Privacy Policy

Effective Date: April 7, 2026

Culture Freedom Foundation (“Culture Freedom Foundation,” “we,” “us,” “our”) is committed to protecting the privacy of individuals who interact with our website, applications, services, partners, developers, and customers. This Privacy Policy (“Policy”) explains how we collect, use, disclose, retain, and protect Personal Data, and describes your rights under various applicable privacy and data protection laws, including GDPR (EU/UK), U.S. state privacy laws (such as CCPA/CPRA, Colorado’s Privacy Act, etc.), and other laws.

1. Scope & Who We Are

We support artists, creators, and communities by connecting culture with technology — enabling individuals and organizations to participate in blockchain-powered ecosystems that reward creativity and collaboration. This Policy applies to all Personal Data (defined below) that we collect when you use our website, services, interact with us, partner with us, or through other touchpoints where we act as data controller (or co-controller) under applicable laws.

If you are located in the EU, UK, or in U.S. states with data privacy laws, additional rights as described below apply.

2. Definitions

• Personal Data / Personal Information: Any information that identifies or can be used to identify an individual.
• Sensitive Personal Data / Special Categories: As defined under GDPR or certain U.S. laws (e.g. racial or ethnic origin, religious beliefs, health data, etc.).
• Processing: Any operation or set of operations performed on Personal Data (collecting, storing, using, disclosing, altering, deleting, etc.).
• Data Subject / Consumer / User: A person whose Personal Data is processed.
• Controller / Processor: As defined under GDPR and relevant U.S. state laws.

3. What Data We Collect

Depending on your interaction with us, we may collect:

• Identity & Contact Data (name, email address, postal address, phone)
• Account / Login Data, Credentials (hashed passwords)
• Transactional Data (records of interactions, rewards, usage)
• Device & Usage Data (IP address, browser/device type, cookies, analytics)
• Blockchain Data (public wallet addresses, transaction IDs/hashes, if applicable)
• Optional / Voluntary Data (preferences, feedback, demographic info)
• Sensitive Data only when you provide it or consent (if applicable)

4. How We Use Your Data

We use your Personal Data for purposes such as:

• Providing, operating, maintaining, and improving our services
• Enabling creators, communities, and partners to participate in blockchain-powered ecosystems and delivering digital reward features
• Customer support, communications, account administration, notifications
• Compliance with legal obligations, fraud prevention, security
• Analytics, research, product/service improvements
• Marketing (only with your consent or as permitted by law)

5. Legal Bases for Processing (Under GDPR & Other Laws)

Under GDPR: Consent; contract performance; legal obligation; legitimate interests (where not overridden by your rights)

Under U.S. state laws: Where required by law, under consent or with opt-out rights; for contract performance; for legal compliance; for legitimate business purposes consistent with your rights under your state’s law

6. Sharing / Disclosure of Data

We may share your Personal Data with:

• Service providers and vendors (e.g. hosting, analytics, payment processors)
• Business partners who provide integrated services, or in co-delivering products/features
• Regulators, law enforcement, courts, as required by law or to protect rights, property, or safety
• Potential acquirers or in business transfers, under confidentiality and data protection safeguards

7. International Transfers

If data transfers outside the EU/UK occur, we will use recognized safeguards (e.g. Standard Contractual Clauses) or rely on adequacy decisions/different lawful bases under those laws. We ensure similar protection for cross-border data transfer as required by GDPR or other applicable laws.

8. Data Retention

We keep Personal Data only as long as needed for the purposes stated in this Policy, or as required by law, or to resolve disputes and enforce agreements. When retention is no longer necessary, we securely delete or anonymize data in accordance with our internal policies and legal obligations.

9. Your Rights

Depending on your jurisdiction, you may have rights such as:

• Access your Personal Data
• Correct inaccurate or incomplete information
• Delete or erase your Personal Data (subject to legal or contractual exceptions)
• Restrict or object to certain processing
• Data portability (for GDPR or state laws where applicable)
• Withdraw consent (if consent is the basis for processing)
• Opt-out of sale or sharing of your Personal Data (as required under state laws)

If you are in the EU/UK, these are rights under GDPR. If you are in certain U.S. states (e.g. California, Colorado, Virginia, Connecticut, Delaware, etc.), you have rights under those state laws. See links below.

10. Cookies, Tracking & Similar Technologies

We may use cookies, web beacons, and similar tracking technologies to provide, analyze, personalize, and secure our services. You may be able to disable or manage cookies via browser settings or via consent tools, though some features may be impacted.

11. Security

We maintain reasonable technical, physical, and administrative safeguards to protect your Personal Data. We conduct regular reviews of our security practices. If a breach occurs, we follow applicable laws regarding notification to affected individuals and authorities.

12. Children’s Privacy

We do not knowingly collect Personal Data from children under 13 (or applicable state age) without consent of a parent or guardian. If you believe we have collected such data, contact us at the email below and we will take steps to remove it.

13. Applicable U.S. State Privacy Laws

Culture Freedom Foundation complies with all applicable U.S. state consumer and data privacy laws to the extent required by law. These laws grant residents of certain states specific rights regarding the collection, use, and disclosure of their personal information. We are committed to honoring those rights and ensuring transparency in our privacy practices.

For your convenience, we have provided direct links below so that you can review the full text of each applicable state privacy law. By accessing these links, you may view the specific requirements, consumer rights, and obligations imposed under each statute. We encourage you to review the laws that apply to your jurisdiction to better understand your rights and our responsibilities.

State	Law	Link
California	CCPA / CPRA	oag.ca.gov/privacy/ccpa
Colorado	Colorado Privacy Act (CPA)	coag.gov/privacy/colorado-privacy-act
Virginia	VCDPA	law.lis.virginia.gov
Connecticut	CTDPA	portal.ct.gov
Delaware	DPDPA	delaware.gov/dpdpa
Iowa	ICDPA	legis.iowa.gov
Utah	UCPA	le.utah.gov
Oregon	OCPA	oregonlegislature.gov
Montana	MCDPA	leg.mt.gov
New Hampshire	NHPA	gencourt.state.nh.us
New Jersey	NJDPA	nj.gov/state/privacy/njdpa
Nebraska	NDPA	nebraska.gov/laws/privacy-act

14. European / UK Data Protection (GDPR)

If you are located in the European Economic Area (EEA) or UK:

Our compliance is aligned with the General Data Protection Regulation (GDPR), which you can review at the official EU GDPR text: EU Regulation 2016/679 — https://eur-lex.europa.eu/eli/reg/2016/679/oj.

You have rights including access, rectification, erasure, restriction of processing, objection, data portability, and to withdraw consent at any time where consent is the basis of processing.

15. How to Exercise Your Rights & Contact Us

If you wish to access, correct, update, delete, or request erasure of your Personal Data (or otherwise enforce any of your rights under this Privacy Policy), please contact our Data Privacy Officer at:

We will verify your identity before honoring any request. We aim to respond to your request within the timeframes required by applicable law.

16. Erasure or Deletion Requests (Right to be Forgotten)

Where permitted by law, you have the right to request that we erase your Personal Data. To do so, please submit a request to support@culturenetwork.io, specifying what data you want erased. We will evaluate the request in accordance with applicable law, and if granted, we will take reasonable steps to permanently delete or anonymize your data, subject to any legal, regulatory, or contractual obligations to retain certain information.

17. Changes to This Privacy Policy

We may update this Policy from time to time. When we do:

• We will update the “Effective Date” above.
• We may notify you via prominent notice on our services, email, or other means.
• We encourage you to review this Policy periodically.

18. Contact Information & Jurisdiction