Privacy Policy
Where we are today
Culturally Speaking Inc. (“Culturally Speaking,” “we,” “us”) is a Delaware corporation developing the Cultural Navigation System™ (“CNS”). The CNS is in development and is not yet available. The walkthroughs on our website are simulations that illustrate the concept. Viewing a walkthrough does not create a CNS profile or any record about you in the CNS. Like every page of our website, walkthrough pages are subject to the ordinary website data collection described in section 1.
Today, the information we handle comes from visits to our website, people who send us a message or share their story through our forms, people who sign up for updates, people who add an anonymous thread to our community map, and people and organizations who contact us about walkthroughs, Pilots, or brand partnerships. When we run a Pilot of the CNS, that Pilot will have its own privacy notice, agreed with the partner institution, before any participant information is collected.
The short version
- We collect what we need to respond to you, keep in touch if you ask us to, and run our website safely.
- We do not sell your information or share it for targeted advertising.
- If you share your story, it stays private. We read it and may reply, and we publish it only with your separate written consent.
- If you add a thread to our community map, it carries no name, and we keep no IP address or other identifier with it. The map is for people aged 18 and over and shows totals only.
- A person reads and decides on every walkthrough request.
- We do not use your information to train artificial intelligence models. Where a service provider offers a setting that keeps customer data out of its own artificial intelligence training, we turn it on.
- You can ask to see, correct, or delete your information by emailing culturally@culturallyspeaking.com.
1. Information we collect
- Contact information. Your name and email address, and anything else you choose to put in a message to us.
- Updates list. If you join through “Culture Connection™” in our website footer, join the Culturally Speaking® Community™ waitlist, follow the Community Tapestry, or tick “Keep me in the conversation” on any form: your email address, your name if you give it, and that choice. We first email you a link to confirm, and add you to the list only after you confirm.
- Stories you share. If you use our Stories form: your name, email address, whether you are sharing as an individual or on behalf of an institution, your story in your own words, and your age confirmation and consent.
- Community map. If you add a thread to the Culturally Speaking® Community™ map: the kind of thread you chose, your answers to four multiple-choice questions, the region where you live now (or “Prefer not to say”), and the date. The map asks for no name, contact details, or free text, and we keep no IP address or other identifier with your thread, so threads are designed not to be linked to you. We do not try to identify anyone from a thread, re-identify a thread, or combine threads with other data for that purpose. When you click “Add my thread,” Cloudflare Turnstile checks that a person, not an automated program, is adding it; for this check, Cloudflare processes your IP address and information about your browser and device. While you use the journey, your browser holds your thread for that tab only, as described in section 4. Cloudflare, which hosts the map, processes your IP address in the ordinary course of delivering the map. To limit automated abuse, the map’s server counts adds from each network for one minute, in memory only, and never saves that count. Request logging for the map is turned off, so we keep no record of these requests and never connect this data to a thread.
- Walkthrough and business information. If you request a private walkthrough or ask to host a Pilot: your name, work email, organization, organization website, role, the capacity in which you are reaching out, sector, country, organization size, the decision you are exploring, your timeline, how you heard about us, and whether you are willing to sign a mutual non-disclosure agreement. If you contact us about funding a Pilot: your name, email address, the foundation, company, or individual you represent, the sector you would fund, and where you would like a Pilot to happen. If you contact us about a brand partnership: your name, email address, your brand or company, the partnership areas you are interested in, and what you tell us about your brand. If a walkthrough goes ahead, we also handle the details needed to sign a non-disclosure agreement and hold the meeting.
- Verification information. Publicly available information, such as an organization’s website or press coverage, that we use to confirm who we are meeting.
- Device and usage information. Your IP address, browser and device type, approximate location (country or city, estimated from your IP address), the pages you view, and how you arrived at our site. Our customer relationship management tool (HubSpot) measures these visits and receives the requests you send through our walkthrough, Pilot, and brand partner forms, and sends email updates to people who join our updates list. Squarespace, which hosts our website, also counts visits for our website’s built-in analytics: the pages viewed, the sites that referred you, and your approximate location. Squarespace does this without placing analytics cookies. Stories and other messages you send through our website forms stay with Squarespace and our inbox.
- Social media. Our website links to our pages on Instagram and LinkedIn; it does not embed their feeds. If you interact with our pages on those platforms, we receive what the platform shares with us under your settings there.
Our forms do not ask about race, ethnicity, religion, health, sexual orientation, political views, immigration status, or government ID numbers. Stories are different: a story about identity or belonging may naturally include heritage, national origin, family, adoption, or health history. When you choose to include these details in a story, you give us your explicit consent to store and read them for the purposes in section 2, and you can withdraw that consent and ask us to delete your story at any time. We do not use these details to categorize, score, or make decisions about you. Please leave out details that identify other people unless they have agreed, and keep government ID numbers and financial account details out of every form.
2. How we use it
- To respond to you and answer your questions.
- To send updates about Culturally Speaking and Adopting Threads™, only if you asked for them. You can unsubscribe at any time.
- To read and respond to stories. Access to stories is limited to Culturally Speaking’s founder and the providers that store them for us. We publish a story, or any detail that could identify you or anyone else, only with your separate written consent, and only in the way that consent describes. We do not use stories to train artificial intelligence models.
- To run the Culturally Speaking® Community™ map. We add each thread to totals by region and kind of thread, and show those totals publicly. A region shows its exact total once 5 threads arrive from people who live there; below that, the total shows as a range, and a kind of thread appears only where 5 or more threads in a region share that kind. The red thread connects every region with at least one thread and shows only that people there took part, never their answers. Public totals update once an hour, so a single new thread does not stand out, and you see your own thread right away in your tab. The map shows counts only, never names. We may also report totals in our materials as threads, not people, with the date of the count, for example “1,200 threads added from 14 regions.”
- To draw the Community Tapestry. The totals shown on the map also draw the Community Tapestry on our website, an artwork in which each thread is one strand. The tapestry uses no region, name, or identifier and follows the same rules as the map: a kind of thread appears only once 5 threads share that kind, and the tapestry updates hourly. A finished piece made from the tapestry may be displayed publicly or placed with a cultural organization, or it remains with Culturally Speaking Inc. It contains no personal information.
- To review walkthrough requests. We review every request against the same criteria: whether the organization and person can be verified, whether the request fits the sectors we serve, the requester’s role, timing, and the decision being explored. A person makes every decision. We do not treat anyone less favorably because of their name, writing style, language fluency, or background. Where availability depends on location, for example because a future Pilot is offered only in certain countries, we will tell you.
- To hold walkthroughs and manage relationships with partners, advisors, and investors, including preparing and signing non-disclosure agreements.
- To run and protect our website, understand how it is used, and keep our forms and community map free of spam and automated abuse.
- To meet legal obligations and keep business records.
We do not make decisions about you by automated means alone.
3. Who we share it with
We do not sell your information or share it for targeted or cross-context behavioral advertising. We share it with service providers that help us operate, under terms that limit how they use it:
| Provider | What they do for us | Location |
|---|---|---|
| HubSpot, Inc. | Contact management, website analytics, and sending email updates to people who join our updates list | United States |
| Squarespace, Inc. | Website hosting, including our website fonts; counting visits for our website analytics; and storing messages and stories submitted through our website forms | United States |
| Google LLC (reCAPTCHA) | Spam and abuse protection on our forms, provided through Squarespace and HubSpot | United States |
| Google LLC (Google Fonts) | Displaying fonts on our website | United States |
| Cloudflare, Inc. | Hosting the community map and its database, and checking that a person adds each thread (Turnstile) | United States; requests pass through Cloudflare’s global network |
| Microsoft Corporation, through GoDaddy | Business email, including form submissions sent to our inbox | United States |
| Marketcircle Inc. (Daylite) | Contact and relationship management for partners, advisors, and investors | Canada (company); data may be stored in the United States |
| Dropbox, Inc. (Dropbox Sign) | Electronic signature and storage of non-disclosure agreements | United States |
| Zoom Communications, Inc. | Video meetings for walkthroughs | United States |
Some providers also act as independent controllers for part of the information they receive, under their own privacy policies: HubSpot for information from its tracking code after you accept analytics cookies (HubSpot Privacy Policy), Squarespace for the security of its services (Squarespace Privacy Policy), Google for the fonts it delivers (Google Privacy Policy), and Cloudflare, which runs Turnstile checks for us as our processor under a data processing agreement and is a separate controller only for the check information it uses to improve its bot detection (Turnstile Privacy Addendum).
From each Turnstile check we receive only a pass or fail result, and we store nothing from the check with your thread.
We may also share information with our professional advisors, who are bound by confidentiality; when the law requires it or to protect the rights and safety of others; with your consent; or as part of a merger, acquisition, or financing, in which case this Privacy Policy will continue to apply.
4. Cookies and similar technologies
| Technology | Purpose | Your choice |
|---|---|---|
| Squarespace site cookies | Run the website and remember your cookie choice | Always on; the site cannot work without them |
| HubSpot analytics cookies | Understand visits to our website | Off until you accept; until then, HubSpot’s tracking records nothing about your visit. HubSpot still delivers our cookie banner and website forms, so its servers receive your IP address and the page address when they load. Change any time through Cookie Settings |
| HubSpot form security cookies (__cf_bm, __cfruid, _cfuvid) | Set by HubSpot’s network provider, Cloudflare, when our HubSpot forms load, to block bots and limit automated requests | Necessary for security; __cf_bm lasts 30 minutes, the others until you close your browser |
| Google reCAPTCHA | Protects our forms from spam and abuse. Provided through Squarespace and HubSpot; Google processes information about your device and how you use the form | Necessary for security; loads when you use a form and sets one security cookie (_GRECAPTCHA) |
| Cloudflare Turnstile | Checks that a person, not an automated program, adds a thread to the community map. Cloudflare processes your IP address and information about your browser and device | Necessary for security; loads only after you click “Add my thread” |
| Community map note in your browser tab (csc-thread) | Holds the kind and region of your own thread while the tab is open, to mark “YOU” on the map. Your other answers stay only in the open page | Necessary for the map feature you use. We never receive this note, which clears when you close the tab; you can also clear the note in your browser |
| Cookie choice cookies (__hs_cookie_cat_pref, __hs_do_not_track) | Remember whether you accepted or declined, and keep HubSpot from receiving anything until you accept | Always on; each lasts 6 months |
| Google Fonts | Display some of our typefaces; Google receives your IP address and sets no cookies | Always on |
The community map uses no cookies, and no browser storage that tracks you, recognizes you on a return visit, or links a thread to your device.
We use no advertising cookies or advertising pixels. You can change your choice at any time through Cookie Settings in our website footer, or block cookies in your browser.
Browser privacy signals. Our cookie banner treats a Global Privacy Control signal as a choice to decline optional cookies. We do not respond to other “Do Not Track” signals, because no common standard exists for them.
5. How long we keep it
| Information | How long |
|---|---|
| Messages and inquiries | 24 months after our last exchange, then deleted |
| Stories you share | 24 months after our last contact about your story, then deleted, unless you have given written consent to publish it (then for as long as that consent lasts) or ask us to delete it sooner |
| Updates list | Until you unsubscribe. We then delete your details, keeping only your email address and the date you unsubscribed on a do-not-contact list so we honor your choice |
| Community map threads | For as long as the map runs, since threads contain no information that identifies you. A thread carries no identifier, so we cannot find or delete a single thread on request. The hourly update of public totals deletes nothing. If we reset or close the map, all threads are deleted |
| Walkthrough requests that do not lead to a walkthrough | 24 months, then deleted |
| Non-disclosure agreements and partner, advisor, and investor records | The life of the relationship plus 6 years, or longer where the law requires |
| Website analytics | 26 months, then deleted or kept only as totals that no longer identify anyone |
We review the information we hold once a year, each January, and delete anything that has reached the end of the period above at that review.
6. Your rights
Wherever you live, you can ask us to tell you what information we hold about you and give you a copy, correct it, delete it, or stop sending you updates. Depending on where you live, you may also have rights to restrict or object to our use of your information, to receive it in a portable format, and to withdraw consent at any time. To make a request, email culturally@culturallyspeaking.com with the subject line “Privacy request.” We may need to confirm your identity first. We respond within the time your law requires and will not treat you differently for using your rights. If we decline a request, we will explain why and how to appeal. You may also complain to the data protection authority where you live. Community map threads carry no name or identifier, so we cannot find, correct, or delete a single thread. Adding a thread is always your choice.
7. Legal bases (EEA, UK, Switzerland and similar laws)
| Purpose | Legal basis |
|---|---|
| Responding to messages | Legitimate interests: answering people who contact us |
| Updates list | Consent |
| Receiving, reading, and keeping stories | Consent; explicit consent for any special category information you choose to include |
| Publishing a story | Separate written, explicit consent |
| Adding and showing community map threads | Legitimate interests: running the community map you choose to join and keeping the site secure. Once saved, a thread does not identify you; the limited technical data that reaches our servers when you add a thread is never kept with the thread |
| Turnstile person check | Legitimate interests: protecting the map from automated abuse |
| Reviewing walkthrough requests and verifying requesters | Legitimate interests: choosing whom to meet, fairly and consistently |
| NDAs and walkthrough meetings | Legitimate interests, where you act for an organization; steps before entering a contract, where you sign in your own capacity |
| Partner, advisor, and investor relationships | Legitimate interests: running and growing our business |
| Analytics cookies | Consent |
| Site cookies, Squarespace visit statistics, and spam protection | Legitimate interests: running a secure website and understanding how it is used |
| Legal compliance and records | Legal obligation |
You can object to any use based on legitimate interests and withdraw consent at any time.
8. International transfers
Culturally Speaking is based in the United States, and our providers process information in the United States and Canada. Cloudflare also handles community map requests, including Turnstile checks, in the data center nearest you, and as a United States company may also process them in the United States. Where the law requires, we protect transfers with appropriate safeguards, such as the European Commission’s Standard Contractual Clauses, the UK International Data Transfer Addendum, or the EU-U.S. Data Privacy Framework where a provider is certified.
9. Regional information
- United States. We do not sell personal information or share it for targeted advertising. You still have the rights described in section 6. If we decline a privacy request, you may appeal by replying with the subject line “Privacy appeal,” and you may contact your state attorney general if you disagree with the outcome.
- California. You may contact the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs at 1625 North Market Blvd., Suite N 112, Sacramento, CA 95834, or (800) 952-5210.
- Canada. Our person responsible for privacy is listed in section 12. Your information is stored in Canada and the United States and may be accessible under the laws of those countries. You may complain to the Office of the Privacy Commissioner of Canada or, in Quebec, the Commission d’accès à l’information.
- EEA, UK, and Switzerland. You may complain to the supervisory authority where you live or work, such as the ICO in the United Kingdom.
- Elsewhere. Including Japan, the Republic of Korea, Brazil, and other countries with data protection laws: you have the rights your local law gives you, and you may contact us or your local data protection authority.
10. Security
We use reasonable measures to protect your information, including limited access, multi-factor authentication, encrypted connections, and reputable providers. No method is completely secure. If a breach affects your information, we will notify you and the relevant authorities as the law requires.
11. Children
Our forms are for people aged 18 or older. Our website is for a general audience and is not directed to children under 13, or under 16 in the EEA and UK. If you believe a child has given us information, contact us and we will delete it.
The Culturally Speaking® Community™ map is intended for people aged 18 and over. We don’t direct the map to children, and we don’t knowingly collect information from children. The map isn’t designed for classroom use without contacting us first: if you’re a teacher or school, please email culturally@culturallyspeaking.com before using the map with students. If you believe a child has used the map, contact us and we will delete any related information we hold.
12. Changes and contact
We will post updates here with a new date, and tell you before any significant change, such as a change in how we use stories or the launch of a Pilot. If we ever change what threads include, such as adding accounts or a way to revisit your thread, we will update this policy and ask for your consent where required. Questions and requests: Culturally Speaking Inc., 8 The Green, Ste A, Dover, DE 19901, USA · culturally@culturallyspeaking.com (preferred). Our person responsible for privacy is our Founder and CEO.