Privacy Policy

Cultivating Sales, LLC. and its affiliates (collectively, “Cultivating Sales”) respect the privacy of users (a “User” or “Users”) and Clients (an “Client” or “Clients”) alike. This privacy policy explains Cultivating Sales’ privacy practices in connection with the use of the web-application (the “Web-App”) operated by Cultivating Sales for Client and Users and the services rendered through the Web-App by Client to User (the “Services”). It also describes the ways Cultivating Sales collects and uses personal information of Users and Clients and the rights and options available to Users and Clients with respect to their information.

This privacy policy is incorporated into the Terms of Service between Cultivating Sales and Client (the “Agreement”). Capitalized terms not defined herein shall have the meaning ascribed to them in the Agreement.


To the extent that the provisions of Regulation (EU) 2016/679 (“GDPR”) apply to the processing of personal data under these Website Terms and Conditions, the Cultivating Sales’ Data Processing Addendum serves as an integral part of these Website Terms and Conditions.

What personal information does the Client provide to Cultivating Sales?

As a Client, when you register to the Web-App, you are asked to provide Cultivating Sales an active e-mail address and other contact and personal details (or other allowed means of identification) and are given a temporary password. It is highly suggested that you change that password immediately.

Cultivating Sales can ask you to provide additional payment and transaction related personal information, to the extent required to provide the Services.

As a Client, you also need to set-up a profile using the Web-App, which is available on websites other than your own. Cultivating Sales does not have any obligation under this privacy policy with respect to information which a Client provides and which is intended to be publicly available.

Please bear in mind that false, incorrect, incomplete, or outdated information can prevent you from registering and using the Services or the Web-App or impair Cultivating Sales’ ability to provide you with the Services or the Web-App and to contact you.

What Internet traffic does Cultivating Sales collect?

Cultivating Sales’ Web-App provides a comprehensive solution to Users and Clients, which enables them to contact each other, schedule an appointment, form a contract, pay and receive fees, interact and manage their engagement by using the Web-App. The Web-App is installed on Cultivating Sales’ vendor’s servers, and when you use the Web-App, the information routed via the Web-App is accessible to Cultivating Sales & their vendors.

When you use the Services or the Web-App, Cultivating Sales will collect information, such as session durations, page impressions, Internet protocol (IP) addresses, the domain name that served you to access the Services or the Web-App, and content types and origins.

Cultivating Sales will also store information related to online data or metadata that is routed through Cultivating Sales’ vendor’s servers, such as web page addresses, structure, data fields and images.

The stored data will be attributed to you in person, only to the extent necessary for the use of the Web-App or the Services, as set in the following section. In all other cases, Cultivating Sales vendor will anonymize the data and will not knowingly use the data to personally identify you.

Further information is collected when you and Cultivating Sales exchange communications, for example, when you submit an inquiry to customer support at: [email protected]

Does Cultivating Sales collect location-based information?

Cultivating Sales does not actively collect any personal information that is based on your geographical location, except for the country that you reside in when accessing the Services or the Web-App.

However, certain location-based information is stored on Cultivating Sales’ vendor’s servers, for example if you use the Services or the Web-App to access geographic based services.

Cultivating Sales vendor will use such information subject to this privacy policy and will anonymize such data as soon as it is no longer necessary for the performance of the Services by Client or the use of the Web-App.

What does Cultivating Sales do with your personally identifiable information?

Cultivating Sales uses personally identifiable information for the following purposes and for as long as they serve such purposes:

  • To provide and operate the Services or the Web-App;
  • To send you updates and notices and to provide you with information related to the Services or the Web-App, provided that Cultivating Sales will not share your e-mail address or any other personally identifiable information with online advertisers and advertising networks, without your explicit consent;
  • To enforce the Agreement;
  • To contact you as and when it is necessary for providing the Services;
  • To comply with any applicable law, respond to lawful requests of personal information by public authorities, and assist law enforcement agencies as required, including to meet national security; in any case where Cultivating Sales believes that the use of the information is necessary to prevent imminent physical harm or damage to property;
  • To collect fees and debts, and to prevent fraud, misappropriation, infringements, identity thefts and any other misuse of the Services or the Web-App;
  • To take any action in any case of dispute, or legal proceeding of any kind between you and Cultivating Sales, or between you and other users or third parties with respect to, or in relation with the Services or the Web-App.

Privacy Shield

As a Cultivating Sales user, your personal information is maintained, processed and stored by Cultivating Sales, our affiliates, and our service providers in the United States or other jurisdictions.

Cultivating Sales complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States.

Cultivating Sales has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit

In compliance with the Privacy Shield Principles, Cultivating Sales commits to resolve complaints about our collection or use of your personal information. European Union individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Cultivating Sales at: [email protected]

For any Privacy Shield related complaints that are not resolved within 45 days, you can file a complaint with Whistic, our independent dispute resolution provider, at the following website: The services of Whistic are provided at no cost to you.

Cultivating Sales is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).

The Clients controlling and operating the Cultivating Sales Web-App will be considered the controllers of such Clients’ Data and are responsible for complying with all laws and regulations which are applicable to the collection and control of such Clients’ Data including privacy or data protection laws of all relevant jurisdictions.

Cultivating Sales cannot provide legal advice to Clients, but Cultivating Sales recommends that all Clients that create and maintain websites using Cultivating Sales platform should maintain clear and comprehensive privacy policies complying with the applicable laws and regulations.

Important notice about privacy of persons under the age of 16

The Services and the Web-App are not intended for use by persons under the age of 16. If you are not 16 years old or older, then you cannot use any of the Services or the Web-App and must not provide any of your personal details.

Cultivating Sales strongly encourages parents to monitor their children’s use of the Web. Cultivating Sales will delete a child’s personally identifiable information if a parent so requests by sending an e-mail to [email protected]. If Cultivating Sales learns that a child under the age of 16 years has provided personally identifiable information to Cultivating Sales without verifiable parental consent, Cultivating Sales will use commercially reasonable efforts to delete such information from Cultivating Sales’ and their respective vendor’s databases.

How does Cultivating Sales share your personally identifiable information with others?

Cultivating Sales does not sell, rent or lease your personally identifiable information to third parties. Cultivating Sales shares personally identifiable information with others only in any of the following instances, or otherwise subject to your explicit consent:

To operate the Services or the Web-App, including to store and process your information through a third-party hosting services and to process payments;

To contact you. For example, Cultivating Sales uses a third party’s mailing platform to send you messages and updates from time to time;

If Cultivating Sales believes that you have breached the Agreement or any other agreement with Cultivating Sales or abused your rights to use the Services or the Web-App or performed any act or omission that Cultivating Sales believes to be violating any applicable law, rules, or regulations. Cultivating Sales may share your information with law enforcement agencies, governmental agencies and other competent authorities as well as with other third parties, as may be required;

If Cultivating Sales is required, or believes that it is required by law to share or disclose your information; In any case of dispute, or legal proceeding of any kind between you and Cultivating Sales, or between you and other users or third parties with respect to, or in relation with the Services or the Web-App (including a dispute between User and Client), Cultivating Sales can use your information in preparing its legal case in connection with such dispute or proceedings;

In any case where Cultivating Sales believes that sharing information is necessary to prevent imminent physical harm or damage to property;

If Cultivating Sales organizes the operation of the Services or the Web-App within a different framework, or through another legal structure or entity, or if Cultivating Sales is acquired by, or merged with another entity it can share your information with the new entity who will operate the Services or the Web-App, provided, however, that those entities agree to be bound by the provisions of this privacy policy, with respective changes taken into consideration;

Cultivating Sales can also share personally identifiable information with sub-contractors and other companies or organizations connected, or affiliated with Cultivating Sales, such as subsidiaries, sister-companies and parent companies;

Cultivating Sales is liable for onward transfers of personal data to third parties.

 How does Cultivating Sales use anonymous, statistical or aggregated information?

Cultivating Sales also uses anonymous, statistical or aggregated information to properly operate the Services or the Web-App; to improve the quality and functionality of the Services or the Web-App; to enhance your experience; to create new services, including customized services; to change or cancel existing content or services, and for other internal and statistical purposes.

Cultivating Sales can share, publish, post, disseminate, transmit or otherwise communicate or make available anonymous, statistical or aggregated information to vendors, business partners, sponsors, affiliates and any other third party, at Cultivating Sales’ sole discretion, provided, however, that Cultivating Sales will not knowingly, or intentionally use the information to reveal your identity without your consent.

How does Cultivating Sales access & use your Google user data?

Cultivating Sales uses Google OAuth in order to get access to your Google data as describes as follows:

As part of your registration, you can choose to register using your Google account. As part of this process Cultivating Sales will create a Cultivating Sales account using your Google email address, and later on will use it as your system email address.

If you choose to synchronize your Google Calendar with Cultivating Sales’ app, Cultivating Sales will access your Google calendar and will use it to display your availability on your Cultivating Sales calendar(s).

If you choose to synchronize your Google Contacts with Cultivating Sales’ app, Cultivating Sales will import your Google Contacts into Cultivating Sales’ app and will use it to allow you to contact your clients.

You can choose to export your Google data from Cultivating Sales’ app at any time.

How can you access your personal information?

If you are a Client and registered to the Web-App, then you can access your personal account and edit or amend your personal information at any time using the designated user interface in the Web-App.

If you find that the information on your personal account is not accurate, complete or updated, then you can make all necessary changes to correct it. Otherwise, both Clients and Users can contact us at: [email protected].

Which ‘opt out’ and deletion options are available to you?

At any time, you can opt out of Cultivating Sales’ mailing lists, by sending Cultivating Sales a removal request to: [email protected]. It can take up to ten (10) business days for your opt-out request to take effect.

If you wish to delete your personally identifiable information that is stored in Cultivating Sales’ database, you can send a request to delete information to: [email protected]. Cultivating Sales will inform you whether it can accept your request. Cultivating Sales will strive to accept requests to delete personally identifiable information. Cultivating Sales can refuse your request, for example, if Cultivating Sales believes that removal of certain information can harm other users.

In any case, Cultivating Sales can keep any aggregated or anonymized information for statistical, marketing and other purposes, indefinitely.

It is Cultivating Sales’ policy to keep Client personal information on file unless specifically requested to be deleted.

How does Cultivating Sales secure your personal information?

Cultivating Sales and third parties on its behalf implement information security systems and procedures to secure your personal information. While such systems and procedures reduce the risk of security breaches, they do not provide absolute security.

Therefore, Cultivating Sales cannot guarantee that the Services or the Web-App will be immune from any wrongdoings, malfunctions, unlawful interceptions or unauthorized access to the information stored therein and to other information security risks, or that your private communications on or through the Services or the Web-App will remain private.

We restrict access to personal information you provided Cultivating Sales to our employees, contractors, vendors and agents who need to know that information for the purposes described in this privacy policy.

These individuals are obligated to keep your personal information confidential and they can be subject to penalties, termination of relations and criminal prosecution, if they fail to comply with such obligations.

Your rights under the GDPR

Please note that under the GDPR Cultivating Sales processes personal data as a data processor. As such, Cultivating Sales is committed to assist Cultivating Sales’ data controllers to fulfill individuals’ rights under the GDPR.

If you wish to exercise your rights under the GDPR or have any questions in this matter, please contact the relevant Cultivating Sales’ data controller directly. Should you need Cultivating Sales’ assistance to indicate who the relevant Cultivating Sales’ data controller is, please feel free to contact us at: [email protected].

To the extent required and upon a written request from Cultivating Sales’ data controller, Cultivating Sales will assist the Cultivating Sales’ data controller to fulfill your rights under the GDPR. Also see our additional GDRP focused page at

How does Cultivating Sales use Cookies?

Cultivating Sales uses cookies when operating the Services or the Web-App. Cookies are packets of information sent by Cultivating Sales’ vendors servers to your web browser and then sent back by the browser.

Cultivating Sales uses cookies for various purposes, for example, to save you the need to re-enter your password each time you log-in to the Services or the Web-App, to facilitate the use of the Services or the Web-App, to collect information for statistical and analytical purposes, to verify information, to customize the Services or the Web-App to your personal preferences and for information security purposes.

Some of the cookies can expire when the session ends, and you exit your browser. Other cookies can be stored on your computer’s hard drive. If you wish to block the cookies, then please use the help button in your browser and follow the necessary instructions. However, bear in mind that disabling cookies can complicate or even prevent your use of the Services or the Web-App, or certain features thereof.

Where is my personal information processed?

Cultivating Sales stores and processes the information through third party hosting services in the USA or in other jurisdictions, at its discretion. If you are in the European Economic Area, or in any other jurisdiction that regulates the transfer of personal information outside that jurisdiction, then you hereby grant Cultivating Sales your explicit and unambiguous consent to transfer your personal information to the USA or to any other jurisdiction where Cultivating Sales’ hosting services operate, for the purposes described in this privacy policy.


Cultivating Sales is doing its utmost to comply with this privacy policy. If you have any questions, concerns or complaints regarding this privacy policy and the enforcement thereof, please refer them to: [email protected].

After receiving your complaint, Cultivating Sales can contact you to better understand your concerns and will make all efforts to promptly answer your question or resolve your complaint to your full satisfaction.

Changes to this Privacy Policy

Cultivating Sales can change and update the terms of this privacy policy from time to time. Changes will take effect seven (7) days after their initial posting on the Website or the Web-App, unless Cultivating Sales amends this privacy policy to comply with legal requirements. In the latter cases the amendments will become effective as required or ordered.

Last Updated: May 23, 2018