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.
1.4 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“). The service data may include your responses to our survey including your geographic area of work and job department and also responses made by one of your colleagues naming you in the free text sections of our survey. The source of the service data is you, your colleague 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|
|AWS||Personal data outlined in Section 2||Website hosting|
|Hubspot||Marketing||Customer relationship data|
|Usage||Google Analytics service|
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.
11. About cookies
11.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
11.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
11.3 Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
12. Cookies that we use on our website
|Strictly necessary cookies: These cookies are necessary for our website to function and cannot be switched off using our cookie preference tool. They are usually only set in response to actions made by you which amount to a request for services, such as setting your cookie preferences, logging in to your account, or filling in forms. These cookies do not store any personally identifiable information.You can set your browser to block or alert you about this type of cookies, but some parts of our website will not then work.|
|Cookie name||Description||Expiry||1st/3rd party|
|_grecaptcha||This cookie is used to distinguish between humans and bots. This is beneficial for the website, in order to make valid reports on the use of the website.||Persistent||1st party – culture15.com|
|_GRECAPTCHA||This cookie is used to distinguish between humans and bots. This is beneficial for the website, in order to make valid reports on the use of the website.||179 days||3rd party – Google.com|
|CookieConsent||Stores the user’s cookie consent state for the current domain||1 year||1st party – culture15.com|
|cookielawinfo-checkbox-advertisement||Used to detect if the visitor has accepted the marketing category in the cookie banner. This cookie is necessary for GDPR-compliance of the website.||1 year||1st party – culture15.com|
|cookielawinfo-checkbox-analytics||Used to detect if the visitor has accepted the statistics category in the cookie banner. This cookie is necessary for GDPR-compliance of the website.||1 year||1st party – culture15.com|
|cookielawinfo-checkbox-functional||Determines whether the user has accepted the cookie consent box.||1 year||1st party – culture15.com|
|cookielawinfo-checkbox-necessary||Determines whether the user has accepted the cookie consent box.||1 year||1st party – culture15.com|
|cookielawinfo-checkbox-performance||Store’s the user’s cookie consent state for the current domain.||1 year||1st party – culture15.com|
|cookielawinfo-checkbox-others||Store’s the user’s cookie consent state for the current domain.||1 year||1st party – culture15.com|
|elementor||Used in context with the website’s WordPress theme. The cookie allows the website owner to implement or change the website’s content in real-time.||Persistent||1st party – culture15.com|
|rc::a||This cookie is used to distinguish between humans and bots. This is beneficial for the website, in order to make valid reports on the use of their website.||Persistent||3rd party – Google.com|
|rc::b||This cookie is used to distinguish between humans and bots.||Session||3rd party – Google.com|
|rc::c||This cookie is used to distinguish between humans and bots.||Session||3rd party – Google.com|
|rc::d-#||Tis cookie is used to distinguish between humans and bots.||Persistent||3rd party – Google.com|
|Performance cookies: These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our website. They help us to know which pages are the most and least popular and see how visitors move around our website. All information these cookies collect is aggregated and therefore anonymous.If you do not allow these cookies we will not know when you have visited our website and will not be able to monitor its performance.|
|Cookie name||Purpose||Expiry||1st or 3rd party|
|_ga||Registers a unique ID that is used to generate statistical data on how the visitor uses the website.||2 years||1st party – culture15.com|
|_gat||Used by Google Analytics to throttle request rate.||1 day||1st party – culture15.com|
|_gid||Registers a unique ID that is used to generate statistical data on how the visitor uses the website.||1 day||1st party – culture15.com|
|Functional cookiesThese cookies enable our website to provide enhanced functionality and personalisation and to recognise you when you return to our website. This enables us to personalise our website content for you and remember your preferences (for example, your choice of language or region). They may be set by us or by third party providers whose services we have added to our website. If you do not allow these cookies, then some or all of these services may not function properly.|
|Cookie name||Purpose||Expiry||1st or 3rd party|
|CookieConsentBulkSetting-#||Enables cookie consent across multiple websites||Persistent||1st party – culture15.com|
13. Cookies used by our service providers
13.2 These services include Google Analytics.
13.3 Where these services involve the setting of third party cookies, the providers are identified in the table in the ‘Cookies that we use on our website’ section above.
14. Managing cookies
14.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
( a ) https://support.google.com/chrome/answer/95647 (Chrome);
( c ) https://help.opera.com/en/latest/security-and-privacy/ (Opera);
( d ) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
14.2 Blocking all cookies will have a negative impact upon the usability of many websites.
14.3 If you block cookies, you will not be able to use all the features on our website.
15.1 We may update this policy from time to time by publishing a new version on our website.
15.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
16. Our details
16.1 This website is owned and operated by Culture15 Limited.
16.2 We are registered in England and Wales under registration number 13171909, and our registered office is at Friars House, 2 Friars Lane, Richmond upon Thames, TW9 1NL.
16.3 Our principal place of business is at Friars House, 2 Friars Lane, Richmond Upon Thames TW9 1NL.
16.4 You can contact us:
( a ) by post, to the postal address given above;
( b ) using our website contact form;
( c ) by telephone, on the contact number published on our website; or
( d ) by email on email@example.com.
16.5 Our data protection registration number is ZB082052