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Effective as of October 26, 2021

CultureFire (“us”, “we”, or “ours”) is committed to respecting the privacy of its users. Our Privacy Policy (“Privacy Policy”) is designed to help you (“Customer”) understand how we collect, use, disclose, transfer, store, and safeguard the information you provide to us (“Customer Data”) and to assist you in making informed decisions when using our Service.

For purposes of this Privacy Policy, “Site” refers to the CultureFire  website, which can be accessed at “Service” refers to CultureFire’s product and services accessed via the Site, in which users can access, input, retrieve, and display their Customer  information, including information relating to customers, vendors, employees, contractors, and other individuals. “You” refers to you, the Customer, as a user of our Site or our Service. “Authorized User” refers to a person you authorize to use the Service.

By accessing our Site or our Service, you accept our Privacy Policy and Terms and Conditions (as set forth at the bottom of our Site), and you consent to our collection, use, disclose, transfer, store and secure your Personal Information as described in this policy.

This Privacy Policy applies to the processing of Customer Data collected by us or inputted by you (a) when you use the CultureFire Service as an authorized user through the Site or through the CultureFire app, (b) when you direct your Authorized User to input their information through the Site or through the CultureFire app, or (c) when you direct us to input information for any individual into the Site or Service. This Privacy Policy further advises you of your rights and choices regarding your Customer Data. This policy does not cover or apply to the practices of any third-party organizations that you or your organization may engage or any other third parties outside the control of CultureFire. Authorized users of the Customer of the CultureFire shall be 18 years or older.


We collect “Non-Personal Identifiable Information” (“Non-PII”) and “Personal Identifiable Information” (“PII”).  Non-PII includes information that cannot be used to personally identify you, such as anonymous usage data, general demographic information we may collect, referring/exit pages and URLs, platform types, preferences you submit and preferences that are generated based on the data you submit and number of clicks. Non-PII may further include information health status information (e.g., symptoms), travel information, testing information, and other pertinent-health related information. PII includes information that can be used to personally identify you, such as your name, title, email, phone number, residential address, employment history, visual information (e.g., photo or video information), date of birth, marital status, name of spouse, and possibly information relating to a potential exposure to another individual, which you may submit to us through the Product at the Site.

1.   Information collected via Technology

To activate the Service you do not need to submit any Personal Information other than your email address. To use the Service thereafter, you determine what information you want to input into the Product, which may or may not include PII.

2.   Information collected through Registration

We may further collect information from registration materials; information from the Statement of Work; requests for additional information forms or communications with us; support; attachments uploaded to the CultureFire interface; product and service information; emails from you, and information relating to our blog and/or newsletter.

3.   Ongoing collection of Information from Customer 

Through the active use of the Site and/or Service, we will continue to collect Non-PII and PII specifically inputted from your or inputted by us at your direction.

4. Information relating to Billing and Account Information

If you sign up for a paid service or subscription with us, we collect your billing information (“Account”) including the name of the contact person for billing and your billing address. We will never disclose your identifiable Account Information to third parties for commercial or other purposes not permitted by this Privacy Policy. We use your Account Information to bill you for the Services, measure our business success, to identify the most effective ways to reach you, to more effectively meet your needs and requests for certain new product features and services, and to contact you about product upgrades. We may also use your Account Information in order to provide you with support which you have requested in connection with your Account and the Software/Services, or to identify services or products that we may provide at your request.

If you have chosen to receive email communications, you will receive our news and announcements from time to time. You may update or change your Account Information with CultureFire at any time by logging into your Account and updating such information.

To the extent permitted by applicable law, we may also use and disclose your Account Information

(1) if required by court order, legal process or applicable law,

(2) in connection with suspension, termination or expiration of the Terms of Service as set forth in the Terms of Service; and

(3) as necessary to enforce or defend CultureFire intellectual property or other rights, as necessary in connection with legal action, or, in exigent circumstances, to protect the safety of CultureFire, CultureFire’ customers or the public.

5. Other Information Collected by CultureFire

We may automatically receive and record information on our server logs from your browser including your IP address, browser type, referrer page, domain name, access time, entry page, exit page, operating system type, and search engine keywords.


We host and process Customer Data in connection with your Account. By creating, maintaining, using or disclosing Customer Data in connection with the Site and Service, you acknowledge that

(a)  you are the owner of such Customer Data, 

(b) you have the right, authority or consent to control such Customer Data, and/or

(c) you have the right, authority or consent directly from the Individual to control such Customer Data,

AND you authorize CultureFire and its employees, agents and contractors to take such actions with respect to Customer Data as described in this Privacy Policy.



Except as otherwise stated in this Privacy Policy, we do not sell, trade, rent or otherwise share for marketing purposes your PII with third parties without your consent. We do share PII with vendors who are performing services for CultureFire, such as the servers for our email communications who are provided access to the Authorized User’s email address for purposes of sending emails from us. Those vendors use your PII only at our direction and in accordance with our Privacy Policy.

In general, the PII you provide to us is used to help us communicate with you. For example, we use Personal Information to contact users in response to questions, solicit feedback from users, provide technical support, and inform users about promotional offers.

We may share PII with outside parties if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to meet any applicable legal process or enforceable governmental request; to enforce applicable Terms and Conditions, including investigation of potential violations; address fraud, security or technical concerns; or to protect against harm to the rights, property, or safety of our users or the public as required or permitted by law.


In general, we use Non-PII to help us improve the Service and customize the user experience. We also aggregate Non-PII in order to track trends and analyze use patterns on the Site. This Privacy Policy does not limit in any way our use or disclosure of Non-PII and we reserve the right to use and disclose such Non-PII to our partners, advertisers and other third parties at our discretion.

In the event we undergo a business transaction such as a merger, acquisition by another company, or sale of all or a portion of our assets, your PII may be among the assets transferred. You acknowledge and consent that such transfers may occur and are permitted by this Privacy Policy, and that any acquirer of our assets may continue to process your PII as set forth in this Privacy Policy. If our information practices change at any time in the future, we will post the policy changes to the Site so that you may opt out of the new information practices. We suggest that you check the Site periodically if you are concerned about how your information is used.


We implement security measures designed to protect your information from unauthorized access. Your account is protected by your account password and we urge you to take steps to keep your personal information safe by not disclosing your password and by logging out of your account after each use. CultureFire facilitates and provides tools for you to securely manage access to and use your Customer Data, including sharing such information to CultureFire directly or making such information available to an Authorized User. You control whether and what Customer Data to create, maintain, use, or disclose in connection with your Account. CultureFire is happy to assist you in setting up your Account, including an initial set up in which we input Customer Data at your request.You are ultimately responsible for granting access to Authorized Users, publishing, sharing, updating, or deleting such Customer Data in your Account. We will  maintain administrative, physical, and technical safeguards at a commercially reasonable level to ensure the safety and confidentiality of your PII Data and Non-PII Data. Those safeguards will include measures for preventing unauthorized access, use, modification, deletion and disclosure of Customer Data by our personnel. We will never share PII Data with any third party unless required by a governmental authority. Before sharing Non-PII Data, which shall be stripped of any PII, with any of our third party service providers, we will ensure that the third party maintains, at a minimum, reasonable data practices for maintaining the confidentiality and security of Customer Data and preventing unauthorized access. However, these measures do not guarantee that your information will not be accessed, disclosed, altered or destroyed by such protections. By using our Service, you acknowledge that you understand and agree to assume these risks.


You have the right at any time to prevent us from contacting you for marketing purposes.  When we send a promotional communication to a user, the user can opt out of further promotional communications by following the unsubscribe instructions provided in each promotional e-mail. You can also indicate that you do not wish to receive marketing communications from us in the opt-out page of the Site. Please note that notwithstanding the promotional preferences you indicate by either unsubscribing or opting out in the opt-out page of the Site, we may continue to send you administrative emails including, for example, periodic updates to our Privacy Policy.


As part of the Service, we may provide links to or compatibility with other websites or applications. However, we are not responsible for the privacy practices employed by those websites or the information or content they contain. This Privacy Policy applies solely to information collected by us through the Site and the Service. Therefore, this Privacy Policy does not apply to your use of a third party website accessed by selecting a link on our Site or via our Service. To the extent that you access or use the Service through or on another website or application, then the privacy policy of that other website or application will apply to your access or use of that site or application. We encourage our users to read the privacy statements of other websites before proceeding to use them.

In certain circumstances, CultureFire facilitates your ability to publish or share data or materials. You are solely responsible for any data or materials which you publish or share in connection with your CultureFire account. By publishing or sharing data or materials with any third party or websites, you represent that you are the owner of such data or materials, or that you have the right or authority to publish or share such data or materials. CultureFire is not responsible for any data or materials which may be published or shared with other websites or third parties.


CultureFire’ Use of Third Party Company or Individual

CultureFire may engage third party companies or individuals as service providers or business partners to process Customer Data and support our  business. These third parties may, for example, provide virtual computing and storage services, or we may share business information to develop strategic partnerships with third party service providers to support our common customers. Each subprocessor assures that it has the appropriate privacy, security and confidentiality practices in place to ensure the privacy of Customer Data. To date, CultureFire is currently uses the following infrastructure subprocessors to support delivery of our Services:

In limited circumstances, CultureFire or its employees, agents and contractors may have access to, use or disclose Customer Data in order to provide the Services. The following are some, but not all, circumstances under which CultureFire, and its employees, agents and contractors may have access to, use or disclose Customer Data in order to provide the Services:

  1. To host, process, conduct data backups and maintenance, upgrades, debugging, troubleshooting, programming and other related administrative or technical activities required to provide the Services;

  2. To conduct security activities related to preventing, detecting, investigating and responding to security incidents, threats or vulnerabilities, implementing security safeguards and controls and other activities related to security;

  3. To respond to or provide service, support, address technical issues, and other related activities in connection with your Account and the Services, or which you have otherwise consented to;

  4. In response to court orders, legal process, or as otherwise required by applicable law. We will notify you and provide you with the opportunity to seek protection against disclosure in accordance with the terms and conditions set forth in the Terms of Service;

  5. In connection with suspension, termination or expiration of the Terms of Service as set forth in the Terms of Service, or as necessary to resolve any dispute related to the Terms of Service;

  6. To conduct business-related analyses of the integrity and validity of the Services; or

  7. When we act under exigent circumstances, to the extent permitted by applicable law, to protect the safety of customers or the public.

Collection and Use of Customer Data Subject to Regional Data Protection Laws

In certain circumstances, customers may have Customer Data which is subject to additional local, national, regional or international data protection laws (“Data Protection Laws”), including but not limited to (i) the Health Insurance Portability and Accountability Act and its related regulations, as amended from time to time (“HIPAA”), which governs “covered entities” and their “business associates” as each term is described by HIPAA; and (ii) the GDPA, which governs “data controllers”, “data processors” , and the processing of “personal data”, as each term is described by the GDPR. The Services is not intended for HIPAA or GDPA Customer Data and CultureFire cannot independently determine whether or not your Customer Data is subject to such Data Protection Laws. If you feel that the Services in connection with your Customer Data requires an addendum, CultureFire would be happy to enter into such an agreement. You must (1) notify CultureFire and (2) enter into an addendum with CultureFire prior to creating, maintaining, using or disclosing any such data in connection with your Account. Failure to comply with this section and the Terms and Conditions may result in suspension or termination of your Account in CultureFire’ sole discretion.

CultureFire and its employees, agents and subcontractors may only access, maintain, use and disclose such as permitted by the terms and conditions of the applicable written addendum. This includes, but is not limited to, access, use or disclosure in order to provide the Services and as described in this Privacy Policy. If a use or disclosure of Customer Data described in this Privacy Policy would be prohibited by such addendum, including but not limited to a HIPAA BAA or Regional Data Processing Addendum, such addendum will control with respect to such use or disclosure.


CultureFire Services use cookies tied to personally identifiable information for their operation. Certain services and functionalities will not work if you disable cookie functions on your browser.

In providing services to our clients, it is CultureFire‘ policy to use cookies only when necessary to maintain the identity of the user in a given session. The cookie information does not include personal data such as name, age, phone number, e-mail address or mailing address. Most browsers are initially set up to accept cookies. If you prefer, you can set your browser to reject cookies, however this may interfere with your usage of some of the Services offered by CultureFire. The Service uses customized JavaScript code provided by CultureFire to contact CultureFire‘ servers, to receive a form or application, to load an image or content, or to submit and update information.


For both security and privacy purposes, your CultureFire Account is password protected. You are responsible for safeguarding your CultureFire account password and for any uses of your CultureFire account, whether by you or another individual.

CultureFire implements privacy, security and other data protection controls and mechanisms to safeguard against unauthorized access to or disclosure of Account Information and Customer Data. CultureFire also conducts routine data backups to protect the availability of Account Information and Customer Data. All communications between your Account and CultureFire servers are encrypted with an industry-standard encryption protocols at no extra charge. If you have any questions regarding security, please contact the CIO via


From time to time, we post customer testimonials on this Site that may include their name, logo, graphic, sound or image. We obtain customer consent prior to posting their testimonials on this site. We are not responsible for the personal information a user elects to disclose in their testimonial.


By using this Site and the CultureFire Services, you consent to the collection and use of the information you provide to us as outlined in this Privacy Policy. We reserve the right to make changes to this Privacy Policy at our sole and absolute discretion, and we may do so from time to time and without notice. Should we make material changes to the manner in which your collected personal information is utilized, we shall post a prominent notice on the Site, notify you by email of the applicable changes and/or publish those changes on this page, and your continued use of this Site and any CultureFire Services shall constitute your acceptance of such changes and the revised Privacy Policy and your agreement to be legally bound thereby.


To contact us regarding this Privacy Policy, please contact us at

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