Privacy Policy

Welcome to Qulture.

At Qulture, we believe the best experiences happen in the real world. Whether you’re joining a Hotspot at your favorite café, participating in a live conversation at a concert, connecting with friends through Circles, or discovering what’s happening around you, we want you to feel confident that your personal information is handled responsibly.

This Privacy Policy explains how Qulture Labs (“Qulture,” “we,” “our,” or “us”) collects, uses, shares, stores, and protects your information when you use our mobile applications, websites, and related services (collectively, the “Services”).

Our goal is to be transparent about what information we collect, why we collect it, and the choices you have regarding your data.

By using Qulture, you agree to the practices described in this Privacy Policy.

If you do not agree with this Privacy Policy, please do not use our Services.

Qulture is a location-based social platform that transforms real-world places into live digital communities.

Through Qulture, users can:

• Discover nearby Hotspots
• Join conversations happening around them
• Share posts, photos and videos
• Connect with friends
• Create and join Circles
• Participate in Moments, including polls, questions and challenges
• Exchange direct messages
• Discover events
• Participate in Speed Match experiences
• Receive personalized recommendations
• Build communities around shared real-world experiences

Qulture is designed to enhance physical experiences—not replace them.

Qulture is intended only for individuals who are 16 years of age or older.

You may not create an account or use our Services if you are under the age of sixteen (16).

If we become aware that we have collected personal information from a person under sixteen, we will take reasonable steps to suspend or permanently remove the account and delete the associated information unless we are legally required to retain it.

Parents or guardians who believe a child under sixteen has created an account should contact us immediately.

This Privacy Policy applies whenever you use:

• The Qulture mobile application
• Our website (www.joinqulture.com)
• Hotspots
• Events
• Circles
• Speed Match
• Direct Messaging
• Push notifications
• Customer support
• Beta testing
• Any other products or services that link to this Privacy Policy

This Privacy Policy does not apply to third-party websites, applications, venues, businesses, or services that may be linked to or integrated with Qulture.

Those services maintain their own privacy policies, and we encourage you to review them.

We designed Qulture with a few core privacy principles in mind.

Your information belongs to you.

We do not claim ownership of the content you create or upload.

You control your participation.

You decide what you post, who you connect with, which Circles you join, and which Hotspots you participate in.

Location is permission-based.

Qulture only accesses your location when you grant permission through your device settings.

You can revoke location access at any time through your device.

Please note that some features, including discovering nearby Hotspots, local recommendations, and certain real-world experiences, may not function properly without location access.

We collect only what we need.

We collect information necessary to provide and improve the Services, maintain security, personalize your experience, and comply with applicable laws.

We do not sell your personal information.

Safety comes first.

We use technical and organizational safeguards to help protect your information and maintain a safe experience for everyone using Qulture.

Summary of Key Points

This section provides a simplified overview of our Privacy Policy. It does not replace the full Privacy Policy.

What information do we collect?

We collect information that you provide directly to us, information generated through your use of Qulture, and certain technical information automatically collected when you use the Services.

Why do we collect it?

We use your information to:

• Create and manage your account
• Provide Hotspots and location-based experiences
• Enable messaging and social interactions
• Improve recommendations
• Personalize your experience
• Maintain security
• Prevent fraud and abuse
• Improve Qulture through analytics and research
• Comply with legal obligations

Do we sell personal information?

No.

Qulture does not sell your personal information.

Do we share information?

We may share information with trusted service providers, business partners, legal authorities where required, or as part of a merger, acquisition, financing, or sale of the company.

We never share your information for purposes inconsistent with this Privacy Policy.

Do we use Artificial Intelligence?

Yes.

Qulture may use Artificial Intelligence (“AI”) to enhance your experience, including generating recommendations, improving content discovery, assisting with moderation, personalizing experiences, and developing new features.

AI-generated results are intended to enhance the user experience and should not be relied upon as factual or definitive.

What rights do you have?

Depending on your location, you may have the right to:

• Access your personal information
• Correct inaccurate information
• Delete your account
• Request a copy of your information
• Withdraw consent where applicable
• Object to certain processing activities

Additional information is provided later in this Privacy Policy.

At Qulture, we collect information to provide, improve, secure, and personalize our Services. The information we collect depends on how you use Qulture and the permissions you grant.

We collect information in the following ways:

• Information you provide directly to us.
• Information generated through your use of Qulture.
• Information collected automatically from your device.
• Information received from third-party services when you choose to connect them.

Information You Provide

When you create an account or interact with Qulture, you may provide us with personal information including:

Account Information

• Full name
• Username
• Email address
• Password or authentication credentials
• Date of birth or age confirmation
• Profile photograph
• Biography or profile description

We use this information to create and manage your account, verify your identity, personalize your experience, and help other users identify you on the platform.

Profile Information

You may choose to provide additional information including:

• Interests
• Social links
• Profile images
• Preferred pronouns (if offered)
• Languages
• City or general location
• Other information you voluntarily include in your profile

Providing optional profile information helps improve discovery and recommendations but is not required unless specifically indicated.

User Content

Qulture is built around user-generated content.

When using the Services, you may create or upload:

• Posts
• Comments
• Photos
• Videos
• Captions
• Reactions
• Event content
• Circle content
• Hotspot content
• Poll responses
• Challenge submissions
• Questions
• Speed Match prompts
• Reports submitted through moderation tools

You retain ownership of the content you create. However, by uploading content to Qulture, you grant us the rights described in our Terms of Service to host, process, display, distribute, and operate the Services.

Messages

Qulture allows users to communicate through:

• Direct Messages
• Circle conversations
• Event chats
• Hotspot discussions
• Future messaging features

We process message content to deliver conversations, maintain the integrity of the platform, investigate reports of abuse, comply with legal obligations, and improve the Services.

We do not use private messages for advertising purposes.

Location Information

Because Qulture is a location-based platform, location information plays an important role in many of our Services.

Depending on the permissions you grant, we may collect:

• Approximate location
• Precise GPS location
• Location history while actively using Qulture
• Check-ins and participation in Hotspots
• Event attendance information
• Nearby venue information

Location data helps us:

• Recommend nearby Hotspots
• Display nearby Events
• Enable location-specific conversations
• Support Speed Match experiences
• Improve recommendations
• Prevent fraud and abuse
• Enhance safety features

You may disable location permissions at any time through your device settings. Certain features may become unavailable or function differently without location access.

Hotspot Activity

When you participate in a Hotspot, we may collect information about your activity within that Hotspot, including:

• Hotspots joined
• Posts created
• Comments made
• Reactions
• Moments participated in
• Poll responses
• Challenge participation
• Time spent within a Hotspot
• Community interactions

This information helps us operate Hotspots, improve recommendations, identify trending communities, maintain safety, and better understand how users engage with real-world experiences.

Circles

When you create or participate in a Circle, we may collect information including:

• Circle membership
• Messages
• Shared media
• Posts
• Reactions
• Circle settings
• Invitations
• Participation history

Information shared within a Circle is generally visible only to members of that Circle, subject to the privacy settings selected by the creator or administrator.

Events

If you create, attend, or interact with Events, we may collect:

• Event registrations
• RSVPs
• Event participation
• Event posts
• Photos and videos shared during Events
• Reactions
• Comments

This information enables us to provide event experiences and improve future recommendations.

Speed Match

When you choose to use Speed Match, we may process information including:

• Profile information
• Interests
• Preferences you voluntarily provide
• Match participation
• Match outcomes
• Feedback you submit
• Reports concerning inappropriate behaviour

Speed Match is entirely optional. You decide whether to participate, continue conversations, or connect with another user.

Artificial Intelligence Features

Some Qulture features may use Artificial Intelligence (“AI”) to improve your experience.

Depending on the feature, AI may process information including:

• Posts
• Comments
• Photos
• Videos
• Captions
• User interactions
• Community activity
• Hotspot activity
• Public profile information

AI may be used to:

• Recommend communities
• Improve content discovery
• Generate summaries
• Personalize experiences
• Detect spam or abusive behaviour
• Improve moderation
• Develop new platform features

AI-generated outputs are designed to assist users and improve the platform but may not always be accurate or complete.

Information Collected Automatically

When you use Qulture, we automatically collect certain technical information, including:

• Device model
• Operating system
• App version
• IP address
• Device identifiers
• Language settings
• Time zone
• Crash reports
• Performance information
• Network information
• Browser type (where applicable)

We use this information to:

• Maintain security
• Diagnose technical issues
• Improve reliability
• Prevent abuse
• Optimize performance
• Understand usage trends

Analytics Information

We collect analytics information about how users interact with Qulture, including:

• Features used
• Screens visited
• Session duration
• Navigation patterns
• Engagement with Hotspots
• Participation in Moments
• Notification interactions
• Content engagement
• General usage statistics

Analytics help us improve the Services, understand user behaviour, and prioritize future product development.

Information from Third Parties

If you choose to sign in using a supported third-party authentication provider, we may receive certain information from that provider, such as:

• Name
• Email address
• Profile picture
• Unique account identifier

We only receive the information you authorize the provider to share with us.

We may also receive information from service providers, analytics providers, fraud prevention services, and business partners where necessary to operate and improve the Services.

Information We Do Not Collect

Unless specifically introduced as part of a future feature, Qulture does not intentionally collect:

• Government-issued identification documents
• Payment card information directly (payments are processed by trusted third-party payment providers)
• Health information
• Biometric identifiers
• Sensitive personal information beyond what users voluntarily choose to share in publicly visible content

We encourage users not to post sensitive personal information publicly through Qulture.

We use your personal information to provide, operate, improve, secure, and personalize Qulture.

The way we process your information depends on how you use the Services, the permissions you grant, and the features you choose to use.

Specifically, we may use your information for the following purposes.

Account Creation and Authentication

We use your information to:

• Create your Qulture account.
• Verify your identity.
• Authenticate your login credentials.
• Maintain your account.
• Allow you to securely access the Services.
• Recover your account if you forget your password.
• Prevent unauthorized access.

Delivering the Qulture Experience

Our Services rely on your information to provide the core Qulture experience.

This includes enabling you to:

• Discover nearby Hotspots.
• Join location-based communities.
• Participate in Events.
• Create and join Circles.
• Exchange Direct Messages.
• Share photos, videos, and posts.
• Participate in Moments, including polls, questions, and challenges.
• Use Speed Match.
• Build your public profile.
• Connect with other users.

Without processing certain information, many of these features would not function.

Location-Based Services

Qulture uses location information to power features designed around real-world experiences.

Depending on your permissions, we use your location to:

• Show nearby Hotspots.
• Recommend relevant Events.
• Improve local discovery.
• Enable location-aware Speed Match.
• Display nearby communities.
• Prevent location fraud.
• Improve the relevance of recommendations.

Location data is only used as described in this Privacy Policy and according to your device permissions.

Personalization

We want every Qulture experience to feel relevant and engaging.

We may use your information to personalize:

• Hotspot recommendations.
• Event recommendations.
• Suggested users.
• Suggested Circles.
• Content displayed in your feed.
• Notification preferences.
• Future product recommendations.
• Search results.

Personalization helps reduce irrelevant content and improve discovery across the platform.

Artificial Intelligence

Qulture may use Artificial Intelligence (“AI”) to improve the Services and create more personalized experiences.

AI may assist with:

• Content recommendations.
• Hotspot recommendations.
• Community discovery.
• Spam detection.
• Abuse detection.
• Content moderation.
• Personalized summaries.
• Future AI-powered insights.
• Product improvements.
• Research and development.

AI systems may analyze user-generated content, public profile information, community activity, and other information necessary to provide these features.

AI-generated recommendations and insights are intended to enhance the user experience and should not be considered factual or definitive.

Community Safety and Trust

Maintaining a safe community is one of our highest priorities.

We may process information to:

• Detect spam.
• Prevent fraud.
• Identify fake accounts.
• Investigate reports.
• Remove harmful content.
• Enforce our Community Guidelines.
• Protect users from abuse.
• Respond to safety incidents.
• Detect suspicious activity.
• Improve moderation systems.

Where appropriate, we may combine automated systems with human review to investigate potential violations of our policies.

Communications

We may use your information to communicate with you regarding:

• Account verification.
• Password resets.
• Security alerts.
• Friend requests.
• Messages.
• Circle invitations.
• Event invitations.
• Hotspot activity.
• Product updates.
• Service announcements.
• Customer support.
• Legal notices.

Where required by law, we will obtain your consent before sending promotional communications.

You may opt out of marketing emails at any time.

Notifications

Qulture uses notifications to keep users informed about activity that matters to them.

Depending on your preferences, notifications may include:

• Friend requests.
• Messages.
• Circle activity.
• Hotspot activity.
• Event reminders.
• Replies.
• Mentions.
• Reactions.
• Product announcements.
• New features.
• Safety alerts.

Notification preferences can be managed within the app or your device settings.

Improving Our Services

We continuously analyze how people use Qulture to improve the platform.

We may use information to:

• Understand feature adoption.
• Improve usability.
• Identify bugs.
• Improve reliability.
• Measure performance.
• Develop new features.
• Conduct internal research.
• Improve recommendation systems.
• Optimize the user experience.

Whenever possible, we use aggregated or de-identified information for research and analytics.

Customer Support

If you contact us, we may process your information to:

• Respond to questions.
• Investigate reported issues.
• Resolve technical problems.
• Improve support quality.
• Verify your identity.
• Maintain records of support interactions.

Legal Compliance

We may process your information where necessary to:

• Comply with applicable laws.
• Respond to lawful requests.
• Cooperate with regulators.
• Protect our legal rights.
• Prevent illegal activity.
• Enforce our Terms of Service.
• Defend against legal claims.

Business Operations

We may process information as necessary to operate our business, including:

• Internal reporting.
• Financial management.
• Auditing.
• Corporate governance.
• Business continuity.
• Mergers, acquisitions, investments, or financing activities.

If Qulture undergoes a merger, acquisition, investment, or sale, personal information may be transferred as part of that transaction, subject to appropriate confidentiality and legal protections.

Research and Product Development

We may use information, including aggregated or anonymized information, to:

• Better understand how people interact in real-world communities.
• Improve Hotspots.
• Improve Speed Match.
• Improve recommendation systems.
• Evaluate new features.
• Conduct internal product research.
• Improve AI systems.
• Build future versions of Qulture.

Where practical, this research uses aggregated or anonymized data that cannot reasonably identify individual users.

With Your Consent

In some situations, we may process your information for purposes not specifically described in this Privacy Policy.

When required by applicable law, we will obtain your consent before using your information for those purposes.

The legal basis we rely on to process your personal information depends on where you are located and how you use Qulture.

We process your information only when we have a lawful reason to do so under applicable privacy laws.

These reasons may include:

• Your consent.
• Performing our contract with you.
• Complying with legal obligations.
• Protecting your vital interests or those of others.
• Pursuing our legitimate business interests where those interests are not overridden by your rights and freedoms.

If You Are Located in the European Economic Area (EEA), United Kingdom, or Switzerland

If you are located in the European Economic Area, the United Kingdom, or Switzerland, we process your personal information under the legal bases recognized by the General Data Protection Regulation (GDPR), the UK GDPR, and other applicable privacy laws.

These legal bases include:

Consent

We may process your personal information when you have given us permission to do so.

For example, we may rely on your consent when:

• You enable location services.
• You opt in to marketing communications.
• You allow notifications.
• You grant access to your camera or photo library.
• You participate in optional research or beta programs.

Where we rely on consent, you may withdraw that consent at any time through your device settings, your Qulture account settings, or by contacting us.

Withdrawal of consent does not affect processing that occurred before your withdrawal.

Performance of a Contract

Most of the information we process is necessary to provide the Services you request.

For example, we process information to:

• Create your account.
• Authenticate your identity.
• Deliver messages.
• Display your profile.
• Operate Hotspots.
• Operate Circles.
• Provide Speed Match.
• Display your content.
• Synchronize your account across devices.

Without processing this information, we would be unable to provide many core features of Qulture.

Legitimate Interests

We may process personal information where it is reasonably necessary for our legitimate business interests, provided those interests are balanced against your privacy rights.

Examples include:

• Improving Qulture.
• Preventing fraud.
• Maintaining platform security.
• Detecting abuse.
• Measuring platform performance.
• Understanding feature usage.
• Developing new products.
• Conducting internal research.
• Improving recommendations.
• Enhancing user safety.

Whenever possible, we use aggregated or anonymized information for these purposes.

Legal Obligations

We may process personal information where necessary to comply with applicable laws, regulations, court orders, or lawful requests from public authorities.

Examples include:

• Responding to lawful legal requests.
• Cooperating with law enforcement where legally required.
• Meeting tax and accounting obligations.
• Complying with regulatory requirements.
• Protecting legal rights.
• Resolving disputes.

Vital Interests

In limited circumstances, we may process personal information where necessary to protect someone’s life, health, or safety.

Examples include:

• Responding to credible threats of harm.
• Cooperating with emergency responders where legally required.
• Preventing imminent danger.

If You Are Located in Canada

If you reside in Canada, Qulture processes personal information in accordance with applicable Canadian privacy laws, including the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy legislation.

We generally process your information based on your knowledge and consent.

Consent may be:

• Express, where you explicitly agree to the processing of your information; or
• Implied, where your actions reasonably indicate your agreement.

You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice.

Withdrawal of consent may affect your ability to use certain features of Qulture.

Circumstances Where Consent May Not Be Required

Applicable law may permit us to process certain personal information without obtaining consent in limited circumstances, including where necessary to:

• Detect or prevent fraud.
• Protect individuals from harm.
• Comply with legal obligations.
• Respond to lawful requests from government authorities.
• Investigate violations of our Terms of Service.
• Complete certain business transactions.
• Protect the rights, property, or safety of Qulture, our users, or the public.

If You Are Located in the United States

If you are located in the United States, the collection, use, and sharing of your personal information may be governed by applicable federal, state, or local privacy laws.

Depending on your state of residence, you may have additional rights regarding your personal information, including rights to access, correct, delete, or limit certain processing activities.

These rights are described later in this Privacy Policy.

Automated Decision-Making

Qulture may use automated systems, including Artificial Intelligence, to improve the Services.

Examples include:

• Recommending Hotspots.
• Suggesting Circles.
• Ranking content.
• Detecting spam.
• Detecting fraudulent activity.
• Identifying potentially harmful behaviour.
• Personalizing recommendations.

These systems are designed to assist our platform and improve the user experience.

Where required by applicable law, users may request human review of certain decisions that produce legal or similarly significant effects.

Your Choices

Where processing is based on your consent, you may withdraw that consent at any time.

You may also manage many privacy preferences directly through:

• Your Qulture account settings.
• Your device settings.
• Notification preferences.
• Location permissions.
• Communication preferences.

Some features may not function properly if certain permissions are withdrawn.

We understand that your personal information is important.

We do not sell your personal information.

We only share personal information when it is necessary to operate Qulture, provide our Services, comply with legal obligations, protect users, or support our business operations.

Whenever we share personal information, we take reasonable steps to ensure appropriate contractual, technical, and organizational safeguards are in place.

Service Providers

We work with trusted third-party service providers who help us operate Qulture.

These providers perform services on our behalf and may process personal information only as necessary to perform those services.

Depending on the Services you use, these providers may assist with:

• Cloud hosting
• Data storage
• Authentication
• Push notifications
• Analytics
• Crash reporting
• Customer support
• Email delivery
• Artificial Intelligence services
• Security monitoring
• Fraud prevention
• Infrastructure management

Examples may include providers such as Amazon Web Services (AWS), Google Cloud Platform, Firebase, Supabase, Cloudflare, Apple, Google, Stripe (if payments are introduced), and other trusted vendors.

We require our service providers to protect your information and use it only for the purposes we specify.

Artificial Intelligence Providers

Some Qulture features may use trusted third-party AI technologies.

Where AI services are used, information may be processed to:

• Generate recommendations
• Improve discovery
• Assist with moderation
• Produce summaries
• Improve personalization
• Enhance user experiences

We do not permit AI providers to use your personal information for purposes unrelated to providing services to Qulture unless you separately authorize such use.

Whenever possible, we minimize the information shared with AI providers and implement appropriate safeguards.

Location-Based Features

Because Qulture provides location-based experiences, certain information is shared within the platform as part of the Services you choose to use.

For example:

If you join a Hotspot,

other users within that Hotspot may be able to see:

• Your username
• Profile photo
• Public profile information
• Posts you create
• Comments
• Reactions
• Participation in public Moments

Similarly, information you choose to share in Events or Circles may be visible to members of those communities.

Your participation in public spaces is controlled by your privacy settings and the nature of the feature you choose to use.

User Content

Information you choose to make public may be visible to other users.

This may include:

• Public posts
• Photos
• Videos
• Comments
• Profile information
• Public Circle content
• Public Event content
• Public Hotspot activity

You are responsible for the information you choose to share publicly.

Please remember that information made public may be copied, shared, or captured by others.

Business Partners

From time to time, Qulture may partner with organizations to improve the Services or offer experiences through the platform.

Examples include:

• Event organizers
• Venue partners
• Universities
• Community organizations
• Promotional partners

Where appropriate, we may share limited information necessary to provide those experiences.

We do not allow partners to use your personal information for unrelated purposes without your consent.

Venue Partners

Some Qulture features may be available through participating venues.

For example:

• Bars
• Restaurants
• Cafés
• Campuses
• Sports venues
• Entertainment venues
• Conference organizers

Venue partners do not receive unrestricted access to your personal information.

Where applicable, venue partners may receive:

• Aggregated analytics
• Anonymous engagement metrics
• Participation statistics
• Operational information necessary to manage official Hotspots

Unless you expressly choose to interact with a venue or authorize additional sharing, we do not provide venues with your private messages or personal account information.

Legal Requirements

We may disclose personal information if we believe disclosure is necessary to:

• Comply with applicable law.
• Respond to lawful requests from courts, regulators, or government authorities.
• Enforce our Terms of Service.
• Protect our rights or property.
• Protect the safety of our users.
• Investigate suspected fraud or illegal activity.
• Prevent imminent harm.

We review legal requests carefully and disclose only the information we reasonably believe is required.

Business Transfers

If Qulture undergoes:

• A merger
• An acquisition
• A financing
• A restructuring
• A sale of assets
• A bankruptcy
• Another corporate transaction

your personal information may be transferred as part of that transaction.

If ownership of Qulture changes, we will take reasonable steps to notify users where required by applicable law.

Protecting the Community

We may share information where necessary to:

• Investigate reports
• Prevent fraud
• Detect spam
• Enforce Community Guidelines
• Remove harmful content
• Protect users from abuse
• Improve trust and safety

This may include sharing information with trusted safety vendors or legal authorities where appropriate.

Aggregated and De-Identified Information

We may share information that has been aggregated or de-identified so that it cannot reasonably identify any individual.

Examples include:

• Hotspot engagement statistics
• Platform usage trends
• Anonymous analytics
• Product research
• Industry reports

This information does not identify you personally.

We Do Not Sell Personal Information

Qulture does not sell your personal information.

We do not exchange your personal information for money.

If our practices change in the future, we will update this Privacy Policy and provide any notices required by applicable law.

Future Advertising

As Qulture grows, we may introduce sponsored content, venue promotions, or advertising experiences.

If we do, advertisements may be personalized using limited information such as:

• General location
• Language
• Interests
• Platform activity

We will not sell your personal information to advertisers.

Advertisers will not receive your private messages or personal account information simply because you viewed or interacted with an advertisement.

International Service Providers

Some of our service providers may operate in countries other than your own.

Where personal information is transferred internationally, we implement appropriate safeguards consistent with applicable privacy laws.

Additional information about international transfers is provided in the next section of this Privacy Policy.

Qulture uses cookies, software development kits (SDKs), analytics tools, and similar technologies to operate, improve, and secure our Services.

Because Qulture is primarily a mobile application, many of these technologies function differently from traditional website cookies. Depending on the platform you use, they may include mobile identifiers, local storage, software development kits, application logs, and similar technologies.

These technologies help us understand how users interact with Qulture while maintaining the reliability, security, and performance of our Services.

Why We Use These Technologies

We use cookies and similar technologies to:

• Keep you signed in to your account.
• Remember your preferences.
• Maintain the security of your account.
• Prevent fraudulent activity.
• Improve application performance.
• Diagnose technical issues.
• Measure feature usage.
• Understand engagement across Hotspots, Circles, Events, and other features.
• Improve recommendations.
• Analyze trends.
• Develop new features.

Analytics

We use analytics services to better understand how people use Qulture.

Analytics may collect information such as:

• Screens viewed
• Features used
• Session duration
• Device type
• Operating system
• Crash reports
• Performance metrics
• Navigation patterns
• General location (such as country or city)
• App version

Analytics information helps us:

• Improve user experience.
• Identify bugs.
• Prioritize new features.
• Improve reliability.
• Measure product adoption.
• Improve Hotspots and recommendations.
• Understand community engagement.

Whenever practical, we use aggregated or de-identified information for analytics.

Mobile Device Identifiers

Your mobile device may generate unique identifiers that help us:

• Authenticate your device.
• Improve security.
• Detect fraud.
• Analyze app performance.
• Improve stability.

These identifiers are used only for legitimate business purposes consistent with this Privacy Policy.

Crash Reports and Diagnostics

To maintain a reliable platform, we may automatically collect technical information when the app experiences an error.

This information may include:

• Device model
• Operating system
• App version
• Crash logs
• Diagnostic information
• Performance metrics
• Error reports

Crash information helps us quickly identify and resolve technical issues.

Security Technologies

We use security technologies to protect both Qulture and our users.

These technologies help us:

• Detect suspicious activity.
• Prevent unauthorized access.
• Protect user accounts.
• Prevent spam.
• Identify fraudulent behaviour.
• Monitor platform integrity.

These technologies are designed to improve platform security and protect our community.

Location Technologies

Certain Qulture features depend on location technologies provided by your device.

If you enable location permissions, we may use your device’s location services to:

• Display nearby Hotspots.
• Recommend Events.
• Improve local discovery.
• Enable Speed Match.
• Support future location-aware features.

You can disable location permissions at any time through your device settings. Some location-based features may no longer function correctly if location access is disabled.

Push Notification Technologies

Qulture may use push notification services provided by Apple, Google, or other trusted providers.

Push notifications help us notify you about:

• Friend requests
• Direct Messages
• Circle activity
• Hotspot activity
• Event reminders
• Replies
• Mentions
• Reactions
• Product updates
• Security alerts

You may manage notification preferences at any time through your device settings or within Qulture.

Future Advertising Technologies

As Qulture evolves, we may introduce advertising or sponsored experiences.

If we do, we may use limited information such as:

• Approximate location
• Device type
• Language
• General interests
• Platform activity

to display more relevant advertisements.

We do not sell your personal information to advertisers.

Private conversations, personal messages, and private media are never shared with advertisers for advertising purposes.

If personalized advertising is introduced in the future, users will be provided with any notices, choices, or consent options required by applicable law.

Managing Cookies and Tracking Technologies

Depending on your device and platform, you may control or disable certain tracking technologies by:

• Adjusting your device privacy settings.
• Managing app permissions.
• Resetting your advertising identifier.
• Changing browser settings (for our website).
• Using privacy controls provided by your operating system.

Please note that disabling certain technologies may affect the functionality of some Qulture features.

Do Not Track Signals

Some browsers and devices provide a “Do Not Track” (“DNT”) setting.

At this time, there is no universally accepted standard for recognizing or responding to DNT signals.

Accordingly, Qulture does not currently respond to browser-based Do Not Track signals.

If an industry standard is established or applicable law requires us to respond to such signals, we will update this Privacy Policy accordingly.

Future Cookie Notice

If Qulture expands its web presence or introduces additional website functionality, we may publish a separate Cookie Notice providing more detailed information about the specific cookies and similar technologies we use.

Qulture is a global platform. As a result, your personal information may be processed, stored, or transferred outside the country where you live.

For example, if you use Qulture in Canada, your information may be processed in Canada, the United States, Europe, or other countries where we or our trusted service providers operate.

These transfers are necessary to provide, maintain, secure, and improve the Services.

Where Your Information May Be Processed

Depending on the infrastructure and service providers we use, your personal information may be processed in countries including:

• Canada
• United States
• Member States of the European Union
• Other jurisdictions where our trusted service providers operate

As Qulture grows, additional service providers may process information in other countries. We will ensure appropriate safeguards are implemented before transferring personal information internationally where required by law.

How We Protect International Transfers

Whenever personal information is transferred across borders, we take reasonable steps to ensure it receives an appropriate level of protection.

These safeguards may include:

• Contractual commitments with our service providers
• Standard Contractual Clauses (where applicable)
• Encryption during transmission
• Secure storage practices
• Access controls
• Compliance with applicable privacy laws

We require third-party service providers to protect your personal information in accordance with applicable legal requirements and our contractual obligations.

If You Live in the European Economic Area (EEA), United Kingdom, or Switzerland

If your personal information is transferred outside your jurisdiction, we will rely on appropriate legal safeguards where required.

These safeguards may include:

• Standard Contractual Clauses approved by the European Commission.
• Adequacy decisions adopted by relevant authorities.
• Other legally recognized transfer mechanisms.

Where required by law, you may request additional information regarding the safeguards used for international transfers by contacting us.

If You Live in Canada

If you are located in Canada, your personal information may be transferred outside your province or outside Canada.

While your information is in another country, it may become subject to the laws of that jurisdiction and may be accessible to courts, law enforcement agencies, or government authorities in accordance with local laws.

Regardless of where your information is processed, Qulture remains committed to protecting your personal information in accordance with this Privacy Policy.

Data Security During Transfers

Whenever reasonably possible, personal information transferred internationally is protected using industry-standard security measures, including:

• Encryption in transit
• Secure authentication
• Access restrictions
• Monitoring and logging
• Secure cloud infrastructure

Although no system can guarantee absolute security, we continuously work to protect your information using appropriate technical and organizational safeguards.

Future Infrastructure Changes

As Qulture continues to grow, we may change our hosting providers, cloud infrastructure, or technology partners.

If those changes result in new international data transfers, we will update this Privacy Policy where required and implement appropriate safeguards before transferring personal information.

We retain your personal information only for as long as it is reasonably necessary to provide the Services, fulfill the purposes described in this Privacy Policy, comply with legal obligations, resolve disputes, enforce our agreements, and protect the integrity of Qulture.

Different types of information may be retained for different periods depending on the nature of the information and the purpose for which it was collected.

Account Information

We generally retain your account information for as long as your account remains active.

This includes information such as:

• Name
• Username
• Email address
• Profile information
• Authentication information
• Account preferences

User Content

Content you create, including posts, comments, photos, videos, and public profile information, may remain available until:

• You delete the content.
• You delete your account.
• We remove the content for violating our policies.
• We are required to remove it by law.

Some content may remain visible to other users if it has already been shared or redistributed before deletion.

Messages

Direct Messages and other conversations are retained as necessary to deliver the messaging service, maintain security, investigate reports, and comply with applicable legal obligations.

Deleted conversations may remain in encrypted backups for a limited period before permanent deletion.

Hotspot, Circle, and Event Activity

Information relating to your participation in Hotspots, Circles, Events, and Moments may be retained to:

• Improve recommendations
• Maintain community history
• Support safety investigations
• Prevent fraud
• Improve the Services

Where practical, historical engagement data may be anonymized and retained for research and analytics.

Technical and Analytics Information

Technical logs, crash reports, analytics, and diagnostic information are generally retained only for as long as reasonably necessary to:

• Improve platform performance
• Investigate issues
• Maintain security
• Develop new features

Whenever possible, this information is aggregated or anonymized.

Legal Requirements

In some circumstances, we may retain certain information longer where necessary to:

• Comply with applicable law
• Resolve disputes
• Enforce our Terms of Service
• Prevent fraud
• Protect the safety of our users
• Respond to lawful requests from government authorities

What Happens When You Delete Your Account?

If you request deletion of your account, we will take reasonable steps to:

• Deactivate your account.
• Remove your profile from public view.
• Delete or anonymize your personal information where appropriate.
• Remove access to your content.

Certain information may be retained where required to:

• Comply with legal obligations.
• Resolve disputes.
• Prevent fraud.
• Enforce our agreements.
• Maintain the security of our platform.

Information stored in secure backup systems may not be immediately deleted but will be removed in accordance with our normal backup retention schedules.

Anonymized Information

We may retain information that has been anonymized or aggregated so that it can no longer reasonably identify you.

This information may be used indefinitely for purposes such as:

• Product improvement
• Analytics
• Research
• Trend analysis
• Platform performance
• Understanding how communities interact through Qulture

Anonymized information is no longer considered personal information under many applicable privacy laws.

Data Minimization

We regularly review the information we hold and strive to delete or anonymize personal information that is no longer required for the purposes described in this Privacy Policy.

We are committed to retaining only the information reasonably necessary to operate and improve Qulture.

Protecting the privacy and safety of young people is important to us.

Qulture is intended only for individuals who are 16 years of age or older.

We do not knowingly permit individuals under the age of sixteen (16) to create an account or use our Services.

If you are under sixteen years of age, you must not use Qulture or provide us with any personal information.

If We Learn About an Underage Account

If we become aware that we have collected personal information from someone under the age of sixteen, we will take reasonable steps to:

• Suspend or disable the account.
• Remove the personal information associated with the account.
• Delete the account unless we are legally required to retain certain information.

Where appropriate, we may also request additional information to verify a user’s age before allowing continued access to the Services.

Reporting Underage Accounts

If you believe that a child under the age of sixteen is using Qulture, please contact us immediately at:

privacy@joinqulture.com

We will investigate the report promptly and take appropriate action.

Age Verification

Qulture may use reasonable measures to verify that users meet our minimum age requirement.

These measures may include:

• Date of birth confirmation during registration.
• Age confirmation prompts.
• Device or platform-provided age information where available.
• Additional verification where necessary.

We reserve the right to suspend or remove accounts if we reasonably believe a user has misrepresented their age.

Parents and Guardians

If you are a parent or legal guardian and believe your child under the age of sixteen has created a Qulture account, please contact us as soon as possible.

Upon verification, we will take reasonable steps to remove the account and delete the associated personal information unless retention is required by applicable law.

Our Commitment to Young Users

Although Qulture is intended for users aged sixteen and older, we are committed to fostering a respectful, safe, and inclusive community.

We continually improve our safety features, moderation tools, reporting systems, and Community Guidelines to help protect all users and promote positive interactions.

Depending on where you live, you may have certain rights regarding your personal information under applicable privacy laws.

These rights may vary depending on your country, province, state, or region.

Where applicable, Qulture will honor these rights in accordance with the law.

Right to Access

You may request confirmation of whether we process your personal information and request access to the information we hold about you.

This may include:

• Account information.
• Profile information.
• Activity information.
• Personal data associated with your account.

Right to Correct Information

If your personal information is inaccurate, incomplete, or outdated, you may request that we correct or update it.

Many account details can also be updated directly within your Qulture profile.

Right to Delete Your Information

You may request deletion of your account and associated personal information.

Please note that we may retain certain information where necessary to:

• Comply with legal obligations.
• Prevent fraud.
• Resolve disputes.
• Enforce our Terms of Service.
• Protect the safety of our users.

Right to Data Portability

Where required by applicable law, you may request a copy of the personal information you have provided to us in a structured, commonly used, and machine-readable format.

Right to Withdraw Consent

Where we rely on your consent to process personal information, you may withdraw that consent at any time.

Examples include:

• Marketing communications.
• Location permissions.
• Camera access.
• Photo library access.
• Notification permissions.

Withdrawal of consent does not affect processing that occurred before consent was withdrawn.

Please note that disabling certain permissions may affect the functionality of some Qulture features.

Right to Object

Where permitted by law, you may object to certain types of processing, including processing based on our legitimate interests.

We will consider your request and respond in accordance with applicable law.

Right to Restrict Processing

Depending on your jurisdiction, you may request that we temporarily restrict certain processing of your personal information while we evaluate your request.

Rights Related to Automated Decision-Making

Qulture may use automated technologies, including Artificial Intelligence, to improve recommendations, personalize experiences, detect fraud, and moderate content.

Where required by applicable law, you may request human review of certain automated decisions that produce legal or similarly significant effects.

Most recommendations and personalization features within Qulture are designed to improve your experience and do not produce legal or similarly significant effects.

Managing Your Information

You can manage many aspects of your personal information directly within the Qulture app.

Depending on available features, you may:

• Update your profile.
• Change your username (subject to availability and our policies).
• Update your profile photo.
• Manage notification preferences.
• Control location permissions.
• Manage privacy settings.
• Block or unblock other users.
• Report inappropriate content.
• Delete content you have posted.
• Request account deletion.

How to Exercise Your Rights

To exercise any applicable privacy rights, you may:

• Submit a request through our Data Subject Access Request portal (if available).
• Contact us at privacy@joinqulture.com.
• Reach out through the contact information provided at the end of this Privacy Policy.

We may need to verify your identity before processing certain requests to help protect your privacy and the security of your account.

Response Time

We will respond to privacy requests within the timeframes required by applicable law.

If additional time is needed due to the complexity of your request, we will notify you where required.

No Discrimination

We will not discriminate against you for exercising your privacy rights.

However, certain features of Qulture may become unavailable if you choose to delete your account or withdraw permissions necessary for those features to operate.

Some web browsers and mobile devices offer a “Do Not Track” (“DNT”) setting that allows users to indicate a preference not to have certain online activity tracked.

At this time, there is no universally accepted standard for recognizing or responding to Do Not Track signals.

Accordingly, Qulture does not currently respond to browser-based Do Not Track signals or similar mechanisms.

If an industry standard is established or applicable law requires us to respond to such signals in the future, we will update this Privacy Policy accordingly.

If you reside in the United States, you may have additional privacy rights under applicable federal, state, or local laws.

Depending on where you live, these rights may include:

• The right to know whether we collect your personal information.
• The right to access personal information we maintain about you.
• The right to correct inaccurate information.
• The right to request deletion of your personal information.
• The right to obtain a copy of your personal information.
• The right to opt out of certain processing activities where required by law.
• The right not to receive discriminatory treatment for exercising your privacy rights.

Where required by applicable law, Qulture will honor these rights.

Categories of Information We Collect

The categories below describe the types of personal information we may collect.

Identifiers

Examples include:

• Name
• Username
• Email address
• Device identifiers
• IP address
• Account information

Collected: Yes

Protected Characteristics

Examples include:

• Age (for age verification purposes)

Qulture does not intentionally collect information regarding race, ethnicity, religion, disability, or other protected characteristics unless voluntarily included in user-generated content.

Collected: Limited

Commercial Information

Examples include:

• Subscription information (if applicable in the future)
• Purchase history for premium services

Collected: Not currently

Internet or Network Activity

Examples include:

• App usage
• Feature engagement
• Navigation
• Device information
• Analytics

Collected: Yes

Geolocation Information

Examples include:

• Approximate location
• Precise location (with permission)

Collected: Yes

Audio, Images, and Video

Examples include:

• Photos
• Videos
• Voice recordings (where applicable)
• User-generated media

Collected: Yes

Professional or Employment Information

Collected: No

Education Information

Collected: No

Inferences

We may generate recommendations based on activity within Qulture to improve personalization.

These recommendations are designed to enhance your experience and are not used to make decisions that produce legal or similarly significant effects.

Collected: Limited

Sensitive Personal Information

Qulture does not intentionally collect or process sensitive personal information unless you voluntarily include such information in content you choose to share.

Collected: No

How to Exercise Your Rights

If you would like to exercise your privacy rights, you may:

• Contact us at privacy@joinqulture.com
• Submit a Data Subject Access Request through any portal we make available
• Use account settings where available

We may request additional information to verify your identity before fulfilling certain requests.

Authorized Agents

Where permitted by applicable law, you may designate an authorized representative to submit requests on your behalf.

We may request documentation verifying that the representative has authority to act for you.

Technology evolves quickly, and so does Qulture.

We may update this Privacy Policy from time to time to reflect:

• Changes to our Services.
• New product features.
• Improvements to our privacy practices.
• Changes in applicable laws.
• New security measures.
• Business developments.

When we make material changes, we will take reasonable steps to notify users before the changes become effective.

Depending on the nature of the update, notification may occur through:

• Email.
• In-app notifications.
• Notices displayed within Qulture.
• Updates published on our website.

The “Last Updated” date at the top of this Privacy Policy indicates when it was most recently revised.

Your continued use of Qulture after changes become effective constitutes acceptance of the updated Privacy Policy, to the extent permitted by applicable law.

If you have any questions, concerns, requests, or comments regarding this Privacy Policy or our privacy practices, please contact us.

Qulture Labs

165 Ontario Street

St. Catharines, Ontario L2R 5K4

Canada

Email:

privacy@joinqulture.com

Website:

https://www.joinqulture.com

If you are contacting us regarding a privacy request, please provide enough information for us to verify your identity and understand your request.

We will respond as promptly as reasonably possible and within the timeframes required by applicable law.

We believe you should remain in control of your personal information.

Depending on your location and applicable law, you may request to:

• Access your personal information.
• Correct inaccurate information.
• Update your profile.
• Download certain information associated with your account.
• Delete your account.
• Delete content you have posted.
• Withdraw consent where applicable.
• Restrict certain processing activities.

Many of these actions can be completed directly within the Qulture app.

If you require additional assistance, you may contact us at:

privacy@joinqulture.com

Where required, we will verify your identity before processing requests to protect your privacy and the security of your account.

We may decline requests where permitted by law, including where fulfilling the request would:

• Violate another person’s rights.
• Prevent us from complying with legal obligations.
• Compromise the security of Qulture.
• Interfere with fraud prevention or ongoing investigations.

If we cannot fulfill your request, we will explain the reason where required by applicable law.

At Qulture, privacy is more than a legal obligation—it is fundamental to the trust our community places in us.

Our mission is to bring people together through meaningful real-world experiences while respecting and protecting the information they share with us.

As Qulture evolves, we will continue investing in privacy, security, transparency, and user control so that our community can confidently explore, connect, and build lasting relationships both online and in the real world.

Thank you for being part of Qulture.