Effective Date: May 1, 2018

This Privacy Policy describes the types of information gathered by CultureIQ Inc. (“CultureIQ”, “we” or “us”) in the course of rendering certain services to its customers and visitors (the “Service(s)”), how we use it, with whom the information may be shared, what choices are available to you regarding collection, use and distribution of information and our efforts to protect the information you provide to us in the course of our rendering of the Service.

By participating in a Service-related survey, using our administrative tools, or visiting our web sites, you hereby consent to allow us to process information in accordance with this Policy. Registered users should also refer to our Terms of Use, which are incorporated as if fully recited herein. You may be shown a confidentiality notice before participating in a survey. Please note that in cases where the terms of any such survey-specific confidentiality notice conflict with any terms in this Policy, the survey-specific terms will take precedence over the terms in this Policy.

Who We Are

The Services are owned and operated by CultureIQ, which has its principal place of business at 115 West 30th Street, 6th Floor, New York, NY 10001, USA. More information about CultureIQ can be found at www.cultureiq.com.

Information Collected

Information We Collect From You or Your Employer:

If you are an employee of a CultureIQ customer, your employer may provide information about you including name, business email address, organization, and may include other job-related information such as job title, position, and other demographic information. We collect your opinions and input on the surveys you participate. You may also be asked to provide certain types of information (e.g., email address, phone number, name, address) to register on our site, submit a question, participate in a survey, or engage with our web sites.

Information from other sources:

When you visit our corporate website, we may periodically obtain information about you from other sources. The collection of such information will be in accordance with applicable privacy laws. Examples of information we receive include updated contact information and additional demographic information used for marketing purposes.

Information collected automatically:

When you visit our websites, we automatically collect and analyze certain information about your use of the sites and the device you used to access the sites. This information includes your IP address, information about your browser type and language, operating system of your computer, the date and time you are accessing our sites, applications or articles downloaded, search terms entered, the content of any undeleted cookies that your browser previously accepted from us, and the referring website address.

Use of cookies and other technologies:

Cookies: When you visit our Sites, you may be prompted to allow us to assign your computer one or more “cookies.” A cookie is a small text file containing information that we can read later to facilitate your access to our Sites and personalize your online experience. We may use cookies to collect information about your activity on our Sites, such as the pages you visit and links you click. If you choose to decline cookies, you may not be able to sign in or use some of the interactive features offered on the Sites.

Other Technologies: We also use standard Internet technologies, such as embedded links on web pages and other similar technologies to track usage across the application. We also include web beacons in e-mail messages or newsletters to registered users to track whether you open the messages. We use this information to customize our services and measure the overall effectiveness of our online content, advertising campaigns, and products and services we offer.

How We Use Information We Collect

• To provide the Services.
• To customize the content you see or tailor the experience.
• To develop and improve our Service.
• To respond to your inquiries and requests.
• To communicate to you about surveys, marketing, promotions, and our other products which you may be interested in.
• To engage in research and analysis in order to maintain, protect and improve our Services.
• To enforce the legal terms that govern your use of the Services.
• To ensure the technical functioning of the Services.

Choices About Use of Your Information

We believe that it is important to give you choices about the use of your information. We will use your information as described in this Policy or survey specific privacy and data protection notices. If we want to use your information for a purpose not described in this Policy, we will first obtain your consent to do so.

Marketing Communications: We will respect your wishes not to receive, or stop receiving, marketing communications. If you provided us with your email address in order to receive such communications, you can opt out at any time by using the unsubscribe links or instructions at the bottom of our emails. Please note that we will continue to send you service-related communications regardless of any such request. We will not share or sell your information and personal details with third parties (for avoidance of doubt, other than subsidiaries and/or affiliates) for their own promotional or marketing purposes unless you give us consent to do so and where permitted by applicable law.

Surveys: For surveys your employer, client or business associate (sponsor) has asked you to participate in, you may choose not to respond or select the decline or opt-out option where available. We only process information you provide as directed by your sponsor. Inquiries about sponsor-provided information should be directed to the sponsor or contact information provided in the survey instructions.

Disclosure of Information

We may share your information with third-party companies or individuals in the following instances:

• When we engage service providers and third-party agents to process personal information on our behalf. When we do so, we contractually require these service providers to implement adequate security and privacy measures to ensure that your personal information will be appropriately protected and only used for the purposes of performing the services for us.
• In response to subpoenas, court orders, or other legal process (including for national security and law enforcement purposes); to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases we reserve the right to raise or waive any legal objection or right available to us.
• When we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the justified rights, property, or safety of CultureIQ or its subsidiaries, our customers, or others; and in connection with our Terms of Service and other agreements.
• In connection with a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, including any pre-transaction diligence, or in the unlikely event of bankruptcy.

We may also share aggregate or anonymous information with third parties, including the individual or entity that sponsored the Service, for the purpose of analytics, marketing, decision-making, reports, assessment and other business purposes. We may also publish or share reports we prepare based on such aggregated information. Aggregate or anonymous information does not contain any personal information and its use and disclosure is not subject to the terms of this Policy.

International Transfers of Your Information

We operate the Services in the United States and, depending on your country of residence, the submission of information to our Services may involve the transfer of such information to the United States.

In addition, we may transfer information to our subsidiaries or affiliated companies and service providers and/or third party agents in various countries, including the United Kingdom, India, Germany (and other EU Member States) for certain processing operations. You should be aware that privacy laws in these countries may not provide protections equivalent to those of your country of residence.

CultureIQ will ensure that transfers of Personal Data to a third country or an international organization are subject to appropriate safeguards as described in Article 46 of the GDPR and that such transfers and safeguards are documented according to Article 30(2) of the GDPR.

All transfers of Personal Data out of the European Economic Area and Switzerland to countries that do not ensure an adequate level of data protection within the meaning of applicable data protection laws shall be governed by the European Union (“EU”) Commission Approved Standard Contractual Clauses for transfer of data outside the European Economic Area.

CultureIQ shall comply with the data protection policies and procedures, applicable laws, and the terms of our client contracts governing the collection and use of information.

Access to Your Information

In some cases, you may directly access your online profiles and other personal details, and amend, update or add information yourself at any time by logging into your account.

You may request access to any certain information that we hold about you, ask us to correct certain information which may be inaccurate, and/or ask us to block or delete such information and object to the processing of personal data except where the law requires otherwise. Please note that in cases where your employer is the Data Controller of such information, we will inform your employer so they may take appropriate actions to abide by your request. To request to access or correct your information, or to raise inquiries concerning your information in our possession, please email us at privacy@cultureiq.com or contact:

Data Protection Officer
CultureIQ
115 West 30th Street, 6th Floor
New York, NY 10001, USA

Please include “Request for Privacy Information” in the subject line. Please include enough detail for us to locate your file; at a minimum, your name and email. We may require you to prove your identity with approved identification.

We will retain your information for as long as needed to provide any Services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

California Residents

California Civil Code Section 1798.83 permits California residents to request certain information regarding our disclosure of personal information (as defined by this law) to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@cultureiq.com.

Information Security

We have implemented reasonable technical and organizational security measures to help protect against unauthorized access, unauthorized alteration, disclosure, or destruction of information. Unfortunately, no data transmission over the Internet can be guaranteed to be entirely secure, and we cannot and do not guarantee or warrant the security of any information that you transmit on or through our Sites.

We make reasonable efforts to restrict access to information to only those employees, contractors, and agents who need to know that information in order to operate, develop, or improve our products and services, and consistent with the level of sensitivity of such data. We subject our third-party agents to contractual controls to ensure that they appropriately protect and use the information they access or receive from us.

Please note that the effective security with respect to our Sites depends, in part, on registered using ensuring that any IDs and passwords that you have been issued by us are kept confidential and secure and that you adhere to the restrictions on password and ID-sharing set forth in our Terms of Service.

Other Websites

Our Service may contain links to other websites or services. We are not responsible for the privacy practices of others. When you leave our Service to visit another website or service, please read their privacy statements. This Privacy Policy applies solely to information collected by CultureIQ through the Service.

Questions, Complaints and Dispute Resolution

CultureIQ maintains an active privacy and data protection compliance program. The Data Protection Officer is responsible for implementing and overseeing the administration of this Policy. If you have any questions about this Policy or how CultureIQ processes your information, please email us at privacy@cultureiq.com or contact us at:

Data Protection Officer
CultureIQ
115 West 30th Street, 6th Floor
New York, NY 10001, USA

Any complaints about our adherence to the practices described in this Policy should first be addressed to CultureIQ’s Data Protection Officer at privacy@cultureiq.com.

Children and Privacy

Our Sites contain business-related content and are specifically aimed at and designed for use by adults. We do not knowingly solicit or collect personal information (as defined by the Children’s Online Privacy Protection Act) from or about individuals under the age of 13 years. If we become aware that a visitor is under the age of 13 and has registered without prior verifiable parental consent, we will remove his or her personally identifiable registration information from our files. If you are the parent or guardian of a person under the age of 13 who has provided personally identifiable information to us without your approval, please inform us by contacting us at privacy@cultureiq.com and we will remove such information from our database.

Changes to This Policy

This Policy may change from time to time. If we make any changes to this Policy, we will post any Policy changes on this page. Where we make any material changes to this Policy, we will make a more prominent notice. Your continued use of our Sites following such posts or notices will signal your acceptance of such changes. Please refer to the “Effective Date” above to see when this Policy was last updated.