Privacy Policy

Traverze Culture operates through affiliated entities in the United States and Kenya, including a Florida-registered U.S. entity and a Kenya-registered operating entity.

Depending on the service you use, the entity responsible for your personal information may be the U.S. entity, the Kenya entity, or both working together for legitimate operational purposes.

This policy applies to personal information collected through:

• Traverze Culture websites and digital properties
• Assessments and program routing
• Contact forms and program inquiries
• Client onboarding and program administration
• Relocation & Integration services
• Healthcare Navigation and Medical Tourism
• Local Healthcare Navigation & Patient Advocacy
• Veteran Transition
• Investigative Relocation & Market Entry
• Corporate Mobility
• Property and development planning
• Electronic communications and client portals where applicable

Third-party healthcare providers, insurers, banks, attorneys, developers, payment processors, and other independent professionals operate under their own privacy policies and professional obligations. This policy does not govern their handling of your information.

Because Traverze Culture operates in both the United States and Kenya, personal information may be subject to different privacy, security, consumer-protection, healthcare, and data-protection requirements depending on where you are located, where the information is processed, and which Traverze Culture entity is providing the service.

Our privacy practices are designed around a consistent set of protective principles applied across both jurisdictions: lawful and transparent processing, collection limited to what is reasonably necessary, purpose limitation, appropriate retention, restricted internal access, heightened care for sensitive information, and defined routes for individuals to exercise their rights.

We apply these principles regardless of whether a particular threshold-based statute applies to a given activity. Where a specific law grants you rights beyond those described here, those rights apply.

Information you provide

• Identity and contact information: name, email address, telephone number, country and city of residence, organization where relevant
• Assessment information: goals, readiness, timeline, household composition, and the program areas you are seeking support with
• Program information: details necessary to coordinate an approved scope of services
• Healthcare-related information: see Section 5
• Coverage information: whether you hold health insurance or other coverage, and where you choose to provide it, the identity of your insurer
• Family information: where you are seeking support for a spouse, partner, child, parent, or other family member
• Veteran-related information: where you elect to pursue the Veteran Transition Pathway
• Financial and property information: where relevant to an approved program scope
• Identity and immigration documentation: where required for a coordinated service
• Communications: correspondence with our team

Information collected automatically

• Device and browser type, operating system, and approximate location derived from IP address
• Pages visited, referring pages, and interaction data
• Cookie and similar-technology data: see Section 11

Information from other sources

Where you authorize it, or where necessary to deliver an approved service, we may receive information from healthcare providers, insurers, professional partners, or family members acting on your behalf.

We use personal information for defined business and service purposes, including to:

• Review assessments and determine program fit, scope, and the appropriate next step
• Coordinate and deliver an approved scope of services
• Communicate with you about your inquiry, assessment, or program
• Coordinate with healthcare providers, professional partners, and service partners where necessary for an approved service
• Administer client accounts, agreements, scheduling, and documentation
• Process payments and maintain financial records
• Maintain the security and integrity of our systems
• Operate, evaluate, and improve our websites and services
• Meet legal, regulatory, professional, and contractual obligations
• Establish, exercise, or defend legal claims

We do not sell personal information. We do not use healthcare information for unrelated marketing purposes.

Our assessment is the entry point to Traverze Culture programs. Information you provide is used to understand your circumstances, determine whether a program is appropriate, and identify which program pathway may fit your needs.

The assessment presents different questions depending on your responses, so that you are asked only what is relevant to your situation. This is a data-minimization measure: it limits the information collected from any individual to what is reasonably necessary for their circumstances.

Assessment responses are reviewed by Traverze Culture personnel. Completing an assessment does not create a client relationship and does not obligate you to proceed.

We share personal information only where necessary for approved services, legitimate operations, professional obligations, purposes you have consented to, or legal requirements. Categories of recipient include:

• Traverze Culture entities: our U.S. and Kenya entities, where necessary for coordinated service delivery
• Healthcare providers and facilities: see Section 9
• Professional partners: legal, immigration, financial, property, and other independent professionals engaged in connection with an approved scope
• Service partners: housing, transportation, and logistics partners where relevant to your program
• Insurance partners: where you have asked us to coordinate coverage information
• Technology and administrative providers: hosting, communications, scheduling, payment processing, and similar operational services
• Professional advisers: our own legal, accounting, and insurance advisers
• Authorities: where required by applicable law, regulation, legal process, or enforceable governmental request

Where we engage service providers to process personal information on our behalf, we seek to put appropriate contractual arrangements in place requiring them to protect the information, use it only for the purposes we specify, and apply appropriate security measures.

We do not sell personal information, and we do not share personal information for unrelated third-party marketing.

Where your program involves healthcare navigation, medical tourism, or patient advocacy, we may share relevant information with hospitals, clinics, licensed specialists, and other healthcare providers in order to coordinate appointments, records, and continuity of care.

We share only the information reasonably necessary for the coordination requested, and additional authorization may be required before certain healthcare information is shared.

Healthcare providers are independent. They make their own clinical decisions, maintain their own records, and operate under their own privacy policies and professional and legal obligations. Traverze Culture does not control how an independent provider handles information once it is in their care.

Traverze Culture operates in the United States and Kenya. As a result, personal information may be transferred to, stored in, or accessed from either country, and in some cases from other countries where our service providers operate.

This means that information collected in Kenya may be transferred to or accessed from the United States, and information collected in the United States may be transferred to or accessed from Kenya, where doing so is necessary to deliver a coordinated service.

Data-protection laws differ between countries. Where we transfer personal information across borders, we seek to apply appropriate safeguards, which may include contractual protections, restricting transfers to what is necessary for the service, limiting access to personnel with a legitimate operational need, and obtaining your consent where required.

Where sensitive personal information, including health-related information, is transferred across borders, additional safeguards and, where required, specific consent may apply.

Our websites use cookies and similar technologies to operate the site, remember preferences, understand how the site is used, and improve performance. Categories may include:

• Strictly necessary: required for the site and forms to function
• Functional: remember preferences and settings
• Analytics: help us understand site usage in aggregate

You can control cookies through your browser settings. Disabling certain cookies may affect how parts of the site function.

We may contact you regarding your inquiry, assessment, program, or account. These service communications are part of delivering the services you have requested.

Where you subscribe to our newsletter or other updates, you may unsubscribe at any time using the link in those messages or by contacting us. Unsubscribing from marketing communications does not stop service communications relating to an active program.

We do not use healthcare information to target marketing.

We retain personal information only for as long as necessary for the purposes described in this policy, including to deliver services, maintain records of our engagements, meet legal, regulatory, professional, tax, and accounting obligations, and establish or defend legal claims.

Retention periods vary by category. Assessment information from inquiries that do not proceed is retained for a shorter period than records relating to a completed program engagement. Healthcare-related information is retained in line with the purpose for which it was collected and applicable requirements.

When information is no longer required, we take steps to delete it or render it no longer attributable to you.

We apply administrative, technical, and organizational measures designed to protect personal information against unauthorized access, disclosure, alteration, and loss. These measures include limiting internal access to personnel with a legitimate operational need, applying access controls to systems holding client information, and applying heightened handling practices to sensitive information.

No method of transmission or storage is completely secure. While we take reasonable steps to protect personal information, we cannot guarantee absolute security. You also play a role: please avoid sending sensitive information through unsecured channels, and let us know promptly if you believe your information has been compromised.

We maintain procedures for identifying, assessing, and responding to security incidents affecting personal information.

Where a breach of security affecting personal information occurs, we will assess the incident and, where required by applicable law, notify affected individuals and the relevant authorities within the timeframes those laws require.

Depending on your location and the applicable law, you may have rights in relation to your personal information, including to:

• Be informed of how your personal information is used
• Request access to the personal information we hold about you
• Request correction of inaccurate or incomplete information
• Request deletion of your information in certain circumstances
• Object to or request restriction of certain processing
• Withdraw consent where processing is based on consent, without affecting processing already carried out
• Request a copy of certain information in a portable format, where applicable
• Lodge a complaint with the relevant data-protection or consumer-protection authority

To exercise these rights, contact us using the details in Section 20. We may need to verify your identity before responding, and some rights are subject to legal, contractual, and professional limitations, for example where we are required to retain records.

Individuals in Kenya may also lodge a complaint with the Office of the Data Protection Commissioner.

Our services are directed to adults. We do not knowingly collect personal information directly from children through our websites or assessments.

Our programs frequently involve families. Where an adult provides information about a child or another family member in connection with a program, for example education, healthcare, or relocation planning, that information is treated in line with this policy, and information about a child is treated with heightened care.

If you provide information about another person, you confirm that you are entitled to do so.

If you believe a child has provided us with personal information directly, please contact us and we will take appropriate steps.

Our websites may link to third-party websites and services that we do not control, including insurance, travel-health, and information resources. We provide these links for convenience. We are not responsible for the content, privacy practices, or security of third-party sites, and this policy does not apply to them. Please review their privacy policies before providing information.

We may update this policy from time to time to reflect changes in our services, operations, technology, or legal requirements. The Last Updated date at the top of this page indicates when it was most recently revised.

Where changes are material, we will take reasonable steps to bring them to your attention. We encourage you to review this policy periodically.

For privacy-related questions, requests, or complaints, contact us:

United States

• Phone: +1-800-816-5587
• Email: info@tverze.com

Kenya

• Email: info@tverze.com
• Email: admin@tverze.com
• Nairobi, Kenya

Please mark privacy requests clearly so they can be routed appropriately. We will respond within the timeframes required by applicable law.