PRIVACY POLICY - WORKCULTURATI SARL-S

 

 

INTRODUCTION  

 

We respect your privacy and are committed to protecting your personal data. This Privacy Policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. 

  

1.  IMPORTANT INFORMATION AND WHO WE ARE  

 

PURPOSE OF THIS PRIVACY POLICY

 

This Privacy Policy aims to give you information on how we collect and process your personal data through your use of this website and your interactions with us, including any data you may provide through this website when you sign up to our newsletter, sign up for our free or paid services or offerings, or take part in a competition.

 

This website is not intended for children and we do not knowingly collect data relating to children.

 

It is important that you read this Privacy Policy together with any other privacy policy or notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other policies or notices and is not intended to override them.

 

CONTROLLER  

 

Workculturati SARL-S is the controller and responsible for your personal data (collectively referred to as “we”, “us” or “our” in this Privacy Policy).

  

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

 

CONTACT DETAILS  

 

Our contact details are set out in table 1below:

 

Table 1
 

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You have the right to make a complaint at any time to the National Commission for Data Protection (“CNPD”), Luxembourg’s supervisory authority for data protection issues (https://cnpd.public.lu/en.html). We would, however, appreciate the chance to deal with your concerns before you approach the CNPD so please contact us in the first instance.

 

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES  

 

This version was last updated in October 2021.

  

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

 

THIRD-PARTY LINKS  

 

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

 

2.  THE DATA WE COLLECT ABOUT YOU  

 

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

 

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together in table 2 below:

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Table 2

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We also collect, use and share Aggregated Datasuch as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does notdirectly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

 

We do not collect any Special Categories of Personal Dataabout you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

 

IF YOU FAIL TO PROVIDE PERSONAL DATA  

 

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with products or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

 

3.  HOW IS YOUR PERSONAL DATA COLLECTED?  

 

We use different methods to collect data from and about you, as set out in table 3 below:

 

Table 3

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4.  HOW WE USE YOUR PERSONAL DATA  

 

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

 

• where you have consented for us to do so;

• where we need to perform the contract we are about to enter into or have entered into with you;

• where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;

• where we need to comply with a legal or regulatory obligation.

 

See table 4 below to find out more about the types of lawful basis that we will rely on to process your personal data. 

 

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA  

 

We have set out below in table 4 descriptions of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

 

Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us via email at hello@workculturati.com or via the contact page on our website if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in table 4 below:

 

Table 4

 

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MARKETING  

 

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

 

PROMOTIONAL OFFERS FROM US  

 

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

 

You will receive marketing communications from us if you have requested information from us or purchased products or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

 

THIRD-PARTY MARKETING  

 

We will get your express opt-in consent before we share your personal data with any company for marketing purposes.

 

OPTING OUT  

 

You can ask us or third parties to stop sending you marketing messages at any time by: 

 

• by following the opt-out or “unsubscribe” links on any marketing message sent to you; or 

• by contacting us via email at hello@workculturati.com or via the contact page on our website at any time.

 

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, service experience or other transactions.

 

COOKIES  

 

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy, which is available here.

 

CHANGE OF PURPOSE  

 

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us via email at hello@workculturati.com or via the contact page on our website.

 

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

 

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

 

5.  DISCLOSURES OF YOUR PERSONAL DATA  

 

We may have to share your personal data with the parties set out in table 5 below for the purposes set out in the table in paragraph 4 above.

 

Table 5

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We may also share your personal data with service providers who we engage to work with our business, including but not limited to those providing IT support, administrative support, and professional advice such as legal and financial advisers.

 

We may also share your personal data with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.

 

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

 

6.  INTERNATIONAL TRANSFERS  

 

To deliver services to you, it is sometimes necessary for us to share your personal data outside the UK. Under data protection law, we can only transfer your personal data to a country or international organisation outside the UK where:

 

• the UK government or, where the EU GDPR applies, the European Commission, has decided the particular country or international organisation ensures an adequate level of protection of personal data (known as an ‘adequacy decision’);

• there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for data subjects; or

• a specific exception applies under data protection law.

 

Please contact us via email at hello@workculturati.com or via the contact page on our website if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

 

7.  DATA SECURITY  

 

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

 

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

8.  DATA RETENTION  

 

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?  

 

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

 

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

 

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six (6) years after they cease being customers for tax purposes.

 

In some circumstances you can ask us to delete your data: see clause 9.3below regarding Request erasurebelow for further information.

 

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

 

9.  YOUR LEGAL RIGHTS  

 

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see below to find out more about these rights:

 

9.1 Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

 

9.2 Request correction of your personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

 

9.3 Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see clause 9.4below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

 

9.4 Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

 

9.5 Request restriction of processing your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: 

a) if you want us to establish the data’s accuracy; 

b) where our use of the data is unlawful, but you do not want us to erase it; 

c)where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or 

d) you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

 

9.6 Request transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

 

9.7 Right to withdraw consent any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

 

If you wish to exercise any of the rights set out above, please contact us via email at hello@workculturati.com or via the contact page on our website.

 

NO FEE USUALLY REQUIRED  

 

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

 

WHAT WE MAY NEED FROM YOU  

 

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

 

TIME LIMIT TO RESPOND  

 

We try to respond to all legitimate requests within one month from receiving the request from you. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated on expected timeframes.