CKC CARES Ventures Ltd. Privacy and Data Use Policy

Effective: June 2025

This Privacy and Data Use Policy explains how CKC Cares Ventures Ltd. (CKC Cares), collects, processes, stores, and protects your personal information across our websites, services, products, digital tools, and AI agents. This includes our educational programs, Shopify storefront, virtual sessions, assessments, sound empowerment offerings, and ethical AI tools.

CKC Cares is committed to protecting your privacy and dignity while upholding global standards of ethical data governance.

Global Data Protection Alignment

CKC Cares aims to comply with and align its practices with the following regulations and frameworks:

Bermuda Personal Information Protection Act (PIPA)
European Union General Data Protection Regulation (GDPR)
United Kingdom Data Protection Act 2018 (UK DPA)
OECD Privacy Guidelines
UNESCO Data Ethics Recommendations
Relevant provisions under the California Consumer Privacy Act (CCPA) for US-based users

Where local laws offer stronger protections, CKC Cares adheres to the higher standard by default.

Information We Collect

We only collect data that is necessary to deliver services and improve user experience. This includes:

Contact Information: name, email address, organisational affiliation
Service Data: session notes, responses to assessments, participation in workshops
Technical Data: device/browser type, usage logs, cookies (non-identifying)
Feedback & Communications: survey responses, queries, testimonials
AI Interaction Data: non-identifying input and output from CKC Cares AI agents for service personalisation

We do not collect sensitive data (e.g., health records, ID numbers) unless explicitly needed and consented to in advance.

How We Use Your Information

Your data may be used for the following purposes:

To deliver coaching, workshops, policy diagnostics, and assessments
To personalise AI agent responses (non-identifying, session-based only)
To issue certificates, diagnostics reports, or participation summaries
To process payments or bookings securely
To inform the development of future services, offerings, and frameworks

We never sell your data or share it with third parties for commercial gain.

Your Rights Under Global Law

Depending on your jurisdiction, you may have the right to:

Access, correct, or delete your data
Request a copy of your data
Object to certain types of processing
Withdraw consent at any time
File a complaint with your local data authority (we will assist if needed)

To exercise your rights, contact privacy@ckccares.com.

Data Storage, Security & Retention

Data is stored using secure, access-controlled cloud platforms.
Only authorised CKC Cares team members can access personal information.
We use privacy-by-design and security-by-default principles across all services.
Personal data is retained only as long as necessary to fulfil its purpose. Data from assessments, AI agents, and events is reviewed for deletion after 12–18 months unless extended by client request.
Websites use secure SSL encryption and verified platforms (e.g., Shopify, Webflow, Notion) to manage data securely.

AI Tools & Agent Use

When using CKC Cares AI agents, including through platforms such as ChatGPT:

Conversations with AI agents are not used to train third-party AI models, including OpenAI or other model providers, unless explicitly stated and consented to.
CKC Cares agents are designed to avoid retaining data between sessions unless explicitly configured otherwise.
Where agents collect data (such as through assessments or reflections), that data is anonymised by default unless users provide explicit and informed consent to the contrary.
These agents do not make decisions on your behalf and are not a substitute for legal, clinical, or regulatory advice.
All AI agents display clear disclaimers describing their nature, purpose, and limitations. Where deployed on client-facing sites, opt-out options or alternatives are provided.

We routinely test our AI tools for potential bias, emotional clarity, and signs of misuse to uphold high standards of ethical assurance.

All CKC Cares agents operate under human oversight. They do not use session data to train any models, and are not connected to third-party analytics systems unless explicitly stated.

Users are informed when interacting with AI tools, and all agents include embedded disclaimers or access to agent descriptions via linked documentation. Where applicable, users may opt out or choose human-only alternatives.

Use of AI-Based Advisory Tools

CKC Cares uses AI-assisted tools to support ethical reflection, digital risk assessment, and values-aligned decision support. These tools help individuals and organisations explore the social, legal, and ethical dimensions of the technologies they use or offer.

Examples include agents like ETHIQ, which provides structured, non-binding ethical assessments. Additional agents may be introduced in future to support areas such as community safety, emotional wellbeing, or digital dignity.

AI outputs are always subject to human interpretation and review. We do not use AI tools for fully automated decisions that produce legal or similarly significant effects as defined under Article 22 of the GDPR.

Data Collection and AI Assessments

AI advisory tools used by CKC Cares may process:

Reflections or inputs submitted voluntarily by teams or individuals during assessments, workshops, or ethical design exercises
Interaction metadata that is anonymised and non-identifiable
Contextual information provided explicitly for advisory use

We do not process personal data through our AI agents unless such data is intentionally submitted with informed, documented consent. If personal data is submitted during workshops, reflections, or assessments, it is reviewed for purpose limitation and minimised in accordance with Article 5(1)(c) of the GDPR (data minimisation principle).

If personal information is shared, it is handled in accordance with applicable data protection laws, including the GDPR. You may request access, correction, or deletion of your data at any time.

AI Oversight & Monitoring

CKC Cares AI agents are developed, tested, and monitored under human supervision. We conduct regular evaluations to:

Identify and reduce unintended bias or exclusion
Detect potential misuse or over-reliance
Ensure agents function in line with our ethical design standards and reflective safety principles

Any significant updates to the capabilities or functions of our AI agents are logged, reviewed, and disclosed where appropriate, ensuring transparency and ongoing ethical accountability.

Children's Data & Parental Guidance

CKC Cares does not knowingly collect personal information from children under 13 without parental or legal guardian consent. For youth programs, parental approval is required. All content for minors is designed to be trauma-informed, culturally safe, and age-appropriate.

We may require age confirmation or verified consent on forms or tools that are intended for or accessible by users under age 18, in accordance with applicable child data protection laws.

AI agents are not designed for direct engagement with users under 13. If an AI-supported activity is used in youth programming, a human facilitator must remain present, and content is designed to meet standards for trauma-informed and culturally safe learning.

Third Parties, Platforms & International Transfers

CKC Cares does not allow third-party access to personal data unless explicitly required for payment, hosting, or delivery of services (e.g., Shopify, Stripe, Webflow, Google Workspace, Notion).
Any third-party vendor is subject to contractual data protection obligations.
Data may be processed in jurisdictions outside your country, but always under secure conditions that meet international standards.

A full list of sub-processors is available upon request.

Consent, Cookies & Website Tracking

Our websites use cookies and analytics tools (e.g., Google Analytics, Shopify Pixel) for performance monitoring and user experience improvements.
Where required by law (EU/UK/Bermuda), we seek explicit opt-in consent before setting cookies.
You can update or withdraw your cookie preferences at any time via our site settings.

All form submissions include clear consent checkboxes and data use notices in alignment with global privacy laws.

Sub-Processors Used by CKC Cares Ventures Ltd.

We use a limited number of carefully vetted service providers to support our operations. A few core vendors include:

Shopify (commerce platform)
Stripe (secure payment)
OpenAI (AI agent processing – session-based only, no training on inputs, no data retention beyond processing)
Bitrix24 (communication, storage)

A full sub-processor list is available upon request at privacy@ckccares.com. All partners are bound by data protection agreements and are reviewed regularly for security and legal compliance.

Updates to This Policy

We review this policy regularly. Updates will be posted on our website with the “Effective Date” noted above. For material changes, we may notify you via email if you're on our mailing list.

Questions or Concerns?

Please contact our Privacy & Data Ethics team:

privacy@ckccares.com

We will respond within 5–10 business days and are happy to explain any part of this policy in more detail.

This Privacy & Data Use Policy reflects our global commitment to ethical design, human-centred services, and respect for your digital sovereignty.

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