Privacy Policy

Effective Date: October 1, 2026

Responsible Business: Cul7ure Corporation (“Cul7ure Corp”), [address], hello@kul7ure.com

About This Privacy Policy

Your privacy matters to us.

This Privacy Policy explains how Cul7ure Corp handles personal information when you use Kul7ure, create an account, accept an invitation, contribute content, or contact us.

This policy applies to visitors, registered Members, and Invited Members.

Information We Collect

We collect and process the following categories of information:

Account and Profile Information: Your Google account email address and name; the Username you choose; your profile photo (if you upload one) or default avatar color; your Country and Language settings; notification settings; your blocked-user list; your account type (member, invited member, or operator); and your previous Username for 30 days after a change.

Invitation Information: Your application form responses (Google account email, name, country, categories, topics you create about, channel links, posting languages, your optional reason for joining, and your consent to be contacted about your application), and invitation records, including the invited email address and when the invitation was sent, re-sent, cancelled, expired, or accepted.

Contributions and Communications: Content you submit, reports, and support messages.

Technical and Usage Information: Sign-in session data (kept up to 30 days after your last activity); browser language and time zone; activity such as posts and News you view, nodes and communities you open, your searches and recently viewed items, and your likes, claps, votes, reports, blocks, and “Not interested” choices; identifiers used to count views and visitors without double-counting, including for visitors who are not signed in; and IP address and browser information recorded in access and server logs.

Kul7ure accounts use Google sign-in. From Google, we receive your name, email address, profile photo URL, and a unique Google account identifier. We store your name, email address, and Google account identifier; we do not use your Google profile photo as your Kul7ure profile image. We do not receive your Google account password.

How We Use Your Information

We use personal information as necessary to create and secure accounts, provide requested features, manage invitations, display contributions, respond to requests, and enforce our community rules.

We also use usage and technical information, such as which pages, nodes, posts, and News are viewed, searches, and reactions, to understand and improve Kul7ure.

Optional marketing emails are managed separately from account and security notifications.

Legal Bases for Processing: For processing subject to the GDPR, we distinguish data necessary to perform our contract (account access and requested community functions), legitimate interests balanced against your rights (security, abuse prevention, and proportionate service administration), legal obligations, and freely given consent for activities requiring it, such as certain optional cookies or marketing. The purposes, data categories, legal bases, and choices are set out in the list below. Acceptance of the User Agreement does not itself supply a legal basis for every use.

Performance of contract: creating your account, signing you in with Google, and keeping you signed in; providing the features you request, such as posting, commenting, reactions, voting, search history, notifications, translation, and settings; reviewing your application to become an invited member and managing invited-member access, as steps you request before and under our agreement; and processing account deletion. Data used: account and profile information, Google sign-in information, session data, contributions, usage information, and invitation information.

Legitimate interests: keeping Kul7ure safe and preventing abuse, including reports, hidden content, blocking, posting-rate limits, and filtering automated views; understanding and improving Kul7ure, including counting views and visitors and calculating trend signals and rankings such as Weekly Best; and enforcing our Rules and Terms and establishing or defending legal claims. Data used: contributions, usage information, and technical information.

Legal obligations: responding to lawful requests, handling copyright (DMCA) notices, and handling and recording privacy rights requests. Data used: the information needed for the specific request.

Consent: contacting you by email about your application, where you agreed in the application form, and optional cookies where the law requires consent. Data used: your application email address and cookie information.

Where we rely on legitimate interests, you can ask us for more information about how we balanced those interests against your rights. You can withdraw consent at any time; withdrawal does not affect processing that took place before it.

Public Information and Data Sharing

Your Username (@handle), profile image, and content posted in public spaces may be visible to others. Please avoid posting information you wish to keep private.

We share information with service providers that help us operate Kul7ure, subject to appropriate arrangements: Amazon Web Services (servers, database, image storage, logs, and email delivery), Vercel (website delivery), Google (sign-in and application forms), Sentry (error monitoring), Bunny Stream (video hosting), and translation and AI services provided through griplabs.io and sndworks.ai, which may use their own service providers. Embedded YouTube and TikTok videos are provided by those services, which may collect information under their own policies.

We may disclose information when legally required, when reasonably necessary to protect rights and safety, or in connection with a business transfer subject to applicable protections.

Advertising, Data Sale, Sharing, and Third-Party Tracking: Our advertising, sale, sharing, and opt-out practices are described in the United States Privacy Supplement. Cookie details and controls are listed in the cookie inventory.

Cookies and International Data Processing

We use essential cookies and similar technologies to keep you signed in (for up to 30 days after your last activity) and to protect accounts and the service. Their names and durations are listed in the cookie inventory.

Cookie Inventory: refresh_token keeps you signed in (30 days); post_visitor and community_visitor count post views and community visitors without double-counting, including for visitors who are not signed in (365 days). These are first-party cookies. We also use browser session storage for sign-in, navigation, and diagnostics. Embedded YouTube and TikTok players load only when you choose to play a video; until then, those providers do not set cookies through Kul7ure. Once a player loads, Google (YouTube) or TikTok may set cookies or similar technologies under their own privacy and cookie policies. Optional Cookies and Your Choices: Kul7ure does not currently use optional cookies that require consent. The visitor-counting cookies above are used only to produce aggregate view and visitor counts for Kul7ure; they are not used for advertising or shared with third parties. You can block or delete cookies in your browser settings; blocking refresh_token will sign you out. If we add optional cookies, we will update this inventory and request any required consent before they are used.

Personal information is mainly processed in South Korea, where our main servers, database, backups, and email delivery are located, and in the United States for website delivery and error monitoring. Video hosting (Bunny Stream, based in Slovenia) and translation and AI processing may also take place in other countries where those providers or their service providers operate. Our operations teams access data from South Korea and the United States.

International Transfer Safeguards: See the EEA Privacy Supplement for the transfer-mechanism and safeguards disclosure.

Data Retention and Deletion

We retain personal information for the purposes described in this policy and according to the following periods: account and profile information for 30 days after account deletion; sign-in sessions until 30 days after your last activity; notifications for 30 days (notices about hidden content remain until the content is restored or deleted); recent searches and recently viewed items until you clear them or delete your account; a previous Username for 30 days after a change or account deletion, during which no one else can use it; invitation links for 14 days after they are sent; server and API access logs for 60 days; post and community visitor cookies for 365 days; automatic database backups for 7 days; database logs for 60 days; server visit records for 365 days; report and moderation records for 1 year after the report is resolved; copyright notices and counter-notices for 3 years after they are resolved; previous image storage versions for 30 days; application form responses from applicants who are not selected for 6 months after the decision (responses from selected applicants are kept with their invitation records); and error-monitoring (Sentry) data for up to 90 days.

You can request account deletion through Settings > Account > Delete Account.

We handle accounts, public contributions, support records, invitation records, and backup copies as follows: when you delete your account, access to your account and your posts, comments, and replies ends immediately. The account and contributions cannot be restored. We retain them for 30 days and then permanently delete them (a comment that has replies is replaced by “This comment was deleted.”); remove your likes, votes, and claps from all counts; and delete your block list, notifications, recent searches, and recently viewed items. Your Username cannot be used by others for 30 days. After permanent deletion from the active database, remaining backup copies expire within 7 days. Support records and invitation records are kept for 1 year after the request is handled or the invitation is accepted, expires, or is cancelled, and previous image storage versions are deleted after 30 days.

Some information may be retained when required by law or necessary for defined security or dispute-related purposes. We will explain any applicable exceptions.

Deleting your account does not remove copies independently held by third parties.

Your Privacy Rights and Choices

You can request assistance with accessing, correcting, or deleting your personal information at hello@kul7ure.com.

Depending on your location, you may also have rights to data portability, restriction of processing, objection, withdrawal of consent, or opting out of certain processing activities, as well as the right to complain to a regulator.

We may need to verify your identity before processing a request.

Regional Rights and Request Procedures: See the United States and EEA supplements below. We use proportionate verification and explain any lawful refusal, applicable appeal, and available regulator or court remedies. Contact hello@kul7ure.com.

You can unsubscribe from marketing emails using the link included in those emails. Necessary account or security notifications may still be sent.

Children's Privacy and Security

Kul7ure’s minimum account age is 14, or a higher age where local law requires. Any required parental agreement or data-processing authorization must also be obtained. A contractual minimum age does not replace applicable child-privacy obligations.

We do not knowingly collect personal information from children below that age.

If you believe an ineligible child has provided personal information, please contact hello@kul7ure.com, and we will delete it.

We use reasonable administrative, technical, and organizational safeguards, such as HTTPS, encryption of our database and image storage, and access controls, to protect information, although no system can guarantee complete security.

Updates and Contact

We may revise this Privacy Policy and will post the effective date. Nonmaterial clarifications may be posted without separate individual notice where lawful. Material changes receive prominent advance notice and any separate consent required before the relevant new processing begins. We do not use a policy update or continued use as a substitute for legally required consent.

For privacy-related questions, contact hello@kul7ure.com or [address].

United States Privacy Supplement

Cul7ure Corp is the U.S. operator responsible for its processing described in this Policy. Where applicable state privacy law covers both you and our activities, rights may include access, correction, deletion, a portable copy, and opt-outs of sale, targeted advertising, or certain profiling. California rights can also include limits on certain sensitive-information uses. We do not discriminate for exercising protected rights. Authorized agents may act where the law permits.

Send requests and eligible appeals to hello@kul7ure.com. We respond within the applicable statutory period; for covered California access, correction, and deletion requests, generally within 45 days, with any lawful extension explained. Sale/sharing opt-outs have different timelines and generally do not require identity verification. Where legally required, we honor recognized opt-out preference signals, including Global Privacy Control. Our advertising, sale, and sharing practices and available opt-out methods: Kul7ure does not show advertising and does not use advertising or tracking pixels. [Confirm after vendor contract review, including embedded YouTube and TikTok players: we do not sell personal information or share it for cross-context behavioral or targeted advertising, so no sale or sharing opt-out currently applies.] If this changes, we will update this Policy and provide opt-out methods before the change takes effect.

EEA Privacy Supplement

Where the GDPR applies to our processing, Cul7ure Corp is the controller for the purposes it determines. U.S. incorporation does not remove applicable European obligations. You may request access, correction, erasure, restriction, or portability where available, object to qualifying processing, withdraw consent without affecting earlier lawful processing, and complain to a competent supervisory authority. You have applicable protections against solely automated decisions with legal or similarly significant effects.

Contact hello@kul7ure.com. We respond without undue delay, normally within one month. Where legally justified, we may extend by two further months and explain the extension within the first month. We request only proportionate verification. Processing based on legitimate interests is subject to the applicable objection rules, and you may object to direct marketing at any time.

Optional cookies requiring consent are not activated before that consent, and withdrawal must be as easy as giving consent. The cookie inventory in “Cookies and International Data Processing” describes the required consent controls. Transfers to the United States or another third country use an applicable lawful mechanism, such as a European Commission adequacy decision (including the decision for the Republic of Korea) or the Standard Contractual Clauses approved by the European Commission. We do not claim Data Privacy Framework certification. You may request information about relevant safeguards. EU representative details, if legally required: [EU representative name, address, and contact].

UK and Swiss privacy rules apply separately where relevant; this EEA supplement does not cover them.