Privacy Notice

1. Our Role and Our Clients

Culture Index provides the Survey and related Services to the organizations that request them (each, a "Client"). For purposes of the CCPA, Culture Index is a "business" with respect to the personal information described in this Notice. Once Survey results are delivered, the Client may use the Survey in connection with recruitment, hiring, placement, team composition, employee development, coaching, succession planning, and other workforce-related decisions. Culture Index provides Survey results and related insights but does not make employment, promotion, compensation, or other personnel decisions on behalf of the Client. Responsibility for the interpretation and use of Survey results, as well as compliance with applicable employment laws and regulations, remains solely with the Client.

2. Personal Information Culture Index Collects

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular person or device ("Personal Information"). In the preceding 12 months, Culture Index has collected the following categories of personal information in connection with the Services:

• Basic Identifiers: Name, email, phone number (if required by Client or provided by individual), birth month and day (excluding birth year), IP address, and login details when applicable.
• Work Details: Job title, department, and the position being applied for, if requested.
• Survey Responses: Responses provided and selections made while completing the Survey.
• Survey Insights (Inferred Data): Culture Index uses the Survey responses to create a profile of the individual's work style preferences and behavioral traits. These are generated using a structured scoring methodology based on arithmetic calculations and numerical comparisons rather than machine-learning models or generative AI.
• Website Usage Data: Information about devices used to access the Services and activity on the website, collected through cookies and similar technologies. Culture Index uses cookies to operate and secure the Services, remember user preferences, and understand how the website is used. Cookies are used for Culture Index's own business purposes only. Culture Index does not use cookies to sell Personal Information or to share it for cross-contextual behavioral advertising. Non-essential cookies are set only if the user accepts them through the cookie consent banner, and cookie preferences may be changed at any time through the website's cookie preference tool or browser settings.

Culture Index collects Personal Information directly from Survey-Takers, from the Clients that request Surveys, and from its service providers. To the extent any of this information is considered "sensitive personal information" under applicable law, such information is used solely to provide and improve the Services. Sensitive personal information is not used for advertising purposes or to infer characteristics for unrelated purposes. Such information is collected, used, and disclosed only as permitted under the CCPA and other applicable U.S. laws and regulations.

3. How We Use Your Personal Information

Culture Index collects, uses, and discloses personal information for the following business and commercial purposes:

• Providing the Services: Personal information is processed to provide Survey results and related Services requested by the Survey-Taker or the Client.
• Security and Improvement: Personal information is processed to maintain platform security, prevent fraud, improve Survey methodology, and support the operation and enhancement of the Services.
• Marketing and Preferences: Marketing communications and non-essential cookies are used in accordance with the Survey-Taker's preferences, which may be updated at any time through applicable website settings or by contacting [email protected].
• Legal Compliance: Personal information may be retained or processed as required to comply with applicable laws, regulations, court orders, tax requirements, and record-retention obligations.

4. How We Disclose Personal Information

Personal information may be disclosed in the following circumstances:

• Client. Survey results and related reports may be provided to the Client that requested completion of the Survey.
• Service Providers and Contractors. Culture Index utilizes trusted partners for services such as cloud hosting of our applications and data, communications services, and security. Under applicable privacy laws, these partners are commonly referred to as service providers and contractors. Each partner is under contract to ensure protection of the Personal Information it processes. A list of these partners is available upon request by contacting [email protected].
• Professional Advisors. Personal information may be disclosed to professional advisors, including legal counsel, auditors, consultants, and insurers, subject to confidentiality obligations.
• Legal and Regulatory Requirements. Personal information may be disclosed to regulators, courts, law enforcement agencies, or other governmental authorities where required by law or where necessary to protect the rights, property, or safety of Culture Index, Clients, Survey-Takers, or others.
• Corporate Transactions. Personal information may be disclosed in connection with a merger, acquisition, financing transaction, reorganization, sale of assets, or other corporate transaction, subject to applicable legal requirements.

Culture Index does not sell or share Personal information, as those terms are defined under U.S. state privacy laws. Personal information is not used for advertising.

5. Privacy Rights

Depending on location, the Survey-Taker may exercise the following rights:

• Right to Know and Access. The Survey-Taker may request confirmation regarding whether Culture Index processes Personal information and may request a copy of such information, including the categories of Personal information, sources of collection, purposes of processing, and categories of recipients.
• Right to Portability. The Survey-Taker may request a copy of Personal information in a structured, commonly used, and machine-readable format, where applicable.
• Right to Correction. The Survey-Taker may request correction of inaccurate or incomplete Personal information.
• Right to Delete. The Survey-Taker may request deletion of Personal information, subject to applicable legal, contractual, and regulatory exceptions.
• Right to Opt Out of Certain Processing. Certain state privacy laws may provide consumers with the right to opt out of specific processing activities. Where such rights apply to Culture Index's processing activities, Culture Index will honor those rights as required by applicable law. Culture Index does not sell or share Personal Information as those terms are defined under applicable privacy laws.
• Right to Limit the Use of Sensitive Personal Information. To the extent Culture Index collects or processes sensitive personal information and applicable law provides a right to limit such processing, Culture Index will honor those rights as required by law. Culture Index does not use sensitive personal information for purposes that require offering a right to limit under applicable privacy laws.
• Right to Appeal. If Culture Index declines to take action on a request, the Survey-Taker may appeal that decision by contacting [email protected].
• Right to Non-Discrimination. Culture Index will not discriminate or retaliate against a Survey-Taker for exercising applicable privacy rights.

Requests relating to the exercise of privacy rights may be submitted to [email protected] or by phone at +1 (816) 361-7575. Culture Index may need to verify the identity of the requestor before responding and may request additional information reasonably necessary for verification. A Survey-Taker may use an authorized agent to submit a request on their behalf, and Culture Index may require proof of the agent's authorization. Culture Index will respond within 45 days or within any shorter timeframe required by applicable law.

Culture Index intends to honor privacy rights afforded under other applicable U.S. privacy laws where those rights apply to an individual and to Culture Index. Individuals who wish to exercise privacy rights available to them may contact Culture Index using the contact information provided below.

6. Data Security and Retention

7. Children's Privacy

The Services are not directed to children. Culture Index does not knowingly collect Personal information from individuals under eighteen (18) years old, and the Survey may be completed only by individuals who are at least 18 years old. If Culture Index becomes aware that Personal information has been collected from an individual under 18, such information will be deleted promptly.

8. Changes to This Notice

Culture Index may update this Notice as necessary to reflect changes in business practices, legal requirements, regulatory guidance, or the Services. Any revisions will be reflected by updating the Effective Date of this Notice. Where required by applicable law, or where changes are considered material, additional notice may be provided through appropriate means, including email or a prominent notice on the Culture Index website, before such changes become effective.

9. Contact Us

For questions about this Notice or to exercise applicable privacy rights, contact us at:

• Email: [email protected]
• Phone: +1 (816) 361-7575
• Address: 10200 State Line Road, Leawood, KS 66206
• Chief Privacy Officer: Mike Provance, Ph.D.