PRIVACY POLICY"Culture Insights", "AI Coaching Insights", “”, "CI", “us,” "we," or “our”) is committed to protecting and respecting your privacy in connection with your use of our product, CI Coach (the "product", "app", "application") and other products, services and features are collectively referred to herein as the “Product” or “Products”, which may be updated from time-to-time at the sole discretion of Culture Insights). This privacy policy (“Privacy Policy”) and any other documents referred to herein set forth the basis on which any personal data we collect from you, or that you provide to us, in connection with the Products will be processed by us. Please read the following carefully to understand our practices regarding your personal data and how we will collect, use and disclose your personal data. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact us at

We may collect and process the following data about you: your name, e-mail address, data about your usage of the Products inluding device type, OS and browser versions.

The security of your personal data is important to us. We follow generally accepted standards to protect any data collected by us and any data submitted by you while using the Products, both during transmission and once it is received. If you have any questions about the security of your personal data, you can contact us at We do not provide your personal data to any third party without your specific consent, as defined by applicable law.

If you opt in to receive notification via email or mobile notifications, we will use the data you give us to provide the communications you have requested. If you choose not to receive communications from us, you can do so by turning off notifications from the Settings tab of CI Coach

4. TRACKING TECHNOLOGIES and our analytics partners use technologies such as cookies, beacons, tags, and scripts to enable a service to recognize your device so you don't have to provide the same data several times during one task, to recognize that you may have already given a username and password so you don't need to do it for every web page requested, and to measure how people are using the Products. We use cloud-bases storage to store content data and preferences. We use our both internal and partner services, such as Google analytics, to gather statistical data to better understand how our products are used
MOBILE ANALYTICS - We track app installation in mobile devices through the built-in Google and Apple app stores tracking mechanism. No app installation data is shared with third-party vendors or partners.
LOG FILES - As true of most websites and mobile apps, we gather certain data and automatically and store it in log files. This data may include Internet Protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. If you receive the HTML-formatted version of our email newsletter, your opening of the newsletter is notified to us and saved. Your clicks on links in the newsletter are also saved. These and the open statistics are used in aggregate form to give us an indication of the popularity of the content and to help us make decisions about future content and formatting.

All data you provide to us through the Products is stored on our secure servers located in the United States. We never store your password because all CI Coach users must log in with their respective cloud or SSO accounts where the authentication is made at the identity provider, such as Google, Microsoft, Apple, Zoom or the organization's own Single-Sign-on system. All data transmitted to and from us are encrypted with today's accepted level of encryption.

You may be able to log-in to our Products using sign-in services provided by companies like Google, Microsoft, Apple, and Zoom. These services will authenticate your identity, provide you the option to share certain personal data (such as your name and email address) with us, and to pre-populate our sign-up form.

As you may know, a recent European Union law called the General Data Protection Regulation (“GDPR”) give certain rights to applicable individuals in relation to their personal data. Accordingly, we have implemented transparency and access controls to help such users, including residents of the EU, Switzerland, and the United Kingdom exercise those rights. As required under applicable law, the rights afforded to you are:
A right of access: you have the right to obtain (i) confirmation as to whether personal data concerning you are processed or not and, if processed, to obtain (ii) access to such data and a copy thereof. We provide an easy-to-view snapshot of such data via the “My Data” tab in the Products.
A right to rectification: you have the right to obtain the rectification of any inaccurate personal data concerning you. You also have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
A right to erasure: in some cases, you have the right to obtain the erasure of personal data concerning you. Upon request, will permanently and irrevocably anonymize your data such that it can never be reconstructed to identify you as an individual. However, this is not an absolute right and may have legal or legitimate grounds for keeping such data.
A right to restriction of processing: in some cases, you have the right to obtain restriction of the processing of your personal data.
A right to data portability: you have the right to receive the personal data concerning you which you have provided to, in a structured, commonly used and machine-readable format, and you have the right to transmit those data to another controller without hindrance from This right only applies when the processing of your personal data is based on your consent or on a contract and such processing is carried out by automated means.
A right to object to processing: you have the right to object at any time, on grounds relating to your particular situation, to processing of personal data concerning you when such processing is based on the legitimate interest of may, however, invoke compelling legitimate grounds for continued processing. When your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of such data. You may, in particular, exercise that right by clicking on the “unsubscribe” link provided at the bottom of any messages received, or by managing your privacy preferences by logging in to your account and following the instructions here.
A right to lodge a complaint with the competent supervisory authority: you have the right to contact the supervisory authority to complain about’s personal data protection practices.
A right to give instructions concerning the use of your data after your death: as required by applicable law, you may have the right to give instructions concerning the use of your personal data after your death. To exercise one or more of these rights, you can email
You may access your personal data to modify or update at any time via an online account, or by emailing
We will respond to your request in a reasonable timeframe in accordance with applicable law.


We use information held about you in the following ways:
To provide you with the Products.
To answer your questions or requests for information or handle your complaints.
To ensure that content provided by the Products is presented in the most effective manner for you and for your computer or other device.
To provide you with promotional communications, such as email, to the extent that you have provided consent to receive such communications under applicable law.
To carry out our obligations arising from any agreements entered into between you and us.
To allow you to participate in interactive features of the Products, when you choose to do so.
To notify you about updates or changes to Product features and content.
To understand your broad, non-specific geographic location to help us identify groups of users by general geographic market (such as zip code, state or country).
To account for applicable sales taxes based on zip codes provided to our payment processors for purchases made through the Website.
To inform your Community about your registration and use of the Products as described under Corporate and Other Community Sharing in section 6 above.
To serve our advertisements to you through third party platforms, such as Facebook or Google, on other sites and apps or across your devices, to the extent that you have provided consent for such uses under applicable law.
To provide you with the SMS Service to the extent that you have provided consent for such practices under applicable law.
We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
To manage your payments and orders.
If you are an existing customer, we will only contact you by electronic means (e-mail or in-Product communication) with information about products and services similar to those which were the subject of a previous sale to you, except if you opt-out to such communications.
If you choose to become a primary account holder of a Family plan, we may cross reference the address you’ve provided with that of any subsidiary account holder seeking to join your Family plan in order to verify the validity of the subsidiary account holder.
If you choose to become a subsidiary account holder of a Family plan, we may cross reference the address you’ve provided with that of any primary account holder administering your Family plan in order to verify the validity of your subsidiary account


In accordance with GDPR, provides the following information regarding its Article 6 legal bases for personal data processing:

The performance of the contract (the Terms & Conditions) between you and for the data processing relating to your use of’s Products (including your orders and payments);’s legitimate interest, more specifically:
Our business interest in providing you with emails and push notifications for timely introductory materials and information about your account, our Product features and updates, and offers to upgrade your free account to a subscription account.
Our financial interest in providing you with promotional offers and/or discounts with respect to paid subscriptions and special offerings, such as the Family Plan.
Our business interest in offering you particularized or adapted content based on your usage of the Products.
Our business interest in collecting data regarding your general usage activities for the purpose of improving our user experience.
Our business interest in requesting that you partake in Product surveys in order to better understand your needs and expectations.
Our financial interest in providing you the opportunity to purchase subscriptions for the benefit of a third party through the “gifting” program.
Our business interest in providing you the opportunity to invite a “Buddy” to and share information about your activities with your connected “Buddies”.
Our business interest in providing you with customer service communications regarding your account, questions about our content offerings or your mindfulness practice, or any other matters directed to customer service staff, in order to have clear and easy communication with you and to respond to all your requests.
Our business interest in collecting data related to unplanned downtime or errors in the Products.
Our business interest in complying with our legal obligations, such as maintaining accurate financial records.
Our business interest in verifying your eligibility in a Community and providing limited reporting to such Community, as further described in section 6.

We may disclose your personal data to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.
We may also disclose your personal data to third parties as follows:
In some circumstances, based on your specific requests, we may need to disclose your personal data to a third party so that it can provide a service you have requested from such party, or fulfill a request for data from such party. An example of this is the SMS Service.
In some circumstances, we may disclose the personal data that you have provided to Culture Insights to a third party that offers and/or provides goods or services complementary to our own for the purpose of enhancing our users’ experiences by offering you integrated or complementary functionality, complementary services or bundled pricing options.
If’s service providers (like hosting, IT maintenance, market analytics, and payment service providers) require this data to provide services to Culture Insights requires each of its service providers to agree to maintain the confidentiality and security of your personal data.
In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
If or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets.
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation such as to comply with a subpoena, bankruptcy proceedings, similar legal process, or in order to enforce or apply our agreements with you; or to protect the rights, property, or safety of, our customers, or others. This includes exchanging data with other companies and organizations for the purposes of fraud protection and credit risk reduction.
With your Community, if your subscription is a Community Subscription, as described under Corporate and Other Community Sharing above.
With third parties, such as Facebook, in order to serve advertisements on such third party platforms, to the extent that you have consented to such practices under applicable law.
If you choose to have your account verified to confirm your status as a student, we may allow a third party platform to access the specific personal data you provide in order to perform the verification.
If you chose to have your account verified to confirm your status as a US-based healthcare provider, we may collect your National Provider Identifier (“NPI”) in connection with your email address in order to perform the verification.

The retention periods applied by comply with applicable legislation in effect on the date hereof, namely:
For data relating to your account: such data will not be retained beyond your request that your account be deleted.
For transactional data relating to your purchases: such data is kept for the entire period of the contractual relationship, then in accordance with legal obligations and applicable statute of limitation periods. Please note that this data does not include Payment Card information, which is processed by our third-party payment processors, and not
For data collected based on your consent to receive our marketing communications: we will use such data until you withdraw consent or applicable law requires that such data is no longer used.
When your data are collected in the context of requests/queries: such data are kept for the period necessary to process and reply to such requests or queries.
When cookies or other trackers are placed on your terminal, they are kept for a period of 12 months.
Other data will be kept as long as necessary for the purposes pursued and in compliance with our legal obligations, including the applicable statute of limitations.

To the extent that you have provided appropriate consent under applicable law to certain processing activities, such consent can be withdrawn at any time by emailing

The Products may, from time to time, contain links to and from the Products of our partner networks, advertisers and affiliates. If you follow a link to any of these external websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these websites or their policies. Please check these policies before you submit any personal data to these external websites.

Our Products include social media features, such as the Facebook Like button, and widgets, such as the “Share This” button, or interactive mini-programs. These features may collect your Internet protocol address, which page you are visiting on or Products, and may set a cookie to enable the feature to function properly. Social media features and widgets are hosted by a third party or hosted directly on our Products. Your interactions with these features are governed by the privacy statement of the company providing it.

You must be 18 years of age, or the age of majority in your province, territory or country, to sign up as a registered user of the Products. Individuals under the age of 18, or the applicable age of majority, may utilize the Products only with the involvement and consent of a parent or legal guardian, under such person's account.

16. DATA POSTED ON FORUMS users may have the ability to post content to one or more forums. All such users may request and obtain removal of such posted content by contacting at and specifically identifying the content to be removed. Please be advised that any such removal does not ensure complete or comprehensive removal of all traces of the content posted on the forum(s).

We may update this Privacy Policy to reflect changes to our data practices. If we make any material changes we will notify you by in-Product message, email (sent to the e-mail address specified in your account) or by means of a notice in the Products prior to the change becoming effective. We encourage you to periodically review this page for the latest data on our privacy practices.

Our Products 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 consumer or device (“personal information”). In particular, the Products have collected the following categories of personal information from consumers:
1. Identifiers: First and last name, email address, Internet Protocol address, online identifiers. YES
2. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)): First and last name. YES
3. Internet or other similar network activity: Browsing history or information on a consumer’s interaction with the Products or our advertisements on third-party platforms.