Privacy Policy
This Privacy Notice provides details of the personal data we collect from you, what we do with it, how you might access it and who it might be shared with. We are not going to insult your intelligence by saying, "Your privacy is very important to us..." We rather demonstrate how we operate and value our relationships with people by actually respecting their privacy. We collect a minimal amount of data about individuals and we do not track people who visit our websites or use web analytics, in keeping with our privacy-forward philosophy. Though not subject to GDPR, we have adopted a strict privacy framework.
Our Contact Information (Data Controller)
When accessing the https://www.rethinkprivacy.com website, Cultiva Partners LLC will learn certain information about you during your visit.
Similar to other commercial websites, our website utilizes a standard technology called "cookies" (see explanation below) and server logs to collect information about how our site is used. Information gathered through cookies and server logs may include the date and time of visits, the pages viewed, time spent at our site, and the websites visited just before and just after our own, as well as your IP address.
Use of Cookies
A cookie is a very small text document, which often includes an anonymous unique identifier. When you visit a website, that site"s computer asks your computer for permission to store this file in a part of your hard drive specifically designated for cookies. Each website can send its own cookie to your browser if your browser"s preferences allow it, but (to protect your privacy) your browser only permits a website to access the cookies it has already sent to you, not the cookies sent to you by other sites.
IP Addresses
IP addresses are used by your computer every time you are connected to the Internet. Your IP address is a number that is used by computers on the network to identify your computer. IP addresses are automatically collected by our web host's server as part of demographic and profile data known as “traffic data” so that data (such as the Web pages you request) can be sent to you.
Email Information
If you choose to correspond with us through email, we may retain the content of your email messages together with your email address and our responses. We provide the same protections for these electronic communications that we employ in the maintenance of information received online, mail and telephone. This also applies when you register for our website, sign up through any of our forms using your email address or make a purchase on this site. For further information see the email policies below.
How Do We Use the Information That You Provide to Us?
Broadly speaking, we use personal information for purposes of administering our business activities, providing customer service and making available other items and services to our customers and prospective customers.
Cultiva Partners LLC will not obtain personally-identifying information about you when you visit our site, unless you choose to provide such information to us, nor will such information be sold or otherwise transferred to unaffiliated third parties without the approval of the user at the time of collection.
We may disclose information when legally compelled to do so, in other words, when we, in good faith, believe that the law requires it or for the protection of our legal rights.
What we do with your personal data
We process personal data only for the purpose for which they are collected. The purpose is dependent on whether you use only our website, or additionally, our services. If you use our services you are required to register and we collect your personal data. We use this personal data for the provision of the service or the performance of the contract. We may use your personal data for other similar purposes, including marketing and communications, but that will only occur in the case we have your consent or another legal justification for doing so.
From our Service Providers we process and retain personal data for the following purposes and periods, with the applicable legal basis.
| Processing purpose | Legal basis | Retention period |
| Organization's administration and management | 6(1)(b) - we have a contract with the data subject | Until tax or other retention period expires |
| Site management and security | 6(1)(b) - we have a contract with the data subject | Until contract completed |
| Supplier Management | 6(1)(b) - we have a contract with the data subject | Until tax or other retention period expires |
From our Prospects we process and retain personal data for the following purposes and periods, with the applicable legal basis.
| Processing purpose | Legal basis | Retention period |
| Contact management | 6(1)(a) - we have the data subject's consent | Until consent withdrawn |
| Communications, marketing and intelligence | 6(1)(a) - we have the data subject's consent | Until consent withdrawn |
From our Consultants we process and retain personal data for the following purposes and periods, with the applicable legal basis.
| Processing purpose | Legal basis | Retention period |
| Contact management | 6(1)(b) - we have a contract with the data subject | 2 years post service completion |
| Organization's administration and management | 6(1)(b) - we have a contract with the data subject | Until contract completed |
From our Customers and Clients we process and retain personal data for the following purposes and periods, with the applicable legal basis.
| Processing purpose | Legal basis | Retention period |
| Business operations and due diligence | 6(1)(b) - we have a contract with the data subject | Until tax or other retention period expires |
| Organization's administration and management | 6(1)(b) - we have a contract with the data subject | Until tax or other retention period expires |
| Payment Card Processing | 6(1)(b) - we have a contract with the data subject | Until tax or other retention period expires |
| Sales and Distribution of Products and Services | 6(1)(b) - we have a contract with the data subject | Until contract completed |
| Service delivery | 6(1)(b) - we have a contract with the data subject | Until contract completed |
| Support requests | 6(1)(b) - we have a contract with the data subject | Until service completed |
| Communications, marketing and intelligence | 6(1)(a) - we have the data subject's consent | Until consent withdrawn |
What personal data do we collect?
The personal data we collect depends on whether you just visit our website or use our services. If you visit our website, you do not need to provide us with any personal data. However, your browser transmits some data automatically, such as the date and time of retrieval of one of our web pages, your browser type and settings, your operating system, the last web page you visited, the data transmitted and the access status, and your IP address.
If you use our services, personal data is required to fulfill the requirements of a contractual or service relationship, which may exist between you and our organisation.
We collect:
- Name
- Telephone contact details
- Banking Details
- Confidential Correspondence
- Email, Social Networks
- Identification Number
- Location Information
Who might we share your personal data with?
To maintain and improve our services, your personal data may need to be shared with or disclosed to service providers, other Controllers or, in some cases, public authorities. We may be mandated to disclose your personal data in response to requests from a court, police services or other regulatory bodies. Where feasible, we will consult with you prior to making such disclosure and, in order to protect your privacy, we will ensure that we will disclose only the minimum amount of your information necessary for the required purpose.
We transfer personal data to the following organizations and countries:
| Data subject type | Organization name | Type | Country |
| Service Providers | Blog Vault | Processor | United States |
| Service Providers | Bank | Processor | United States |
| Service Providers | Cloze | Processor | United States |
| Service Providers | Web Host | Processor | United States |
| Service Providers | Fastmail | Processor | Australia |
| Service Providers | Google Drive | Processor | United States |
| Service Providers | Mailer Lite | Processor | United States |
| Service Providers | Stripe | Processor | United States |
| Service Providers | SuiteDash | Processor | United States |
| Service Providers | Tresorit | Processor | Switzerland |
| Service Providers | Xero | Processor | United States |
| Prospects and leads | Cloze | Processor | United States |
| Prospects and leads | Mailer Lite | Processor | United States |
| Consultants | Cloze | Processor | United States |
| Consultants | Fastmail | Processor | Australia |
| Consultants | Google Drive | Processor | United States |
| Consultants | Tresorit | Processor | Switzerland |
| Customers and Clients | Bank | Processor | United States |
| Customers and Clients | Cloze | Processor | United States |
| Customers and Clients | Fastmail | Processor | Australia |
| Customers and Clients | Google Drive | Processor | United States |
| Customers and Clients | Mailer Lite | Processor | United States |
| Customers and Clients | Stripe | Processor | United States |
| Customers and Clients | SuiteDash | Processor | United States |
| Customers and Clients | Tresorit | Processor | Switzerland |
| Customers and Clients | Xero | Processor | United States |
When a Processor or Controller is in a country outside the EU, we apply the necessary safeguards which may include, confirming whether the EC approves of transfers to the country, whether we need to use the EDPB Standard Contractual Clauses or, if the transfer is internal to our organization, commitment to Binding Corporate Rules. Details of these safeguards may be obtained by contacting us directly.
How do we look after personal data?
We limit the amount of personal data collected only to what is fit for the purpose, as described above. We restrict, secure and control all of our information assets against unauthorized access, damage, loss or destruction; whether physical or electronic. We retain personal data only for as long as is described above, to respond to your requests, or longer if required by law. If we retain your personal data for historical or statistical purposes we ensure that the personal data cannot be used further. While in our possession, together with your assistance, we try to maintain the accuracy of your personal data.
How can you access your personal data?
You have the right to request access to any of your personal data we may hold. If any of that information is incorrect, you may request that we correct it. If we are improperly using your information, you may request that we stop using it or even delete it completely.
If you would like to make a request to see what personal data of yours we might hold, you may make a request
Where you have previously given your consent to process your personal data, you also have the right to request that we port or transfer your personal data to a different service provider or to yourself, if you so wish.
Where it may have been necessary to get your consent to use your personal data, at any moment, you have the right to withdraw that consent. If you withdraw your consent, we will cease using your personal data without affecting the lawfulness of processing based on consent before your withdrawal.
Email Policies
We are committed to keeping your e-mail address confidential. We do not sell, rent, or lease our subscription lists to third parties, and we will not provide your personal information to any third party individual, government agency, or company at any time unless strictly compelled to do so by law.
We will use your e-mail address solely to provide timely information about ReThinkPrivacy.com resources, research and services.
We will maintain the information you send via e-mail in accordance with applicable federal law.
CAN-SPAM Compliance
In compliance with the CAN-SPAM Act, all e-mail sent from our organization will clearly state who the e-mail is from and provide clear information on how to contact the sender. In addition, all e-mail messages will also contain concise information on how to remove yourself from our mailing list so that you receive no further e-mail communication from us.
Choice/Opt-Out
Our site provides users the opportunity to opt-out of receiving communications from us by reading the unsubscribe instructions located at the bottom of any e-mail they receive from us at anytime.
How Do We Protect Your Information and Secure Information Transmissions?
Email is not recognized as a secure medium of communication. For this reason, we request that you do not send private information to us by email. However, doing so is allowed, but at your own risk. Some of the information you may enter on our website may be transmitted securely via a secure medium known as Secure Sockets Layer, or SSL. Credit Card information and other sensitive information is never transmitted via email.
For site security purposes and to ensure that this service remains available to all users, Cultiva Partners LLC uses software programs to monitor network traffic to identify unauthorized attempts to upload or change information, or otherwise cause damage.
Policy Changes
We reserve the right to amend this privacy policy at any time with or without notice. However, please be assured that if the privacy policy changes in the future, we will not use the personal information you have submitted to us under this privacy policy in a manner that is materially inconsistent with this privacy policy, without your prior consent.
We are committed to conducting our business in accordance with these principles in order to ensure that the confidentiality of personal information is protected and maintained.
