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New Cultural Code Privacy Policy

Published: November 2, 2026

This policy explains what personal data we collect, why we collect it, whom we share it with, how long we keep it, and how you can manage it. It supplements Section 11 of the Public Offer and User Agreement. The terms "Summit," "Evening," "Ticket," "Buyer," "Participant," "Site" and "Platform" have the meanings given to them in the Public Offer and User Agreement.

1. Who We Are and What This Policy Covers

1.1. Data is processed by MAYRII Inc., a Delaware corporation (USA), with its address at 16192 Coastal Highway, Lewes, DE 19958, USA (the "Organizer," "we" or "us"). The Organizer independently determines the purposes and means of processing data (as the data controller or data operator). For any questions about data, contact mariaproject617@gmail.com.

1.2. This policy applies when you visit the Site at newculturalcode.com, buy a Ticket, attend the Summit, complete forms on the Site (for example, an application to join The Eight community), receive our emails or contact support.

1.3. This policy does not apply to third-party websites and services (for example, Zoom or Stripe), which have their own policies. Purchases paid for through a regional partner under a separate offer are governed by that partner's policy.

2. What Data We Collect

2.1. We collect only the data needed to sell Tickets, run the Summit and operate the Site.

Category Details Source
Contact data Name, email, country From you, at purchase or in a form
Purchase data Payment date and amount, promo code, card country and type, last 4 digits of the card. We do not receive or store the full card number or CVC From the Stripe payment service
Attendance data Zoom name and email, join and leave times, IP address and device type, chat messages and questions; image and voice if you turn on your camera or microphone From the Zoom Platform
Site form data First and last name, email, Telegram, age, country, occupation, question text From you
Professional data Job title, company name, work email (only if you provide them) From you
Correspondence Support emails, Evening transfer and refund requests, claims From you
Site technical data IP address, browser, device, pages viewed, referral source and advertising tags (UTM), cookies Automatically, with your consent where required (Section 4)

2.2. We do not request or intentionally collect data about health, religious or political beliefs, or other special categories of data. Please do not share such information in the general broadcast chat, as other Participants can see it.

Purpose Data Legal basis
Processing the purchase, sending the confirmation and broadcast links, handling Evening transfers Contact data, purchase data, correspondence Performance of the agreement (the offer)
Running the broadcast and interpretation, answering questions, technical support Attendance data, correspondence Performance of the agreement
Tax and accounting records, calculating sales taxes in the Buyer's country Contact data, purchase data Legal obligation
Preventing fraud and unauthorized connections, resolving disputes and payment chargebacks Purchase and attendance data, correspondence Legitimate interests
Internal recording of the broadcast and short excerpts to showcase the Summit (Sections 8.5–8.6 of the Public Offer and User Agreement) Participant's image, voice, name and messages Legitimate interests; use of a Participant's likeness in advertising only with separate consent
Responding to an application submitted through a form on the Site Site form data Steps taken at your request before entering into an agreement
Marketing and informational emails about future events and the Come2Unity community Name, email Consent in the EU, EEA, UK and other countries where it is required; elsewhere, legitimate interests, with the right to unsubscribe in any email
Site analytics, ad measurement and showing ads to Site visitors Site technical data, purchase data Consent through the cookie settings, where required
Sharing with a Speaker's agency under Section 11.3 of the Public Offer and User Agreement Name, job title, company, work email Consent

3.1. Where data is needed to perform the agreement, we cannot sell you a Ticket or give you access to the broadcast without it. Consent to marketing emails, cookies and sharing of data with a Speaker's agency is optional. Declining does not affect your purchase or attendance.

3.2. You may withdraw your consent at any time by clicking "Unsubscribe" in an email, through the cookie settings on the Site, or by writing to mariaproject617@gmail.com. Withdrawal does not affect the lawfulness of processing carried out before it.

3.3. Residents of Kazakhstan, Ukraine, Uzbekistan and other countries whose laws require consent to the collection and processing of personal data give such consent by checking a separate box on the payment page or in a form on the Site, for the purposes and to the extent described in this policy.

4. Cookies and Advertising Tags

4.1. Cookies are small files that the Site stores in your browser. Advertising pixels work in a similar way. We use three types:

Type Purpose Examples Consent required?
Necessary Site operation, payments, security, remembering your cookie choices Cookie consent management service, Stripe No
Analytics Counting visits and understanding which pages and traffic sources perform well Google Analytics Yes, in the EU, EEA, UK and other countries where required by law
Advertising Measuring ad performance and showing ads to Site visitors on social media Meta Pixel, Google Ads Yes, in the same countries

4.2. On your first visit to the Site, you will see a banner where you can accept all cookies, allow only necessary cookies or choose specific types. You can change your choice at any time using the "Cookie Settings" link at the bottom of the Site. You can also delete or block cookies in your browser settings.

4.3. If your browser sends a Global Privacy Control signal, we treat it as an opt-out of advertising cookies.

5. Whom We Share Data With

5.1. We do not sell personal data. We share it only with those needed to sell Tickets and run the Summit, and only to the extent necessary:

Recipient Purpose Where data is processed
Stripe Payment processing, tax calculation, fraud prevention USA and other countries
Zoom Running the broadcast and interpretation USA
Email service provider Purchase and broadcast emails; mailings USA and other countries
Site hosting and website builder Operation of the Site and forms USA and other countries
Meta, Google Analytics and advertising, only with your consent where required USA and other countries
Contractors: broadcast technical support, simultaneous interpreters, digital agency Running the broadcast, setting up advertising and analytics. They work under contracts that include confidentiality obligations USA and other countries
The agency of one of the Speakers Name, job title, company and work email, only with your consent (Section 11.3 of the Public Offer and User Agreement) UK

5.2. Partners and bloggers who promote the Summit receive only aggregate information on the number and value of sales made with their promo code, without Buyers' names or contact details.

5.3. We may disclose data to government authorities in response to a lawful request, and to protect our rights in a dispute. In the event of a reorganization or sale of the business, data will pass to the successor, which must comply with this policy.

6. International Data Transfers

6.1. The Organizer is located in the United States, and its contractors are located in the United States and other countries. As a result, your data may be processed outside your country of residence, where data protection rules may differ.

6.2. For data of residents of the EU, EEA and UK, we use the mechanisms provided by the GDPR and UK GDPR: adequacy decisions (including the EU–U.S. Data Privacy Framework and its UK Extension, if the recipient is certified under it) or standard contractual clauses. You may request a copy of the applicable safeguards at mariaproject617@gmail.com.

6.3. Residents of Kazakhstan, Ukraine, Uzbekistan and other countries whose laws require consent to the cross-border transfer of personal data give such consent by checking a separate box on the payment page or in a form on the Site (Section 3.3).

7. How Long We Keep Data

Data Retention period
Purchase and payment data The period required by tax and accounting laws, generally up to 7 years
Broadcast attendance data and internal recording No longer than 12 months after the Summit, unless needed to resolve a dispute
Mailing data Until you unsubscribe or withdraw consent
Site form data Up to 24 months after the last contact, unless you become a community member
Support correspondence and claims Up to 3 years or until the dispute is resolved
Cookies As specified in the cookie settings, but no longer than 13 months

When the retention period expires, data is deleted or anonymized.

8. How We Protect Data

8.1. We use reasonable technical and organizational measures, including: access to data only for those who need it for their work; two-factor authentication for our services; encryption in transit; and confidentiality obligations for contractors. Card data is processed only by Stripe, in accordance with the Payment Card Industry Data Security Standard (PCI DSS).

8.2. If a data breach creates a risk to you, we will notify you and the supervisory authorities within the time required by applicable law.

9. Your Rights

9.1. We grant all users the right to: find out what data we hold about them and receive a copy; correct inaccurate data; request deletion of their data, except data we are required by law to retain; and withdraw consent and unsubscribe from emails.

9.2. Residents of the EU, EEA and UK also have the right to: restrict processing; receive their data in a machine-readable format and transmit it to another controller; object to processing based on legitimate interests, and object to direct marketing without giving reasons; and lodge a complaint with the data protection supervisory authority in their country. We respond within one month. In complex cases, this period may be extended by two months, and we will let you know if it is.

9.3. U.S. residents. Residents of states with data protection laws (for example, California) have the right, to the extent provided by their state's law, to: know what categories of data we collect and with whom we share them; access, correct or delete their data; and opt out of the use of their data for targeted advertising through the cookie settings, by sending a Global Privacy Control signal, or by writing to mariaproject617@gmail.com. We will not treat anyone less favorably for exercising these rights. We respond within 45 days.

9.4. Residents of Kazakhstan, Ukraine, Uzbekistan and other countries have the data subject rights provided by the laws of their country, including the right to withdraw consent to the processing and cross-border transfer of their data, provided that this does not contradict the law or prevent the performance of an agreement already in place.

9.5. How to exercise your rights. Email mariaproject617@gmail.com from the address you provided at purchase or in the form. To protect your data, we may ask you to verify your identity. We handle requests free of charge.

10. Children

The Site and the Summit are not intended for persons under 18. We do not knowingly collect their data and delete any such data if we become aware of it.

11. Automated Decision-Making

We do not make decisions based solely on automated processing that produce legal or similarly significant effects for you. Ads are shown to Site visitors on social media only if you choose to allow this in the cookie settings (Section 4).

12. Changes to This Policy

We may update this policy. Each new version is published on the Site with its effective date. Buyers are notified of material changes by email. If a change requires new consent, we will ask for it.

13. Contacts

Data controller MAYRII Inc., 16192 Coastal Highway, Lewes, DE 19958, USA
Email for data inquiries mariaproject617@gmail.com
Website newculturalcode.com