Legal

Cultara ("we", "our", "us") is committed to protecting privacy and maintaining transparency in how information is collected, used, stored, and protected across our website, application, and related services. This Privacy Policy explains how we handle information when you visit our website, contact us, request information, or use the Cultara platform.

1. Scope

This Privacy Policy applies to:

• Our public website.
• Contact forms, demo requests, and other website interactions.
• The Cultara application platform.
• Services related to cultural analytics, organizational insights, and AI-enabled analysis.
• Customer users, administrators, and authorized representatives.

2. Information We Collect

a. Website Data

• Contact form submissions, including name, email address, company, and message content.
• Demo request information.
• Basic website analytics, such as page views, traffic source, browser type, device type, and interactions with the website.
• Cookie and similar tracking information, where permitted.

b. Account and Application Data

• Name, email address, role, and organization details.
• Authentication and account access information.
• Workspace, assessment, configuration, and user permission data.
• Usage records required to operate, secure, and support the platform.

c. Customer-Provided Organizational Data

• Anonymized and tokenized communication content.
• Associated metadata generated during customer-controlled preprocessing.
• Functional mappings, such as grouping individuals into departments, teams, or functional areas.
• Configuration inputs needed to generate analytics and insights.

Cultara does not collect raw internal documents, original org charts, or identifiable communication records as part of its standard platform workflow. Customer organizational data is expected to be anonymized before upload.

3. Required Anonymization and Data Preparation

Cultara uses an anonymization-first architecture designed to reduce exposure of personal and sensitive information before data reaches the platform.

• Data must be anonymized before upload to the Cultara platform.
• Anonymization is performed locally within the customer's own environment.
• Cultara may provide parser tooling to assist with this process.
• The parser may use industry-standard techniques, including Microsoft Presidio, to detect and replace sensitive information.
• Customers remain responsible for reviewing and validating the data they upload.

Sensitive values, such as names, email addresses, identifiers, or similar information, may be replaced with generalized tokens such as "FIRST NAME", "EMAIL", or similar placeholders. This approach is designed to prevent personally identifiable information from being transmitted to or stored in the Cultara platform.

4. Data Ingestion and Processing Model

• Processed data is exported from the local parser environment.
• Customers upload anonymized data into the Cultara platform.
• Data is stored in tenant-isolated environments.
• The Cultara AI Engine processes anonymized data to generate structured cultural insights.
• Cultara systems do not access original identifiable source data as part of the normal workflow.

5. Use of Artificial Intelligence

Cultara uses AI and related analytical technologies to:

• Extract patterns from anonymized organizational data.
• Classify and score organizational behaviors.
• Generate aggregated insights, summaries, dashboards, and related outputs.
• Support cultural analytics and organizational decision-making.

We do not use customer data to train public AI models. Customer data is used to provide the requested Service and generate customer-specific insights.

6. How We Use Information

• Provide, operate, maintain, and improve the Cultara website and platform.
• Respond to inquiries, demo requests, and support requests.
• Create and manage user accounts, organizations, workspaces, and assessments.
• Generate cultural analytics, insights, dashboards, and related outputs.
• Maintain platform security, reliability, performance, and auditability.
• Communicate service updates, administrative notices, and relevant product information.
• Comply with legal obligations and enforce our agreements.

7. Data Ownership

Customers retain ownership of all customer-provided data. Cultara does not sell, rent, or monetize customer data. Customer data is processed only to provide the Service, generate requested insights, maintain the platform, and fulfill related obligations.

8. Data Sharing

We do not sell, rent, or share personal data for advertising or commercial resale purposes.

We may share information only in limited circumstances, including:

• With trusted subprocessors and infrastructure providers that support hosting, storage, processing, email delivery, security, monitoring, or related operations.
• When required by law, court order, subpoena, or other legal obligation.
• To protect the security, rights, or integrity of Cultara, our customers, or the Service.
• With explicit customer authorization.
• In connection with a business transaction such as a merger, acquisition, financing, or sale of assets, subject to appropriate confidentiality protections.

9. Security

Cultara applies commercially reasonable technical and organizational safeguards designed to protect data, including:

• Encryption in transit and at rest where appropriate.
• Access controls and role-based permissions.
• Tenant-level data isolation.
• Monitoring, logging, and security controls.
• Operational controls designed to protect platform integrity.

10. Security Incidents

If we confirm a security incident affecting customer data, we will notify affected customers without undue delay and take appropriate steps to investigate, contain, and mitigate the incident.

11. Cookies and Website Tracking

Our website may use limited cookies and similar technologies to support website functionality, understand site usage, and improve visitor experience.

• Essential cookies: Required for core website functionality.
• Analytics cookies: Help us understand how visitors interact with the website.

We do not use cookies for advertising or cross-site behavioral tracking. You can control cookies through your browser settings. Where required, you may be presented with a cookie notice allowing you to accept or manage non-essential cookies.

12. Data Retention

We retain information only as long as reasonably necessary to provide the Service, fulfill the purposes described in this Privacy Policy, comply with legal obligations, resolve disputes, enforce agreements, and maintain security records.

Unless otherwise agreed in writing, customer data is generally deleted within sixty (60) days after subscription termination or expiration, except where retention is required for legal, audit, security, or legitimate business purposes.

13. Your Rights

Depending on your location and applicable law, you may have rights to:

• Access personal information.
• Request correction or deletion.
• Restrict or object to processing.
• Request a copy of certain information.
• Withdraw consent where processing is based on consent.

Requests can be made by contacting us at connect@cultara.ai.

14. Children’s Privacy

Cultara services are not intended for individuals under the age of 16. We do not knowingly collect personal information from children.

15. International Data Transfers

Information may be processed in jurisdictions outside your own. Where required, appropriate safeguards are used to protect information during transfer and processing.

16. Third-Party Services

The Service may rely on trusted third-party providers for hosting, infrastructure, email delivery, authentication, analytics, monitoring, or AI processing. These providers process information only as needed to support the Service and are subject to appropriate contractual or operational safeguards.

17. Updates to This Policy

We may update this Privacy Policy periodically. Updated versions will be posted with a revised "Last Updated" date. Continued use of the website or Service after an update means the revised policy applies going forward.

18. Contact

Questions regarding this Privacy Policy may be directed to:

Email: connect@cultara.ai