Privacy Policy

CultureAlly Software Inc. ("We", "Us", "Our" and terms of similar meaning) is a B2B Software provider that delivers customized diversity and inclusion learning content to our Customer (“Employer”) employees (“Users”) through our web application. 

Users are notified by email (and other communication tools) when new learning content (“Content” or “Learning Content”) is available and can be accessed through Our web application (the “Service”). 

We take privacy rights very seriously. We are committed to transparently describing our privacy practices, including how we collect, use and disclose: (a) personal or personally identifiable information ("Personal Information"); and (b) other data we obtain from Users using the Service as more fully described below ("Data"). 

We encourage you to read our Terms of Service and this privacy policy ("Privacy Policy") before accessing and/or using the Service.  By accepting the Terms of Service and Privacy Policy and using the Website or Service, Users expressly consent to our collection, use and disclosure of Personal Information and Data in accordance with this Privacy Policy as stated hereunder. This Privacy Policy is incorporated into the Terms of Service.

  • Each User has an account and receives Content through Our Service. To use certain Service features We will ask Users to share certain Personal Information depending on the feature:

    To Create a User Account: Users will be provided with a User account and create a password in order to access and use the Service. We will collect User’s name and contact information.

    User Profile Data: We may also ask for your learning preferences (content delivery day, content topics, videos or articles), time zone and location. We ask for Users to share their interests such as sports, entertainment, politics etc. (“User Interests”). User Interests are not personally identifiable and not shared on an individual basis with the Employer. The purpose of learning User Interests is to enhance User engagement with Learning Content by improving Content and delivering Content more relevant to User’s interests.

    Surveys and other User research: We may collect and use User feedback about our Service to better understand Users and enhance our Service. The information delivered through third parties such as Typeform, Google Forms or Survey Monkey is used in an aggregated, non-personally identifiable form. We use this information to help us understand our Users, and to enhance our Service and future product offerings.

    Demographic Information: may include information regarding your race, ethnicity, age, gender, sexual orientation and other statistical/demographic data. All demographic data is used in an aggregated, non-personally identifiable form. This data is sometimes shared back with the Employer in aggregate form (no less than 5 people per group).

    You have the option to choose ‘prefer not to disclose’ in this questionnaire.

  • We may share your Personal Information and Data with third parties for specific purposes including, but not limited to, the following:

    Metabase: Analytics graphing to we use to monitor software interactions

    Bubble.io: Our hosting platform for the software which stores all Data using AWS.

    Typeform, Google Form: We use to deliver and share surveys.

    GSuite: We may store reports and Data here

    CRM: To store and track client information and contract information

    Such third parties are engaged by Us to host, store and analyze Data more efficiently. We do not sell any Personal Information or Data to any third parties and we do not target Users for sales or advertising based on User’s Personal Information.

    Data Collected Automatically

    When You use the Website and Service, it automatically receives and records Data from your device, including, without limitation, your general location, IP address, browser type (if applicable), operating Data, and Application IDs, "cookie" information, and the page you requested. Unless otherwise stated in this Privacy Policy, We only use this Data in aggregate form.

    "Cookies" and similar technologies are small files placed on your computer and devices that assist us in providing the Service. We and our third-party service providers use cookies and similar technologies to provide and personalize the Service and analyze use. You can disable cookies in your browser settings, however, if you do so, some parts of the Service may not function properly.

    Analytics: We use Google Analytics to track the above.

    Usage Data: may include information about how frequently Users use/interact with the Service. We track every page load and every button click. We may share the frequency and length of engagement of identifiable individual User’s with Employers but not specific answers on an identifiable User basis with Employers.

    User Engagement: We track all interactions with the CultureAlly software. We share on aggregate interaction trends back with the Employer. We use this data at CultureAlly to make software and experience improvements.

  • General Disclosure. We may share your Personal Information and Data with third parties only in the ways that are described in this Privacy Policy and in accordance with your consent.

    Anonymized Aggregated Data. We may aggregate and anonymize Data and use and disclose it for a variety of purposes, including analytics. However, in these situations, we do not disclose any Personal Information.

    Laws and Jurisdictions. Notwithstanding anything to the contrary in this Privacy Policy, we may preserve or disclose Personal Information and Data if we believe that it is reasonably necessary to comply with a law, regulation or legal request; to protect the safety of any person; to address fraud, security or technical issues; or to protect our or any other person’s or entity’s rights or property. However, nothing in this Privacy Policy is intended to limit any legal defenses or objections that you may have to a third party’s, including a government’s, request to disclose your Personal Information and Data.

    Storing and Processing Information and Data. In some cases, Personal Information and Data that we collect may be stored or processed outside of Canada. When that occurs, we continue to protect the Personal Information and Data with appropriate safeguards and data export requirements, but it may be subject to the legal jurisdiction of those countries and governmental authorities in those countries.

    Service Providers. We may use the services of unrelated service providers (collectively, “Third Parties") in connection with our provision of the Service, including, without limitation, off premise data hosting and communication services. We may disclose your Personal Information and Data to the Third Parties in the course of our use of their services solely in connection with their provision of the services. We take care to use Third Parties that we believe are reputable and capable of performing the services we require of them, including, without limitation, the handling of confidential information and Personal Information and Data and the compliance with all applicable laws.

    General Retention Policy. We keep Personal Information and Data for as long as it is required for the purposes for which it was collected, in accordance with the applicable laws. Notwithstanding the foregoing, We may periodically de-identify and delete (a) Information from collected Data in unused Accounts and Logins; and (b) unnecessary information from Data collected elsewhere on and/or through the Service. Subject to the terms and conditions of this Privacy Policy and applicable law, we may delete unused Accounts and the Personal Information and Data associated with them.

  • Call Recording: We may monitor and record (with consent) our telephone conversations/zoom meetings for training and quality assurance purposes.

  • We strive to protect your Personal Information and Data by putting in place a range of technical and organizational measures to safeguard and secure the Personal Information and Data we receive from you, including without limitation, security technologies. We are continuously utilizing security measures to protect your Personal Information and Data from unauthorized access or against loss, misuse or alteration. Despite our efforts, we cannot guarantee the security of any Personal Information and Data.

  • Except as otherwise expressly included in this Privacy Policy, this Privacy Policy only addresses the use and disclosure of Personal Information and Data we collect from you. To the extent that you disclose Personal Information and Data directly to other parties, different rules may apply to their use, collection and disclosure of Personal Information and Data.

  • We may amend this Privacy Policy from time to time. The use of Personal Information and Data we collect is subject to the Privacy Policy and the Terms of Service. If we make any material changes in the way we use Personal Information and Data, we will post a notice on the Service, but in all respects, We will only use Your Personal Information in accordance with Canada’s Personal Information Protection and Electronic Documents Act ("PIPEDA") and other relevant provincial privacy legislation. You are bound by any changes to the Privacy Policy and the Terms of Service when you use the Service after such changes have been first posted.

  • It is our goal to make our privacy practices easy to understand. If you have questions, concerns or if you would like more detailed information, please email us at help@cultureally.com.

Updated December 2022