PRIVACY POLICY

Last updated October 2026

This is a Norwegian translation of the English privacy policy ("Privacy policy"). In case of conflict or discrepancy between this translation and the English original, the English version shall apply. Read the English original at kulturella.io/privacy-policy.

This privacy policy for Kulturella AS ("the company," "we," "us," or "our") describes how and why we may collect, store, use, and/or share ("process") your information when you use our services ("the services"), for example when you: visit our website at https://kulturella.io, or any of our websites that link to this privacy policy, or use our platform and its features. Are in contact with us in other related ways, including sales, marketing, or events.

Questions or concerns? Reading this privacy policy will help you understand your privacy rights and choices. If you do not agree with our policies and practices, we ask you not to use our services. If you still have questions or concerns, contact us at post@kulturella.no.

SUMMARY OF KEY POINTS

This summary provides the key points from our privacy policy, but you will find more details about each topic by using the table of contents below to find the section you are looking for.

What personal information do we process?

When you visit, use, or navigate our services, we may process personal information depending on how you interact with Kulturella AS and the services, what choices you make, and what products and features you use.

Do we process sensitive personal information?

We do not process sensitive personal information.

Do we receive information from third parties?

We do not receive personal information from third parties. We receive basic profile information when you register with an account from social media.

How do we process your information?

We process your information to deliver, improve, and administer our services, communicate with you, maintain security and prevent fraud, and to comply with the law. We process anonymized and aggregated behavioral data to produce cultural statistics for the public sector — with your consent.

How do we keep your information safe?

We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or storage technology can be guaranteed to be 100% secure.

What rights do you have?

Depending on where you are located geographically, applicable privacy legislation may give you certain rights related to your personal information, including the right to access, correction, deletion, restriction, or objection to processing.

How do you exercise your rights?

The easiest way to exercise your rights is to contact us at post@kulturella.no. We assess and follow up on every request in accordance with applicable privacy legislation.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. HOW DO WE ANONYMIZE DATA FOR CULTURAL STATISTICS?
4. WHAT LEGAL BASIS DO WE RELY ON?
5. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
6. WHAT IS OUR POSITION ON THIRD-PARTY WEBSITES?
7. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGY?
8. HOW DO WE HANDLE SOCIAL MEDIA LOGIN?
9. HOW LONG DO WE RETAIN YOUR INFORMATION?
10. HOW DO WE KEEP YOUR INFORMATION SAFE?
11. DO WE COLLECT INFORMATION FROM MINORS?
12. WHAT PRIVACY RIGHTS DO YOU HAVE?
13. "DO NOT TRACK" SETTINGS
14. DO WE UPDATE THIS POLICY?
15. HOW CAN YOU CONTACT US ABOUT THIS POLICY?
16. HOW CAN YOU VIEW, CHANGE, OR DELETE THE DATA WE COLLECT ABOUT YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you provide to us

In short: We collect personal information that you give us. We collect personal information that you voluntarily provide to us when you register for the services, express interest in information about us or our products and services, when you participate in activities on the services, or when you otherwise contact us.

Personal information you provide yourself.

Which personal information we collect depends on the context in which you interact with us and the services, what choices you make, and what products and features you use. The personal information we collect may include the following:
– name
– telephone numbers
– email addresses
– contact or authentication data
– personal preferences
– artistic field, genre, biography, and profile picture

Sensitive information.

We do not process sensitive personal information.

Social media login data.

We may give you the option to register with us using an existing social media account, for example your Facebook account. If you choose to register this way, we collect the information described in the "HOW DO WE HANDLE SOCIAL MEDIA LOGIN?" section below.

Behavioral data.

We collect data about actions you perform on the platform, including which buttons you click on, and which options (funding schemes, activities, collaboration requests) you show interest in by clicking "Apply Now" or similar action buttons. This data is used to understand user behavior and to generate anonymized cultural statistics. See section 3 for details on how anonymization works.

Survey data.

When you show interest in a funding scheme, activity, or collaboration, you may receive an automatic follow-up survey. We ask whether you applied or participated, whether you received funding and if so how much, and whether a collaboration involved payment. Participation in surveys is voluntary. The responses are used only in anonymized and aggregated form.

Information collected automatically

In short: Some information — such as your IP address and/or the characteristics of your browser and device — is collected automatically when you visit our services.

We automatically collect certain information when you visit, use, or navigate the services. This information does not reveal your specific identity, but may include device and user information, such as your IP address, browser and device characteristics, operating system, language settings, referring URLs, device name, country, location, information about how and when you use our services, and other technical information. This information is needed primarily to maintain the security and operation of our services, and for our internal analysis and reporting.

Like many other businesses, we also collect information through cookies and similar technology.

The information we collect includes:

Log and usage data. Log and usage data is service-related, diagnostic information and usage and performance information that our servers automatically collect when you use the services, and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings, and information about your activity on the services (such as timestamps related to your use, pages and files you have viewed, searches and other actions you take, such as which features you use), as well as device events (such as system activity, error reports, and hardware settings).

Device data. We collect device data, which is information about the computer, phone, tablet, or other device you use to access the services. Depending on which device is used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, internet service provider and/or mobile operator, operating system, and system configuration.

Location data. We collect location data, which is information about the location of your device, and this may be either precise or imprecise, based on your IP address. You can opt out of our collection of this information by turning off the location settings on your device. If you choose to opt out, you may not be able to use certain parts of the services.

Applications for activities. When you apply for an activity via the application form on Kulturella, we store your answers and any attachments (for example, CV, portfolio or images). The application and attachments are only visible to you and the person who posted the activity. Attachments are stored in a closed area that is not accessible from the internet.

Invitations. If someone invites you to apply for an activity, we store the invitation, any greeting message, and whether you have viewed or replied to it.

Availability. If you enter when you are available or busy, we store the periods. Logged-in members can see your availability when they search for collaborators. You can turn off "Open for invitations" at any time, and then you will not appear in candidate suggestions.

Position you share yourself. If you yourself click "Use my position" on the map or in the candidate search, we use the position from your device to center the search. The position is rounded (to approximately 100 meters–1 kilometer), is used only right then, and is not stored.

Verification. When we verify profiles, we register the status (verified, pending or not verified), when you requested verification, and which steps have been taken (for example, that we have asked for more information). Verification messages are sent as regular messages on Kulturella.

What you are looking for. The field "What are you looking for on Kulturella?" is not visible to other members. We use it only to suggest relevant people and opportunities to you.

Calendar connection (Google Calendar and other calendars). If you yourself connect to Google Calendar or enter a private calendar address, we only fetch when you are busy (time slots), never titles, descriptions, participants or other details. The same applies to Outlook/Microsoft 365. In the app, you can also grant access to the calendar on your phone: the app then only reads the start and end times of your appointments and sends them to us, never titles or other details, and we only store which days you are busy. From Google we also fetch the email address of the account, so you see which calendar is connected. The information is used only to display your availability on Kulturella, is updated automatically every hour, is not shared with others and is not used for advertising or to train artificial intelligence. Access is stored encrypted. You can disconnect at any time under "See availability" on your profile – the busy time we have fetched is then deleted, and access is revoked with Google. Kulturella's use and transfer of information received from Google's APIs follows Google API Services User Data Policy, including the requirements for limited use (Limited Use).

Where you found us. When you register via a link from us (for example a campaign, a Facebook group or a referral link), we store which source the link came from. New members can also voluntarily answer "How did you hear about Kulturella?". We use this only to understand which channels work.

Newsletter without account. If you sign up for a newsletter by email, we store the email address, the field of expertise and the county you chose, when you confirmed, and when you last clicked in an email. We send nothing until you have confirmed the registration (double confirmation), and you can unsubscribe with one click in each email. The legal basis for processing is your consent.

Confirmed role in organizations. If you are an owner or administrator for an organization on Kulturella, you can confirm your role in three ways: (1) We check the name and date of birth you provide against the roles in the Brønnøysund Register (managing director, owner, board member, participant). We only store the result, never the information from the register. (2) We send a code to an email address on the organization's own domain. (3) You submit a case to our verification team, possibly with an attachment. The attachment is stored privately and deleted 30 days after the case is decided.
Invoice information. If you send an invoice through Kulturella, we store your invoice profile (for example, name, address, organization number, and account number) on your account, so you don't have to fill it out each time.

2. HOW DO WE PROCESS YOUR INFORMATION?

In short: We process your information to deliver, improve, and administer our services, communicate with you, maintain security and prevent fraud, comply with the law, and — with your consent — to produce anonymized cultural statistics for the public sector.

We process your personal information for the following purposes:

2.1 To deliver and administer our services
We process your information so you can create and log into your account, use the platform's features, communicate with other users, and receive the services you have requested.

2.2 To improve our services
We analyze usage data and behavioral data to improve platform functionality, fix technical errors, and train and improve the AI models that underpin our matching and recommendation features.

2.3 To produce cultural statistics for the public sector
We aggregate and anonymize behavioral data and survey responses to produce cultural statistics. This statistics can be delivered to Norwegian municipalities, county authorities, and other public actors as a basis for cultural management and planning. Statistics deliveries never contain personally identifiable information. It is not possible to identify individual users from the data delivered to the public sector.

This purpose requires your active consent. You can grant or withdraw consent at any time under Account Settings > Privacy, or by contacting us at post@kulturella.no.

2.4 To send administrative information
We may process your information to send you information about our products and services, changes to terms and policies, and other similar information.

2.5 For security and fraud prevention
We may process your information when necessary to protect the security of our services and to prevent fraud and misuse.

2.6 To comply with legal obligations
We may process your information where we believe it is necessary to comply with our legal obligations, such as to cooperate with law enforcement or regulatory authorities.

Keywords for better suggestions. To give you better suggestions, we create short keywords from your profile and what you're looking for (for example "photographer" or "festival"). The keywords are created by an open language model that we run on our own server in the EU (Amsterdam), and are not shown to others. The same model calculates how well profiles, cultural resources and activities match together. Your profile text is not sent to external AI services for this. They are recreated when you change your profile, and deleted when you delete your account.
ELLA, the AI assistant. When you chat with ELLA, your messages are sent to Anthropic (USA, EU Standard Contractual Clauses apply), which generates the responses. Conversations are stored with us for 90 days so you can continue where you left off. Your IP address is not stored in plain text together with the conversation, only as a one-way checksum (hash). From the conversations, we create short keywords about the topics discussed, so we can suggest relevant content. You can delete your entire conversation history anytime under Settings > Privacy, and everything is deleted when you delete your account. The only thing we keep is anonymous numbers for how often a topic is discussed, with no connection to you. Words that are a member's name or contain numbers are not included.
Translation. When you use Kulturella in English, the text on the website is translated with an open language model (OPUS-MT) that we run on our own server in the EU (Amsterdam). If our service does not respond, or a translation does not pass our verification, the text will instead be sent to Anthropic (EU Standard Contractual Clauses apply). The same applies when English profile text is translated into Norwegian. Translations are stored so that the same text does not have to be translated again, and translations of your own profile text are deleted when you delete the account.

3. HOW DO WE ANONYMIZE DATA FOR CULTURAL STATISTICS?

Before data is used for cultural statistics, it goes through the following processing steps:

– All personally identifiable information (name, email address, phone number) is permanently removed
– Data is aggregated — minimum group size is 10 users, so no individual can be identified
– Geographic data is coarsened to municipal level or higher
– Data is pseudonymized internally during processing and stored separately from personal profiles

Kulturella follows the principle of data minimization: we use no more data than necessary to produce the requested statistics.

The aggregated and anonymized statistics delivered to the public sector cannot be traced back to you as an individual.

4. WHAT LEGAL BASIS DO WE RELY ON?

In short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., a legal basis) to do so under applicable law.

The General Data Protection Regulation (GDPR) requires us to explain what valid legal bases we rely on when processing your personal information. We rely on the following bases:

Consent (GDPR Art. 6 No. 1 a)
We rely on your consent for the production of cultural statistics for the public sector (section 2.3 above). You may withdraw your consent at any time, without affecting the lawfulness of processing carried out before the withdrawal. To withdraw your consent, go to Account Settings > Privacy or contact us at post@kulturella.no.

Contract performance (GDPR Art. 6 No. 1 b)
We rely on this basis to deliver our core services — account creation, platform features, and communication between users.

Legitimate interest (GDPR Art. 6 No. 1 f)
We rely on this basis to improve our services, analyze usage patterns, train our AI models, and prevent fraud. We have assessed that our legitimate interests do not override your interests or fundamental rights.

Legal obligation (GDPR Art. 6 No. 1 c)
We rely on this basis where processing is necessary to comply with a legal obligation, such as cooperation with regulatory authorities or law enforcement.

5. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In short: We may share information in certain situations described in this section and/or with the following third parties.

Other users of the platform. The profile information you enter — name, artistic field, biography, and profile picture — is visible to other registered users. You decide what information you enter in your profile.

Public profile page. A limited version of your profile is by default visible to everyone on the web, including search engines: name, profile picture, title, field of culture, city (without address) and the first lines of your biography. Email, phone, address, documents, CV, references, availability and messages are never displayed publicly. Profiles that are hidden, set to "Only me" or not approved are not displayed. The processing is based on our legitimate interest in making members visible to clients and partners. You can turn it off at any time with the option "Show my profile outside Kulturella" under Edit profile. When you turn it off, the page is removed immediately from our end, but it may take some time for search engines to update their results.

Response time. If you usually reply to messages within one day, your profile can show "Usually replies within one day" (or "within a few hours"). This is calculated based on the timestamps of messages from the last 90 days, never from the content, and is only shown when it's positive and based on at least three inquiries. The basis is our legitimate interest in making it easier to get in touch. You can turn it off with the option "Show my response time on my profile" under Edit profile.

Data processors. We use data processors who operate technical infrastructure on our behalf. All data processors are bound by data processing agreements and cannot use your data for their own purposes. Our main data processors are:
– DigitalOcean — cloud infrastructure and server services. Our servers, database, and our own language model are located in Amsterdam (EU). DigitalOcean is a US company, and EU Standard Contractual Clauses apply.
– Stripe — payment for membership and services (EU Standard Contractual Clauses apply)
– SendGrid (Twilio) — email delivery (USA, EU Standard Contractual Clauses apply)
– Google Firebase — push notifications to the app (EU Standard Contractual Clauses apply)
– Apple and Google — in-app purchases and subscriptions, handled according to their own terms
– Anthropic — KI engine for ELLA, and translation reserve (US, EU standard contract terms apply)

Public sector. Aggregated and anonymized cultural statistics may be shared with Norwegian municipalities, county authorities, and state actors. No personal information is included in these deliveries. See section 2.3 and 3 for details.

Business transfer. We may share or transfer your information in connection with, or during negotiations about, a merger, sale of company assets, financing, or acquisition of all or part of our business by another company. You will be notified in advance.

Legal requirements. We may disclose your information where the law, a court order, or a public regulation requires it.

Video meetings (Jitsi). If an organizer selects "Create meeting link automatically" in the community calendar, we create a meeting link on meet.jit.si, which is operated by 8×8. The link contains only a random code, not the meeting title. When you join the meeting, audio, video and the name you provide are processed by Jitsi/8×8 according to their privacy policy. The person who starts the meeting logs in to Jitsi with Google, GitHub or Facebook.

6. WHAT IS OUR POSITION ON THIRD-PARTY WEBSITES?

In short: We are not responsible for the security of information you share with third parties that we may link to, or that advertise on our services without being affiliated with them.

The services may link to third-party websites, web services, or mobile applications. We provide no guarantees regarding such third parties, and we are not responsible for loss or damage caused by use of such websites, services, or applications. Data collected by third parties is not covered by this privacy policy. You should read the policies of such third parties and contact them directly with any questions.

7. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGY?

In short: We use cookies and other tracking technology to collect and store information.

We use cookies and similar tracking technology (such as web beacons and pixels) to retrieve or store information. We use cookies to:
– Keep you logged in between visits
– Remember your settings and preferences
– Analyze traffic and usage patterns

You can manage cookies in your browser settings. Please note that if you turn off certain cookies, it may affect the functionality of the platform. For more information on how you can decline certain cookies, see our cookie statement.

Cookies that show where you came from (for example from a Facebook group, a search page or a referral link), are only set if you have consented to statistics in the consent banner. Without consent, the source only follows the link you clicked on, and is stored only if you register.

Measuring registration. To understand where people drop out in registration, we count how far each registration progresses. For this, we use a random code that only exists in your browser while you register. We do not store IP address, name, or email in this measurement, and rows are deleted after 180 days.

8. HOW DO WE HANDLE SOCIAL MEDIA LOGIN?

In short: If you choose to register or log in to our services with a social media account, we may gain access to certain information about you.

Our services give you the option to register and log in using account details from a third-party social media provider (for example, Facebook login). If you choose to do this, we receive certain profile information about you from the social media provider.

Which profile information we receive may vary depending on the provider, but will often include name, email address, and profile picture, in addition to other information you choose to make public on the platform.

We use only the information we receive for the purposes described in this privacy policy. Please note that we do not control, and are not responsible for, other use of your personal information by the third-party social media provider. We recommend that you read their privacy policy to understand how they collect, use, and share your personal information.

9. HOW LONG DO WE RETAIN YOUR INFORMATION?

In short: We retain your information as long as it is necessary to fulfill the purposes described in this privacy policy, unless otherwise required by law.

We retain different categories of data for different periods:

– Account information: For as long as your account is active. Deleted within 30 days after the account is closed.
– Behavioral data: 12 months from the time of collection, then anonymized or deleted.
– Survey responses: 12 months in personally identifiable form, then only in aggregated form.
– Aggregated cultural statistics: Retained indefinitely — contains no personal information.
– Log and security data: 90 days.

When we no longer have an ongoing legitimate need to process your personal information, we will either delete or anonymize it, or — where this is not possible (for example, because your personal information is stored in backups) — store the personal information securely and keep it separate from further processing until deletion is possible.

Applications, invitations and availability. Applications and attachments are automatically deleted 12 months after the activity has expired. Invitations and availability are stored as long as you have an account, and are deleted when you delete your account.

Unconfirmed newsletter signups are deleted after 7 days. Confirmed signups are deleted when you unsubscribe, or automatically after 12 months without you having clicked on anything in the emails.

ELLA and verification. Conversations with ELLA are stored for 90 days, and you can delete them yourself anytime. Keywords from conversations older than 12 months are kept only as anonymous monthly figures. Attachments in cases about confirmed role are deleted 30 days after the case is decided.

Payments and accounting. Information about payments, orders, and invoices is kept for five years, because accounting law requires it. When you delete your account, this information is disconnected from your profile, but the actual accounting information is kept until the deadline.

10. HOW DO WE KEEP YOUR INFORMATION SAFE?

In short: We work to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures to protect the personal information we process, including:
– Encryption of data in transit (TLS) and at rest
– Access control — only authorized personnel have access to personal information
– Data processing agreements with all subcontractors
– Regular security assessments

However, no electronic transmission over the internet or storage technology can be guaranteed to be 100% secure. In the event of a security breach affecting your rights, we will notify you and the Data Protection Authority within 72 hours, as the privacy regulation requires.

11. DO WE COLLECT INFORMATION FROM MINORS?

In short: We do not knowingly collect data from, or market to, persons under 16 years of age.

Kulturella's services are not directed to persons under 16 years of age. We do not knowingly collect personal information from minors. If we become aware that we have received information about a minor, we delete it immediately. If you become aware of data we may have collected from persons under 16 years of age, we ask you to contact us at post@kulturella.no.

12. WHAT PRIVACY RIGHTS DO YOU HAVE?

In short: As a user in the European Economic Area (EEA), you have rights that give you better insight into and control over your personal information.

Under the privacy regulation, you have the following rights:
– Right to access: You can request a copy of all information we have about you.
– Right to correction: You can ask us to correct inaccurate information.
– Right to deletion: You can ask us to delete your personal information ("the right to be forgotten").
– Right to restriction: You can ask us to restrict the processing of your personal information.
– Right to data portability: You can request your data in a machine-readable format.
– Right to object: You can object to processing based on legitimate interest.
– Right to withdraw consent: You can withdraw your consent to processing for cultural statistics at any time under Account Settings > Privacy. This does not affect the lawfulness of processing carried out before the withdrawal.

To exercise your rights, log into your account and go to Settings, or contact us at post@kulturella.no. We will respond within 30 days.

You also have the right to lodge a complaint with the Data Protection Authority: datatilsynet.no | post@datatilsynet.no | +47 22 39 69 00.

Account information

If you wish at any time to review or change the information on your account, or close your account, you can log into your account settings or contact us using the contact information below. When you request to close your account, we will deactivate or delete your account and information from our active databases within 30 days. However, we may retain some information in our archives to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms, and/or comply with applicable legal requirements.

13. "DO NOT TRACK" SETTINGS

Most browsers and some mobile operating systems and mobile applications have a "Do-Not-Track" (DNT) feature or a setting you can turn on to signal that you do not want data about your online activity to be monitored and collected. Currently, there is no finalized, uniform technical standard for recognizing and following DNT signals. We therefore do not currently respond to DNT signals from your browser or other mechanisms that automatically convey a choice not to be tracked online. If a web tracking standard is introduced that we must follow in the future, we will inform you in an updated version of this privacy policy.

14. DO WE UPDATE THIS POLICY?

In short: Yes, we update this policy as needed to comply with relevant legislation.

We may update this privacy policy from time to time. The updated version will be marked with a new "Last updated" date at the top of the policy. If we make material changes to this privacy policy, we will notify registered users by email at least 30 days before the change takes effect. We encourage you to review the privacy policy regularly so you are informed about how we protect your information.

15. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this policy, you can email us at post@kulturella.no or write to:

Kulturella AS
Naustskaret 2
Molde, Møre og Romsdal 6409
Norway

Supervisory authority:
Datatilsynet — datatilsynet.no | post@datatilsynet.no | +47 22 39 69 00

16. HOW CAN YOU VIEW, CHANGE, OR DELETE THE DATA WE COLLECT ABOUT YOU?

You have the right to request access to the personal information we collect about you, change it, or have it deleted.

To review or update your information, log into your account and go to Settings.

To delete your account and all associated personal information, log in and go to Settings > Account > Delete account.

To exercise your privacy rights, or withdraw your consent to processing for cultural statistics, contact us at post@kulturella.no. We will respond within 30 days.

Privacy Preference Center