Culture Software Solutions, Inc. Global Privacy Policy

Last Updated: October 18, 2023

Culture Software Solutions, Inc. (“Company,” “we,” “our,” or “us”) respects your right to privacy. This Privacy Policy (this “Policy”) describes the types of information we may collect from you or that you may provide when you visit https://lollipop.co (our “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

It is our policy to comply with all applicable privacy and data protection laws. This commitment reflects the value we place on earning and keeping the trust of our customers, business partners and others who share their personal information with us.

This Policy applies to all information we collect:

• On this website
• In email, text, and other electronic messages between you and this Website; ter
• When you interact with us by means other than our Website, for example, in person or by telephone; and
• When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this polic

By using our Website you signify that you have read, understood, and agree to our collection, storage, use and disclosure of your personal information as described in this policy and our TERMS OF USE. [ADD HOT LINK] This policy may change from time to time.

• Personal Information We Collect

We collect the following types of personal information:

1. Information You Provide

   We collect personal information you provide us, which may include:

   • Identity data, such as your name, company/organization name, job title, address, e-mail address, fax numbers, and phone number;
   • Registration data, such as information provided by you when you register for an account to use our Website, including usernames and passwords;
   • Additional information about you to help us get to know you better, such as your gender, age, date of birth, nationality, professional associations and registration numbers, information about how you use our products, and demographic information
   • Transaction data, including comments, questions, requests and orders you may make, as well as purchase order history and information;
   • Financial information needed to process payments if you make purchases, such as credit card or other financial account information; and
   • Marketing and communications data, such as your preferred methods of communication, your subscriptions to our publications, and product types in which you are interested.
2. Information Automatically Gathered from Your Device
   • Device and browser information. We may collect technical information about your device, such as device type, browser type, IP address, operating system, and device identifier. We collect this information automatically from your device and web browser through cookies and similar technologies.
   • Information about how you interact with us. We may collect technical data about your usage of our Websites and Apps and how you interact with our digital advertisements and promotions, such as content viewed or downloaded, features used, links clicked, our promotional emails opened, and dates and times of interactions. We collect this information using cookies and similar technologies.
   • Additional information about you to help us get to know you better, such as your gender, age, date of birth, nationality, professional associations and registration numbers, information about how you use our products, and demographic information
   • Location information. We may collect location information, including precise real-time location information from your device and imprecise location information derived from, for example, your IP address or postal code. Our Apps will NOT access precise-real time location information from your device unless you grant permission to do so.
3. Cookies and Similar Technologies:

   A "cookie" is a file of information placed on your device when you visit a website. Cookies and similar technologies can enhance your user experience by saving your preferences, personalizing your online experience, holding items in your shopping cart, and sometimes providing you with advertising which is tailored to your interests.

   The types of cookie or similar technology that may be used on Website can be put into the following categories:

   Performance cookies. These cookies collect information about how you use our Website, for example which pages you go to most often and if you get any error messages from certain pages. These cookies collect information that is used to improve how our Website works. Without these cookies we cannot learn how our Website is performing and make relevant improvements that could better your browsing experience.

   Functionality & profile cookies. These cookies allow our Website to store information that you provide, such as preferences, and to store technical information useful for your interactions with our Website. For instance, they remember your user ID and elements of your user profile. They also ensure that your experience using our Website is relevant to you. These cookies will not be used to track your browsing activity on other websites. Without these cookies, a website cannot remember choices you have previously made or personalize your browsing experience.

   Strictly necessary cookies. These cookies are essential for the basic functionalities of our Website, and they enable you to move around Website and use its features, particularly in connection with information searches and order placement. Without these cookies, services you have asked for cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet. For example, basket cookies remember the products that you wish to purchase when you add products to your shopping basket. A login/authentication cookie allows and manages your ability to log into our Website and identifies you after logging in for a single session. These types of cookies are regularly stored only as long as required for their purpose.

   Certain countries require your consent to the use of cookies when you visit our Website. If you access our Website for one of these countries, you will be presented with information regarding your options, including the option to accept or reject certain categories of cookies. You will be able to change these settings on subsequent visits. Please note that you will not be able to opt out of receiving certain cookies that are strictly necessary for the delivery of a service requested by you.

   Although you are not required to accept cookies when you visit our Website, you may be unable to use all of the functionality of the site if you reject certain cookies. In addition, you can usually modify your browser settings to decline cookies and you can withdraw your consent any time by modifying the settings of your browser to reject or disable cookies.

4. Analytics and Advertising. We use third-party analytics services to better understand how users engage with our Website. The information generated by the cookie about your use of our Website (including your IP address) will be transmitted to and stored by our web analytics providers on their servers. The web analytics providers will use this information for the purpose of evaluating your use of our Sites, compiling reports on website activity for website operators and providing other services to website activity and internet usage. The web analytics providers may also transfer this information to third parties where required to do so by law, or where such third parties process the information on their behalf.

   We use different analytic tools which serve the purpose of measuring, analyzing and optimizing our marketing measures and provide you with customized advertisements that could be of particular interest to you..

   Our Website allows selected third parties, including these analytics and advertising services, to place cookies on our Websites. These third parties may collect information about your online activities over time and across third-party websites.These third parties may be members of industry self-regulatory groups such as the Network Advertising Initiative (“NAI”) and Digital Advertising Alliance (“DAA”). Our Websites for these groups provide more information on interest-based online advertising and how to opt out of receiving interest-based online ads from participating companies.

   Do Not Track Browser Settings. Some browsers may transmit "Do Not Track" ("DNT") signals to our Websites you visit. Because there is not common agreement about how to interpret DNT signals, we currently do not take action in response to them.

5. Information from Business Partners and other Third Parties

   We may collect personal information through our business partners. This information may include contact information, such as name, company name, job title, address, e-mail address, and phone number.

   We may also obtain personal information from other third-party sources, including publicly and commercially available sources. We may combine the information we receive from our business partners and other third-party sources with information that we collect from you or your device, as described above.

   You have choices about the personal information you provide us. You may choose not to provide information that we request, but if you do so, we may not be able to provide you a relevant service or a particular feature for our Website or a product.

• How We Use Your Personal Information
1. We may use your personal information to:
1. Develop and manage our relationships with you and our business partners. This may include:
   • delivering services or carrying out transactions that you or our business partners have requested; and
   • providing information about our products, services, and transactions, and advertisements, that may be of interest to you.
   • providing you and our business partners a more consistent experience in interacting with us, including by learning more about you and how you use and interact with our Website, products, and services; and
   • planning, managing, and performing under our contractual relationships with our business partners.
2. Communicate with you or your company. This may include:
   • informing you of our products, services, and promotional activities that may be of interest to you or your company;
   • providing information about our relevant products, services, and transactions, including, for example, pricing information, technical data, invoice, shipping, or production information, warranty or recall information, or information about product or service improvements;
   • responding to questions or inquiries that you make, including customer service requests; and
   • inviting you to participate in, or informing you of the results of, customer satisfaction or market research surveys.
3. Provide and improve our Websites, Apps, products, and services. This may include:
   • customizing them to your preferences or interests, making them more compatible with your technology, or otherwise making them easier to use;
   • maintaining the security of and otherwise protecting them; and
   • developing new Internet Sites, Apps, products and services.and
4. Address legal issues. This may include:
   • complying with our obligations to retain certain business records for minimum retention periods;
   • establishing, exercising, or defending legal claims;
   • complying with laws, regulations, court orders, or other legal process;
   • detecting, preventing, and responding to fraud, intellectual property infringement, violation of our contracts or agreements, violations of law, or other misuse of our Website, Apps, products or services; and
   • protecting our rights or property, or yours or others’ health, safety, welfare, rights, or property.

We may also use your personal information for other uses consistent with the context in which the information was collected or with your consent.

We may anonymize or aggregate any of the information we collect and use it for any purpose, including for research and product-development purposes. Such information will not identify you individually.

• When We May Share Your Personal Information
We will not disclose your personal information except as described here:
1. We may share your personal information with third parties we hire to perform support services for us. These third parties are required to use the personal information we share with them only to perform services on our behalf and to treat your personal information in compliance with all applicable privacy and data protection laws.
2. In some cases, we. may share your personal information with third parties who partner with us to provide products and services to our customers, such as distributors. If so, we will require our business partners to use that information in a manner consistent with this policy, any applicable specific privacy statements, and all applicable privacy and data protection laws.
3. We may share your personal information with third parties when we have a good faith belief that disclosure is necessary:
4. We may share your personal information with third parties in connection with our sale, purchase, merger, reorganization, liquidation or dissolution or under similar circumstances. If such an event occurs, we will take appropriate steps to protect your personal information.
5. We may share your information with your permission or at your request

We may share anonymized or aggregated information internally and with third parties for any purpose, including, but not limited to, selling such information to third parties. Such information will not identify you individually.

• Security of Your Personal Information

Your personal information will generally be stored in our databases or databases maintained by our service providers. Many of these databases are stored on servers located in the United States. We take appropriate measures, by contract or otherwise, to provide adequate protection for personal information that is disclosed to a third party or transferred to another country.

We maintain reasonable safeguards to protect the confidentiality, security and integrity of your personal information. Although we use security measures to help protect your personal information against unauthorized disclosure, misuse, or alteration, as is the case with all computer networks linked to the Internet, we cannot guarantee the security of information provided over the Internet and will not be responsible for breaches of security beyond our reasonable control.

• Links to Third Party Internet Sites and Plugins

Our Websites and Apps may contain links to websites or mobile apps that are not operated by us and plugins from social media platforms and other third parties. To learn about the information collected by these third-party websites, apps, and plugins, please visit their privacy policies. We encourage you to review the privacy policies for our Websites, apps, and social media platforms you visit before using them or providing personal information.

• Access to Your Personal Information

You may review, correct and update personal information you provide to us by using the feedback mechanisms provided at our Website or App, by clicking on [INSERT FEEDBACK LINK].

• Retention of Your Personal Information

How long we keep your personal information will vary and will depend on the purpose and use of information collected. There are legal requirements that we keep some types of data for specific periods. Otherwise, we will retain it for no longer than is necessary for the purposes for which the data was collected.

• Children

This website is not directed to children under the age of 18, and we do not knowingly collect information from children under the age of 18.

• Your Choice

Where appropriate or legally required, we will describe how personal information about you that we collect on our Website will be used and will provide choices about whether or not to allow us to engage in that use. To exercise your choice, you can contact us to correct, update, amend or request deletion of your personal information at [email protected].

If we publish newsletters or marketing materials, we will use your name and email address to send the newsletter or marketing materials to you. You may choose to stop receiving our newsletters or marketing emails by following the unsubscribe instructions included in these emails, accessing the email preferences in your account settings page or contacting us using the contact information listed below in this Privacy Notice.

• Additional Information for EU Residents
1. Data controller and contact information.
   • The controller for personal data collected under this Privacy Policy is the relevant Culture Software Solutions, Inc. entity in your country, and, as applicable, Culture Software Solutions, Inc.
   • If you are using our services administered by your company, your company may be the controller for personal data collected by services. Please contact your company for more information.
2. Our lawful basis for processing your personal data

   The lawful basis for our processing of your personal data will depend on the purposes of the processing. For most personal data processing activities covered by this Privacy Policy, the lawful basis is that the processing is necessary for our legitimate business interests. Where we process personal data in relation to a contract, or a potential contract, with you, the lawful basis is that the processing is necessary for the performance of our contract with you or to take steps at your request prior to entering into a contract. When we are required to share personal data with law enforcement agencies or other governmental bodies, we do so on the basis that we are under a legal obligation to do so. We will also use consent as the legal basis where we deem appropriate or to the extent required by applicable law, for example, before we collect precise location data from your mobile device.

3. More Information
   • Processing on the basis of legitimate business interests. When we process personal information on the basis that the processing is necessary for our legitimate business interests, such interests include: 
     • providing, improving, and promoting our Internet Website, products, and services;
     • communicating with current and potential customers, other business partners, and their individual points of contact;
     • managing our relationships with our customers and other business partners, and their individual points of contact;
     • other business development purposes;
     • sharing information within our group, as well as with service providers and other third parties; and
     • maintaining the safety and security of our products, services and employees, including fraud protection.
   • Processing on the basis of performance of a contract. Examples of situations in which we process personal information as necessary for performance of a contract include e-commerce transactions in which you purchase a product or service from us on your own behalf, through our Website.
   • Processing on the basis of consent. Examples of processing activities for which we use consent as our legal basis include: 
     • collecting and processing precise location information from your mobile device;
     • sending promotional emails when consent is required under applicable law; and
     • processing personal data on our Websites through cookies and similar technologies when consent is required by applicable law.
   • Processing because we are under a legal obligation to do so. Examples of situations in which we must process personal data to comply with our legal obligations include: 
     • payment of taxes and other government levies;
     • providing your personal data to law enforcement agencies and other governmental bodies when required by applicable laws;
     • retaining business records required to be retained by applicable laws; and
     • complying with court orders or other legal process.
   • Additional information about the retention of your personal data: To determine the period for which your personal data will be retained in accordance with this policy, we consider criteria such as: 
     • any applicable legal requirements to retain data for a certain period of time;
     • any retention obligations related to actual or potential litigation or government investigations;
     • the date of your last interaction with us (including with our Website, communications, etc.);
     • the length of time between your interactions with us;
     • the sensitivity of the data; and
     • the purposes for which the data was collected. and
4. Your individual rights

   In accordance with the applicable laws in the European Union, you have the following rights with respect to your personal data, which apply differently in different circumstances: right of access, right to rectification, right to erasure, right to restriction of processing, right to data portability and right to object to processing. Most of these rights are not absolute. Below we describe these rights in more detail and provide information on how you can exercise them. If you make a request to exercise your rights, we will respond within one month, but have the right to extend this period by two additional months, where necessary. If we extend the response period, we will let you know within one month from your request. You can exercise your rights by emailing us at [email protected], in which cae we will provide you with a request form to complete.

5. More Information
   • Right of Access. You have the right to ask us to confirm whether we process your personal data. If we do, you have the right to request access to your personal data that we process and the following information: (i) the purposes of the processing; (ii) the categories of personal data we process; (iii) the recipients or categories of recipients of your personal data; (iv) the envisaged retention period of the data where possible, or the criteria we use to determine the retention period; (v) your right to request rectification or erasure of your personal data, or restriction of the processing of such data; (vi) your right to file a complaint with a supervisory authority; (vii) if we have not collected the data from you, any information we have available about the source of the data; and (viii) whether we use your personal data to make any automated decisions that have legal or other similar significant effects on you.
   • Right to rectification. You have the right to have us correct your personal data if they are inaccurate. Taking into account the purposes of the processing, you may also have the right to have incomplete personal data about you completed, including by providing a supplementary statement to us.
   • Right to object to processing for our legitimate business interests. You have the right to object to us processing your personal data when that data is processed on the basis of our legitimate business interests. We will honor your objection and stop processing the relevant personal data unless: (i) we have compelling legitimate grounds for the processing that override your interests, rights, and freedoms; or (ii) we need to continue processing your personal data to establish, exercise, or defend a legal claim.
   • Right to object to processing for direct marketing. If we processes your personal data for direct marketing purposes, you have the right to object to this processing. If you exercise this right, we will stop processing your personal data for direct marketing purposes.
   • Right to restrict processing. You have the right to request that we restrict the processing of your personal data in the following circumstances: 
     • for the period of time we need to verify the accuracy of your personal data when you contest its accuracy;
     • when the processing of your personal data is unlawful and you oppose the erasure of the data, and instead request that we restrict the use of the data;
     • for when we no longer need your personal data for the purposes of processing, but you need the data to establish, exercise, or defend a legal claim; or
     • the period of time we need to verify if it has compelling legitimate grounds for processing that override your interests, rights, and freedoms when you object to the processing of your personal data for our legitimate business interests.
   • If following your request, we restrict the processing of your personal data, we will store your data, and otherwise process it only with: 
     • your consent;
     • to establish, exercise, or defend a legal claim;
     • to protect the rights of another natural or legal person; or
     • for reasons of important public interest of the European Union or a Member State. We will also inform you before lifting the restriction of processing.
   • Right to erasure. The right to erasure is also called the “right to be forgotten.” You may ask us to delete your personal data. This right is not absolute. We are required to delete your personal data upon your request only in the following circumstances:
     • your personal data is no longer necessary for the purposes for which we collected or processed them;
     • if we process your personal data on the basis of consent, you withdraw your consent, and no other legal ground exists for us to continue processing your personal data;
     • if we process your personal data for our legitimate business interests, you object to the processing, and there are no overriding legitimate grounds for us to continue processing your personal data;
     • if we have processed your personal data unlawfully; or
     • the personal data must be erased to comply with a legal obligation under European Union or Member State law to which we are subject.
     • We are not required to erase your personal data to the extent that we need to process it to: 
       • exercise our right of freedom of expression and information;
       • comply with a legal obligation under European Union or Member State law to which we are subject; or
       • to establish, exercise, or defend a legal claim.
   • Right to data portability: You have the right to receive personal data you provided to us when: 
     • the processing of the data is based on your consent or is necessary for the performance of a contract between you and us;
     • if we process your personal data on the basis of consent, you withdraw your consent, and no other legal ground exists for us to continue processing your personal data;
     • if our processing of your personal data is carried out by automated means; and
     • complying with your request will not adversely affect the rights and freedoms of others.
     • If you have the right to receive such personal data and request that we provide it, we will provide it to you in a structured, commonly used, and machine-readable format.
   • Right to lodge a complaint with a supervisory authority. We will use our best efforts to address and settle any requests or complaints brought to our attention. In addition, you have the right to approach the competent data protection authority with requests or complaints. This can be the supervisory authority in the country or federal state where you live. The overall competent supervisory authority for us in Europe is: Commission for the Protection of Privacy, Rue de la Presse 35, 1000 Brussels; Telephone: +32 (0)2 274 4800; E-mail: [email protected]; Website: www.privacycommission.be.  

   k.Rights of California Residents

   If you are a verified California resident, you may have, pursuant to the California Consumer Protection Privacy Act (the “CCPA”), the following rights with respect to your personal information with us, which apply differently in different circumstances: right to access, right to information, and the right to deletion. We do not and will not sell personal information, however, may sell aggregated anonymous user data. Most of these rights are not absolute.  Below we describe these rights in more detail and provide information on how you can exercise them.  If you are a verified California consumer and make a request to exercise your rights, we will respond within 45 days, but we have the right to extend this period by 45 additional days where necessary.  If we extend the response period, we will let you know within 45 days from your request. You can exercise your rights by by emailing us at [email protected], in which case we will provide you with a request form to complete.

   1. Right to Access.  You have a right to ask us to provide the categories and specific pieces of personal information that we retain about you through your account with us or, at your option, by mail or in a readily usable electronic format.  We are obligated to respond to no more than two Right-to-Access requests in a 12-month period.  The Right to Access does not apply to information collected by us for a single transaction.
   2. Right to Information.  You have the right to ask us to disclose to you:  (i) the categories of personal information that we have collected about you in the 12 months preceding the request and the specific pieces of that personal information, (ii) the categories of sources from which the personal information was collected (iii) the business purpose or commercial purpose for collecting or selling the personal information, (iv) the categories of third parties with whom or which the personal information is shared, (v) the categories of personal information that we have sold about you and the categories of parties to whom or which we sold each category of personal information, and (vi) the categories of personal information that we have disclosed about you for a business purpose. 
   3. Right to Deletion.  You have the right to ask us to delete personal information we have collected about you.  The Right to Deletion does not apply when we need the personal information:
      • to complete a transaction with you, provide a good or service requested by you, or otherwise perform a contract with you;
      • to detect or prevent security incidents or illegal activity;
      • to identify and correct errors that impair existing functionality;
      • for the exercise of a legal right or to ensure another person can exercise his or her legal right;
      • to comply with the California Electronic Communications Privacy Act;
      • to engage in public or peer-reviewed scientific, historical, or statistical research in the public interest if deletion of the personal information is likely to make the research impossible or seriously impair it;
      • solely for internal uses that are reasonably aligned with expectations based on your relationship with us
      • to comply with a legal obligation; or
      • for lawful internal uses that are compatible with the context in which we obtained the information.
    

• Questions about this Policy or our Privacy Statements  

If you have any questions about this Policy or a Specific Privacy Statement or our use of your personal information, please contact us at [email protected].

• Changes to this Policy and our Privacy Statements

Changes to this Privacy Policy will be posted on this site, along with information on any material changes. We reserve the right to update or modify this Policy and any Specific Privacy Statements at any time and without prior notice. Any modifications will apply only to the personal information we collect after the posting.