Last Updated: February, 2025

Cultural Safeguard Alliance exists to help build connections between the cultural property protection community. We are a community built on trust. A fundamental part of earning that trust means being clear about how we use your information and protecting your human right to privacy.

This Privacy Policy describes how Cultural Safeguard Alliance, Inc. and its affiliates (“we,” “us,” or “CSA”), process personal information in relation to your use of the Cultural Safeguard Alliance platform.

1. Personal Information We Collect

1.1 Information Needed to Use the CSA Platform. We collect personal information about you when you use the CSA Platform. Without it, we may not be able to provide all services requested. This information includes:

1.1.1 Contact, Account, and Profile Information. Such as your first name, last name, phone number, work location, email address, and profile photo, some of which will depend on the features you use.

1.2 Information You Choose to Give Us. You can choose to provide us with additional personal information, including:

1.2.1 Additional Profile Information. Such as gender, preferred language(s), city, and personal description.

1.2.2 Other Information. Such as when you fill in a form, add information to your account, respond to surveys, post to community forums, participate in promotions, communicate with CSA Support and other Members, or share your experience with us. This may include health information if you choose to share it with us.

1.3 Information Automatically Collected by Using the CSA Platform and Our Payment Services. When you use the CSA Platform and Payment Services, we automatically collect certain information. This information may include:

1.3.1 Geolocation Information. Such as precise or approximate location determined from your IP address, mobile or other device’s GPS, or other information you share with us, depending on your device settings. We may also collect this information when you’re not using the app if you enable this through your settings or device permissions.

1.3.2 Usage Information. Such as additional services you have added, access dates and times, the pages you’ve viewed or engaged with before or after using the CSA Platform, and other actions on the CSA Platform, including the pages or content you view and links you click to third-party applications. We may collect this information even if you haven’t created a CSA account or logged in.

1.3.3 Device Information. Such as IP address, hardware and software information, device information, device event information, unique identifiers, crash data, and read receipts. We may collect this information even if you haven’t created a CSA account or logged in.

1.3.4 Cookies and Similar Technologies As Described in Our Cookie Policy.

1.4 Information We Collect from Third Parties. We may collect personal information from other sources, such as:

1.4.1 Third-Party Applications. If you choose to link, connect, or login to the CSA Platform with a third-party service, such as Google, Facebook, and WeChat, you direct the service to send us information such as your registration, friends list, and profile information as controlled by that service or as authorized by you via your privacy settings at that service.

1.4.3 Enterprise Product Invitations and Account Management. Organizations that use our Enterprise products may submit personal information to facilitate account management and invitations to use enterprise products.

1.4.4 Referrals. If you are invited to the CSA Platform, the person who invited you can submit personal information about you.

1.4.6 Complainants. If another member or any third party submits a complaint about you, we may receive information relating to the specific complaint made in order to understand and, where relevant, address the complaint.

 

2. HOW WE USE INFORMATION WE COLLECT. We use personal information as outlined in this Privacy Policy.

2.1 Provide, Improve, and Develop the CSA Platform. We may process this information to:

  • enable you to access the CSA Platform and make and receive payments,
  • enable you to communicate with others,
  • process your request,
  • perform analytics, debug, and conduct research,
  • develop and improve our products and services,
  • provide customer service training,
  • send you messages, updates, security alerts, and account notifications,
  • process, handle, or assess insurance claims or similar claims,
  • personalize and customize your experience based on your interactions with the CSA Platform, your profile information and preferences, and other content you submit, and
  • enable your use of our products and services.

2.2 Safeguard the CSA Platform and Community. We may process this information to:

  • study and combat discrimination
  • detect, prevent, assess, and address fraud and security risks,
  • verify or authenticate information provided by you, including identity information
  • comply with our legal obligations, protect the health and well-being of our employees and members
  • resolve disputes with our members
  • enforce our agreements with third parties,
  • comply with law, respond to legal requests, prevent harm, and protect our rights
  • enforce our terms and other policies
  • assess or evaluate your interactions with the CSA Platform and information obtained from third parties.

In certain cases, automated processes, which analyze your account and activities on the CSA platform as well as information in relation to activities on and off the CSA platform that can be associated with you, could restrict or suspend your access to the CSA Platform if such processes detect activity that may pose a safety or other risk to CSA, our community, or third parties. If you would like to challenge decisions based on automated processes, please contact us via the Contact Information section.

2.3 Provide, Personalize, Measure, and Improve our Advertising and Marketing. We may process this information to:

  • send you promotional and marketing messages, and other information,
  • show, personalize, measure, and improve our advertising on advertising platforms,
  • administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by CSA or its third-party partners,
  • analyze characteristics and preferences to send you promotional messages, marketing, advertising, and other information that we think might be of interest to you, and
  • invite you to events and relevant opportunities.

2.4 Analyze and Share Your Communications. We may review, scan, or analyze your communications on the CSA Platform for reasons outlined in the “How We Use Information We Collect” section of this policy, including fraud prevention, security investigations, risk assessment, regulatory compliance, product development, research, analytics, enforcing our terms, and customer support purposes. For example, as part of our fraud prevention efforts, we scan and analyze messages to mask contact information and references to other sites and, subject to applicable law, we scan and analyze all images uploaded by users to the CSA platform in message threads, profiles, listings, and experiences for certain illegal or inappropriate activities – such as evidence of child exploitation – for the purpose of identifying and reporting content violations to appropriate authorities. In some cases, we may also scan, review, or analyze messages to debug, improve, and expand product offerings. We use automated methods where reasonably possible. Occasionally we may need to manually review communications, such as for fraud investigations and customer support, or to assess and improve the functionality of these automated tools. We will not review, scan, or analyze your messaging communications to send third-party marketing messages to you and we will not sell reviews or analyses of these communications. 

2.5 Provide Payment Services. Personal information is used to enable, or authorize third parties to use, Payment Services, such as to:

  • detect and prevent money laundering, fraud, abuse, and security incidents, as well as conduct risk assessments,
  • comply with legal and compliance obligations, such as anti-money laundering regulations and sanctions enforcement,
  • provide and improve Payment Services.

 

3. SHARING AND DISCLOSURE. 

3.1 Sharing With Your Consent or at Your Direction. Where you provide consent or direct us to share your information, we share your information as described at the time of consent or choice, such as when authorizing a third-party application or website to access your CSA account or participating in promotional activities by CSA partners or third parties.

3.2 Who We Share With. We may share your information with:

3.2.1 Other Members. To help facilitate bookings or other interactions between Members (who may be located in, or use service providers located in, jurisdictions with varying levels of data protection), we may share information in certain situations.

3.2.2 Service Providers. We share personal information with affiliated and unaffiliated service providers (including their service providers) to help us run our business and for their compliance purposes, including those that help us: (i) verify your identity or authenticate your identification documents, (ii) check information against public databases, (iii) conduct background checks, fraud prevention, security investigations, and risk assessments, (iv) perform product development, maintenance, and debugging, (v) allow the provision of the CSA Services through third-party platforms and software tools, (vi) provide customer service, advertising, or payments services  (vii) offer additional services you select, (viii) process, handle, or assess insurance claims or similar claims, (ix) review, scan, and analyze communications on the CSA Platform for certain purposes, such as evidence of child exploitation. These providers are contractually bound to protect your personal information, have access to your personal information to perform these tasks, and may also disclose your information where required by law.

3.2.3 Corporate Affiliates. To support us in providing, integrating, promoting and improving the CSA Platform, Payment Services, and our affiliates’ services, we may share personal information within our corporate family of companies, including:

3.2.3(i) Cultural Safeguard Alliance, Inc. Even if your country of residence is not the United States, your information will be shared with Cultural Safeguard Alliance, Inc., which provides the technical infrastructure for the CSA Platform.

3.3 Why We May Share Your Information. We may share your information in order to:

3.3.1 Build Your Public Profile. Information you share publicly on the CSA Platform may be indexed through third-party search engines. In some cases, you may opt-out of this sharing in your account settings. We may make certain information publicly visible to others, such as:

  • your profile and account information and information derived from them, 
  • listing pages that include information such as your profile photo and additional information you choose to share,
  • reviews, ratings, and other feedback, and
  • content in a community or discussion forum, blog, or social media post, and content you make available to the public, including details on third-party sites, platforms, and apps.

3.3.2 Comply with Law, Respond to Legal Requests, Prevent Harm, and Protect Our Rights.

3.3.2(i) Disclosure. We may disclose your information to courts, law enforcement, governmental or public authorities, tax authorities, authorized third parties, or other Members, if and to the extent we are required or permitted to do so by law or where disclosure is reasonably necessary to: (i) comply with our legal obligations, (ii) comply with a valid legal request, such as a subpoena or court order, or to respond to claims asserted against CSA, (iii) respond to a valid legal request relating to a criminal investigation to address alleged or suspected illegal activity, or to respond to or address any other activity that may expose us, you, or any other of our users to legal or regulatory liability, (iv) enforce and administer our agreements with Members, including our terms, (v) respond to requests for or in connection with current or prospective legal claims or legal proceedings concerning CSA and/or third parties, in accordance with applicable law, or (vi) protect the rights, property or personal safety of CSA, its employees, its Members, or members of the public.

3.3.2(i) To Tax Authorities. Where legally required or permissible according to applicable law, we may disclose information to relevant tax authorities or other governmental agencies, for the purpose of the tax authorities’ determination of proper compliance with relevant tax obligations.

3.3.2(ii) Notification. Where appropriate and/or legally required, we may notify Members about legal requests, unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon or harm to CSA, our Members, or expose CSA to a claim of obstruction of justice.

3.3.3 Effectuate Business Transfers. If CSA undertakes or is involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer, or share some or all of our assets, including your information in connection with such transaction or in contemplation of such transaction, such as due diligence. In this event, we will notify you before your personal information is transferred and becomes subject to a different privacy policy.

 

4. THIRD-PARTY PARTNERS AND INTEGRATIONS.

4.1 Linking Third-Party Services. You can link your CSA account with certain third-party services, such as social networks. When you direct the data sharing by creating this link:

  • some of the information provided to us from linking accounts may be published on your public profile,
  • information you provide to us from the linking of your accounts may be stored, processed, and transmitted for fraud prevention, security investigations, and risk assessment purposes,
  • we share information about your reservation with third-party travel partners and reward programs, and
  • publication and display of information that you provide to the CSA Platform through this linkage is subject to your settings and authorizations on the CSA Platform and the third-party service.

4.2 Third-Party Service Terms. Parts of CSA may link to third-party services. CSA does not own or control these third parties. When you interact with these third parties and choose to use their service, you are providing your information to them. Your use of these services is subject to the privacy policies of those providers, including the Stripe Privacy Policy

 

5. YOUR RIGHTS. You can exercise any of the rights described in this section consistent with applicable law. We may ask you to verify your identity and request before taking further action on your request.

5.3 Managing Your Information. You can access and update some of your personal information through your Account settings. You are responsible for keeping your personal information up to date.

5.4 Access and Portability. In some jurisdictions, applicable law may entitle you to request certain copies of your personal information or information about how we handle your personal information, request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format, and/or request that we transmit this information to another service provider, where technically feasible.

5.5 Erasure. In some jurisdictions, you can request that your personal information be deleted. Please note that if you request deletion of your personal information, or if your account is suspended, terminated, or voluntarily closed:

5.5.1 Legitimate Business Interests. We may retain your personal information as necessary for our legitimate business interests, such as prevention of money laundering, fraud detection and prevention, and enhancing safety. For example, if we suspend a CSA Account for fraud or safety reasons, we may retain information from that CSA Account to prevent that Member from opening a new CSA Account in the future.

5.5.2 Legal, Tax, Reporting, and Auditing Obligations. We may retain and use your personal information to the extent necessary to comply with our legal, tax, reporting, and auditing obligations.

5.5.3 Shared Information. Information you have shared with others, such as Reviews and forum postings, may continue to be publicly visible on CSA, even after your CSA Account is canceled.

5.5.4 Residual Copies. Because we take measures to protect data from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.

 

6. SECURITY. While no organization can guarantee perfect security, we are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unlawful or unauthorized access, loss, destruction, or alteration.

 

7. CHANGES TO THIS PRIVACY POLICY. We reserve the right to modify this Privacy Policy at any time in accordance with applicable law. If we do so, we will post the revised Privacy Policy and update the “Last Updated” date at the top. In case of material changes, we will also provide you with notice of the modification by email at least thirty (30) days before the effective date. If you disagree with the revised Privacy Policy, you can cancel your Account. If you do not cancel your Account before the date the revised Privacy Policy becomes effective, your continued access to or use of the CSA Platform will be subject to the revised Privacy Policy.

 

8. CONTACT INFORMATION AND RESPONSIBLE CSA ENTITIES. For questions or complaints about this Privacy Policy or CSA's handling of personal information, email us at [email protected].