Last Updated 15 June 2020
This Privacy Notice (“Privacy Notice”) sets out how Culturevist Limited processes your personal data in connection with the Culturevist website, apps and platform (together the “Sites”), and the provision of our Culturevist services (together the “Services”).
This Privacy Notice applies to all users of the Services including Users and Authorised Users (as defined in the User Terms of Service) and Providers and Specialists (as defined in the Provider Terms).
1 Purpose of this privacy notice
This Privacy Notice explains our approach to any personal data that we might collect from you or which we have obtained about you from a third party, and the purposes for which we process your personal data. This Privacy Notice also sets out your rights in respect of our processing of your personal data.
When we talk about “personal data”, we mean any information which relates to an identified or identifiable living individual. Individuals might be identified by reference to a name, an identification number, location data, an online identifier (such as an IP address) or to other factors that are specific to them, such as their physical appearance.
This Privacy Notice informs you of the nature of the personal data about you that is processed by us and how you can request that we delete it, update it, transfer it and/or provide you with access to it.
This Privacy Notice is intended to assist you in making informed decisions when using the Sites and our Services. Please take a moment to read and understand it. It should be read in conjunction with our User , and/or Provider Terms as applicable, incorporated when you register for our Services, and our .
This Privacy Notice only applies to the use of your personal data obtained by us. It does not apply to personal data collected by third parties during your communications with those third parties or your use of their products or services (for example, when a User and Provider engage directly with each other for the provision of Provider Services (see User Terms of Service), or where you follow links to third party websites over which we have no control). See Sections 10 on Third Party Links and Services and Section 11 on Sharing Personal Data, below for more details.
2 About us
The Sites and our Services are made available by Culturevist Limited of , Company number (“Culturevist”, “we”, “us, “our”). Culturevist Limited is the data controller responsible for your personal data.
3 How to contact us
If you have any questions about this Privacy Notice or want to exercise your rights set out in this Privacy Notice, you can contact us by:
- using the on our Site.
- sending an email to email@example.com.
- writing to Culturevist, 69-75 Thorpe Road, Norwich, NR1 1UA, United Kingdom.
4 What personal data we collect
In the course of providing you with Sites and Services, we may collect the following types of personal data about you:
- Contact Data, such as your:
- email address;
- telephone number;
- social media handle; and
- the name of your organisation;
- Registration Data, such as your:
- first name and last name;
- date of birth;
- any KYC information that we may collect; and
- any other personal data you may provide when you register or open an account with us;
- Payment Data, such as your:
- bank and account details; and
- information relating to a particular transaction;
- Profile Data, such as:
- your username;
- your profile picture;
- your interests and preferences;
- your contact preferences;
- whether you have participated in any promotions or competitions;
- information about any of our events that you have attended; and
- the content of any messaging you send using the chat and messaging function on the Sites;
- Behavioural Data, such as:
- when your current or previous sessions started; and
- details about any products you viewed or purchased through the Sites; and
- Technical Data, such as your:
- IP address;
- browser type and operating system;
- geolocation, to ensure we’re showing you the correct notices and information; and
- any other unique numbers assigned to a device.
5 How we collect and receive personal data
We collect and receive personal data using different methods:
- Personal data you provide to us.
- You may give us your personal data directly. This will be the case when, for example, you register to use the Site or receive the Services, complete forms on our Sites, sign up to receive our marketing communications or provide feedback to us.
- Personal data we collect using cookies and other similar technologies.
When you access and use our Sites, we will collect certain Behavioural Data or Technical Data. We collect this personal data by using cookies and other similar technologies (see the ‘Insight, analysis and retargeting through Cookies’’ section below).
- Personal data received from third parties.
From time to time, we will receive personal data about you from third parties. Such third parties may include analytics providers, data brokers, payment providers and third parties that provide technical services to us so that we can operate our Sites and provide our Services.
Publicly available personal data.
From time to time we may collect personal data about you (Contact Data or Profile Data) from publicly available sources (including open source data sets).
6 Who we collect personal data about
We collect and process personal data from the following people:
- Site visitors.
If you browse our Sites, register to use the Services, contact us with an enquiry through our Sites, submit a complaint through our Sites or otherwise use any Services available on our Sites, we will collect and process your personal data in connection with your interaction with us and our Sites.
- Registered users.
If you sign up or register to use the Site or receive the Services from us, we may collect and process your personal data in connection with the supply of services to you.
- Personnel or users that work for a registered user or who otherwise access the Services under the authorisation of a registered user.
If you access the Services on behalf of another person or entity, we may collect and process your personal data in connection with your receipt of those services as above.
7 How we use your personal data
We use your personal data for the following purposes:
- Fulfilment of our Services including connecting you with others.
We collect and maintain personal data that you submit to us for the purpose of supplying Services that you have requested from us. We may collect and process your personal data whether you are interacting with us on your own behalf or on behalf of any organisation you represent.
The personal data we process may include your Contact Data, Registration Data, and Payment data (where applicable). We process this information so that we can fulfil the supply of Services, maintain our user databases and to keep a record of how our Services are being used.
Our use of your personal data by us may also involve us providing it to other users of the Service with whom you wish to connect. We will only do this where you specifically request us to make such a connection with another user, and only for those purposes. See Section 10 on Third Party Links and Services and Section 11 on Sharing Personal Data below for more details.
Our legal basis for processing
It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you, or it is in our legitimate interest or a third party’s legitimate interest to use personal data in such a way to ensure that we provide the Services in an effective, safe and efficient way.
- Use of our Sites.
We collect and maintain personal data that you submit to us during your use of our Site in the following ways
- Registering and accessing your account.
Our Sites and Services may enable or require you to register with us in order to gain access to additional features or services. We may ask users to complete a registration form, providing a username, email address and password as well as certain other Registration Data.
We will use your personal data in order to create and maintain your account. Once you are registered, we will process your username and password to identify you when you login to your account and the secure areas of our Sites. We will also process your login information and certain Technical Data, so that we can administer your account and contact you about your account.
Our legal basis for processing
It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you for the relevant Services, or it is in our legitimate interest or a third party’s legitimate interest to use personal data in such a way to ensure that we provide the relevant Services requested by you and others in a secure and effective way.
Linking to social media sites and interacting with our social media pages,
If you click on one of the social media links on our Sites or otherwise interact with our social media pages such as on Facebook or Instagram (including interacting with any ‘like’ or similar embedded features on our Sites or social media accounts) we and the relevant social media platform may receive information relating to such interaction and may share your personal data in connection with this purpose, such as certain Behavioural Data and Technical Data. For more information about how we use this personal data, please see the ‘Insight, analysis and retargeting through Cookies’ section below.
Our legal basis for processing
It is in our legitimate interest or a third party’s legitimate interest to use personal data in such a way to ensure that we provide the Site and our Services in an effective way and to promote our Site and our Services via social media.
- Customer service and general enquiries.
Our Sites feature a “Contact” page which may invite you to submit general enquiries about our Sites and our Services by email, telephone, message, or via a “live chat” function.
You may also be able to submit specific enquiries on other pages of our Sites in relation to particular Services offered via those pages.
When you make an enquiry, we will collect and process your Contact Data and certain Profile Data, as well as any other personal data that is relevant to your enquiry. We use this information to manage and respond to your enquiry.
Our legal basis for processing
It is in our legitimate interest to use your personal data in the ways described above to ensure that we are able to help you with your enquiry and provide a good standard of service to you.
- Surveys and feedback.
From time to time, we will invite you to provide feedback about us, our Sites or our Services in the form of online surveys etc. We will collect and process your Contact Data, certain Profile Data, and any other personal data you choose to volunteer in your survey response or other feedback.
We use this information to help us to monitor and improve our Sites, our Services and to assist with the selection of future product and service lines, and to train our personnel.
You can also voluntarily provide feedback by contacting our Customer Service team.
Our legal basis for processing
It is in our legitimate interest to use the personal data provided by you so that we can improve our Services and provide them in an effective way.
Prize draws, prize competitions and other promotions
From time to time, we may run prize draws, prize competitions and other promotions on our Sites and/or on our social media accounts. For the purposes of administering such draws, competitions and promotions, we may process your Contact Data, Payment Data (if relevant), Profile Data, and any other personal data volunteered by you in your prize draw, competition or promotion entry.
Our prize draw, competition and promotions may be subject to separate terms and conditions which you may be required to accept as a condition of entry.
Our legal basis for processing
It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you (e.g. the terms and conditions applicable to the prize draw, competition or promotions to which you may be asked to agree) or it is in our legitimate interest to use your personal data to enable us to administer the applicable prize draws, prize competitions or promotion.
- Insight, analysis and retargeting through Cookies.
emails that you receive from us). The data that is collected includes Behavioural Data and Technical Data, and certain Profile Data. our App[ and
Please see our for further information, including details of the third party partners that are used.
We and our third party partners use this data, in combination with your Contact Data, for the following purposes:
- for the purposes described in the ‘Online personalised advertising’ and the ‘Advertising to other people who share similar interests and characteristics to you’ sections below;
- to analyse how you use, and the effectiveness of, our Sites and Services, including:
- to count users who have visited our Sites or opened an email and collect other types of information, including insights about our visitors’ browsing habits, which helps us to improve our Sites, Services and the effectiveness of our emails;
- to measure the effectiveness of our content;
- to learn what pages of our Sites are most attractive to our visitors, which parts of our Sites are the most interesting and what kind of features and functionalities our visitors like to see; and
- to help us with the selection of future product and service lines, website design and to remember your preferences
In some of our email messages, we use a “click-through URL” linked to certain websites administered by us or on our behalf. We may track click-through data to assist in determining interest in particular topics and measure the effectiveness of these communications.
Our legal basis for processing
Where your data is collected through the use of non-essential cookies we rely on consent to collect your data. Please see our for further details.
Where we use this personal data for the purposes described in the ‘Online personalised advertising’ and ‘Advertising to other people who share similar interests and characteristics to you’ sections of this Privacy Notice, please see those sections to see the legal basis that we rely on.
Where we use this personal data to analyse how you use our Sites and Services, it is in our legitimate interest to use your personal data in such a way to improve our Site and our Services.
Advertising and Marketing activities.
We carry out the following marketing activities using your personal data:
- Email and SMS/MMS marketing.
We use your Contact Details to send you (or the organisation you represent) marketing communications by email, and to send you marketing communications by SMS/MMS. Our email and SMS/MMS marketing communications will include press releases and information as well as general information about our organisation, our Sites, the Services we provide and the events and promotions we offer.
Our email and SMS/MMS marketing will include personalised and non-personalised email marketing. Personalised marketing is marketing which has been specifically tailored to you. For example, our personalised email marketing will feature services, events, offers and/or promotions that we think are most likely to appeal to you. Non-personalised marketing is marketing about our services, events, offers and/or promotions generally and is not tailored to any particular individual.
Where we are sending you personalised email or SMS/MMS marketing, we also use Behavioural Data and other information that we observe about you from your interactions with our Sites, with our email communications to you, and/or with our Services in order to decide what sort of personalised marketing communications to send you. Please see the ‘Insight, analysis and retargeting through Cookies’ section above for more details about the personal data collected and how it is collected.
Our legal basis for processing
Where data that we process is anonymised, we do not require a legal basis to use it as the information does not constitute personal data. However, our collection and use of such anonymised information may be subject to other laws where your consent is required. Please see our for further details.
Where your personal data is not in an anonymous form (for example, your email address), it is in our legitimate interest to use your personal data for postal marketing purposes.
We will only send you marketing communications by email where you have consented to receive such communications, or where we have another lawful right to send such communications to you.
- Online personalised advertising.
We and our third party partners use may use your Behavioural Data, Profile Data and Technical Data and other data that is collected through your interactions with third party Sites and Services to provide you with, and analyse the effectiveness of, personalised ads when you visit other websites and/or use other services (including the social media and other platforms described in the Advertising to you on social media and other platforms section below).
By ‘personalised ads’, we mean advertisements for products and services that you have shown an interest in when you have used our Sites or which you otherwise might be interested in based on your browsing habits, although our third party partners may use the data that is collected to show personalised ads for products and services offered by third parties.
Our legal basis for processing
Where we use your personal data to display online personal advertising to you, we rely on the consent that you have provided in respect of the collection of such data, or it is otherwise in our legitimate interests to promote our Site and our Services to you.
- Business administration and legal compliance.
We use your personal data for the following business administration and legal compliance purposes:
- to comply with our legal obligations;
- to enforce our legal rights;
- to protect the rights of third parties; and
- in connection with a business transition such as a merger, reorganisation, acquisition by another company, or sale of all or a portion of our assets.
Our legal basis for processing
Where we use your personal data in connection with a business transition, to enforce our legal rights or to protect the rights of third parties, it is in our legitimate interest to do so. For all other purposes described in this section, we have a legal obligation to use your personal data to comply with any legal obligations imposed upon us such as a court order.
We will not process any special (or sensitive) categories of personal data or personal data relating to criminal convictions or offences except where we are able to do so under applicable legislation or with your explicit consent.
- Any other purposes for which we wish to use your personal data that are not listed above, or any other changes we propose to make to the existing purposes, will be notified to you using the contact details we hold for you.
8 How we obtain your consent
Where our use of your personal data requires consent, you can provide such consent:
• at the time we collect your personal data following the instructions provided; or
• by informing us using the contact details set out in the “How to Contact Us” section above.
Our Sites may use certain cookies, web beacons, pixel tags, log files and other technologies. Please see our to find out more about the cookies and other similar technologies we use, the purposes for which we use them and how to manage, block or delete them.
10 Third party links and services including provider services.
This Privacy Notice will only apply to your interaction with third parties, including Providers, directly on the Site or via the Services. Providers and other third parties may have further terms and privacy policies that also apply to their use of your personal data.
- Our Service may connect you with third party Providers, and our Sites may also contain links to third party websites and services.
For more on how we share your data with Providers see Section 11 on Sharing Personal Data.
When you use a link to go from our Sites to another website (even if you don’t leave our Sites) or you request a service from a third party including a Provider, this Privacy Notice shall not apply to the processing of your personal data carried out by the relevant third party provider.
Your browsing and interactions on any other websites, or your dealings with any other third party service provider, is subject to that website’s or third party service provider’s own rules and policies. When you click on the links we provide to such platforms, you will be transferred from our website to the relevant platform and the privacy notice (and other terms and conditions) of that platform will apply to you.
We do not monitor, control or endorse the privacy practices of any third parties.
We encourage you to become familiar with the privacy practices of every website you visit or third party service provider that you use in connection with your interaction with us and to contact them if you have any questions about their respective privacy notices and practices.
This Privacy Notice applies solely to personal data processed by us through your use of our Sites, your receipt of our Services and/or in connection with our business operations. It does not apply to the processing of your personal data by these third party websites and third party service providers.
11 Sharing personal data
We will only share personal data with others when we are legally permitted to do so. This is mainly to (i) other Users or Providers on the Service; or (ii) companies that we contract with to help us run the technical functionality of the platform (not including Providers).
(i) Our use of your personal data by us may involve us providing it to other users of the Service with whom you wish to connect including Providers and other Users (see User Terms of Service and Provider Terms as applicable for more details). This includes: when a User makes an order of Product(s) from a Provider, the User’s name and billing address are provided to the Provider, together with any add-on information entered by user (e.g. any relevant context, the names and roles of the people who will be participating in the call or class, etc.). We will only do this where you specifically request us to make such a connection with another Provider or User, and only for those purposes. See also section 10 on Third Party Links and Services. When a User messages another User or Provider (either directly, or on a community/discussion forum), their name and message are provided. When Users join group calls or sessions, their name and any comments they make may be visible to other participants. When applying to become a Provider, we may share your name with other Users for references.
(ii) Otherwise, we share personal data with other businesses who provide us with functionality to run our platform, as further detailed below. In doing so, we put contractual arrangements and security mechanisms in place to protect the personal data shared and to comply with our data protection, confidentiality and security standards and obligations.
Payment providers and banks: We share personal data with third parties who assist us with the processing of payments and refunds.
Advertising partners. Wemay share personal data with the third party advertising partners, including those set out in our Cookies Policy when you use our Sites. This data is used to provide you with, and measure the effectiveness of, online personalised advertising and for other advertising related activities.
Third-party email marketing and CRM specialists: We share personal data with specialist suppliers who assist us in managing our marketing database and sending out our email marketing communications and membership-related communications.
Third-party organisations that assist us with the administration of our promotions: We may share personal data with specialist suppliers who assist us in administering our prize draws, prize competitions and other promotions.
Auditors, lawyers, accountants and other professional advisers: We share personal data with professional services firms who advise and assist us in relation to the lawful and effective management of our organisation and in relation to any disputes we may become involved in.
Law enforcement or other government and regulatory agencies and bodies: We share personal data with law enforcement or other government and regulatory agencies or other third parties as required by, and in accordance with, applicable law or regulation.
Sharing with other third parties: Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, or to establish, exercise or defend legal rights. We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.
This list is non-exhaustive and there may be circumstances where we need to share personal data with other third parties in order to operate our Sites and to provide our Services.
12 Transfers outside the European economic area (“EEA”) and the UK
Where necessary in order to operate our Sites and to otherwise deliver our Services, we will transfer personal data to countries outside the UK and the EEA.
Non-EEA countries do not have the same data protection laws as the UK and the EEA. In particular, non-EEA countries may not provide the same degree of protection for your personal data, may not give you the same rights in relation to your personal data and may not have a data protection supervisory authority to help you if you have any concerns about the processing of your personal data. However, when transferring your personal data outside the UK or the EEA, we will comply with our legal and regulatory obligations in relation to your personal data, including having a lawful basis for transferring personal data and putting appropriate safeguards in place to ensure an adequate level of protection for the personal data.
We will take reasonable steps to ensure the security of your personal data in accordance with applicable data protection laws.
When transferring your personal data outside the UK or the EEA, we will ensure that, where required by applicable law, at least one of the following safeguards is implemented:
Adequacy decisions: We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en.
Model clauses: Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.
EU-U.S. Privacy Shield: Where we have partners or suppliers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/eu-us-privacy-shield_en.
Please contact us if you would like further information on the specific mechanisms used by us when transferring your personal data outside the UK or the EEA.
13 How long we keep your personal data
In respect of personal data that we process in connection with the supply of our Services, we may retain your personal data for up to six years from the date of supply of the relevant Services and in compliance with our data protection obligations. We may then destroy such files without further notice or liability.
In respect of any other personal data that we process, we will retain relevant personal data for up to three years from the date of our last interaction with you and in compliance with our data protect obligations. We may then destroy such files without further notice or liability.
If any personal data is only useful for a short period (e.g. for a specific event or marketing campaign or in relation to recruitment), we will not retain it for longer than the period for which it is used by us.
If you have opted out of receiving marketing communications from us, we will need to retain certain personal data on a suppression list indefinitely so that we know not to send you further marketing communications in the future.
14 Confidentiality and security of your personal data
We are committed to keeping the personal data you provide to us secure and we will take reasonable precautions to protect your personal data from loss, misuse or alteration.
We have implemented information security policies, rules and technical measures to protect the personal data that we have under our control from:
• unauthorised access;
• improper use or disclosure;
• unauthorised modification; and
• unlawful destruction or accidental loss.
All our employees and data processors (i.e. those who process your personal data on our behalf, for the purposes listed above) who have access to and are associated with the processing of personal data are obliged to respect the confidentiality of the personal data of all users of our Sites and our Services.
15 Personal data of children
We do not specifically target our Sites or our Services at children. However, due to the nature of our organisation and the Services we provide, we may from time to time collect and process personal data relating to individuals under the age of 18. Where we do so, we will comply with all applicable laws and regulations relating to the processing of personal data of minors. However, if you are under the age of 13, you must ask a parent or guardian for permission before using our Sites and our products and services. If you are a parent or guardian, please supervise your child’s use of our Sites and our Services.
16 How to access your information and your other rights
You have the following rights in relation to the personal data we hold about you. If you would like to exercise any of these rights, please contact us using the details set out in the ‘How to contact us’ section above.
Your right of access.
If you ask us, we will confirm whether we are processing your personal data and, if so, provide you with a copy of that personal data (along with certain other details). If you require additional copies, we may charge a reasonable fee for producing those additional copies.
Your right to rectification.
If the personal data we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If we have shared your personal data with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we will also tell you who we’ve shared your personal data with so that you can contact them directly.
Your right to erasure.
You can ask us to delete or remove your personal data in some circumstances, such as where we no longer need it or where you withdraw your consent (where applicable). If we have shared your personal data with others, we will let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal data with so that you can contact them directly.
Your right to restrict processing.
You can ask us to ‘block’ or suppress the processing of your personal data in certain circumstances such as where you contest the accuracy of that personal data or you object to us processing it for a particular purpose. This may not mean that we will stop storing your personal data but, where we do keep it, we will tell you if we remove any restriction that we have placed on your personal data to stop us processing it further. If we’ve shared your personal data with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal data with so that you can contact them directly.
Your right to data portability.
You have the right, in certain circumstances, to obtain personal data you have provided to us (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer it to a third party of your choice.
Your right to object.
You can ask us to stop processing your personal data, and we will do so, if we are:
- relying on our own or someone else’s legitimate interest to process your personal data, except if we can demonstrate compelling legal grounds for the processing; or
- processing your personal data for the purposes direct marketing.
Your rights in relation to automated decision-making and profiling.
You have the right not to be subject to a decision when it is based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for the entering into, or the performance of, a contract between you and us.
Your right to withdraw consent.
If we rely on your consent (or explicit consent) as our legal basis for processing your personal data, you have the right to withdraw that consent at any time. You can exercise your right of withdrawal by contacting us using our contact details in the “How to Contact Us” section above or by using any other opt-out mechanism we may provide, such as an unsubscribe link in an email.
Your right to lodge a complaint with the supervisory authority.
If you have a concern about any aspect of our privacy practices, including the way we have handled your personal data, please contact us using the contact details provided in the “How to Contact Us” section above. You can also report any issues or concerns to a national supervisory authority in the Member State of your residence or the place of the alleged infringement. You can find a list of contact details for all EU supervisory authorities at: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. As we are incorporated in the UK, our regulatory authority is https://ico.org.uk.
17 Changes to this privacy notice
We may make changes to this Privacy Notice from time to time.
To ensure that you are always aware of how we use your personal data, we will update this Privacy Notice from time to time to reflect any changes or proposed changes to our use of your personal data. We may also make changes to comply with changes in applicable law or regulatory requirements.
We will notify you by e-mail of any significant changes to this Privacy Notice. However, we encourage you to review this Privacy Notice periodically to be informed of how we use your personal data.