Privacy Policy
Cultioo App
United States
Cultioo App: United States Privacy Policy
Effective Date: January 1, 2026
Version: 1.0
Governing Entity: Cultioo Inc., a Delaware Corporation
Table of Contents
1. Scope and Application
2. Company Information and Contact Details
3. Definitions
4. Registration and Consent
5. Categories of Information Collected and Processing Purposes
6. Data Storage and Data Security
7. Payment Processing via Stripe Inc.
8. Data Disclosure and Display
9. Messenger Function and Communication Data
10. Location Data (My Location)
11. User Account and Personal Settings
12. System and App Settings
13. Data Usage: Business and Commercial Purposes
14. Data Sharing with Third Parties
15. Sale and Sharing of Personal Information
16. Your Privacy Rights
17. Retention Period
18. Privacy of Minors
19. Do Not Track and Tracking Technologies
20. Changes to This Privacy Policy
21. Contact Information
Privacy Policy
Cultioo App
United States
Cultioo Inc., a Delaware corporation, understands that privacy and the security of Personal Information (PI) are fundamental concerns for its users. This Privacy Policy details the data collection, usage, sharing, and security practices implemented by Cultioo in compliance with United States federal and state laws, including the regulations set forth by the Federal Trade Commission (FTC) and the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), as well as other applicable state privacy laws.
Cultioo is committed to maintaining the trust of its users by prioritizing data protection, implementing technical and organizational measures (TOMs) to secure user data, and ensuring transparency regarding all data processing activities.
1. Scope and Application
1.1 Scope
This Privacy Policy applies to all users of the Cultioo mobile application and associated services within the United States of America. The Cultioo App functions as a marketplace platform facilitating transactions between buyers and sellers, including payment processing and logistics services.
1.2 Legal Framework
Cultioo's commitment to data privacy aligns with:
- Federal Trade Commission (FTC) Act — Requirements for fair data practices
- California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA)
- Virginia Consumer Data Protection Act (VCDPA)
- Colorado Privacy Act (CPA)
Privacy Policy
Cultioo App
United States
- Connecticut Data Privacy Act (CTDPA)
- Utah Consumer Privacy Act (UCPA)
- Other applicable state privacy laws
1.3 Consent Through Use
By registering for or using the Cultioo App, you provide explicit consent to the collection and processing of your data in accordance with this Privacy Policy.
2. Company Information and Contact Details
Responsible Entity:
Cultioo Inc.
A Delaware Corporation
8 The Green, Ste A
Dover, DE 19901
United States of America
Contact: privacy@cultioo.com
3. Definitions
3.1 Personal Information (PI)
Information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, including but not limited to: names, email addresses, physical addresses, phone numbers, IP addresses, purchase history, device IDs, and usage data.
Privacy Policy
Cultioo App
United States
3.2 Sensitive Personal Information (SPI)
A subcategory of Personal Information requiring enhanced protection, including:
- Precise geolocation data (GPS location)
- Financial account information and credentials
- Contents of private communications (messenger messages)
- Other highly sensitive identifiers
3.3 Sale
The selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal information to another business or third party for monetary or other valuable consideration.
3.4 Sharing
The sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal information to a third party for cross-context behavioral advertising.
3.5 Service Provider
A business that processes personal information on behalf of Cultioo and is contractually bound to use the data exclusively for the agreed-upon purposes.
Privacy Policy
Cultioo App
United States
4. Registration and Consent
4.1 Registration Requirement
Use of the Cultioo App requires registration. Certain personal information must be provided to utilize the app's features.
4.2 Explicit Consent
Upon registration or when modifying your data in the settings, you explicitly consent to the processing of your personal information in accordance with this Privacy Policy.
4.3 Right to Withdraw
You have the right to withdraw your consent at any time. The withdrawal does not affect the lawfulness of processing based on consent before its withdrawal.
4.4 Data Storage Upon Registration
When registering or modifying your data in the settings, your data is securely stored in the Cultioo database. Passwords are exclusively stored in hashed (encrypted) form in the database.
5. Categories of Information Collected and Processing
Purposes
In accordance with CCPA/CPRA, Cultioo discloses the following categories of personal information collected in the last 12 months:
Privacy Policy
Cultioo App
United States
5.1 Detailed Overview of Data Categories
CCPA/CPR
Examples of
Data
A Category
A:
Identifiers
B: Personal
Records
Informatio
n
D:
Commerci
al
Informatio
n
F: Internet
or Other
Similar
Network
Activity
Collected
Real name,
username,
address,
physical
address,
phone
number,
device ID, IP
address
Name,
address,
phone
number
Purchase
history,
transaction
records,
payment
method
display (last
four digits)
Interaction
with app,
session
duration,
settings
changes,
Source of
Collection
User
registration,
transactional
input, device
User input,
transactional
input
Transaction,
user activity
Device, app
usage
Primary
Purpose
Account
management,
security, order
fulfillment,
delivery
Order fulfillment,
emergency
contact (Delvioo
Driver)
Order
processing,
auditing,
internal
research
Debugging,
quality
assurance,
service
improvement
Disclosed to Third
Parties
Yes (Service
Providers/Contractor
s)
Yes (Service
Providers/Contractor
s)
Yes (Service
Providers/Contractor
s)
Yes (Analytics
Providers/Service
Providers)
Privacy Policy
Cultioo App
United States
CCPA/CPR
A Category
K: Sensitive
Personal
Informatio
n (SPI)
Examples of
Data
Collected
device/OS
details
Precise
geolocation
(device
location),
financial
account
information
(last 4
digits/payme
nt type),
contents of
user
messages
Source of
Collection
Primary
Purpose
Disclosed to Third
Parties
Device,
transaction,
user
communicatio
n
Service
provision
(communicatio
n), transaction
management,
localization
Yes (Payment
Processor,
Communication
Storage Service
Provider)
5.2 Detailed Description of Data Categories
A. Identifiers
Data Collected:
- Full name / username
- Email address
- Physical address (delivery address)
- Phone number
- Device ID and unique identifiers
- IP address
Processing Purposes:
- Creation and management of your user account
Privacy Policy
Cultioo App
United States
- Authentication and access control
- Communication with you
- Order processing and delivery
- Fraud prevention and security
Sources: Direct input by user upon registration; automatic collection by device.
B. Commercial Information
Data Collected:
- Purchase history and order details
- Transaction records
- Display of last four digits of payment methods
Processing Purposes:
- Processing purchases and sales
- Customer service and support
- Dispute resolution
- Internal analysis to improve the platform
Sources: User activity within the app.
C. Internet and Network Activity
Data Collected:
- Interaction data with the app
- Pages and features visited
- Click and scroll behavior
- Session duration
- Device type, operating system, browser information
- App version
Processing Purposes:
- Ensuring app functionality
Privacy Policy
Cultioo App
United States
- Identifying and fixing errors (debugging)
- Analyzing usage to improve user experience
- Security monitoring
Sources: Automatic collection during app usage.
D. Sensitive Personal Information (SPI)
1. Precise Location Data
- Data Collected: GPS coordinates, precise geographic location
- Processing Purposes: Localized services (e.g., displaying nearby sellers)
- IMPORTANT: Location data is stored exclusively locally on your device and is NOT transmitted to Cultioo servers or third parties.
- Sources: User's device (with explicit device permission)
2. Financial Account Information
- Data Collected: Last four digits of credit cards or bank accounts
- Processing Purposes: Display and management of payment methods
- Special Note: Complete financial information is processed and stored exclusively by Stripe Inc.
- Sources: User input during payment transactions
3. Contents of Private Communications
- Data Collected: Message contents in the messenger between buyer and seller
- Processing Purposes: Enabling communication for transaction processing
- Sources: Direct input by user in the messenger
Privacy Policy
Cultioo App
United States
6. Data Storage and Data Security
6.1 Highest Priority
Protection and Privacy Are Our Priority.
Cultioo treats data security as a core business function and implements comprehensive technical and organizational measures (TOMs) to protect user data from unauthorized access, use, or disclosure.
6.2 Technical and Organizational Measures (TOMs)
a) Cryptography and Password Security
- Irreversible Hashing: All user passwords are immediately encrypted upon creation using an irreversible hashing procedure
- No Plain Text Storage: Passwords are never stored in plain text
- No Employee Access: Even Cultioo employees and administrators have no access to your original passwords
- Industry Standard: Use of cryptographic standards (e.g., bcrypt, Argon2) b) Encrypted Data Transmission
- Transport Layer Security (TLS): All data transmissions between your app and Cultioo servers occur over encrypted HTTPS/TLS connections
- End-to-End Protection: Protection against eavesdropping and man-in- the-middle attacks c) Access Control
- Strict Internal Access Policies: Only authorized employees with legitimate business needs have access to personal information
- User-Exclusive Modifications: Personal data can only be changed by the authenticated user themselves via the secure app
- Multi-Factor Authentication: Critical operations (account deletion, password change) require password confirmation
Privacy Policy
Cultioo App
United States
d) Secure and Irreversible Deletion
- Final Data Deletion: When you delete your account, all associated data is finally and irrevocably removed from the database
- No Recovery Possible: Deleted data cannot be restored
- Secure Deletion Protocols: Use of secure deletion methods that prevent recovery e) Infrastructure Security
- Secure Server Environment: Use of professional, certified data centers
- Regular Security Audits: Conducting penetration tests and security reviews
- Incident Response Plan: Established procedures for handling security incidents
- Regular Backups: Secure data backups to ensure data integrity f) Employee Training
- Regular training of all employees on data privacy and data security
- Commitment to confidentiality
6.3 No Sharing with Third Parties for Marketing
Your data is fundamentally not shared with third parties for advertising or marketing purposes.
7. Payment Processing via Stripe Inc.
7.1 Exclusive Use of Stripe
Cultioo Inc. works with Stripe Inc., a leading PCI-DSS certified payment service provider. All payment processing is conducted exclusively through Stripe.
Privacy Policy
Cultioo App
United States
7.2 Security of Your Payment Data
- Secure Storage: All payment processing and bank data are securely stored and processed by Stripe Inc.
- Cultioo Does Not Store Complete Financial Data: Cultioo never receives or stores your complete credit card numbers or bank account information.
- PCI-DSS Compliance: Stripe meets the highest security standards of the payment card industry (PCI-DSS Level 1).
7.3 Display of Payment Information
For security and verification purposes, Cultioo displays exclusively the last four digits of your payment methods:
- In your personal account settings ("Payments" section)
- To the seller for transaction confirmation
7.4 Stripe as Independent Controller
- Independent Responsibility: Stripe Inc. acts as an independent data controller for the personal information it processes.
- Separate Privacy Policy: Users are subject to Stripe's separate privacy policy and terms of service.
- Stripe Privacy Policy: https://stripe.com/privacy
7.5 Disclaimer
Cultioo assumes no responsibility or liability for the security or use of data processed by Stripe. Use of Stripe occurs at the user's own risk as a third- party service.
Privacy Policy
Cultioo App
United States
8. Data Disclosure and Display
8.1 Disclosure to Sellers
To process and fulfill the order, the seller receives the following information:
- The delivery address selected at checkout
- Your name/username
- The last four digits of your payment method (for payment confirmation) Purpose: Order processing, shipping preparation, transaction verification. Legal Basis: Contract performance (necessary to complete the transaction).
8.2 Disclosure to Delvioo Driver (Delivery Service)
The Delvioo driver receives the following data to successfully deliver your order:
Data Purpose
Delivery address (Delivery
Location) Creation of an optimized delivery route
Name/Username For correct order assignment
Phone number Exclusively for emergency contact (e.g., difficulty finding the delivery address)
Email address Exclusively for emergency contact
Purpose: Creation of an optimized delivery route, successful delivery of the order, emergency communication in case of delivery difficulties. Legal Basis: Contract performance (necessary to complete delivery). Contractual Safeguards: Delvioo acts as a Service Provider of Cultioo and is contractually obligated to use the data exclusively for delivery purposes and implement appropriate security measures.
Privacy Policy
Cultioo App
United States
9. Messenger Function and Communication Data
9.1 Purpose of the Messenger Function
Cultioo offers an integrated messenger function that enables direct communication between buyers and sellers to clarify transaction details and facilitate the purchase process.
9.2 Storage of Message History
- The entire message history between sender and recipient is stored in the Cultioo database.
- Storage occurs to make communication permanently available to both parties.
- Messages are not forwarded to third parties or made public.
9.3 Access Restrictions
- Exclusive Access: Only sender and recipient have access to the respective message history in the Cultioo App.
- No Third-Party Sharing: Message contents are not shared with third parties.
- Limited Cultioo Access: Cultioo employees generally have no access to private messages, except:
- In case of reasonable suspicion of fraud, criminal activity, or violation of terms of service
- To comply with legal obligations (e.g., court orders)
- To resolve technical issues (only with explicit consent)
9.4 Pinned Messages
Messages you mark as "pinned" or "important" are stored locally on your device and not additionally stored on Cultioo servers.
Privacy Policy
Cultioo App
United States
9.5 Sensitive Data (SPI)
Message contents are classified as Sensitive Personal Information (SPI) under CCPA/CPRA, as they contain private communications not directed to Cultioo as a business.
9.6 Deletion of Messages
You can request deletion of your entire message history at any time (see Section 16.3).
10. Location Data (My Location)
10.1 Use of Location Data
The Cultioo App can access your device's location function to offer you localized services, such as:
- Displaying sellers in your geographic proximity
- Regional filtering of products and offers
- Optimizing search results based on your location
10.2 Privacy by Design: Local Storage — NO Server Transmission
IMPORTANT PRIVACY NOTICE: Your location is stored exclusively locally on your device.
- Location data is NEVER transmitted to the Cultioo database
- Location data is NEVER sent to Cultioo servers
- Location data is NEVER shared with or sold to third parties Privacy Policy
Cultioo App
United States
This technical decision follows "Privacy by Design" principles and significantly minimizes the risk of misuse of your highly sensitive location information.
10.3 Control Over Location Access
You have complete control over location access at all times:
- Device Settings: You can control the Cultioo App's access to your location data via your mobile device settings (iOS or Android).
- Options:
- Completely disable location access
- Allow location access only while using the app
- Disable precise location (approximate location only)
Note: Disabling location services may limit the functionality of certain features (e.g., local search results).
10.4 Classification as Sensitive Data
Precise location data is classified as Sensitive Personal Information (SPI) under CCPA/CPRA and receives enhanced protection.
10.5 Legal Basis
The use of location data occurs exclusively with your explicit consent, which you grant through your device's permission settings.
Privacy Policy
Cultioo App
United States
11. User Account and Personal Settings (My Account)
11.1 Payment Information (Payments)
In the "Payments" section of your account, your personal bank accounts and credit cards are managed:
Security:
- All payment accounts are exclusively secured and managed by Stripe Inc.
- Cultioo displays only the last four digits of your payment methods.
- Only you as the user have access to your stored payment methods in the Cultioo App.
Management:
- You can add, modify, or remove payment methods.
- All changes are securely processed through Stripe.
11.2 Modification of Personal Data
You have the ability to modify your personal data at any time: Security Measure: Modifications can only be made by you via the Cultioo App. Personal data can only be changed through the Cultioo App. This prevents unauthorized modifications by third parties.
Modifiable Data:
- Name/username
- Email address
- Phone number
- Delivery address(es)
- Profile picture
Privacy Policy
Cultioo App
United States
11.3 Account Deletion (Right to Deletion)
Security Procedure: If you wish to delete your account, this is only possible by entering your password. This security measure protects against unauthorized or accidental account deletion.
Deletion Process:
1. Navigate to account settings
2. Select "Delete Account"
3. Enter your current password for confirmation
4. Confirm final deletion
Irrevocable Deletion:
- After confirmation, all data associated with your account is finally and irrevocably removed from the database.
- Data recovery is not possible.
- This process ensures complete fulfillment of your right to deletion. Exceptions: Certain data may be retained for a limited period due to legal retention obligations (e.g., tax requirements).
11.4 Password Change
Security Procedure: When creating a new password, the old password must be entered for confirmation. This prevents unauthorized password changes if someone has access to your device.
Recommendations:
- Use a strong, unique password
- Change your password regularly
- Never share your password with third parties
Privacy Policy
Cultioo App
United States
12. System and App Settings
12.1 Local Processing
All changes you make in the Cultioo App settings are initially processed locally on your device.
12.2 Synchronization
After local processing, settings are securely synchronized with Cultioo servers to:
- Ensure consistency across multiple devices
- Restore your settings upon reinstallation
- Optimize app functionality
12.3 Data Security
Transmission of settings data occurs over encrypted connections (HTTPS/TLS).
13. Data Usage: Business and Commercial Purposes
Cultioo uses the collected personal information and sensitive personal information primarily for defined business purposes necessary for platform operation, and secondarily for commercial purposes that enhance user experience.
13.1 Business Purposes
According to CCPA/CPRA, business purposes are processing activities required for service provision and generally not subject to opt-out rights: Privacy Policy
Cultioo App
United States
a) Service Provision and Transaction Management
- Processing orders and purchases
- Managing user accounts
- Enabling communication between buyers and sellers
- Coordinating delivery through Delvioo
Data Used: Identifiers, Personal Records Information, Commercial Information
b) Security and Fraud Prevention
- Detecting, preventing, and prosecuting security incidents
- Identifying fraudulent activities
- Protecting against illegal actions
- Performing internal audits
- Verifying transactions
Data Used: Identifiers, Internet/Network Activity, Commercial Information c) Debugging and Technical Functionality
- Identifying and fixing errors
- Ensuring platform functionality
- Troubleshooting technical problems
Data Used: Internet/Network Activity, Identifiers
d) Customer Account Management and Rights Fulfillment
- Enabling exercise of consumer rights (access, correction, deletion)
- Updating and correcting data
- Secure account deletion
Data Used: All categories of personal information
Privacy Policy
Cultioo App
United States
e) Internal Research and Quality Improvement
- Analyzing platform usage (Internet/Network Activity)
- Improving user experience
- Developing new features
- Optimizing existing functions
Data Used: Internet/Network Activity, aggregated usage data
(anonymized)
13.2 Commercial Purposes
Commercial purposes serve business development and are conducted in a manner that does not constitute "sale" or "sharing" of data under CCPA/CPRA:
a) Marketing and Communication
- Sending information about new products or services
- Notifications about special offers and promotions (only with your consent)
- Personalized in-app content
Data Used: Identifiers (email, name), Commercial Information Opt-Out: You can unsubscribe from marketing communications at any time (see Section 16.7).
b) Personalization and Recommendations
- Displaying personalized product recommendations based on your purchase history
- Adapting the app interface to your preferences
Data Used: Commercial Information, Internet/Network Activity Privacy Policy
Cultioo App
United States
13.3 Transparency for Sensitive Data (SPI)
Precise Location Data: The decision to store location data exclusively locally on the device and not transmit it to servers inherently reduces Cultioo's liability regarding sensitive data processing and complies with data minimization principles.
Financial Data: Cultioo limits its storage of sensitive financial data by delegating complete account security and processing to Stripe. Message Contents: Messenger histories are securely stored and accessible exclusively to sender and recipient.
14. Data Sharing with Third Parties
14.1 Principle: No Sharing for Advertising Purposes
Cultioo fundamentally does not share your personal information with third parties for advertising or marketing purposes.
14.2 Sharing with Service Providers
Cultioo works with carefully selected service providers who process personal information on behalf of Cultioo. These service providers are contractually obligated to use the data exclusively for agreed-upon purposes and implement appropriate security measures.
a) Delvioo (Delivery Service / Logistics Partner)
Purpose: Delivery of orders to buyers
Shared Data:
- Delivery address (Delivery Location)
Privacy Policy
Cultioo App
United States
- Name/username
- Phone number (emergency contact only)
- Email address (emergency contact only)
Legal Basis: Business purpose (service provision on behalf of Cultioo) Contractual Safeguards: Delvioo acts as a Service Provider under CCPA/CPRA with a written contract obligating Delvioo to:
- Use data exclusively for delivery purposes
- Not use data for own commercial purposes
- Not resell or share data
- Implement appropriate security measures
- Treat data confidentially
Compliance Rationale: The sharing with Delvioo is necessary and proportional to the service provided and is not classified as "sale" or "sharing" under CCPA/CPRA.
b) Stripe Inc. (Payment Processor)
Purpose: Secure processing of all payment transactions
Shared Data:
- Payment data (complete credit card or bank account information)
- Transaction details
- Name and email address
Special Note: Stripe acts as an independent controller, not as a Service Provider of Cultioo.
Legal Basis: Contract performance (necessary for payment processing) Disclaimer: Cultioo assumes no responsibility for data processing by Stripe. Users are subject to Stripe's separate privacy policy: https://stripe.com/privacy
Privacy Policy
Cultioo App
United States
c) IT and Infrastructure Service Providers
Purpose:
- Cloud hosting and server management
- Database administration
- IT security and monitoring
- Backup and disaster recovery
- Analytics services
Shared Data: All categories of personal information stored in the app (depending on service provider)
Contractual Safeguards: All IT service providers are contractually bound as Service Providers under CCPA/CPRA.
Examples:
- Cloud hosting providers (e.g., AWS, Google Cloud, Microsoft Azure)
- Analytics tools (e.g., Google Analytics, Mixpanel)
- Email delivery services
- Customer support platforms
14.3 Disclosure Due to Legal Obligations
Cultioo is obligated to disclose personal information upon lawful request to the following entities:
- Law Enforcement Agencies: In response to court orders, subpoenas, or statutory requirements
- Government Agencies: To fulfill regulatory obligations
- Tax and Financial Authorities: To comply with tax-related retention requirements
Legal Basis: Compliance with legal obligations
Transparency Commitment: Cultioo will notify users of such requests where legally permissible.
Privacy Policy
Cultioo App
United States
14.4 Disclosure in Corporate Transactions
In the event of a merger, acquisition, restructuring, or sale of assets, personal information may be transferred as part of the transaction to the successor entity.
- Obligation: The successor will be obligated to continue to comply with this Privacy Policy.
- Notification: Users will be informed in advance of such a transaction.
14.5 Aggregated and Anonymized Data
Cultioo may share aggregated, anonymized, or pseudonymized data that cannot be traced back to individual users for the following purposes:
- Market research
- Industry analysis
- Public reports
- Academic research
Important: This data is not considered personal information and is not subject to the restrictions of this Privacy Policy.
15. Sale and Sharing of Personal Information
15.1 No Sale or Sharing (CCPA/CPRA Statement)
Cultioo does NOT sell or share your personal information.
Based on current business practices, Cultioo expressly confirms:
- Cultioo does not sell personal information (including sensitive personal information) as defined by CCPA/CPRA.
Privacy Policy
Cultioo App
United States
- Cultioo does not share personal information for purposes of cross-context behavioral advertising.
15.2 Definitions
"Sale" means under CCPA/CPRA: The selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal information by the business to a third party for monetary or other valuable consideration.
"Sharing" means under CCPA/CPRA: The sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal information to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration.
15.3 Future Changes
Should Cultioo introduce business practices in the future that could be considered "sale" or "sharing" under CCPA/CPRA:
- You will be clearly informed in advance.
- A clear and conspicuous "Do Not Sell or Share My Personal Information" link will be provided on the website and in the app.
- You will have the right to opt-out of the sale or sharing.
16. Your Privacy Rights
Depending on your state of residence, consumers in the United States have specific statutory rights regarding their personal information. Cultioo is committed to facilitating the exercise of these rights through transparent and accessible mechanisms.
Privacy Policy
Cultioo App
United States
16.1 Applicable Laws
The following rights apply particularly to residents of:
- California: CCPA/CPRA
- Virginia: VCDPA
- Colorado: CPA
- Connecticut: CTDPA
- Utah: UCPA
Cultioo grants these rights to all U.S. users, regardless of state of residence, to ensure a uniformly high privacy standard.
16.2 Right to Know / Right to Access
You have the right to request that Cultioo disclose:
- Which categories of personal information were collected about you
- From which sources the personal information originated
- For which business or commercial purposes the data was collected or disclosed
- To which categories of third parties the personal information was disclosed
- The specific personal information that Cultioo has collected about you Time Period: The disclosure relates to the preceding 12 months. Frequency: You can exercise this right up to twice within 12 months free of charge.
16.3 Right to Delete
You have the right to request deletion of your personal information that Cultioo has collected about you.
Self-Service Deletion:
1. Navigate to account settings
2. Select "Delete Account"
Privacy Policy
Cultioo App
United States
3. Confirm by entering your password
After confirmation, all data associated with your account is finally and irrevocably removed from the database. Data recovery is not possible. Exceptions to Right to Delete: Cultioo may deny deletion if data retention is necessary for:
- Completing the transaction for which the data was collected
- Detecting security incidents, protecting against fraudulent or illegal activities
- Debugging to identify and fix errors
- Exercising free speech rights
- Complying with legal obligations (e.g., tax retention periods)
- Internal uses reasonably aligned with consumer expectations
- Asserting or defending legal claims
16.4 Right to Correct
You have the right to request correction of inaccurate personal information that Cultioo has stored about you.
Self-Service Correction:
- Navigate to account settings ("My Account")
- Modify the desired information
- Save the changes
Correctable Data: Name/username, Email address, Phone number, Delivery address(es), Profile picture.
If you need assistance with corrections, contact us using the contact details in Section 21.
Privacy Policy
Cultioo App
United States
16.5 Right to Limit Use of Sensitive Personal Information
You have the right to direct Cultioo to limit the use of your sensitive personal information (SPI) to what is necessary to provide the requested services.
Cultioo's SPI Practices:
a) Precise Location Data:
- Location data is stored exclusively locally on your device.
- It is not transmitted to Cultioo servers.
- Control: You can restrict or revoke location access at any time via your device settings. b) Financial Account Information:
- Cultioo stores only the last four digits of your payment methods.
- Complete financial data is managed exclusively by Stripe. c) Message Contents:
- Stored exclusively to enable communication between buyer and seller.
- Access is restricted to sender and recipient.
A clearly visible link "Limit the Use of My Sensitive Personal Information" is available in app settings.
16.6 Right to Opt-Out of Sale or Sharing
You have the right to opt-out of the sale or sharing of your personal information.
Current Status: Cultioo currently does not sell or share personal information under CCPA/CPRA. Therefore, an opt-out is not currently required.
Privacy Policy
Cultioo App
United States
Future Commitment: Should Cultioo introduce practices in the future that constitute sale or sharing:
- A clearly visible link "Do Not Sell or Share My Personal Information" will be provided.
- You can opt-out at any time without it affecting service quality. Universal Opt-Out Mechanisms (UOOMs): Cultioo commits to respecting Universal Opt-Out Mechanisms such as Global Privacy Control (GPC).
16.7 Right to Data Portability
You have the right to receive the personal information concerning you in a structured, commonly used, and machine-readable format.
Contact us using the contact details in Section 21 to request a copy of your data in a portable format. Data will be provided in a common format (e.g., JSON, CSV).
16.8 Right to Opt-Out of Automated Decision-Making
Cultioo currently does not use fully automated decision-making systems that have legal or similarly significant effects on users (e.g., fully automated credit decisions).
If such systems are implemented in the future, you will be informed and have the right to object to such processing.
16.9 Right to Non-Discrimination
Cultioo expressly commits: You will NOT be discriminated against for exercising any of your privacy rights.
This specifically means:
- You will not be denied service
Privacy Policy
Cultioo App
United States
- You will not be charged different prices or rates
- You will not be provided a different level or quality of goods or services
- You will not be treated differently
Exception: Cultioo may offer you a different price, rate, or quality if that difference is reasonably related to the value your data provides to Cultioo.
16.10 Exercising Your Rights
Submitting a Request: You can exercise your privacy rights through the following channels:
- Online Request Portal: cultioo.com
- Email: privacy@cultioo.com
- Mailing Address: Cultioo Inc., Attn: Privacy Rights Department, 8 The Green, Ste A, Dover 19901, United States
Verification Process: To protect the security of your data, Cultioo must verify your identity before fulfilling your request:
1. Matching: We match the information you provide with the data stored in
2. 3. our records.
Additional Verification: For sensitive requests (e.g., deletion, access to specific data), additional verification steps may be required. Authorized Agent: You can authorize a representative to submit a request on your behalf (written authorization required).
Response Time: Cultioo will process and respond to your request within 45 days of receipt. In complex cases, this period may be extended by an additional 45 days; you will be informed.
Free of Charge: Exercising your privacy rights is free of charge. Cultioo does not charge fees for processing your requests (at reasonable frequency). Privacy Policy
Cultioo App
United States
17. Retention Period
Cultioo stores personal information only as long as necessary to fulfill processing purposes or comply with legal retention requirements.
17.1 Retention Period by Category
Data Category Retention Period Justification
Account Data (name,
Until account deletion
email, username, address,
by user
Necessary for service provision
and account management
phone)
Transaction Data
(purchase history, order
details)
Message History
(messenger)
Payment Data (last 4
digits)
Payment Data (complete,
at Stripe)
Usage and Technical
Data (logs, IP addresses,
device IDs)
Location Data (local) Legally Required
Retention
7 years from
transaction date
IRS requirements for tax
records; potential disputes
Until account deletion
Enabling continuous
communication between
or upon specific
request
transaction parties
Until account deletion
or removal by user
Display and management of
payment methods
According to Stripe
policies
Outside Cultioo's control; see
Stripe Privacy Policy
12-24 months Security, troubleshooting,
analysis
Device only; no server
storage
Localized services; complete
user control
Varies by data type
and requirement
Compliance with legal, tax, or
regulatory obligations
Privacy Policy
Cultioo App
United States
17.2 Deletion After Purpose Fulfillment
After expiration of the retention period or upon your request (right to delete), your data will be securely deleted or anonymized, unless legal retention obligations prevent deletion.
17.3 Secure Deletion Protocols
Cultioo uses secure deletion methods that prevent data recovery and ensure protection of your privacy.
18. Privacy of Minors
18.1 Children's Online Privacy Protection Act (COPPA)
The Cultioo App is directed to a general adult audience and is not specifically designed or intended for children under 13 years of age. Commitment: Cultioo does not knowingly collect personal information from children under 13 years of age without verifiable parental consent.
18.2 Actions Upon Knowledge
If Cultioo obtains actual knowledge that it has collected personal information from a child under 13 without parental consent, we will:
- Immediately notify the parent or guardian
- Seek verifiable parental consent
- Promptly delete the child's information if consent is not obtained within a reasonable timeframe
Privacy Policy
Cultioo App
United States
18.3 Parental Notice
Parents or guardians are encouraged to contact us if they believe their child has provided personal information to Cultioo without their consent.
18.4 Age Verification
Users are required to affirm they meet the minimum age requirements to use the service upon registration.
18.5 State-Specific Requirements for Minors (Ages 13-17)
California (AB 2273 - Age-Appropriate Design Code):
- Cultioo does not sell or share personal information of users known to be under 18 years of age.
- Default privacy settings for minors are set to the highest level. Parental Rights: Parents or legal guardians of minors may exercise privacy rights on behalf of their children by contacting us with appropriate verification.
19. Do Not Track and Tracking Technologies
19.1 Use of Cookies and Tracking Technologies
The Cultioo App may use cookies and similar tracking technologies to ensure functionality and improve user experience.
Privacy Policy
Cultioo App
United States
19.2 Types of Tracking Technologies
Type Purpose Legal Basis Duration
Essential
Cookies
Analytics
Cookies
Functional
Cookies
Enable basic functions
(e.g., login, shopping
cart)
Contract performance
(necessary for service
provision)
Until session end
or up to 12
months
Analyze usage to
improve the app
Consent or legitimate
interest Up to 12 months
Remember user
preferences and
settings
Consent or legitimate
interest Up to 12 months
19.3 Cookie Control
You can adjust your cookie settings at any time via app settings or your device. Disabling certain cookies may limit app functionality.
19.4 Do Not Track (DNT) Signals
Current Position: Cultioo currently does not honor traditional Do Not Track (DNT) browser signals, as there is no uniform industry standard for responding to such signals.
Transparency: We disclose that third-party tracking may occur through integrated service providers (e.g., analytics platforms).
19.5 Global Privacy Control (GPC)
Commitment to Honor GPC: In compliance with CCPA/CPRA and other state laws, Cultioo commits to recognizing and honoring the Global Privacy Control (GPC) signal as a valid opt-out request for:
- Sale of personal information
- Sharing for cross-context behavioral advertising
Privacy Policy
Cultioo App
United States
Implementation: When we detect a GPC signal from your browser or device, we will treat it as a request to opt-out on that browser/device.
19.6 Third-Party Trackers
The Cultioo App may integrate third-party services that use their own tracking technologies:
Examples:
- Google Analytics (analytics)
- Firebase (crash reporting, analytics)
- Social media plugins (if applicable)
Control: These third parties have their own privacy policies. You can manage third-party tracking through device privacy settings, browser settings, and third-party opt-out tools (e.g., Network Advertising Initiative opt-out page).
19.7 Advertising and Marketing
Current Status: Cultioo does not currently display third-party advertising within the app.
Future Disclosure: If third-party advertising is introduced, you will be informed, and appropriate opt-out mechanisms will be provided.
20. Changes to This Privacy Policy
Cultioo reserves the right to update this Privacy Policy from time to time to reflect changes in legislation, business processes, or best practices in data privacy.
Privacy Policy
Cultioo App
United States
20.1 Notification of Changes
Material changes to this Privacy Policy will be communicated clearly and conspicuously through:
- In-app notification
- Email to your registered email address
- Prominent notice on our website
20.2 Effective Date
The current version of this Privacy Policy is effective as of January 1, 2026.
20.3 Review Recommendation
We recommend that you periodically review this Privacy Policy to stay informed about how we protect your information.
20.4 Continued Use
Your continued use of the Cultioo App after changes to this Privacy Policy constitutes acceptance of the updated terms.
21. Contact Information
21.1 General Inquiries
Cultioo Inc.
A Delaware Corporation
8 The Green, Ste A
Dover, DE 19901
United States of America
Privacy Policy
Cultioo App
United States
Email: support@cultioo.com
21.2 Privacy-Specific Inquiries
Privacy Department
Email: privacy@cultioo.com
21.3 Online Request Portal
You can also submit your requests through our online portal: https://cultioo.com/en/en_cultioo_app_info#privacy
21.4 Mailing Address
Cultioo Inc.
Attn: Privacy Rights / Legal & Compliance Department
privacy@cultioo.com
8 The Green, Ste A
Dover, DE 19901
United States of America
21.5 Response Time
- Privacy rights requests: 45 days (may be extended to 90 days for complex requests)
- General inquiries: 5-7 business days
Last Updated: January 1, 2026 · Version: 1.0
© 2026 Cultioo Inc. All Rights Reserved.