Privacy Policy

Privacy Policy

This Privacy Policy was last updated on March 1, 2021.

Thank you for visiting goculture.com, goculture.org, and all of their subdomains and aliases (collectively, the “Website”). We at Go Culture International, Inc. (“Go Culture”, “we”, “us”) respect your privacy, are committed to protecting your information, and want you to understand how we collect, use, and share data about you. This Privacy Policy covers our data collection practices and describes your rights to access, correct, or restrict our use of your personal data.

Unless we link to a different policy or state otherwise, this Privacy Policy applies when you visit or use the Go Culture website, mobile applications, APIs, or related services (the “Services”).

By using the Services, you agree to the terms of this Privacy Policy. You shouldn’t use the Services if you don’t agree with this Privacy Policy or any other agreement that governs your use of the Services.

1. What Data We Collect

We collect certain data from you directly, like information you provide yourself, data about your participation in the Services, and data from third-party platforms you connect with Go Culture.  We also collect some data automatically, like information about your device, browser, operating system, date and time of visit, and other similar information.

1.1 Data You Provide to Us

We may collect different data from or about you depending on how you use the Services. Below are some examples to help you better understand the data we collect.

When you create an account and use the Services, including through a third-party platform, we collect any data you provide directly, including:

Account Data	In order to use the Services, you need to create a user account. When you create or update your account, we collect and store the data you provide, like your name, employer, address, username, email address, password, phone number, occupation, gender, race, ethnicity, age, date of birth, and account settings and assign you a unique identifying number (“Account Data”).
Data from Other Sources	We may obtain certain information from other sources, including through your employer and third party services and organizations.  Those platforms and services make information available to us through their APIs. The information we receive depends on what information you (via your privacy settings) or the platform or service decide to give us. If you access or use our Services through a third-party platform or service, or click on any third-party links, the collection, use, and sharing of your data will also be subject to the privacy policies and other agreements of that third party.
Surveys	We may invite you to complete a survey through the Services. If you participate, we will collect and store the data you provide as part of participating, such as your name, email address, postal address, date of birth, or phone number.
Communications and Support	If you contact us for support or to report a problem or concern (regardless of whether you have created an account), we collect and store your contact information, messages, and other data about you like your name, email address, messages, location, username, and any other data you provide or that we collect through automated means (which is detailed below). We use this data to respond to you and research your question or concern, in accordance with this Privacy Policy.

The data listed above is stored by us and associated with your account.

1.2 Data We Collect through Automated Means

When you access the Services, we collect certain data by automated means, including:

System Data	Technical data about your computer or device, like your IP address, device type, operating system type and version, unique device identifiers, browser, browser language, domain and other systems data, and platform types (“System Data”).
Usage Data	Usage statistics about your interactions with the Services, including time spent on pages or the Services, pages visited, features used, your search queries, click data, date and time, referrer, and other data regarding your use of the Services (“Usage Data”).
Approximate Geographic Data	An approximate geographic location, including information like country, city, and geographic coordinates, calculated based on your IP address.

The data listed above is collected through the use of server log files and tracking technologies, as detailed in the “Cookies and Data Collection Tools” section below. It is stored by us and associated with your account.

2. How We Get Data About You

We use tools like cookies, web beacons, and similar tracking technologies to gather the data listed above.  Some of these tools offer you the ability to opt out of data collection.

2.1 Cookies and Data Collection Tools

We use cookies, which are small text files stored by your browser, to collect, store, and share data about your activities across websites, including with Go Culture. They allow us to remember things about your visits to the Website, like your preferred language, and make it easier to use.

Go Culture and service providers acting on our behalf (like Google Analytics and third-party advertisers) use server log files and automated data collection tools like cookies, tags, scripts, customized links, device or browser fingerprints, and web beacons (collectively, “Data Collection Tools”) when you access and use the Services. These Data Collection Tools automatically track and collect certain System Data and Usage Data when you use the Services. In some cases, we tie data gathered through those Data Collection Tools to other data that we collect as described in this Privacy Policy.  Since there is no widely accepted standard for the browser-initiated Do Not Track signal, we do not currently recognize or respond to Do Not Track signals.

2.2 Why We Use Data Collection Tools

Go Culture uses Data Collection Tools for the following purposes described:

• Strictly Necessary: These Data Collection Tools enable you to access the site, provide basic functionality (like logging in or enrolling in courses), secure the site, protect against fraudulent logins, and detect and prevent abuse or unauthorized use of your account. These are required for the Services to work properly, so if you disable them, parts of the site will break or be unavailable.
• Functional: These Data Collection Tools remember data about your browser and your preferences, provide additional site functionality, customize content to be more relevant to you, and remember settings affecting the appearance and behavior of the Services (like your preferred language or volume level for video playback).
• Performance: These Data Collection Tools help measure and improve the Services by providing usage and performance data, visit counts, traffic sources, or where an application was downloaded from. These tools can help us test different versions of the Website, Services, and Materials to assess which features or content users prefer.
• Social Media: These Data Collection Tools enable social media functionality, like sharing content with friends and networks. These cookies may track a user or device across other sites and build a profile of user interests for targeted advertising purposes.

You can set your web browser to alert you about attempts to place cookies on your computer, limit the types of cookies you allow, or refuse cookies altogether. If you do, you may not be able to use some or all features of the Services, and your experience may be different or less functional. To learn more about managing Data Collection Tools, refer to Section 6.1 (Your Choices About the Use of Your Data) below.

3. What We Use Your Data For

We use your data to do things like provide our Services, communicate with you, troubleshoot issues, secure against fraud and abuse, improve and update our Services, analyze how people use our Services, serve personalized advertising, and as required by law or necessary for safety and integrity.

We use the data we collect through your use of the Services to:

• Provide, maintain, and improve the Services;
• Notify you about changes to the Services;
• Allow participation in interactive features of the Services;
• Provide customer support;
• Monitor the usage of the Services;
• Detect, prevent, and address technical issues;
• Communicate with you about your account by:
  • Responding to your questions and concerns;
  • Sending you information, such as by email or text messages, about your progress, new services, new features, special offers, newsletters, and other general information about other goods, services, and events we may offer (which you can opt out of at any time);
  • Sending push notifications to your wireless device to provide updates and other relevant messages (which you can manage from the “options” or “settings” page of the mobile app);
• Manage your account and account preferences;
• Facilitate the Services’ technical functioning, including troubleshooting and resolving issues, securing the Services, and preventing fraud and abuse;
• Solicit feedback from users;
• Administer surveys;
• Identify unique users across devices;
• Improve our Services and develop new products, services, and features;
• Analyze trends and traffic, and track usage data;
• As required or permitted by law; or
• As we, in our sole discretion, otherwise determine to be necessary to ensure the safety or integrity of our users, employees, third parties, the public, or our Services.

4. Who We Share Your Data With

We may share your data with third parties under the following circumstances or as otherwise described in this Privacy Policy:

• With Analytics and Data Enrichment Services: As part of our use of third-party analytics tools like Amazon Web Services or Google Analytics, we may share certain contact information, Account Data, System Data, Usage Data, or de-identified data as needed. De-identified data means data where we’ve removed things like your name and email address and replaced it with a token ID. This allows these providers to provide analytics services or match your data with publicly-available database information (including contact and social information from other sources). We do this to communicate with you in a more effective and customized manner.
• With Service Providers, Contractors, and Other Third-Parties: We share your data with third-party companies who perform services on our behalf, like payment processing, fraud and abuse prevention, data analysis, marketing and advertising services, email and hosting services, and customer services and support. These service providers may access your personal data and are required to use it solely as we direct in order to provide our requested service.
• With Go Culture Affiliates: We may share your data to Go Culture affiliates and other companies which may become part of Go Culture in the future.
• To Administer Surveys: We may share your data as necessary to administer, market, or sponsor surveys you choose to participate in.
• For Security and Legal Compliance: We may disclose your data to third parties if we (in our sole discretion) have a good faith belief that the disclosure is:
  • Permitted or required by law;
  • Requested as part of a judicial, governmental, or legal inquiry, order, or proceeding;
  • Reasonably necessary as part of a valid subpoena, warrant, or other legally-valid request;
  • Reasonably necessary to enforce our Terms of Use, Privacy Policy, and other legal agreements;
  • Required to detect, prevent, or address fraud, abuse, misuse, potential violations of law (or rule or regulation), or security or technical issues; or
  • Reasonably necessary in our discretion to protect against imminent harm to the rights, property, or safety of Go Culture, our users, employees, members of the public, or our Services.
  • We may also disclose data about you to our auditors and legal advisors in order to assess our disclosure obligations and rights under this Privacy Policy.
• During a Change in Control: If Go Culture undergoes a business transaction like a merger, acquisition, corporate divestiture, or dissolution (including bankruptcy), or a sale of all or some of its assets, we may share, disclose, or transfer all of your data to the successor organization during such transition or in contemplation of a transition (including during due diligence).
• After Aggregation/De-identification: we may disclose or use aggregated or de-identified data for any purpose.
• With Your Permission: with your consent, we may share data to third parties outside the scope of this Privacy Policy.

5. Security

We use appropriate security based on the type and sensitivity of data being stored.  As with any internet-enabled system, there is always a risk of unauthorized access, so it’s important to protect your password and to contact us if you suspect any unauthorized access to your account.

Go Culture takes appropriate security measures to protect against unauthorized access, alteration, disclosure, or destruction of your personal data that we collect and store. These measures vary based on the type and sensitivity of the data. Unfortunately, however, no system can be 100% secured, so we cannot guarantee that communications between you and Go Culture, the Services, or any information provided to us in connection with the data we collect through the Services will be free from unauthorized access by third parties. Your password is an important part of our security system, and it is your responsibility to protect it. You should not share your password with any third party, and if you believe your password or account has been compromised, you should change it immediately and contact us with any concerns.

6. Your Rights

You have certain rights regarding the use of your data, including the ability to opt out of promotional emails, cookies, and collection of your data by certain third parties.  You can update or terminate your account from within our Services, and you can also contact us for individual rights requests about your personal data.  Go Culture does not knowingly collect personal data from anyone under the age of 18.  Parents and guardians who believe we’ve unintentionally collected personal data from a child should contact use to ensure that such information is removed from our servers.

6.1 Your Choices About the Use of Your Data

You can choose not to provide certain data to us, but you may not be able to use certain features of the Services.

• To stop receiving promotional communications from us, you can opt out by using the unsubscribe mechanism in the promotional communication you receive or by changing the email preferences in your account. Note that regardless of your email preference settings, we will send you transactional and relationship messages regarding the Services, including administrative confirmations, order confirmations, important updates about the Services, and notices about our policies.
• If you’re located in the European Economic Area, you may opt out of certain Data Collection Tools by clicking the “Cookie settings” link at the bottom of any page.
• The browser or device you use may allow you to control cookies and other types of local data storage. To learn more about managing cookies, visit https://cookiepedia.co.uk/how-to-manage-cookies. Your wireless device may also allow you to control whether location or other data is collected and shared.
• To opt out of allowing Google Analytics, Mixpanel, ZoomInfo, or Clearbit to use your data for analytics or enrichment, see the Google Analytics Opt-out Browser Add-on, Mixpanel Opt-Out Cookie, ZoomInfo’s policy, and Clearbit data claiming mechanism.
• Apple iOS, Android OS, and Microsoft Windows each provide their own instructions on how to control in-app tailored advertising. For other devices and operating systems, you should review your privacy settings on that platform.

If you have any questions about your data, our use of it, or your rights, contact us at privacy@goculture.com.

6.2 Accessing, Updating, and Deleting Your Personal Data

To update data you provide directly, log into your account and update your account at any time.

Even after your account is terminated, we retain your data for as long as we have a legitimate purpose to do so (and in accordance with applicable law), including to assist with legal obligations, resolve disputes, and enforce our agreements. We may retain and disclose such data pursuant to this Privacy Policy after your account has been terminated.

To request to access, correct, or delete your personal data, please submit these requests by emailing privacy@goculture.com or writing to us at Go Culture, Attn: Privacy/Legal Team, 2591 Lakeside Pkwy, Suite 100, Flower Mound TX 75022. Please allow up to 30 days for a response. For your protection, we may require that the request be sent through the email address associated with your account, and we may need to verify your identity before implementing your request. Please note that we retain certain data where we have a lawful basis to do so, including for mandatory record-keeping and to complete transactions.

6.3 Our Policy Concerning Children

We recognize the privacy interests of children and encourage parents and guardians to take an active role in their children’s online activities and interests. Individuals younger than 18 years of age, but of the required age for consent to use online services where they live (for example, 13 in the US or 16 in Ireland), may not set up an account, but may have a parent or guardian open an account. Individuals younger than the required age for consent to use online services may not use the Services. If we learn that we’ve collected personal data from a child under those ages, we will take reasonable steps to delete it.

Parents who believe that Go Culture may have collected personal data from a child under those ages can submit a request that it be removed to privacy@goculture.com.

7. Jurisdiction-Specific Rules

If you live in California, subject to certain limitations, you have certain rights related to accessing and deleting your data, to know how we use and to whom we disclose your data, and to not be discriminated against for exercising these rights.

7.1 Users in California

Users who are California residents have certain rights under the California Consumer Privacy Act, (“CCPA”). If you are an eligible California user, included in these rights are:

• “Right to Know” — You have the right to request to know more about the categories and specific pieces of personal information that we have collected about you and access a copy of your personal information.
• “Right to Deletion” — You have the right to request deletion of personal information that we have collected about you.
• “Right to Non-Discrimination” — If you choose to exercise any of your rights under CCPA, Go Culture will treat you like all other users. In other words, there is no penalty for exercising your rights under CCPA.
• “Right to Opt-Out” – You have the right to opt out of the sale of your personal information.

To exercise any of these rights under CCPA, please email privacy@goculture.com or write to us at Go Culture, Attn: Privacy/Legal Team, 2591 Lakeside Pkwy, Suite 100, Flower Mound TX 75022. CCPA allows you to designate an authorized agent to make these requests on your behalf. For your protection, we may require that the request be sent through the email address associated with your account, and we may need to verify you and/or your agent’s identity before fulfilling your request.

Additionally, for more information about the personal information we collect and how we collect it, please see the sections above entitled “What Data We Get” and “How We Get Data About You.”

To learn about the business and commercial purposes for which your personal information is collected and the categories of service providers who have access to your personal information, please see the sections above entitled “What We Use Your Data For” and “Who We Share Your Data With.”

7.2 Users in Nevada

Go Culture does not sell its users’ personal information or personal data. Nonetheless, Nevada residents have the right to submit a request that we do not sell your covered personal information, which you can do by emailing privacy@goculture.com or writing to us at Go Culture, Attn: Privacy/Legal Team, 2591 Lakeside Pkwy, Suite 100, Flower Mound TX 75022.

7.3 Users Outside of the U.S.

In order to provide the Services to you, we must transfer your data to the United States and process it there. By visiting or using our Services, you consent to storage of your data on servers located in the United States. If you are using the Services from outside the United States, you consent to the transfer, storage, and processing of your data in and to the United States or other countries. Specifically, personal data collected in the United Kingdom (“UK”), Switzerland, and the European Economic Area (“EEA”) is transferred and stored outside those areas. Additionally, if you are located in the EEA, UK, or Switzerland, you also have the right to lodge a complaint with your data supervisory authority.

Personal data is also processed outside of the UK, Switzerland, and the EEA by Go Culture, or our service providers, including to process transactions, facilitate payments, and provide support services as described in Section 4. We have entered into data processing agreements with our service providers that restrict and regulate their processing of your data on our behalf. By submitting your data or using our Services, you consent to this transfer, storage, and processing by Go Culture and its processors.

8. Updates & Contact Info

8.1 Modifications to This Privacy Policy

From time to time, we may update this Privacy Policy. If we make any material change to it, we will notify you via email, through a notification posted on the Website, or as required by applicable law. Unless stated otherwise, modifications will become effective on the day they are posted.

As permitted by applicable law, if you continue to use the Services after the effective date of any change, then your access or use will be deemed an acceptance of (and agreement to follow and be bound by) the revised Privacy Policy. The revised Privacy Policy supersedes all previous Privacy Policies.

8.2 Interpretation

Any capitalized terms not defined in this Privacy Policy are defined as specified in Go Culture’s Terms of Use. Any version of this Privacy Policy in a language other than English is provided for convenience. If there is any conflict with a non-English version, you agree that the English language version will control.

8.3 Questions

If you have any questions, concerns, or disputes regarding our Privacy Policy, please feel free to contact our privacy team at privacy@goculture.com. You can also send postal mail to us at Go Culture, Attn: Legal, 2591 Lakeside Pkwy, Suite 100, Flower Mound TX 75022.