PRIVACY POLICY

Culcha UG (haftungsbeschränkt) – Privacy Policy

1. Subject of the Agreement

The protection of your privacy and your data is our top priority and has a significant impact on our technical architecture, the selection of our partners, programming tools and structures as well as on many of our general business decisions.

As the controller, Culcha UG has implemented numerous technical and organizational measures to ensure the best possible protection of personal data processed through this website.

By using the website www.culcha.com and affiliated websites (the “Website”), you acknowledge that you have read, understood and agree to be bound by this Privacy Policy.


The following information provides an overview of what happens to your personal data when you visit our Website.

1.1 Introduction

“Controller” under the General Data Protection Regulation (“GDPR”) with respect to any personal data you submit to us through the Culcha Services (or otherwise) is Culcha UG (haftungsbeschränkt), a company registered with the AG Charlottenburg (Berlin) (registration number HRB 210645) with its registered office at Linienstraße 130, 10115 Berlin, Germany (“Culcha”).

 

You can reach Culcha UG (haftungsbeschränkt) by phone at +49 30 44324920 or at info@culcha.com.

 

The personal data that you submit to us via the Culcha website (or otherwise) will be processed by us or by data processors designated by us to carry out the processing on our behalf.

 

Culcha respects your right to privacy and recognizes the importance of protecting the information we collect about you. The privacy policy set out here is intended to set out how we collect, use and store your personal and non-personal data in accordance with the requirements of the GDPR.

 

If you would like to know what personal and non-personal data we hold about you, or have any other questions regarding this Privacy Policy, please contact us by email at privacy@culcha.com. However, we will require proof of your identity before releasing any data.

2. What information does Culcha collect and use and when?

2.1 Use of our website

2.1.1 General

Visiting our website is possible without entering personal data. However, data is automatically collected through log files and cookies.

 

When you access or use our website, we collect the following non-personal data:

  • Request (name of the requested file), if applicable.
  • Browser type/version (e.g.
  • Internet Explorer 11.0)
  • Browser language (e.g.: German)
  • Operating system (e.g.: Windows 7)
  • Javascript active
  • Cookies On / Off
  • Color settings
  • Referrer URL(the page
    visited before)
  • Time of access
  • IP address and hostname of the accessing computer

 

Culcha may also keep log files that contain IP addresses. In general, we use log files to monitor traffic on our website and to troubleshoot technical problems. In case of abuse of our website by users, we reserve the right to block certain IP addresses.

We use the data listed under point 2.1.1. to optimize your experience with the Culcha services. The legal basis for this is Art 6 para 1 p.1 lit f DSGVO. The collection of the data listed under point 2.1.1. is mandatory. The legitimate interest lies in the fact that without this basic data it would not be possible to provide the Culcha services properly, e.g. to ensure a smooth connection setup, a comfortable use or an evaluation of the system stability.

2.1.2 Cookies

We use cookies to ensure that the Culcha services function optimally. Cookies are small text files that are stored by our websites on your internet-enabled device. Cookies allow us to store data about your visit to our website (e.g., when you access it) on your computer and then retrieve it. We may use cookies to provide user-specific content to you, to monitor website usage, or to facilitate your visits to our services (for example, by storing your login information).

 

We may also store Flash cookies (“Local Shared Objects”) on your Internet-enabled device if the Website uses Adobe Flash. Flash cookies are small files similar to cookies and are used to store website settings to personalize the look and feel of the website. Flash cookies collect only aggregate data (metadata). Like regular cookies, Flash cookies are stored as small text files on your Internet-enabled device.

 

Collecting the data explained in this point 3.1.2 is not mandatory. Most browsers are set to automatically accept cookies when you visit a website. However, you can disable cookies or set the browser to notify you when cookies are set. For more information on how to reject cookies via your browser settings, please refer to the “Help” section of your Internet browser (or alternatively at http://www.aboutcookies.org).

 

Insofar as the use of cookies results in the processing of personal data, this is based on the legal basis of Art. 6 (1) p. 1 lit. f DSGVO. The processing serves our legitimate interests as described above to make the Culcha website more user-friendly, more effective and more secure. By continuing to use the website, you consent to our use of cookies as set out in this privacy policy.

 

The following links explain how to access cookie settings in different browsers:

 

Visit the following website to prevent Google Analytics from collecting you on all websites (opt-out):

http://tools.google.com/dlpage/gaoptout.

2.1.3 Analytical Metrics Tools and Other Technologies.

Culcha may also use its own or third party analytic metrics tools or other analytic technologies to collect the data identified in this Privacy Policy. We may use these technologies to generate user-specific content for you and to monitor your use of the Culcha Services.

Our website uses Google Analytics. Information about how Google uses this data and how to opt out can be found at this link:

https://www.google.com/policies/privacy/partners/.

The collection of the data explained in this point 3.1.3. is not mandatory.

2.2 Registration function

We offer you the possibility to register on our website. The data entered in the course of this registration, which can be seen from the input mask of the registration form, is collected and stored exclusively for the use of our offer. With your registration on our site, we will also store your IP address and the date and time of your registration. This serves as a safeguard for us in the event that a third party misuses your data and registers on our site with this data without your knowledge. Your data will not be passed on to third parties (with the exception of order processors, see below). A comparison of the data collected in this way with data that may be collected by other components of our site does not take place.

2.3 Newsletter

On our Side we offer you (in the future) the possibility to subscribe to our newsletter. With this newsletter we inform you about our offers at regular intervals. To receive our newsletter, you need a valid e-mail address. We will check the e-mail address you have entered to ensure that you are indeed the owner of the e-mail address provided or that its owner is authorized to receive the newsletter. With your registration for our newsletter, we will store your IP address and the date and time of your registration. This serves as a safeguard on our part in the event that a third party misuses your e-mail address and subscribes to our newsletter without your knowledge. No other data is collected on our part. The data collected in this way is used exclusively for receiving our newsletter. It is not passed on to third parties (with the exception of order processors, see below). A comparison of the data collected in this way with data that may be collected by other components of our site also does not take place. You can cancel your subscription to this newsletter at any time. Details of this can be found in the confirmation email and in each individual newsletter.

2.4 Contact Option

On our website, we offer you the opportunity to contact us by e-mail and/or via a contact form. In this case, the information you provide will be stored for the purpose of processing your contact. Your data will not be passed on to third parties. A comparison of the data collected in this way with data that may be collected by other components of our site also does not take place.

2.5 Misuse

In case of reasonable suspicion that Culcha services are being or have been misused, Culcha may collect further personal and non-personal data in order to verify or refute this suspicion within the framework of the applicable legal regulations and taking into account your reasonable data protection interests. We will use this information to comply with applicable laws and to enforce our rights under civil and criminal law against such users.

2.6 Crash reports, customer support

In case of technical or commercial issues, you have the options to send crash reports or contact customer support.

In addition to the data listed in the items above, the information you provide may include:

  • Crash reports
  • more detailed machine specifications / technical specifications
  • screenshots
  • any other data you may provide.

Collection of the information listed in this Item 2.6. is not mandatory. However, it is possible that without this data we will not be able to correct errors or technical or commercial problems you may have. For legal reasons, this data will be stored as long as necessary within the applicable limitation periods.

2.7 Marketing data / marketing information

In order to provide you with marketing information and special offers, we may use the collected data listed in the points above, subject to your consent. This use of collected data listed in 2.1.2 to 2.6 above is not mandatory. You can object to the use of your data for these purposes at any time.

3. Does Culcha share data with third parties?

Except as expressly set forth in this Privacy Policy, Culcha will never share your personal data with third parties without your consent.

Culcha may share your personal data with:

  • Third parties in the form of service providers under our control (“Commissioned Data Processors” under the GDPR) and for monitoring purposes where such disclosure is necessary or helpful for us to provide the Culcha Services to you, and such third parties are contractually bound to use your Personal Data and/or Non-Personal Data under the same restrictions as set forth in this Privacy Policy. See sections 3.1 – 3.3 below for more details.
  • any person to whom disclosure becomes necessary to enable us to enforce our rights under this Privacy Policy or our Terms and Conditions (including, for example, law enforcement authorities in the case of fraud)
  • any authorities to whom we are required by law to disclose your personal data and non-personal data (for example, tax authorities with respect to commercial transactions).

 

We will not disclose your personal data to any other entity or person without your express consent.

3.1 Google Analytics

Our website uses Google Analytics, a web analytics service provided by Google, Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043 USA, www.google.com (“Google Analytics” or “Google”). Google Analytics uses cookies that are placed on your computer to help analyze your use of our public website. The data generated by these cookies, such as the time, place and frequency of your visits to our website, including your IP address, are transmitted to Google’s location in the USA and stored there.

 

When using Google Analytics, our website uses the extension “anonymizeIp”. This shortens your IP address from Google and thus anonymizes it before it is passed on from EU/EEA member states. Google uses this data to analyze your use of our website, compile reports on internet activity for us and provide other services relating to our website. We use Google Analytics only on our public website, not on our dashboard after login.

 

Google may also transfer this data to third parties to the extent required by law or if third parties process this data on Google’s behalf. Google states that your IP address will never be linked to any other data stored by Google. You can prevent cookies from being set by adjusting your browser settings accordingly, as explained elsewhere in this privacy policy. Please note, however, that the full functionality of our website may then no longer be available to you.

 

Google Analytics also offers a deactivation add-on for most current browsers that gives you more control over the type of data Google collects on websites you visit. The add-on tells the JavaScript used by Google Analytics (ga.js) not to share information about website visits with Google Analytics. However, the browser disable add-on offered by Google Analytics does not prevent data transmission to us or to other web analytics services we may use.

Google Analytics also uses electronic graphics known as tracking pixels (web beacons, sometimes called single-pixel images), which are used alongside cookies to compile aggregate statistics to analyze the use of our website.

 

For more information on how to install the above-mentioned browser add-on, please visit this link: https://tools.google.com/dlpage/gaoptout?hl=en.

 

Further information and the applicable privacy policy of Google can be found at https://www.google.com/intl/en/policies/privacy/ and at http://www.google.com/analytics/terms/us.html. Further explanations about Google Analytics can be found at the following link: https://www.google.com/analytics/.

3.2 MailChimp

We use a service called Mailchimp to send transactional inquiry emails or to manage subscriber lists for email marketing and to send monthly newsletters to our subscribers. Mailchimp is an online marketing platform operated by The Rocket Science Group LLC, a company headquartered in the state of Georgia in the USA.

 

Mailchimp automatically places tracking pixels (single pixel gifs, also known as web beacons) in every email sent to our users. These are tiny graphics that contain unique markers/identifiers that allow us and our users to recognize when an addressee has opened an email or clicked on certain links. These technologies capture the email address, IP address, and date and time associated with each addressee that opens and clicks for a campaign. We use this data to generate reports for us on how an email campaign is performing and what actions the addressees have taken.

 

Each newsletter includes a link at the bottom for quick and easy unsubscribing; this allows users to opt out at any time.

 

Your email address will remain in Mailchimp’s database as long as we continue to use their services for email marketing or until you request to be removed from the list. You can do this by unsubscribing via the unsubscribe links provided in each newsletter email we send to you, or by requesting deletion via email. If you wish to request deletion via email, please contact us using the email account registered on the mailing list.

 

As long as your email address is in the MailChimp database, you will receive periodic (approximately monthly) newsletter-style emails from us.

 

More information and the applicable privacy policy of MailChimp can be found at https://mailchimp.com/legal/ and at https://mailchimp.com/legal/terms.

3.3 Wix.com

Our website is hosted on the Wix.com platform. Wix.com provides us with the online platform through which we can communicate our products and services to you. Your data may be stored through Wix.com’s data store, databases, and general Wix.com applications. They store your data on secure servers behind a firewall.


Our website, https://www.culcha.digital/, was created with Wix.com Ltd. Namal 40, 6350671 Tel Aviv, Israel (“Wix”) and is also hosted on their servers. Wix takes physical, electronic and procedural safeguards to protect the personal information of its users and website visitors.

Before sending us a message using the message form, please read Wix’s Privacy Policy, which is available here http://de.wix.com/about/privacy.


Wix stores and processes personal data in the United States, Europe, Israel, or other jurisdictions – either itself or through its affiliated companies and service providers. The data storage providers with whom Wix works are contractually obligated to protect your data. Among other things, Wix.com complies with the EU-US and Swiss-US Privacy Shield data storage providers to further protect its users’ data.

Wix.com is responsible for processing personal data received under the Privacy Shield Framework and then transferring it to a third party acting on behalf of Wix.com as an agent on its behalf. Wix.com acts in accordance with the Privacy Shield Principles in any onward transfer of Personal Data from the EU, including the onward transfer liability provisions.

With respect to Personal Data contained or transferred pursuant to the Privacy Shield Framework, Wix.com is subject to the regulatory and enforcement powers of the U.S. Federal Trade.


Wix and its third-party vendors may use cookies and similar tracking technologies on its Services. These technologies are used primarily for the purposes of stability, security, functionality, performance, and advertising. You may block, opt-out, or otherwise manage such tracking technologies yourself through your browser settings or other sources – but we want you to know that doing so may affect your use of the Services.

4. How does Culcha protect your personal data?

The security of your personal data is very important to us. We comply with the GDPR to protect your personal data transmitted to us, both during transmission and storage.

The personal data you provide to us is either collected and processed by us or on the part of the data processors we use to carry out the processing on our behalf in accordance with Article 28 of the GDPR. We have implemented physical, electronic and operational measures to help secure your personal data and prevent unauthorized access, use, alteration, modification and/or disclosure.

Your personal information is stored on servers owned by Microsoft, Inc. and/or other contracted data processors under Sections 3.1 to 3.3 above and/or your respective affiliates, all of which are subject to our contractual control under Section 28 of the GDPR for data protection purposes. Any personal information you provide to us in accordance with this Privacy Policy will be adequately protected by this Privacy Policy, our contracts with Microsoft, or any other third party service providers that implement the requirements of Section 28 of the GDPR.

If you have any questions about security on our website, please contact us at privacy@culcha.com.

5. Review and correction of your data

You may correct, update or delete your account information at any time by please contacting us at privacy@culcha.com. We will be happy to review, update or delete your information as applicable.

6. Third party websites

Our website may contain advertisements or services that link to other websites such as Twitter, Facebook and YouTube. The fact that we link to third party websites does not constitute an endorsement, authorization or opinion regarding any association with that third party website or the operator of that third party website. When you click on a link from a third party website, including an advertisement, you are leaving the Culcha site you are currently visiting and going to the selected website. Because we cannot control the activities of third parties, we are not responsible for the use of personal information by such third parties, and we cannot ensure that they will follow the same privacy and security policies as Culcha. Check the privacy policies of other service providers from whom you request services. If you visit a third party website that links to a Culcha service, you should ask about that third party website’s privacy policy before providing any personal information and personally identifiable information.

We may receive some information that you leave on third party websites when you navigate to them via an advertisement within one of the Culcha Services. Both we and the owner or operator of that third party website is the data controller with respect to such data.

7. Updates to the Privacy Policy

We reserve the right to change this Privacy Policy at any time, so please review it regularly. Changes and clarifications will be effective immediately after they are posted on the Website. If we make material changes to this policy, we will notify you of those changes here. This will help you understand what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it.

8. Contact

If you have any questions or concerns regarding this policy, you can contact us as follows: Privacy Officer at privacy@culcha.com.