Privacy policy

01Interpretation and definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

• For the purposes of this Privacy Policy:
• Account means a unique account created for You to access our Service or parts of our Service.
• Affiliate means an entity that controls, is controlled by or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
• Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to SlashData Limited, which provides Rethink Culture, a company registered in England and Wales under number 05614666, Swan Buildings (1st Floor), 20 Swan Street, Manchester, M4 5JW, United Kingdom.
• Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
• Country refers to: United Kingdom
• Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
• Personal Data is any information that relates to an identified or identifiable individual.
• Service refers to the Website and to the Rethink Culture platform, including the dashboard at dashboard.rethinkculture.co and the surveys We run for Our clients.
• Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
• Website refers to Rethink Culture, accessible from rethinkculture.co
• You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

02Collecting and using your personal data

Types of data collected

Personal data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

• Email address
• Name
• Company name
• job title
• Usage Data

Usage data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

All the above information is collected automatically, due to the way the world wide web works. The legal basis for the initial collection of this data is the Privacy and Electronic Communications Regulations 2003 (PECR), according to which technical storage or access is permitted, when the sole purpose is to carry out the transmission of a communication through an electronic communications network or when it is necessary for the provision of an information society service, which has been explicitly requested by the user. The legal basis for retaining your information is our legitimate interest in the proper and secure operation of our website and in understanding how it is used, through the statistics described below. You have the right to object to the retention of your information on grounds related to your particular situation, if your rights and freedoms override our legitimate interests or the necessity of collecting the data for the establishment, exercise or support of our legal claims. For how to exercise this right, see below under “rights”.

Tracking technologies and cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

Cookies or Browser Cookies. A cookie is a small file placed on Your Device.

Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Analytics Script. Our Website uses a small script from Umami, open-source analytics software that We run on Our own servers, to count visits and produce statistics about how the Website is used (for example, recording the popularity of a certain page). The script does not place Cookies on Your Device and does not track You across other websites. It sends Us Usage Data such as the page visited, the referring website, Your browser, operating system, Device type, screen size and language, and Your approximate location (country, region and city), which is derived from Your IP address. Your IP address itself is not stored. To count unique visitors, Your IP address and browser details are combined into a code that cannot be reversed and that changes every day. We use this information solely for statistical purposes.

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser. You can learn more about cookies on TermsFeed website article.

Our Website, rethinkculture.co, does not use Cookies.

Our dashboard, dashboard.rethinkculture.co, uses only the Cookies it needs to work. A sign-in Cookie (Persistent, lasting up to 30 days, administered by Us) keeps You signed in and helps prevent fraudulent use of Your Account. A security Cookie (Persistent, administered by Us) protects the dashboard’s forms against misuse by other websites.

These Cookies are strictly necessary to provide the service You have asked for, so We do not ask for Your consent to use them. You can set Your browser to refuse all Cookies, but You will then be unable to sign in to the dashboard.

03If you take part in a survey

If Your employer uses Rethink Culture to survey its workplace, Your employer decides to run the survey and is responsible for the survey data as controller. We process that data on Your employer’s behalf, on its instructions and under a written agreement with it.

Your employer gives Us Your work email address so that We can send You the survey, and may also give Us details about Your role, such as Your team, location, job level, length of service or age group. We do not ask Your employer for Your name. When You take part, We receive Your answers and any comments You write, together with Usage Data such as the device You use and how long the survey took.

We use this information to send You the survey and reminders, to check the quality of the responses and to produce results for Your employer. Your employer relies on its legitimate interest in understanding and improving its workplace culture.

Your employer receives only combined results for groups of at least five people, never Your individual answers. Written comments are shared with Your employer word for word but without Your name, so please do not include anything in them that could identify You.

We also combine answers from all the organisations that use Rethink Culture into average scores, so that each organisation can compare itself with others. These averages never show anyone’s individual answers or name any organisation. We do this as controller, on the basis of Our legitimate interest in providing meaningful comparisons.

Taking part is voluntary, and You may leave any question unanswered. If You have questions about a survey, You can contact Your employer or Us.

04Use of your personal data

The Company may use Personal Data for the following purposes:

For our legitimate interest to provide and maintain our Service, including to monitor the usage of our Service.

For our obligation to manage Your Account as part of our service contract: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.

For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.

For our legitimate interest to contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.

For our legitimate interest to provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.

For our obligation to manage Your requests as part of our service contract or prior to entering into a service contract: To attend and manage Your requests to Us.

For our legitimate interest to undergo business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.

• For other purposes

We may share Your personal information in the following situations:

With Service Providers: We may share Your personal information with Service Providers that host the Service, deliver Our emails, host Our survey forms and provide AI services that help Us summarise survey results, as well as to monitor and analyze the use of our Service and to contact You. Service Providers process personal data only on Our instructions, and You can ask Us for their names.

For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.

With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us. In such a case you will be informed in advance, so that you can express your objection.

With business partners: When you specifically consent, We may share Your information with Our business partners to offer You certain products, services or promotions .

With Your consent: We may disclose Your personal information for any other purpose with Your consent.

05Retention of your personal data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for our legitimate interest to perform internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods. Usage Data collected for website statistics is deleted after 25 months.

For survey data, We keep participants’ contact details only for as long as needed to run the survey. We keep survey answers while the employer is Our client, so that it can compare one survey with the next, and for a limited period afterwards. After that, We delete them or keep them only as aggregated results that do not identify anyone.

06Transfer of your personal data

Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located.

We are based in the United Kingdom, which the European Commission recognises as providing an adequate level of protection for personal data. Some of Our Service Providers are located outside the European Economic Area and the United Kingdom, including in the United States. Where such a country does not have an adequacy decision, We transfer personal data only with the safeguards required by the GDPR, such as the European Commission’s Standard Contractual Clauses. You can ask Us for a copy of these safeguards at privacy@rethinkculture.co.

07What are your rights under the General Data Protection Regulation (GDPR)?

Right of access and rectification

You have the right to know whether the personal data concerning you have been or will be processed and in any case to demand from Us the correction of your personal data if it is inaccurate, or their completion in case of deficiencies. When updating your personal information, you may be asked to verify your identity before we can satisfy your request.

Right to portability

You may receive your personal data in electronic form. Your right applies to:

• A) if you provided them yourself
• B) either by giving your consent
• C) or to enter a contract with us.

You will receive them in a structured, commonly used and machine-readable format (i.e. in a type of electronic file widely used and easily readable by common software), as well as transmit them or request their transmission from us to another controller, provided that this does not adversely affect the rights and freedoms of other persons.

Right to erasure

Under the conditions of the law, you can request the deletion of your personal data, as well as in specific cases the restriction of the processing they undergo. Personal data that we are required to keep due to legal obligations cannot be deleted. Deletion of personal data necessary for the performance of a contract may lead to cancellation of the contract or inability to perform it.

Our Service may give You the ability to delete certain information about You from within the Service.

Right to object

You have the right to object at any time to the processing of data concerning you.

This right applies to you if the reason for their processing by us is our legitimate interest and you have an objection due to any of your particular circumstances (for personal, professional or social reasons).

You can also object to the collection of Usage Data for website statistics at any time, free of charge and without giving a reason, by emailing Us at privacy@rethinkculture.co or by turning on the “Do Not Track” setting in Your browser, which We respect.

Right to restriction of processing

You have the right to request the restriction of processing of your data.

This will apply if you contest the accuracy of your data and until we verify it, when you consider that the processing being done is unlawful, when we no longer need it, or when you have exercised your right to object.

Right to withdraw consent

When we process your personal data on the basis of the consent you have given us, you have the right to withdraw it freely, at any time, without retroactive effect, and without suffering any consequence on other services we provide to you for other reasons (eg under a contract that exists between us).

Right to complain

You have the right to lodge a complaint with a data protection authority, in particular in the country where You live or work, in case you consider that your data is being unlawfully processed. We recommend that you contact Us first to submit any complaint or request. You can do this free of charge by emailing Us. We will make every effort to satisfy your request. In case you are not satisfied with our response, you can submit your complaint to the authority. In the United Kingdom this is the Information Commissioner’s Office (Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, tel. 0303 123 1113, ico.org.uk).

How to exercise the above rights

For the exercise of your rights, as well as for any information regarding the processing of your personal data, you may submit a request to Us, at privacy@rethinkculture.co .

If You took part in a survey, You may also contact Your employer, which is responsible for the survey data. We will help Your employer respond to Your request.

We may need to ask you for your identification before responding to make sure that no one else is exercising your right.

As a rule, your request will be complied with within one month of receipt or, if it is particularly complex, you will be informed accordingly at least within one month of the delay that may be caused by the complexity of the request.

Information and all related responses to your requests are provided free of charge, unless they are excessive or repetitive.

08Disclosure of your personal data

Business transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability

09Security of your personal data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

10Children’s privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent’s consent before We collect and use that information.

11Links to other websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

12Changes to this privacy policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

13Contact us

If you have any questions about this Privacy Policy, You can contact us:

• By email: privacy@rethinkculture.co