Privacy Policy
1. Introduction
1.1 We are committed to safeguarding the privacy of our website visitors, service users, individual customers and customer personnel.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.
1.3 We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.
1.4 In this policy, “we”, “us” and “our” refer to Culture15 Limited. For more information about us, see Section 16.
2. The personal data that we collect
2.1 In this Section 2 we have set out the general categories of personal data that we process and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data.
2.2 We may process data enabling us to get in touch with you (“contact data“). The contact data may include your name, email address, telephone number and postal address. The source of the contact data is you and/or your employer.
2.3 We may process your Culture15 dashboard account data (“account data“). The account data may include your account identifier, name, email address, business name, account creation and modification dates, website settings and marketing preferences. The primary source of the account data is you and/or your employer, although some elements of the account data may be generated by our website.
2.4 We may process information relating to our customer relationships (“customer relationship data“). The customer relationship data may include your name, the name of your business or employer, your job title or role, your contact details, your classification/categorisation within our customer relationship management system and information contained in or relating to communications between us and you, or between us and your employer. The source of the customer relationship data is you and/or your employer.
2.5 We may process your personal data that is provided in the course of the use of our services and generated by our services in the course of such use (“service data“). We do not require any personal data to be submitted in connection with any responses in order to provide our services and therefore we have no intention of collecting personal data through our services. However, it is possible that either contained within the responses (through the free text options) or due to limited numbers of respondents or provision by your employer (our customer) of other data sets that may cross relate to respondents or for any other reason, information collected by Culture15 may be fall within the definition of personal data. The service data may include your responses to our survey including your geographic area of work and job department. The source of the service data is you, your colleague (for example where naming you in the free text sections of our survey) and/or your employer and/or generated by our services.
2.6 We may process information relating to transactions, including purchases of our services, that you enter into with us (“transaction data“). The transaction data may include your name, your contact details, your payment card details (or other payment details) and the transaction details. The source of the transaction data is you and/or our payment services provider.
2.7 We may process information contained in or relating to any communication that you send to us or that we send to you (“communication data“). The communication data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms.
2.8 We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system.
2.9 Please do not supply any other person’s personal data to us unless we prompt you to do so.
3. Purposes of processing and legal bases
3.1 In this Section 3, we have set out the purposes for which we may process personal data and the legal bases of the processing.
3.2 Operations – We may process your personal data for the purposes of operating our website, the processing and fulfilment of orders, providing our services, generating invoices, bills and other payment-related documentation, and credit control. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, services and business and the performance of a contract between your employer and us and/or taking steps, at your request, to enter into such a contract.
3.3 Relationships and communications – We may process contact data, account data, transaction data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post and/or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors, service users, individual customers and customer personnel, the maintenance of relationships, and the proper administration of our website, services and business.
3.4 Direct marketing – We may process contact data, account data and/or transaction data for the purposes of creating, targeting and sending direct marketing communications by email, SMS and post and making contact by telephone for marketing-related purposes. The legal basis for this processing is our legitimate interests, namely promoting our business and communicating marketing messages and offers to our website visitors and service users.
3.5 Research and analysis – We may process usage data, transaction data and/or service data for the purposes of researching and analysing the use of our website and services, as well as researching and analysing other interactions with our business. The legal basis for this processing is our legitimate interests, namely monitoring, supporting, improving and securing our website, services and business generally.
3.6 Record keeping – We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.
3.7 Security – We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.
3.8 Insurance and risk management – We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
3.9 Legal claims – We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
3.10 Legal compliance and vital interests – We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.
4. Providing your personal data to others
4.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
4.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.
4.3 The personal data that we collect and process will be stored on the servers of our hosting services provider, Amazon AWS.
4.4 We may disclose personal data to our suppliers or subcontractors as listed below:
| Supplier/ subcontractor | Type of personal data shared | Purpose of personal data sharing | Countries in which personal data is processed | Safeguard to protect transferred personal data | |
| AWS | Personal data outlined in Section 2 | Website hosting | EU & USA | Standard Contractual Clauses and UK Addendum | |
| Hubspot | Marketing | Customer relationship data | US | Standard Contractual Clauses and UK Addendum | |
| Usage | Google Analytics service | EU | |||
| Pendo | Personal data outlined in Section 2 | Product analytics service | EU | ||
| PostHog | Personal data outlined in Section 2 | Product analytics service | USA | Data Privacy Framework |
4.5 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4.6 We transfer Usage Data to Google, situated in the US, by means of cookies (please see Cookies section below). Such transfers are protected by appropriate safeguards, namely Standard Contractual Clauses. Other than that we will not transfer your personal data outside of the UK.
5. Retaining and deleting personal data
5.1 This Section 5 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
5.3 We will retain your personal data as follows:
( a ) contact data will be retained for the duration of your company’s/your employer’s plus a period of 6 years from the date of termination of such contract;
( b ) account data will be retained for the duration of your company’s/your employer’s plus a period of 6 years from the date of termination of such contract;
( c ) customer relationship data will be retained for a minimum period of 6 years following the date of termination of the relevant customer relationship and for a maximum period of 6 years following that date;
( d ) service data will be retained for the duration of your company’s/your employer’s plus a period of 6 years from the date of termination of such contract.
( e ) transaction data will be retained for the duration of your company’s/your employer’s contract with us plus a period of 6 years from the date of termination of such contract;
( f ) communication data will be retained for the duration of your subscription to our marketing communications plus 2 years from the end of your subscription; and
( g ) usage data will be retained for 2 years following the end of the subscription.
5.4 Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
6. Security of personal data
6.1 We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
6.2 We will store your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.
6.3 Data relating to your enquiries and financial transactions that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.
6.4 You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
6.5 You should ensure that your password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password you use for accessing our website confidential and we will not ask you for your password (except when you log in to your Culture15 dashboard).
7. Your rights
7.1 In this Section 7, we have listed the rights that you have under data protection law.
7.2 Your principal rights under data protection law are:
( a ) the right to access – you can ask for copies of your personal data;
( b ) the right to rectification – you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
( c ) the right to erasure – you can ask us to erase your personal data;
( d ) the right to restrict processing – you can ask us to restrict the processing of your personal data;
( e ) the right to object to processing – you can object to the processing of your personal data;
( f ) the right to data portability – you can ask that we transfer your personal data to another organisation or to you;
( g ) the right to complain to a supervisory authority – you can complain about our processing of your personal data; and
( h ) the right to withdraw consent – to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
7.3 These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
7.4 You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.
8. Third party websites
8.1 Our website includes hyperlinks to, and details of, third party websites.
8.2 In general we have no control over, and are not responsible for, the privacy policies and practices of third parties.
9. Personal data of children
Our website and services are targeted at persons over the age of 18. If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
10. Updating information
Please let us know if the personal information that we hold about you needs to be corrected or updated.
Addendum to Privacy Policy: California Consumer Privacy Act (CCPA) Compliance
Effective Date: October 2024
This addendum to our Privacy Policy applies to residents of California and supplements the information contained in our main Privacy Policy (“Privacy Policy”). This addendum is provided to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this addendum.
1. Categories of Personal Information Collected
We collect the categories of personal information set out in Section 2 of the Privacy Policy. “Personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, as further defined in the CCPA.
2. Purposes for Collecting Personal Information
We collect personal information for the purposes set out in Section 3 of the Privacy Policy.
3. Your Rights and Choices
Under the CCPA, California residents have specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Do Not Sell or Share My Personal Information
We will not sell personal information to any third party. For these purposes, “sell” means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by us to another business or a third party for monetary or other valuable consideration, as further defined in the CCPA.
4. Exercising Your Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
- Calling us using the details here: https://culture15.com/contact-us/
- Emailing us at hello@culture15.com
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may only make a verifiable consumer request for access or data portability twice within a 12-month period.
5. Contact Information
If you have any questions or comments about this addendum, the ways in which we collect and use your information described here and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
- Email: hello@culture15.com
- Postal Address: see https://culture15.com/contact-us/