Privacy Policy
Last Updated: 10 November 2026
Effective Date: March 16, 2026
Culture XI (the "Website" or "Service"), accessible at https://culturexi.com/, is operated by Culture XI B.V. ("we", "us", or "our").We are committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our Website, sign up for our newsletter, interact with affiliate links, view ads, or follow links to our related mobile application(s). Where we rely on your consent, we ask for it separately, for example in our cookie banner or newsletter sign-up form, and you can withdraw it at any time.
1. Information We Collect
We collect the following types of information:
a. Information You Provide Voluntarily
b. Automatically Collected Information
c. Third-Party Data
We do not intentionally collect sensitive personal information (e.g., racial/ethnic origin, political opinions, religious beliefs, health data).
2. How We Use Your InformationWe use collected information to:
Legal bases. Under the GDPR we rely on:
For the World Explorer Educators waiting list and optional Culture XI news for educators we rely on your consent (Article 6(1)(a)); for pilot requests we rely on steps taken at your request before a possible agreement (Article 6(1)(b)). See section 17.
3. Advertising (Google AdSense)
We use Google AdSense to show advertisements on culturexi.com. Ads are meant for adult visitors. They appear only on our general articles and pages, never on our family pages (see section 12).
IAB Europe Transparency & Consent Framework. We take part in the IAB Europe Transparency & Consent Framework (TCF) and follow its specifications and policies. Our consent tool is Cookiebot by Usercentrics, a consent management platform registered with IAB Europe (CMP ID 134). The cookie banner records your choices in a "TC string" and passes them to Google.
Our vendor list: one vendor. Google is the only advertising vendor we work with under the TCF:
This list reflects the IAB Europe Global Vendor List as checked on 17 October 2026; our banner always shows the current details. If we add a vendor, it will appear in the banner and we will ask for your choice again. The full Global Vendor List is at https://iabeurope.eu/vendor-list-tcf/.
Google decides for itself. Google is an independent controller for the data it uses for advertising. See "How Google uses information from sites or apps that use our services" (https://policies.google.com/technologies/partner-sites) and Google's EU user consent policy (https://www.google.com/about/company/user-consent-policy/).
What you see depends on your choice.
Legal bases. Storing or reading information on your device needs your consent under article 11.7a of the Dutch Telecommunications Act (Telecommunicatiewet). For purpose 1 and for personalised ads (purposes 3 and 4) we and Google rely on your consent (GDPR art. 6(1)(a)). For purposes 2, 7, 9 and 10 and the special purposes, Google relies on its legitimate interest (GDPR art. 6(1)(f)), and only when you have allowed cookies. Legitimate interest is never used for purposes 3 to 6. You have the right to object to processing based on legitimate interest at any time (GDPR art. 21): use the "Legitimate interest" switches under "Cookie settings".
Changing or withdrawing your choice. The "Cookie settings" link in the footer of every page reopens the banner. There you can withdraw your consent, change it for each purpose and each vendor, or object to legitimate interest. This is as easy as giving consent. From your next page view we stop loading Google's advertising code. Withdrawal does not affect processing that took place before you withdrew (GDPR art. 7(3)). Cookies that Google has already placed stay in your browser until they expire or you delete them, but they are no longer read on our site.
Other ways to manage ads.
These tools store their own opt-out cookie, and they do not replace your choice in our banner.
International transfers. Google may process data in the United States. Google LLC is certified under the EU-US Data Privacy Framework, and Google's data protection terms also include the EU Standard Contractual Clauses. See also section 9.
Who the advertiser is. Ad spaces are marked as advertisements. Google ads show an "AdChoices" / "Why this ad?" icon that tells you who paid for the ad and why you are seeing it.
4. Affiliate Links
We participate in affiliate programs and include affiliate links in some content.If you click an affiliate link and make a purchase, the merchant may share limited transaction data with us (e.g., confirmation that a sale occurred via our link). We earn a commission at no extra cost to you.We do not receive your full payment or personal details from these transactions. Any personal information provided during purchase is handled by the merchant per their privacy policy.
5. Newsletter & Email Collection
We use third-party email service providers (e.g., Mailchimp, Brevo, or similar) to manage newsletter subscriptions.When you subscribe, your email address is shared with the service provider to send emails. These providers have their own privacy policies and security measures.You can unsubscribe at any time via the link in every email. We retain unsubscribed records to prevent accidental re-subscription.
6. Mobile Application Links
The Website may link to our related mobile app(s) in the Apple App Store, Google Play, or other stores. This Privacy Policy covers our Website, and our app for children, Culture XI: World Explorer, is covered in section 16 below.
7. Cookies and Tracking Technologies
We and our partners (Google AdSense, analytics providers, affiliate networks) use cookies, web beacons, pixels, and similar technologies for functionality, analytics, and advertising.Types of cookies we use:
You can manage cookies via your browser settings. However, disabling cookies may limit site functionality. For EEA/UK visitors: We obtain consent for non-essential cookies via a cookie banner where required by GDPR/ePrivacy rules.
Download links on some pages carry a campaign label so the App Store and Google Play can show us, in aggregate, which page led to a download; this does not identify you.
8. Sharing Your InformationWe share information only as described here:
We do not sell your personal information.
9. International Data Transfers
The Website is global. Data may be transferred to and processed in countries outside your residence (including the United States), where privacy laws may differ.We use appropriate safeguards (e.g., Standard Contractual Clauses where applicable) for transfers subject to GDPR.
10. Data Retention
We retain personal information only as long as necessary for the purposes outlined or as required by law.Newsletter subscribers: We retain email addresses until you unsubscribe (plus a short period for compliance). Usage logs: kept for up to 12 months for analytics and security, then deleted or anonymised.
Educators waiting list: until launch plus 12 months at most, or until you unsubscribe. Pilot requests: up to 12 months after your request or after the pilot ends. See section 17.
Advertising cookies are kept for the periods shown in our cookie declaration (Cookiebot), which lists each cookie and how long it lasts. Google declares a maximum cookie lifetime of about 13 months. Your consent choice (the TC string) and the record of your consent are kept for up to 12 months. After that, or earlier if our vendor list changes significantly, we ask you again.
11. Your Rights
Depending on your location, you may have rights to:
To exercise rights, contact us at "info@culturexi.com". We respond within legally required timeframes. You also have the right to complain to a data protection authority: in the Netherlands, the Autoriteit Persoonsgegevens (autoriteitpersoonsgegevens.nl), or the authority in the EU country where you live or work. California residents: See additional CCPA/CPRA notice below (if applicable).
12. Children's Privacy
No ads on family pages. Ads on culturexi.com are for adults only. We do not show ads, and do not load Google's advertising code, on these pages:
Your assessment answers and results are never used for advertising. Our apps show no ads. We do not knowingly show personalised ads to children. If you think a child has seen an ad on our site, please tell us at info@culturexi.com.
The Website is not directed to children under 16 (or 13 in some jurisdictions). We do not knowingly collect data from children. If we learn we have, we delete it. For how our app for children, Culture XI: World Explorer, handles children's information, parents can read section 16 below.
13. Security
We implement reasonable security measures to protect your data. However, no transmission or storage method is 100% secure.
14. Changes to This Policy
We may update this Privacy Policy. Changes are posted here with a revised "Last Updated" date.
15. Contact Us
For questions or to exercise rights:Email: "info@culturexi.com".
16. Culture XI: World Explorer and World Explorer 2 (apps for children)
This section explains how our apps Culture XI: World Explorer and Culture XI: World Explorer 2 (the "Apps"), for iPhone, iPad and Android phones and tablets, handle information. The rest of this Privacy Policy describes our Website; for the Apps, this section applies.
a. Who is responsible
Culture XI B.V., Leeuwendalersweg 15H, 1055 JE Amsterdam, the Netherlands, is responsible for the Apps (the "controller" under data protection law). You can reach us at info@culturexi.com.
b. Designed for children
The Apps are designed for children aged about 6 to 12 and are meant to be set up by a parent or guardian. On the App Store, Culture XI: World Explorer is in the Education category and in the Kids category for ages 6–8; Culture XI: World Explorer 2 is in the Education category. We offer the Apps in the App Store and on Google Play, where they follow Google Play's Families policy.
c. What the Apps do and do not collect
The Apps have no accounts, logins or sign-up. They do not ask for or collect a child's name, email address, location or contacts. They do not use advertising identifiers, contain no advertising and no third-party analytics, and do not track children across other apps or websites. There is no chat, no user-generated content and no social features. We do not sell or share children's data with third parties.
Spoken words in the Apps use the text-to-speech voices built into your device. The Apps do not send this text to us.
If you have chosen in your device settings to share analytics with app developers, Apple may give us crash and usage statistics in a form that does not identify you. You can switch this off in your device's privacy settings. On Android, if you have chosen to share usage and diagnostics with app developers, Google may give us crash statistics in a form that does not identify you. You can switch this off in your device settings.
On Android, apart from those crash statistics, which your device shares under your own settings, the only information that leaves the device because of our Apps is the technical information that Google Play's billing service sends to Google when Culture XI: World Explorer starts (see section e.). Culture XI does not receive it.
d. Progress stays on the device
The stamps and words your child collects are saved only on the device, in the App's own storage. They are not sent to us and we cannot see them. Deleting an App removes this progress from the device. On iPhone and iPad a copy may remain in a device backup (for example an iCloud backup) until that backup is deleted or replaced. On Android the Apps opt out of cloud backup, so progress isn't copied to your Google account.
e. Purchases and subscriptions
World Explorer Plus is an optional subscription in Culture XI: World Explorer. On iPhone and iPad it is sold through Apple's App Store using Apple StoreKit; on Android it is sold through Google Play Billing. Apple or Google processes the payment; we never receive your name, card or other payment details. Culture XI: World Explorer only checks whether a subscription is active so it can unlock the extra worlds. When Culture XI: World Explorer starts on Android, Google Play's billing service sends technical information to Google so purchases can work, such as device model and brand, Android version, language, country and time zone settings, mobile network operator, network type, error codes and a random session number. Google handles this under its own privacy policy. Culture XI does not receive it. You can manage or cancel a subscription at any time in your Apple ID settings or in Google Play under Payments & subscriptions. Apple's or Google's own privacy policy applies to your purchase. World Explorer 2 sells nothing inside the App and does not use Google Play's billing service.
f. Grown-ups gate and links
Before any purchase screen and before any link, the Apps show a grown-ups gate: a question an adult needs to answer. Behind the gate, Culture XI: World Explorer links to this Privacy Policy and the Terms of Use, and on Android also to your subscriptions in Google Play. Culture XI: World Explorer 2 links only to this Privacy Policy. These links open outside the App, in your browser or in Google Play, and the rest of this policy applies to our Website. The Apps have no other external links and no social media links.
g. The law and children's data
We handle personal data in line with the EU General Data Protection Regulation (GDPR, in Dutch the AVG) and the Dutch implementation act (UAVG). Under Dutch law, a child under 16 needs a parent's permission before an online service may rely on consent to process that child's personal data. Culture XI doesn't collect personal data from children. When Culture XI: World Explorer starts on Android, Google Play's billing service sends technical information to Google, as described in section e. We therefore do not ask children for consent. For users in the United States, we follow practices aligned with the Children's Online Privacy Protection Act (COPPA): we do not knowingly collect personal information from children under 13.
h. Your rights as a parent
You can ask us what personal data we hold about you or your child, and ask us to correct or delete it. Because the Apps keep progress only on the device, we normally hold no App data about your child, and you can delete it yourself by deleting the App. If you email us, we use your email only to reply to you. Contact us at info@culturexi.com. If you are unhappy with how we handle your data, you can complain to the Dutch Data Protection Authority, the Autoriteit Persoonsgegevens (autoriteitpersoonsgegevens.nl), or to the data protection authority in your country.
i. Changes to this section
If we change how the Apps handle data, we will update this section and the "Last Updated" date at the top of this page. If a change would mean collecting personal data from children, we will first ask for a parent's permission where the law requires it.
17. Educators waiting list, pilot requests and educator news
If you join the World Explorer Educators waiting list on our Educators page, we use your name, work email, school and role only to tell you when Educators is available and about pilot places. School and role are optional. We also note which page and language you signed up from. We do not ask for any information about pupils.
Lawful basis: your consent (art. 6(1)(a) GDPR). You give it by ticking the consent box and confirming your email address through the link in our confirmation email. You can withdraw your consent at any time; this does not affect processing before you withdrew it.
Retention: we keep your details until launch plus 12 months at most, or until you unsubscribe, whichever comes first, and then delete them.
Pilot requests: if you request a pilot, we use your name, work email, school and (optional) role to handle your request and contact you about a pilot at your school. Lawful basis: steps at your request before a possible agreement (art. 6(1)(b) GDPR). We also note which page and language you signed up from. We keep these details for up to 12 months after your request or after the pilot ends, then delete them.
Culture XI news for educators: on either form you can also choose to receive occasional Culture XI news for educators. This is separate, optional consent (art. 6(1)(a) GDPR); the box is unticked by default and you can unsubscribe at any time. We keep your email address for this until you unsubscribe.
Processor: we manage the waiting list in HubSpot, which processes your details on our behalf in the EU under its Data Processing Agreement. Controller: CULTURE XI B.V., Leeuwendalersweg 15 H, 1055 JE Amsterdam, KvK 91943248.
Unsubscribing: use the unsubscribe link in any email from us, or write to info@culturexi.com.
Additional CCPA/CPRA Notice (for California residents, if applicable) We collect the categories of personal information listed in Section 1. We use/disclose them for business purposes described above.We do not sell personal information.You have the right to know, delete, correct, opt out of sale/sharing (none occurs), and non-discrimination.Submit verifiable requests to the contact above.
