Privacy Policy

Effective Date: July 4, 2026  |  Last Updated: July 4, 2026

1. Who We Are

Cultural Relevance, LLC, a Delaware limited liability company (“Cultural Relevance,” “CR,” “we,” “us,” or “our“), operates culturalrelevance.com, aura.culturalrelevance.com, and related websites, applications, assessments, certifications, events, and services (collectively, the “Services“). This Privacy Policy explains how we collect, use, disclose, and protect personal information when you use the Services. For personal information we process on behalf of our enterprise customers (for example, data submitted by a customer’s workforce into the AURA AI platform under an enterprise agreement), we act as a processor/service provider, and the enterprise customer’s privacy notice and our Data Processing Agreement govern that data. This Policy covers data for which we are the controller/business.

2. Information We Collect

Information you provide

Contact and account details (name, email, company, role, password); assessment and quiz responses, including the Cultural Debt Score™ assessment; certification and program applications (CR Smart™, Culture Collective, accelerator programs); event registrations; payment information (processed by our payment processors — we do not store full card numbers); communications with us; and content you submit to the Services, including prompts and inputs to AURA AI.

Information collected automatically

Device and usage data (IP address, browser type, pages viewed, referring URLs, session activity), collected via cookies and similar technologies as described in our Cookie Policy.

Information from other sources

Business contact data from partners, event co-hosts, publicly available sources, and data providers, used for business development and research.

3. How We Use Information

We use personal information to provide, secure, and improve the Services; deliver assessment results, scores, and certifications; process transactions and registrations; communicate with you, including marketing you can opt out of at any time; conduct research and produce aggregate cultural intelligence insights; comply with law; and protect our rights and users.

AI systems and research data

We do not use enterprise customer content to train artificial intelligence models without the customer’s express written consent. Inputs to AURA AI under an enterprise agreement are governed by that agreement. We may use data that has been de-identified or aggregated so it can no longer reasonably be linked to you — including for our Cultural Persona Databaseâ„¢ research — and we commit to maintaining such data in de-identified form and not attempting to re-identify it.

Legal bases (EEA/UK visitors)

Where the GDPR or UK GDPR applies, we process personal data on the bases of contract performance, our legitimate interests (operating and improving the Services, securing our systems, B2B marketing), consent (where required, e.g., certain cookies and email marketing), and legal obligation.

4. How We Disclose Information

We disclose personal information to: service providers (hosting, analytics, payment, email, customer support) bound by contractual confidentiality and use limitations; business partners where you direct or consent (e.g., event co-hosts); professional advisors; parties to a corporate transaction (merger, financing, acquisition); and authorities where required by law. We do not sell personal information for money. Certain advertising cookies may constitute a “sale” or “sharing”/”targeted advertising” under some state laws; you can opt out as described in Section 6 and in our Cookie Policy.

5. Cookies and Tracking

See our Cookie Policy for details on the cookies we use and your choices. We honor the Global Privacy Control (GPC) and other recognized universal opt-out signals as an opt-out of targeted advertising and any “sale”/”sharing” of personal information, as required by applicable state laws.

6. Your Privacy Rights

Depending on where you live — including California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, Virginia, the EEA, and the UK — you may have the right to:

• Know/Access the personal information we hold about you, including in a portable format;
• Correct inaccurate personal information;
• Delete your personal information;
• Opt out of targeted advertising, “sale”/”sharing” of personal information, and profiling in furtherance of decisions producing legal or similarly significant effects;
• Limit the use of sensitive personal information, where applicable;
• Non-discrimination for exercising any of these rights.

To exercise these rights, email privacy@culturalrelevance.com with the subject line “Privacy Request.” We will verify your identity and respond within the time required by law (generally 45 days). Authorized agents may submit requests with proof of authorization. Appeals. If we decline your request, you may appeal by replying to our decision email with “Appeal” in the subject line. If your appeal is denied, you may contact your state Attorney General.

Notice to California residents

In the preceding 12 months we have collected the following categories of personal information under the CCPA/CPRA: identifiers; commercial information; internet/network activity; professional information; inferences; and, where you provide it through assessments, information that may reveal characteristics protected under law (collected only with your consent and used only for the purposes disclosed at collection). We retain each category only as long as needed for the purposes described in Section 8. California residents may exercise the rights above; we do not knowingly sell or share the personal information of consumers under 16.

7. Sensitive Information

Some CR research and assessments may invite you to voluntarily share information about cultural identity or related characteristics. Providing it is always optional, requires your consent where the law demands it, and is used only for the disclosed research or assessment purpose. You may withdraw consent at any time by contacting us.

8. Data Retention

We retain personal information only as long as reasonably necessary for the purposes described in this Policy, to comply with legal obligations, resolve disputes, and enforce agreements. Retention periods are based on data type, sensitivity, legal requirements, and business need. When no longer needed, data is deleted or de-identified.

9. Security

We maintain administrative, technical, and physical safeguards appropriate to the sensitivity of the data, including encryption in transit and at rest, access controls with multi-factor authentication, logging and monitoring, and vendor security review. No system is perfectly secure; we cannot guarantee absolute security.

10. International Data Transfers

We are based in the United States and process data there. Where we transfer personal data from the EEA, UK, or Switzerland, we rely on appropriate safeguards, including the European Commission’s Standard Contractual Clauses and, where certified, the EU–U.S. Data Privacy Framework.

11. Children

The Services are not directed to children under 16, and we do not knowingly collect personal information from them. If you believe a child has provided us personal information, contact us and we will delete it.

12. Changes to This Policy

We may update this Policy from time to time. Material changes will be announced on this page with an updated effective date and, where required, additional notice or consent.

13. Contact Us

Cultural Relevance, LLC Attn: Privacy Email: privacy@culturalrelevance.com