We value your privacy and want you to understand the choices and control you have over your Personal Information on CultureTalk. “Personal Information” means information that can be used on its own or with other information to identify, locate, or contact a specific individual. These changes will take effect on May 25, 2018. We will not disclose your name, email address or other Personal Information to third parties without your consent, except as specified in this Policy.

We use your Personal Information to provide and improve the services and our products, for billing and payments, for identification and authentication, for targeted online and offline marketing.

Here are some of the highlights of what’s changing:

• Transparency: We’ve provided additional details about the Personal Information we collect and how we use that Personal Information. We’ve also explained your choices and the control you have over your Personal Information.
• GDPR: On May 25, 2018, a new European Union (EU) data protection law, the General Data Protection Regulation (GDPR), takes effect. The GDPR (i) gives individuals in the EU more control over how their Personal Information is used, and (ii) places certain obligations on businesses that process information of those individuals. We’ve updated our Privacy Policy (this “Policy”) to take into account the new requirements of the GDPR. Several of these requirements are specifically set forth below in SECTION 9 – GDPR.
• Functionality: Depending on your location, we may provide you with the ability to access, download, and request deletion of your Personal Information.

By continuing to use our services on or after May 23, 2018, you acknowledge our updated Policy and agree to the rest of the updated Terms of Service. Please be aware that the privacy laws and standards in certain countries, including the rights of authorities to access your Personal Information, may differ from those that apply in the country in which you reside. We will transfer Personal Information only to these countries to which we are permitted by law to transfer Personal Information, and we will take steps to ensure that your Personal Information continues to enjoy appropriate protections. Please read on to learn more about how we protect Personal Information that’s transferred outside of the EEA, as described below in SECTION 9 – GDPR.

SECTION 1 – WHAT DO WE DO WITH YOUR INFORMATION?

We need to process your Personal Information to run our business and provide you with our services. By accepting our Terms of Service, you are confirming that you have read and understand this Policy including how and why we use your Personal Information.

If you don’t want us to collect, use or disclose [referred to in this Policy as “processing”] your Personal Information in the ways described in this Policy, you shouldn’t use our services. We are not responsible for the content or the privacy policies or practices of any of our members, websites hosted through Flywheel (described below), third-party websites, or third-party apps.

When you purchase something from our store, as part of the buying and selling process, we collect the Personal Information you give us such as your name, address and email address. We will only use this Personal Information you give us in order to complete your purchase.

When you browse our store, we also automatically receive your computer’s internet protocol (IP) address in order to provide us with information that helps us learn about your browser and operating system. Although this is considered Personal Information under the GDPR, this information does not identify anything more about you, such as your name or your address.

Email marketing (if applicable): With your permission, which we will obtain in advance if you are in the EU, we may send you emails about our store, new products and other updates.

If you decide that you no longer want to receive direct marketing emails, you have the right to tell us to stop.

SECTION 2 – CONSENT

How do you get my consent?

When you provide us with Personal Information to complete a transaction, verify your credit card, place an order, arrange for a delivery or return a purchase, we imply that you consent to our collecting it and using it for that specific reason only.

Once you provide your Personal Information to us, we will continue to store it in accordance with our normal records retention policies unless or until you withdraw your consent and/or you ask us to destroy your Personal Information. You can find out how long we will store your Personal Information by contacting us at info@culturetalk.com.com or mailing us at: CultureTalk, P.O. Box 2292, Wilton, New York 12831, United States.

How do I withdraw my consent?

If, after you opt-in or provide us with your express consent, you change your mind, you may withdraw your consent for us to contact you, for the continued processing of your Personal Information, at any time, by contacting us at info@culturetalk.com.com or mailing us at: CultureTalk, P.O. Box 2292, Wilton, New York 12831, United States.

Can I ask you to delete Personal Information you have about me?

Yes. Once you have withdrawn your consent for us to process your Personal Information, you have the right to have the Personal Information we have collected about you deleted. You can request deletion of your Personal Information at any time at info@culturetalk.com.com or by mailing us at: CultureTalk, P.O. Box 2292, Wilton, New York 12831, United States.

SECTION 3 – DISCLOSURE

We may disclose your Personal Information if we are required by law to do so or if you violate our Terms of Service.

Can I obtain a copy of all of the Personal Information you have collected from me and a record of how my Personal Information has been used or disclosed by CultureTalk?

Yes. You have the right to obtain a copy of all of the Personal Information that you have provided to us. We will provide you a copy of this data in an electronic format. In addition, you have the right to request a record containing certain details concerning how we have used or disclosed your Personal Information. To obtain a copy of your Personal Information or a record of uses and disclosures of your Personal Information, you can contact us at any time at info@culturetalk.com.com or by mailing us at: CultureTalk, P.O Box 2292, Wilton, New York 12831, United States.

SECTION 4 – Flywheel

Our store is built in Woo Commerce for WordPress and hosted on Flywheel. They provide us with the online e-commerce platform that allows us to sell our products and services to you.

Your Personal Information is stored through Woo Commerce’s data storage, databases and the general Flywheel hosting. They store your Personal Information on a secure server behind a firewall.

Payment

If you choose a direct payment gateway to complete your purchase, then Woo Commerce stores your credit card data. It is encrypted through the Payment Card Industry Data Security Standard (PCI-DSS). Your purchase transaction data is stored only as long as is necessary to complete your purchase transaction. After that is complete, your purchase transaction information is deleted.

All direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover.

PCI-DSS requirements help ensure the secure handling of credit card information by our store and its service providers.

SECTION 5 – THIRD-PARTY SERVICES

In general, the third-party providers used by us will only collect, use and disclose your Personal Information to the extent necessary to allow them to perform the services they provide to us. If required by the GDPR, we will ensure required contractual arrangements are in place with such third-party service providers regarding the privacy of your Personal Information.

However, certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies in respect to the information we are required to provide to them for your purchase-related transactions. For these providers, we recommend that you read their privacy policies so you can understand the manner in which your Personal Information will be handled by these providers.

In particular, remember that certain providers may be located in or have facilities that are located a different jurisdiction than either you or us. So if you elect to proceed with a transaction that involves the services of a third-party service provider, then your Personal Information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.

As an example, if you are located in Canada and your transaction is processed by a payment gateway located in the United States, then your Personal Information used in completing that transaction may be subject to disclosure under United States legislation, including the Patriot Act. Once you leave our store’s website or are redirected to a third-party website or application, you are no longer governed by this Policy or our website’s Terms of Service.

Links

When you click on links on our store, they may direct you away from our site. We are not responsible for the privacy practices of other sites and encourage you to read their privacy statements.

SECTION 6 – SECURITY

To protect your Personal Information, we take reasonable precautions and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed.

If you provide us with your credit card information, the information is encrypted using secure socket layer technology (SSL) and stored with an AES-256 encryption. Although no method of transmission over the Internet or electronic storage is 100% secure, we follow all PCI-DSS requirements and implement additional generally accepted industry standards.

SECTION 7 – COOKIES

Cookies are small data files sent from a server to your web browser. They are stored in your browser’s cache and allow a website or a third party to recognize your browser. Certain Cookies are employed to make our website and/or store function for its intended purpose, and are provided based on contractual necessity based on your agreement with us to perform the services you have requested. These include the functions strictly necessary to the service noted above.

By choosing to use our services after having been notified of our use of Cookies in the ways described in this Policy, and, in applicable jurisdictions, through notice and unambiguous acknowledgement of your consent, you agree to such use.

In addition, when you use CultureTalk via a browser, you can change your web browser’s settings to reflect your cookie preferences for cookies directly from the site you are on or for third-party cookies. Each browser is a little different, but usually these settings are under the “options” or “preferences” menu. The links below provide information about cookie settings for the browsers supported by CultureTalk:

• Microsoft Edge
• Internet Explorer
• Firefox
• Chrome
• Safari

Here is a list of cookies that we use. We’ve listed them here so you that you can choose if you want to opt-out of cookies or not.

Woo Commerce Cookies

• woocommerce_cart_hash
• woocommerce_items_in_cart
• wp_woocommerce_session_

The first two cookies contain information about the cart as a whole and helps WooCommerce know when the cart data changes. The final cookie (wp_woocommerce_session_) contains a unique code for each customer so that it knows where to find the cart data in the database for each customer. No personal information is stored within these cookies.

HubSpot Cookies

This site also uses the HubSpot Platform to support our marketing, sales and customer service efforts. HubSpot’s tracking code sets the following cookies:

__hstc
The main cookie for tracking visitors. It contains: the domain, utk (see below), initial timestamp (first visit), last timestamp (last visit), current timestamp (this visit), and session number (increments for each subsequent session) (Expires: 2 years)

hubspotutk
This cookie is used for to keep track of a visitor’s identity. This cookie is passed to HubSpot on form submission and used when deduplicating contacts. (Expires: 10 years)

__hssc
Cookie for keeping track of sessions. This is used to determine if we should increment the session number and timestamps in the

__hstc cookie.
It contains: the domain, viewCount (increments each pageView in a session), session start timestamp. (Expires: 30 min)

__hssrc
Whenever HubSpot changes the session cookie, this cookie is also set. We set it simply to the value “1”, and use it to determine if the user has restarted their browser. If this cookie does not exist when we manage cookies, we assume it is a new session. (Expires: None. Session cookie)

__hs_opt_out
This cookie is used by the opt-in privacy policy to remember not to ask the user to accept cookies again. This cookie is set when you give users the choice to opt out of cookies. (Expires: 2 years)

__hs_do_not_track
This cookie is set when you give users the choice to opt out of cookies and they choose to do so. It disables tracking and personalization. (Expires: 2 years)

__hs_testcookie
This cookie used to test whether the visitor has support for cookies enabled. (Expires: Session cookie)

hsPagesViewedThisSession
This cookie used to keep track of page views in a session. (Expires: Session cookie)

hsfirstvisit 
This cookie used to keep track of a user’s first visit. (Expires: 10 years)

SECTION 8 – AGE OF CONSENT

By using this site, you represent that you are at least the age of majority in your state or province of residence, or that you are the age of majority in your state or province of residence and you have given us your consent to allow any of your minor dependents to use this site. In addition, CultureTalk is not designed for use by anyone under the age of 13, and any use or access of the website by anyone under the age of 13 is strictly prohibited. If we learn that Personal Information of a user under the age of 13 has been collected through our provision of services, then we will take the appropriate steps to delete this Personal Information.

SECTION 9 – GDPR

At any point while CultureTalk is in possession of or processing your Personal Information that is subject to the GDPR, you have the following rights, some of which are explained elsewhere in this Policy:

• Right of access – you have the right to request a copy of the Personal Information that we hold about you and certain other information as set forth in Article 15 of the GDPR.
• Right of rectification – you have a right to correct Personal Information that we hold about you that is inaccurate or incomplete.
• Right to be forgotten – in certain circumstances you can ask for the Personal Information we hold about you to be erased from our records.
• Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
• Right of portability – you have the right to have the Personal Information we hold about you transferred to another organization.
• Right to object – you have the right to object to certain types of processing such as direct marketing.
• Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.

At your request, we can confirm what Personal Information we hold about you and how it is processed. You can request the following information:

• Identity and the contact details of the person or organization that has determined how and why to process your Personal Information.
• Contact details of our Data Protection Officer, if applicable.
• The purpose of the processing as well as the legal basis for processing.
• If the processing is based on the legitimate interests of CultureTalk or a third party, information about those interests.
• The categories of Personal Information collected, stored and processed.
• Recipient(s) or categories of recipients that the Personal Information is/will be disclosed to.
• How long the Personal Information will be stored.
• Details of your rights to correct, erase, restrict or object to such processing.
• Information about your right to withdraw consent at any time.
• How to lodge a complaint with the supervisory authority (see the link below).
• Whether the provision of Personal Information is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the Personal Information and the possible consequences of failing to provide such Personal Information.
• The source of Personal Information if it wasn’t collected directly from you.
• Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

When you access or use our services, we collect, use, share, and otherwise process your Personal Information as described in this Policy. We rely on a number of legal bases to use your Personal Information in these ways. These legal bases include where:

• necessary to perform the contractual obligations in our Terms of Service and in order to provide our services to you;
• you have expressly consented to the processing, which you can revoke at any time;
• necessary to comply with a legal obligation, a court order, or to exercise or defend legal claims;
• necessary for the purposes of our or a third party’s legitimate interests, such as those of our third-party billing companies or partners; and/or
• you have expressly made the Personal Information public.

Note that we principally rely on consent (i) to send marketing messages, (ii) for third-party data sharing related to advertising, and, to the extent applicable, (iii) for the use of location data for advertising purposes. Where we process your Personal Information on the basis of legitimate interests, we do so as follows:

• Providing and improving our services: We may use your Personal Information to improve and customize our services, including sharing of your Personal Information for such purposes, and we do so as it is necessary to pursue our legitimate interests of improving our services for our users. This is also necessary to enable us to pursue our legitimate interests in understanding how our services are being used, and to explore and unlock ways to develop and grow our business. It is also necessary to allow us to pursue our legitimate interests in improving our services, efficiency, interest in services for users and obtaining insights into usage patterns of our services.
• Keeping our services safe and secure: We may also use your Personal Information for safety and security purposes, including sharing of your Personal Information for such purposes, and we do so because it is necessary to pursue our legitimate interests in ensuring the security of our services, including enhancing protection of our community against spam, harassment, intellectual property infringement, crime, and security risks of all kind.

The United States, European Economic Area (“EEA”) Member States, and other countries all have different laws. When your Personal Information is moved from your home country to another country, the laws and rules that protect your Personal Information in the country to which your Personal Information is transferred may be different from those in the country in which you live. For example, the circumstances in which law enforcement can access Personal Information may vary from country to country. In particular, if your Personal Information is in the US, it may be accessed by government authorities in accordance with US law.

• To the extent that we are deemed to transfer Personal Information outside of the EEA, we rely separately, alternatively, and independently on the following legal bases to transfer your Personal Information:
  • CultureTalk provides a voluntary service; you can choose whether or not you want to use our services. However, if you want to use our services, you need to agree to our Terms of Service, which set out the contract between us and our customers. As we operate in countries worldwide (including in the US) and use technical infrastructure in the US to deliver the services to you, in accordance with the contract between us, we need to transfer your Personal Information to the US and to other jurisdictions as necessary to provide the services. Simply put, we can’t provide you with the services
    and perform our contract with you without moving your Personal Information around the world.
  • The European Commission has adopted standard contractual clauses (also known as Model Clauses), which provide safeguards for Personal Information that is transferred outside of the EEA. Where feasible, we generally will use these Model Clauses if we are transferring Personal Information outside of the EEA.

SECTION 10 – CHANGES TO THIS PRIVACY POLICY

We reserve the right to modify this Policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the website. If we make material changes to this policy, we will notify you here that it has been updated, so that you are aware of what Personal Information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it (i.e., how we process it).

In some cases, we may choose to buy or sell assets or other ownership interests in CultureTalk. Such transactions may be necessary and in our legitimate interests, particularly our interest in making decisions that enable our business to develop over the long term. In these types of transactions (such as a sale, merger, liquidation, receivership, or transfer of all or substantially all of our assets), customer information is typically one of the business assets that is transferred. If we intend to transfer Personal Information about you, we will notify you by email or by putting a prominent notice on the CultureTalk website, and you will be afforded an opportunity to opt out before Personal Information about you becomes subject to a different privacy policy.

QUESTIONS, COMPLAINTS AND CONTACT INFORMATION

How do I complain?

If you are in the EU and are not happy with the way your Personal Information is being handled, or the responses you have received from us, you have the right to lodge a complaint with the appropriate authorities in your home country. You can obtain a partial list of these authorities by visiting: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm. We cannot make any guarantees regarding the type of response you will receive from any of these agencies. If you are outside of the EU, please contact our Privacy Compliance Officer at the email or address below.

How do I contact CultureTalk?

If you would like to: access, correct, amend or delete any Personal Information we have about you, register a complaint, or simply want more information, contact our Privacy Compliance Officer at info@CultureTalk.com or by mail at CultureTalk

[Re: Privacy Compliance Officer] [CultureTalk, P.O Box 2292, Wilton, New York 12831, United States.]