon is a very small pixel which is invisible to the user.  Cultura uses web beacons to collect information that is not of a personal nature;
  • clickstreaming - Clickstreaming is a technology that allows a website operator to track the paths that surfers take as they access a website and look at the site's pages, and as they use links to other sites.
  • Cultura collects such information from visitors to http://www.culturatech.com/ and website traffic information, which is monitored and analyzed in order to determine which products, services, or features may be of interest to visitors, so we may improve our website, products, services, features, or other offerings.

In addition, we may review and analyze your use of products and services to help us serve you better and to bring other products and services to your attention which, we feel, will be of benefit to you. We also collect and analyze information from other sources for the same purposes.

How Cultura May Disclose Personal Information

Cultura does not sell any Personal Information it collects to third parties.  Cultura may share Personal Information with its affiliates, subsidiaries, employees, contractors, and agents in the course of providing you with our business services, support, or the fulfillment or delivery of our products or services.

Cultura may disclose Personal information if we are required to do so to a court of competent jurisdiction or other legal or regulatory authority, or, if there is a good faith belief and reliance on said belief, that disclosure is necessary to:  comply with any legal process served on Cultura; maintain, uphold, or protect Cultura’s rights or property; protect and ensure the personal safety of the public or other Cultura clients; or protect against criminal or quasi-criminal activities, or to detect, prevent, or investigate allegations of, or address, misrepresentation or fraud.

Cultura reserves the right that in the event of a bankruptcy filing, mergers with third parties, acquisition by third parties, sale of assets (all or partial), or any other transfer of all or substantially all of Cultura relevant assets to a third party, that Cultura shall be entitled to share (or sell as an ancillary aspect of the overarching business transaction) the Personal Information you have provided to us to the third party.

Retention and Disposal

We keep information only for so long as it is needed for the efficient and effective delivery or fulfillment of the software, products, or services you are using or contemplating using and for a reasonable time thereafter, or to meet any legal requirements.  We will either destroy or remove information when it is no longer needed.

Security and Storage

Cultura endeavors to maintain appropriate physical, procedural, and technical security with respect to its offices and information storage facilities so as to prevent any loss, misuse, unauthorized access, disclosure, or modification of Personal Information. This also applies to our disposal or destruction of Personal Information.

Cultura keeps the Personal Information we collect from/about you strictly confidential. Only authorized personnel have access to this Personal Information. Cultura personnel who have access to Personal Information receive training regarding privacy protection.

If any employee, contractor, or agent of Cultura misuses Personal Information, this will be considered as a serious offense for which disciplinary action may be taken, up to and including termination of employment or contract for service. If any individual or organization misuses Personal Information - provided for the purpose of providing services to or for Cultura - this will be considered a serious issue for which action may be taken, up to and including termination of any agreement between Cultura and that individual or organization and possible legal action against such individual or organization.
Our computer security specialists build security into all our computer systems. This protects your information at all times, when it is stored in data files or handled by our employees. Our systems also protect your information when it is transmitted, for example, between our data processing centers, our business units, and corporate offices.  Personal Information may be stored or processed in any jurisdiction in which we or our affiliates, suppliers, subsidiaries, or agents maintain facilities. By supplying us with Personal Information you consent to any transfer of this information to other jurisdictions (including countries which have not been assessed for adequacy of privacy laws).

Cultura does and shall continue to use industry-standard technology to maintain the security of your personal information, and for our connections to the internet; however, Cultura cannot and does not guarantee the privacy, security, authenticity, or non-corruption of any information transmitted through the internet or for any information stored in any third-party system connected to the internet. 
While Cultura takes steps to verify that any service providers, suppliers, or the like with whom we share information are committed to maintaining the privacy of Personal Information at standards that are at least as stringent as our own Privacy Policy and has communicated to them to refrain from making any independent or unauthorized use of any Personal Information, Cultura does not and cannot guarantee the actions, conduct, or standards of any such parties. 

Cultura shall not be responsible for any claims, damages, costs, or losses whatsoever arising out of or in any way related to third-party connections to or use of the Internet.  Cultura cannot and does not ensure the protection of any Personal Information that you provide to a third-party website that may reference, be referenced, or link to our website.  Personal Information collected by these third parties is not subject to, or governed by, this Privacy Policy.  Cultura shall not be responsible for events beyond our direct control.  Cultura will not be liable for any direct, indirect, incidental, consequential, or punitive damages relating to the uses or releases of Personal Information.

Contact

We are committed to upholding our Privacy Policy.  We have policies and procedures in place to educate and assist our employees and contractors in fulfilling their obligations under our Privacy Policy.  Our policies and procedures will be reviewed on a regular basis and the results of such review will be presented to Cultura’s personnel responsible for overseeing privacy matters.

Cultura is committed to treating you with the greatest respect and consideration.  Please let us know if you have any questions or concerns, and we will take steps to address them.  If you have any questions regarding this Privacy Policy, would like to confirm the accuracy of your personal information, believe that the privacy of your personal information has not been respected, or would like to update or delete incorrect personal information, please contact us.

Age

Cultura is committed to protecting the safety of children.  Cultura will not knowingly request or use Personal Information from children under the age of thirteen without parental consent.  If Cultura receives collect any Personal Information from children under the age of thirteen, Cultura will take steps to have such information eliminated.  This website is not to be used by anyone under the age of eighteen.  Persons under the age of eighteen are not authorized to use this website and are directed to immediately discontinue use of this website.

Updates

Cultura may from time to time update this Privacy Policy, with the updated policy to be posted on the Cultura website. The use of Personal Information provided to Cultura prior to the update will continue to be governed by the policy in effect at the time the information was provided. We recommend that you revisit this Privacy Policy from time to time on a regular basis.

Consent

By using this website, you agree, and do hereby consent, to our collection and use of information and Personal Information for purposes for which the information/Personal Information was collected and in accordance with this Privacy Policy.  If you do not consent, you are to immediately discontinue use of this website and to refrain from further using this website.

Governing Law and Venue

By visiting and using this website, you acknowledge and agree that the laws of the Province of Ontario shall govern, construe, and apply to this Privacy Policy (without any reference or regards to any principles of conflict of laws).  The venue for the resolution of any question, dispute, proceeding, or other matter arising out of this Privacy Policy shall be the federal or provincial courts located in the Province of Ontario. 

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