Privacy Policy

Welcome to Remo from Culture OS ("Remo", "we", "our", or "Culture OS Inc"). We value your trust and are committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you interact with Remo, our AI-driven conversation platform, and our website https://cultureos.company.

By using our services, you agree to the terms described in this Privacy Policy. If you do not agree, please do not use our products or services.

1. Who We Are

2. Definitions

3. Categories of Personal Information We Collect

4. How We Use Your Information

We process personal information to:

• Conduct and deliver one-on-one AI conversations and telephonic services.
• Improve Remo's AI models and features using anonymized/aggregated data.
• Generate anonymized and named insights, reports, and dashboards for organizations.
• Ensure security, detect fraud, and comply with legal obligations.
• Respond to support inquiries, updates, and feature communications.

California residents: Sensitive personal information is used only for service delivery, product functionality, or as legally permitted. Opt-out options are available. You also have an option to do the conversation in anonymized manner.

5. Audio, Voice & Biometric Data

• Voice recordings are collected only to provide conversation services and generate transcriptions.
• Voice biometric data is treated as sensitive personal information.
• Stored securely for 4 years, encrypted in transit and at rest.
• Consent is obtained where required by law for recording and voice processing.

6. Automated Decision-Making Technology (ADMT)

• Remo uses AI to analyse conversation content, identify trends, and provide engagement/skill-fit scoring.
• Outputs are aggregated and either anonymized or named for organizational reporting.
• California residents may opt-out or request human review if decisions materially affect them.

7. Legal Bases for Processing

• Contractual necessity / service delivery: Fulfilling agreements with your employer.
• Consent: When required, especially for sensitive personal information and biometric data.
• Legitimate interest / compliance: Security, fraud prevention, and legal obligations.

8. How We Share Information

We do not sell personal information. Information may be shared:

• Service providers / sub processors for operational purposes or may be utilised within the product under strict contractual obligations.
• With your employer under contractual agreements (aggregated/anonymized/named/reporting preferred).
• Legal reasons: Subpoenas, lawful requests, or to protect safety.
• With consent or as permitted by law.

9. Data Retention

• Recordings, transcripts, logs, analytics: Retained for 4 years.
• Anonymized data: Retained indefinitely for product improvement and benchmarking.
• Deletion requests are honoured subject to verification and legal exceptions.

10. Security Practices

• Encryption in transit & at rest
• Role-based access control
• Least privilege access
• Continuous monitoring & vulnerability assessments
• Incident response procedures
• Periodic risk assessments & third-party audits

11. Third Parties, Vendors & International Transfers

• Data may be processed by trusted subprocesses (cloud, telephony, analytics).
• Transfers outside the U.S. occur under standard contractual clauses or other lawful safeguards.

12. Children's Privacy

• Not directed to individuals under 16.
• Data collected inadvertently from minors will be deleted promptly.

13. California Privacy Rights

California residents may:

• Request access to personal information
• Request deletion of personal information
• Request correction of inaccurate information
• Opt-out of sale or sharing (Remo does not sell information)
• Limit use of sensitive personal information
• Non-discrimination for exercising rights
• Opt-out of ADMT where applicable

How to exercise rights:

• Online portal
• Email: privacy@cultureos.company
• Authorized agent allowed with signed consent

14. Verification Process

Requests are verified to protect privacy. Methods may include email confirmation, identity documents, or other proof of authorization.

15. Contractual & DPA Clauses

Enterprise Customers / Employers:

• By engaging Remo, you acknowledge and agree to the terms of our Data Processing Agreement (DPA).
• Culture OS Inc acts as a processor and customers as the controller of employee data.
• Subprocesses are approved in writing, bound by confidentiality, security, and privacy commitments.
• We implement organizational and technical measures sufficient to meet legal obligations and security standards.

DPA includes:

• Purpose limitation & lawful processing
• Subprocessor obligations & approval
• Breach notification & incident response
• Data subject request assistance
• Return or deletion of data upon contract termination

View Full DPA

16. Cookies & Tracking

Cookies and similar technologies used for analytics, functionality, and user experience.

Users may manage cookies through browser settings or Cookie Preferences.

17. Law Enforcement & Legal Requests

We may disclose information to respond to legal processes or protect rights and safety. Where lawful, we notify affected parties.

18. Changes to this Privacy Policy

We may update this policy to reflect legal changes, product updates, or business practices. The latest version is always available at: https://cultureos.company/privacy.

19. Contact