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CULTURE AMP PRIVACY POLICY
PRIVACY POLICY
Looking for our Cookie Policy? View the Culture Amp Cookie Policy here.
Last updated: 1 July, 2020
This Privacy Policy explains how Culture Amp collects and handles your personal
information, and applies to all of our Services, which includes this website.
Through our product offerings, Customers and their employees have the ability to
provide organizational feedback and/or individual feedback within their
companies. We value your trust and take our privacy obligations seriously. We
have developed this Privacy Policy to provide you with clear answers to your
questions so you can understand how your personal information and data is
collected, held and processed by Culture Amp.
1. DEFINITIONS
In this Privacy Policy, a reference to:
* Administrator means any person who has log in credentials to a Customer
account to manage that account, create surveys, review and share survey
results, or manage the account to enable individual users to provide
feedback;
* Confidentiality Notice means the notice given to: (i) Respondents at the time
of answering a survey conducted by a Customer, including the degree of
confidentiality and/or anonymity that the Respondent will have when answering
a survey, or (ii) the notice given to Individual Feedback Users of our
individual feedback services, as applicable;
* Culture Amp, Culture Amp Group, we, us or our means Culture Amp Pty Ltd (ACN
138 600 987) of Level 2, 29 Stewart Street, Melbourne VIC 3121, Australia,
and any of its related bodies corporate;
* Customer or Company means, in relation to you, the person or entity that has
contracted with Culture Amp to allow you to use Culture Amp’s Services. The
Customer or Company will generally be your employer, or an identified
subgroup (i.e., division, department, etc.) within your employer;
* Continuous Feedback Messages means the messages that you send to another user
or that another user sends to you which are accessible through your Personal
Profile Page;
* Individual Feedback means the feature in our Services which allows
individuals to give performance related feedback to other individuals in
their Company, including Continuous Feedback Messages;
* Individual Feedback User means any person who has log in credentials to an
individual account within our Services to give Individual Feedback to, and
obtain Individual Feedback from, other users within their Company;
* Network means the in-application organizational network of Individual
Feedback Users within a Company;
* Personal Profile Page means the “my account” page within the Services which
is a personal page available to Individual Feedback Users of our performance
management services when they create an account;
* Personal Review Graphs means the graphs or charts displayed on your Personal
Profile Page created from Continuous Feedback Messages that other users have
provided to you;
* Platform Data means any content or data that you or third parties submit to
Culture Amp using the Services;
* Respondent means any person who accesses our Services to answer surveys
(either wholly or partially) conducted by Customer using the Services;
* Services means all products (including related mobile applications), services
and Websites offered by Culture Amp;
* Visitor means any person who visits our Websites;
* Websites means, collectively, www.cultureamp.com as well as the other
websites that Culture Amp operates and that link to this Privacy Policy; and
* You or your means either an Administrator, Respondent, Individual Feedback
User or Visitor, as applicable.
We may update this Privacy Policy from time to time and the most current version
will be posted on our website. If we make any material changes, we will notify
you by email (to the address associated with your account) or when you next log
in to your account prior to the change becoming effective. We encourage you to
periodically review this page for the latest information on our privacy
practices. If you have any questions or concerns about our Privacy Policy, or
with the handling of your personal information, please contact our Privacy
Officer at privacy@cultureamp.com.
2. A NOTE ABOUT CHILDREN
Unless permitted by applicable law, you must not permit any child under the age
of 16 with access to our Services. We do not intentionally gather personal
information from minors under the legal age range. If a minor submits personal
information to Culture Amp and we learn that the personal information is the
information of a child under the legal age range, we will attempt to delete the
information as soon as possible. If you believe that we may have any personal
information of a child under the legal age range, please contact Culture Amp at:
privacy@cultureamp.com.
3. WHAT INFORMATION DO WE COLLECT?
We collect information relating to you and your use of our Services from a
variety of sources. Some of this information is collected directly from you and
some of this information is collected from your interaction with our Services,
your Company, other individuals at your Company, or from third parties. How and
what information we collect about you will depend on the way that you use our
Services, for example, whether you are an Administrator, Respondent, an
Individual Feedback User or Visitor.
(A) INFORMATION WE GENERALLY COLLECT
* Contact information: When you provide us with your contact information,
whether through use of our Services, creation of an account, a form on our
website, or an interaction with our sales or customer support team, we
collect your contact information. This information may include, for example,
your name and email address.
* Usage information: We collect usage data about you whenever you interact with
our Services. This may include which web pages you visit, what you click on,
when you performed those actions, and other activities. Please see our Cookie
Policy for more information about the cookies we use in our Services.
* Device and browser data: We collect data from the device you use to access
our Services, such as your IP address, operating system, browser details and
time of visit. This information may also tell us your location.
* Cookies and page tags: We use third party tracking services that employ
cookies and page tags (also known as web beacons) to collect aggregated and
anonymous data about Visitors to our Websites. This data includes usage
details and user statistics. Please see our Cookie Policy for more
information about cookies and page tags we use on our Websites.
* Log data: We keep log files that record data each time a device accesses our
servers. The log files contain data about the nature of each access,
including the originating IP address. We may combine this automatically
collected log information with other information we collect about you. We do
this to maintain an audit trail of activity, to improve our Services, to
improve our marketing activities, for system analytics, or to monitor or
improve functionality.
* Referral data: If as a Visitor, you navigate to our Websites from an external
source (such as a link on another website or via an email), we record
information about the source that referred you to us.
* Other data you submit: We may collect your personal information or data if
you submit it to us in other contexts. For example, by giving us a
testimonial, attending an event we host or entering a contest. We may also
collect personal information at other points throughout our Services or
within our Website that states personal information is being collected. If
you contact us at support@cultureamp.com we will also collect any information
that you provide to us voluntarily, such as your operating system version,
and other requested information in order for us to respond to your request.
* Interacting with us on social media: We may collect personal information
about you when you interact with us using social media. For example, if you
post material to our Facebook page or Tweet us on Twitter.
* Third parties: We may collect your personal information or data from third
parties if you give permission to those third parties to share your personal
information with us or where you have made that information publicly
available online.
* Mobile devices: If you connect to the Services using a service provider that
uniquely identifies your mobile device, we may receive this identification
information to provide the Services to you.
(B) INFORMATION SPECIFIC TO ADMINISTRATORS, RESPONDENTS AND INDIVIDUAL FEEDBACK
USERS
We may collect the following information about Administrators, Respondents or
Individual Feedback Users:
* Information collected from your Company: The information that each Customer
provides to us is different. In most cases, your company will provide us with
demographic data such as your name, email information, and other information
related to your role within the Company, including your manager, direct
reports and your position within the Company’s organization chart. Some
Customers may provide us with additional demographic information so they can
better analyze and understand their survey results. In the event that you
are, or you become, part of a Network, your Company may request that we
create an account for you if you are not already an Individual Feedback User.
* Single sign-ons: If you choose to register or login using a third party
account (such as Google or your Company’s SSO provider), the authentication
of your login details are handled by that third party and we only collect the
information you expressly agree to share with us at the time you give
permission to link your Culture Amp account with the third party account. By
using a Google Single Sign-On account (or other supported SSO), you are
allowing us to access your Google (or other supported SSO) account
information.
* HRIS data: If the Customer uses a third-party human resource information
system (for example, Workday or BambooHR) to import information into
Services, we will also receive information from that third party (for
example, your name, email address, employment and demographic data).
* Survey responses: When you answer a Customer survey, we will store your
survey answers and comments.
(C) INFORMATION SPECIFIC TO INDIVIDUAL FEEDBACK USERS
We may collect or share the following information about Individual Feedback
Users:
* Profile page information: When an Administrator creates an account for you,
we may collect the following information from your Company, your name,
company name, email address, title and role within your Company, photograph,
and other organizational information, such as the person you report to and
your direct reports within the Company. When other individuals submit
feedback about you, we will also use that information to create graphs or
charts that will be displayed on your Personal Profile Page.
* Individual feedback: You may be asked by your Company to provide feedback for
other individuals employed by your Company and other individuals employed by
your Company may be asked to provide feedback for you (in each case, a
“Performance Review”). We may send you communications through the Services
requesting that you provide a Performance Review about another employee in
your Company. When you participate in providing Performance Reviews, other
individuals or your Company may be able to review certain information about
you, for example the content in the Performance Review. However, Continuous
Feedback Messages will only be viewable by you and the person you are sharing
Continuous Feedback Messages with.
* Your content: When you use the Services as an Individual Feedback User, we
will store any messages or content that you submit to us when you use this
portion of the Services, such as when you exchange Individual Feedback with
other individuals (including any messages, pictures, files and video) or
submit Performance Reviews, as well as when these messages or files were
sent.
(D) INFORMATION SPECIFIC TO ADMINISTRATORS
We may collect the following information about Administrators:
* Registration details: When you register an account or another Administrator
creates an account for you, we collect your name, company name, email
address, password and other information.
* Survey data: When you create and launch surveys using the Services, we will
store those survey questions and other information related to those surveys.
* Billing details: If you use a credit card for billing, our credit card
processor may collect information such as the cardholder’s name, billing
address, email address, credit card number, expiry date and credit card
security code.
* Account settings: You may be able to set or update various preferences and
personal details on your account settings page or your profile. For example,
your name, email address, default language or time zone.
(E) INFORMATION SPECIFIC TO USERS OF ONA NETWORK ANALYSIS
We may collect the following information about users of ONA network analysis:
If your Company elects to use our ONA network analysis tool, when you first
start using the Services and periodically thereafter, we will ask you to provide
the authentication token for your company email address or the authentication
token for your account on any instant messaging system that your Company uses
for business communications and that we support (“Supported Messaging System”)
(in each case, “Authentication Token”). You can choose not to participate.
Each time you (or another user) provides the Authentication Token for your (or
their) company email address or the Supported Messaging System, we will use the
Authentication Token to collect the last 90 days of email and calendar meta data
(consisting of the To, From, cc, bcc, and Timestamp Fields which we refer to as
“Meta Data”) from your (or their) company email address, or the Supported
Messaging System.
Your Meta Data or the Meta Data collected from other individuals at your Company
may also include communications made to and from third parties outside of your
organization.
We will use your Meta Data to determine the users within your Company that you
communicate with in order to create your Network. The Network is used to send
requests for Individual Feedback to the users within your Network. If another
user in your Company provides us with Meta Data, and you had communicated with
them, it may include your Meta Data also.
If you do not want your Meta Data being used as described in this section, you
must notify your Company to not enable ONA network analysis.
(F) INFORMATION SPECIFIC TO USERS OF THIRD-PARTY INTEGRATION OR SERVICE
A Customer may elect to use a third party with the Services (for example
Microsoft Teams). Culture Amp will not be responsible for any act or omission of
any third party, including such third party’s use of Platform Data. Culture Amp
does not warrant or support any such third party. You should contact the
relevant third party for any issues arising from your use of its services.
If a Customer elects to use a third party integration or service with the
Services, the Customer will be the “controller” and Culture Amp and the relevant
third party will respectively act as “processors”. See also Section 4 (Who is
the data controller or processor?).
When you use a third party with our Services, (a) any Platform Data within
Culture Amp’s control will be processed according to the terms of the agreement
between Customer and Culture Amp and this Privacy Policy, and (b) any Platform
Data within the third party’s control will be processed according to the terms
of the agreement(s) between Customer and such third party.
If a Customer, or any of its Administrators, Respondents, or Individual Feedback
Users wish to exercise their rights with respect to personal information or any
other Platform Data being processed by a third party, the Customer, as the
controller, must make the request with the relevant third party directly. If any
of the preceding parties wish to exercise their rights with respect to any
personal information being processed by Culture Amp, refer to Section 8 (What
are your rights to personal information?).
4. WHO IS THE DATA CONTROLLER OR PROCESSOR?
Data protection law in certain jurisdictions differentiates between the
“controller” and “processor” of information. For Administrators, Respondents and
Individual Feedback Users, your company, which is our Customer will be the
controller of your personal information and Culture Amp will be the processor.
For Visitors, Culture Amp will generally be the controller of your personal
information.
5. HOW DO WE HOLD THE INFORMATION WE COLLECT?
(A) SECURITY OF YOUR PERSONAL INFORMATION
The security of your personal information is very important to us. All your data
is private and confidential and we take reasonable steps to ensure that your
personal information is handled securely and in accordance with this Privacy
Policy. We follow generally accepted security standards, to protect the personal
information submitted to us, both during transmission and once it is received.
Culture Amp is ISO27001 certified.
However, please note that transmitting information over the Internet is never
completely secure. Although we do our best to protect your personal information,
we cannot guarantee that your personal information is absolutely secure in all
situations.
Security is a collaborative effort, so we also recommend that you create a
sophisticated password for logging in to our services and keep that password
secret.
If you suspect there has been any unauthorized access or misuse of your personal
information, immediately contact our Data Protection Officer at
privacy@cultureamp.com.
If you have any concerns about the security of our platform, contact our
Information Security Team at security@cultureamp.com.
(B) WHERE YOUR PERSONAL INFORMATION IS LOCATED
Our servers are based in the United States, so your personal information will
generally be processed and hosted in the United States. However, as some of our
offices and service providers are located outside of the United States, there
may be times when your personal information may be transferred, disclosed or
processed in another country, such as Australia, Ireland and the United Kingdom.
For example, if you contact our Customer Success team for support or questions,
any information you provide us in the support request (including personal
information such as your name and email address) will be processed and hosted in
Ireland by the service provider we use to manage support requests.
(C) EUROPEAN UNION OR SWISS USERS
If you live in the European Union, we will use the following safeguards to
transfer your personal information to a country not currently deemed adequate
under applicable data protection law:
* European Union Standard Contractual Clauses: Culture Amp offers the European
Union Standard Contractual Clauses (EU SCCs), also known as Model Clauses, to
meet the adequacy and security requirements for our Customers that operate in
the European Union, and other international transfers of information. We also
use the EU SCCs when we transfer your personal information to a member of the
Culture Amp Group located in a country not currently deemed adequate under
applicable data protection law. A copy of our standard data processing
addendum, incorporating the EU SCCs, is available on request.
6. HOW DO WE USE THE INFORMATION WE COLLECT?
(A) HOW WE USE YOUR PERSONAL INFORMATION
We use your personal information for a variety of purposes. How and what
information we collect about you will depend on the way that you use our
Services, for example, whether you are an Administrator, Respondent, Individual
Feedback User or Visitor. In each case, the information we collect and process
is reasonably necessary for our business, including providing you with the
Services you would expect from us.
(B) EUROPEAN UNION USERS
When you use our Services as an Administrator, Respondent or Individual Feedback
User, we process your personal information either:
* with your consent;
* to fulfill our contractual responsibility to deliver the Services to the
Customer; or
* to pursue Culture Amp’s legitimate interests of improving our Services or
developing new products and features.
When you use our Services as a Visitor, we process your personal information
either:
* with your consent; or
* to pursue Culture Amp’s legitimate interests of improving our Services or
developing new products and features.
(C) ADMINISTRATORS
When you use our Services as an Administrator, we may use your personal
information to:
* Create an account with us: We need to collect and use your personal
information to allow you to create an account and log in to that account.
* Provide you with our Services: This includes providing you with access and
use of our platform and customer support, which may require us to access your
personal information so that we can assist you, such as with survey design or
technical issues.
* Manage our Services: We use your personal information so we can provide our
Services and improve those Services. Some of these purposes include:
* monitor, maintain and improve our Services and features;
* personalize or customize your experience when you use our Services
(including presenting the Culture Amp platform in the best format for you
or a device you use to access the Culture Amp platform);
* create new services or features;
* enforce our contracts and policies when we are made aware of potential
breaches;
* prevent potentially illegal, undesirable or abusive activities;
* investigate complaints about you or made by you;
* make telephone calls to you, or send you SMS messages from time to time, as
part of secondary fraud protection; or
* respond to legal requests such as subpoenas, warrants or other mandatory
information requests.
* Contact you about the Services or your account: At times we may need to
contact you via email, mail or telephone to tell you about matters, such as
changes to our Services, terms or policies.
* Marketing purposes: We may also send you news and information about our
products or Services that you either request from us, or we believe may
interest you. In most cases, we will contact you via email. As part of our
marketing efforts, we may combine information about you from third party
sources with information we hold about you to create a user profile, which
will help us to make our sales and marketing efforts more relevant to you and
to personalize and improve your experience.
* Respond to legal requests and prevent harm: If we receive a legal request or
are informed of a situation that may cause harm, or potential harm, to
someone, we may need to inspect your personal information or data to respond
appropriately to that request or threat.
(D) RESPONDENTS OR INDIVIDUAL FEEDBACK USERS
When you use our Services as a Respondent or an Individual Feedback User, we may
use your personal information to:
* Create an account with us: We need to collect and use your personal
information to allow you to create an account and log in to that account.
* Provide our Services to the Customer: When and how we use your personal
information is controlled and managed by the Customer (including any
Administrators that act on its behalf).
* Manage our Services: We use your personal information so we can provide our
Services and improve those Services. Some of these purposes include:
* monitor, maintain and improve our Services and features;
* personalize or customize your experience when you use our Services
(including presenting our Services in the best format for you or a device
you use to access our Services);
* create new services or features;
* enforce our contracts and policies when we are made aware of potential
breaches;
* prevent potentially illegal, undesirable or abusive activities;
* investigate complaints about you, or made by you;
* send you a welcome email to verify ownership of the email address provided
when your account was created;
* send you an email when you have been assigned as an administrator of your
Company account;
* send you survey reminders;
* send you emails requesting you provide feedback on other individuals in
your Company or to notify you that you have received feedback from other
individuals in your Company;
* make telephone calls to you, or send you SMS messages from time to time, as
part of secondary fraud protection; or
* respond to legal requests such as subpoenas, warrants or other mandatory
information requests.
* Create de-identified aggregated data: To provide customers with a better
understanding of their survey results, we use survey data in a de-identified
aggregated form to compare customers’ results to the results of other surveys
or other customers. We also use your survey data to continually improve our
Services, including our de-identified aggregated data sets. None of your
survey data will be disclosed to other unrelated customers in a
non-aggregated or identifiable form.
* Respond to legal requests and prevent harm: If we receive a legal request or
are informed of a situation that may cause harm, or potential harm, to
someone, we may need to inspect your personal information or data to respond
appropriately to that request or threat.
* Identify you as a user: We may use your information to identify you as a
Respondent and/or an Individual Feedback User in our systems and within the
Network which you belong.
* Provide information to other users in your Network or your Company: When you
are in a Network, the following will apply to you:
* Your Network may include other employees that you can choose for a
Performance Review. Your Company can also choose employees for a
Performance Review manually.
* When you ask another individual within your Network or Company to provide a
Performance Review about you, we will display your name and photograph (if
provided) to that individual.
* Your Company, may share Performance Reviews that you are involved in, with
other individuals in your Company, at the sole discretion of the Company.
* Continuous Feedback Messages that you provide or receive can be shared at
your discretion. Each of your Continuous Feedback Messages about other
individuals will be shared with the individual to whom the feedback is
addressed.
* If your Company uses our ONA network analysis tool, Your Meta Data may be
shared with the Company or other individuals at your
Company.
(E) VISITORS
When you use our Services as a Visitor, we may use your personal information to:
* Contact you for marketing purposes: We may send you news and information
about our products or Services that you either request from us, or we believe
may interest you (unless prevented by law). In most cases, we will contact
you via email.
* Manage our Services: We use your personal information so we can provide our
Services and improve those Services. Some of these purposes include:
* personalize or customize your experience when you use our Services
(including presenting our Websites in the best format for you or a device
you use to access our Websites);
* create new services or features;
* monitor, maintain and improve our Services and features;
* enforce our contracts and policies when we are made aware of potential
breaches;
* prevent potentially illegal, undesirable or abusive activities; or
* respond to legal requests such as subpoenas, warrants or other mandatory
information requests.
* Profiling for marketing purposes: As part of our marketing efforts, we may
combine information about you from third party sources with information we
hold about you to create a user profile, which will help us to make our sales
and marketing efforts more relevant to you and to personalize and improve
your experience.
(F) ANONYMITY AND PSEUDONYMS
In most cases, it will be very difficult for us to provide you with our Services
if you do not provide us with your real name and contact details (primarily
email). Situations where we might have difficulty interacting with you
anonymously, or via a pseudonym, are when you use our Services as an
Administrator, Respondent or Individual Feedback User.
If lawful and practicable, you may use a pseudonym (or simply not identify
yourself) when dealing with us. For example, if you have a complaint or concern
about our site, or a general question about our Services or this Privacy Policy,
you are welcome to contact us without identifying yourself. In some cases,
however, if you do not provide us with information, we may not be able to
provide you with our products or Services or respond adequately to you.
7. WHO HAS ACCESS TO YOUR PERSONAL INFORMATION?
(A) GENERAL
We will share your personal information with third parties only in the ways that
are described in this Privacy Policy. To provide you with our Services we will
often need to disclose your personal information to our staff or the service
providers we use to operate our business. Examples of our service providers
include: hosting services; project management software; email service providers;
system monitoring services; customer support services; and website analytics.
These companies are only authorized to use your personal information as
necessary for us to provide our Services to you and/or the Customer.
In most cases, the information that we disclose to our staff or service
providers will be directly necessary to provide our Services to you. However,
there may be occasions where we need to disclose your personal information to
our staff, service providers, professional advisors or other third parties,
including to:
* Provide the Services: In providing the Services, we may need to disclose your
personal information to people who work for us or to one of our service
providers. Our agreements with third parties include obligations to protect
the security and confidentiality of your personal information. These
disclosures may be related to activities such as filling orders, processing
payments and mail-outs, storing and managing documents, research, providing
professional advice, facilitating creation of accounts, sending you service
emails, providing technical support, or providing other services to you.
Transfers of Respondent and Individual Feedback User information to our
service providers are covered by our agreement with the Customer.
* Prevent illegality or enforce our terms and policies: If you engage in or
threaten any unlawful activity, we may reasonably believe that it is
necessary to disclose your personal information to the police, a relevant
authority or enforcement body, or your internet service provider, employer,
supervisor or network administrator.
* Protect our rights or the rights of our staff: There may be situations where
disclosing your personal information is necessary to protect the property,
health or safety of Culture Amp or its staff, the Customers or others. For
example, exchanging information with other organizations to protect against
fraud.
* Keep other entities associated with us informed: In some cases, we may need
to disclose your personal information to our agents, business affiliates,
joint venture entities, partners, investors or any applicable subsidiaries or
holding companies. The need to disclose your personal information to these
entities may arise from a legal obligation we owe that entity, or to assist
our or their legitimate business interests.
* Run events, competitions and promotions: We may need to disclose your
personal information to sponsors and promoters when you register or attend an
event or enter any competition that we conduct or promote. This disclosure
will generally not apply to Respondents or Individual Feedback Users.
* Perform actions you request or consent to: You may specifically authorize us
to disclose your personal information to a third party. For example, to
resolve a dispute regarding our Privacy Policy or to integrate a third-party
service. We may also disclose your personal information to a third party with
your prior consent.
* Comply with legal requests: In some situations, we may be compelled to
disclose your personal information in response to lawful requests by public
authorities, including to meet national security or law enforcement
requirements. We may disclose your personal information to third parties such
as law enforcement officials or to comply with court orders, such as
subpoenas or other legal processes.
* Merge or sell our business: We may share some or all of your personal
information in connection with or during negotiation of any merger,
financing, acquisition or dissolution transaction or proceeding involving the
sale, transfer, divestiture, or disclosure of all or a portion of our
business or assets. In the event of an insolvency, bankruptcy, or
receivership, personal information may also be transferred as a business
asset. If another company acquires our company, business, or assets, that
company will possess the personal information collected by us and will assume
and be subject to all the rights and obligations regarding your personal
information as described in this Privacy Policy. If Culture Amp is involved
in a merger, acquisition, or sale of all or a portion of its assets, you will
be notified via email and/or a prominent notice on our website, of any change
in ownership, uses of your personal information, and choices you may have
regarding your personal information.
When we disclose your personal information to third parties such as our service
providers, we sign confidentiality and data processing agreements with them to
ensure they maintain confidentiality and have privacy and security standards to
protect your personal information.
(B) DISCLOSURES SPECIFIC TO ADMINISTRATORS
When you use our Services as an Administrator, your personal information may be
disclosed to other Administrators within your Company.
(C) DISCLOSURES SPECIFIC TO RESPONDENTS OR INDIVIDUAL FEEDBACK USERS
When you use our Services as a Respondent or an Individual Feedback User, we may
also disclose your personal information for the purposes of:
* Providing the Services: When you answer Customer surveys, we will disclose
that information to the Customer and Administrators. How your answers are
displayed and what information may be used to analyze and report your answers
(either in an aggregate or individual form) may vary from survey to survey.
It is important that you read the Confidentiality Notice before answering a
survey so you understand how your survey answers will be used and the ways
they might be shared (if at all). Your survey data will also be visible to
other employees in your Company each time you share your survey reports, or
provide feedback to such employee. Your Company and other employees in your
Company will not be able to see your Personal Profile Page, however, your
personal information may be used to provide Services to other users in your
Network.
* Creating aggregated de-identified data: We may create aggregated
de-identified data for any purpose derived from data we hold about you. For
example, we may create aggregated de-identified data to share with customers,
prospects, partners for business or research purposes, or for provision of
our Services such as our survey benchmarks.
* Fulfilling Customer requests: Because the Customer is the controller of your
personal information, we hold and process your personal information on behalf
of the Customer. There may be occasions when the Customer instructs us to
disclose your personal information to a third party, such as a consultant or
a new service provider. If instructed by the Customer to transfer your
personal information to a third party, we will sign a data transfer agreement
with the Customer and the third party if required, to ensure that they
continue to observe the Confidentiality Notice for each survey.
* Preventing harm: We may also disclose your personal information to the
Customer or relevant authorities if your use of our Services indicates an
imminent risk of harm to you or to others around you.
8. WHAT ARE YOUR RIGHTS TO YOUR PERSONAL INFORMATION?
(A) GENERAL
If you live in certain countries (for example, European Union member states) you
may have rights regarding your personal information, including the right to
access, correct, delete, port, limit or stop the use or disclosure of your
personal information.
We will respond to requests to access and correct (if necessary) your personal
information as soon as possible. You have the following options when exercising
your rights:
* Update your account details: You may be able to update your registration and
other account information on your account settings page or your profile page
and information is updated immediately. To update any other information,
please contact our Privacy Officer at privacy@cultureamp.com or customer
support at support@cultureamp.com.
* Access, correction and deletion: Upon request, we will provide you with
information about whether we process, or provide to a third party to process
on our behalf, any of your personal information. If you want to review,
correct (if necessary) or delete the information that we have collected and
hold about you, please contact our Privacy Officer at
privacy@cultureamp.com.
* Data exports: If you request an export of the information that we hold about
you, we will provide you with the data in a standard CSV format. This data
format may not be applicable or compatible with all uses. To request a data
export, please contact our Privacy Officer at privacy@cultureamp.com.
* Limiting or stopping use or disclosure: If you want to limit or stop our use
or the disclosure of your personal information to third parties, please
contact our Privacy Officer at privacy@cultureamp.com. However, please note
that by limiting or stopping the use of your personal information by us, or
its disclosure to third parties, you may also limit our ability to provide
you with our Services.
* ONA network analysis data:If you want to stop our use of your Meta Data or
stop the collection of further Meta Data about you, please contact your
Company. Data collected through our ONA network analysis tool must be removed
at the Company level.
* Newsletter and other communications: If you subscribe to our newsletter(s) or
other communications, you may choose to stop receiving those communications
by using the unsubscribe instructions included our emails, or by contacting
our Privacy Officer at privacy@cultureamp.com.
* Other queries or requests: If you have a question or want to make a request
that is not listed above, please contact our Privacy Officer at
privacy@cultureamp.com.
(B) REQUESTS FROM ADMINISTRATORS, RESPONDENTS AND INDIVIDUAL FEEDBACK USERS
If you are an Administrator, Respondent or Individual Feedback User, we collect,
hold and process information about you on behalf, and under the direction, of
the Customer. This information includes data uploaded to our Services by the
Customer (for example, your name, email address, employment and demographic
data), your survey responses and comments, and Individual Feedback that you
submit through our Services.
You have the following options when exercising your rights:
* Platform communications: If you would like to stop receiving Culture Amp
platform emails, you must contact your Company. If you contact us directly,
we will forward your request to the Customer to seek their permission and/or
instructions. If you request this, you may no longer be able to use the
Services.
* Correction and deletion of Platform Data: If you would like to request
access, correction, transfer or deletion of your Platform Data, you must
contact your Company. If you contact us directly, we will forward your
request to the Customer to seek their permission and/or instructions. Please
note that when Culture Amp corrects or deletes your Platform Data, data
relating to you may inadvertently be identifiable to the Customer due to its
omission.
* Exceptions to correction of Platform Data: If you are an Individual Feedback
User, you can change any of the personal data in your account (with the
exception of Continuous Feedback Messages, Performance Reviews and your
Personal Review Graphs).
9. HOW LONG DO WE RETAIN YOUR PERSONAL INFORMATION?
(A) ADMINISTRATORS, RESPONDENTS AND INDIVIDUAL FEEDBACK USERS
We retain your personal information for as long as we provide our Services to
the Customer and until the Customer requests us to delete your personal
information, or as needed to comply with our legal obligations, resolve disputes
or enforce our legal rights. We may keep your personal information in our
encrypted and archived backups for up to 90 days from the point of collection.
(B) VISITORS
We will retain your personal information for as long as is necessary to provide
our Services to you, or to comply with our legal obligations, resolve disputes,
and enforce our legal rights.
10. HOW DO YOU MAKE A COMPLAINT?
(A) CONTACTING OUR PRIVACY OFFICER
Please contact our Privacy Officer if you have any complaints about our
compliance with this Privacy Policy or relevant privacy laws. We will treat your
complaint seriously, and will investigate any alleged breach, including how it
occurred, and how best to prevent future breaches (if relevant). You can contact
our Privacy Officer at privacy@cultureamp.com.
(B) EUROPEAN UNION COMPLAINTS
If you live in the European Union and have any complaints regarding our
compliance with our Privacy Policy, please contact our Privacy Officer at
privacy@cultureamp.com. However, if you are dissatisfied with our handling of
your complaint, please contact the relevant EU Data Protection Authority in your
country or the UK Information Commissioner (our lead supervisory authority) at:
UK INFORMATION COMMISSIONER
Information Commissioner’s Office
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, United Kingdom
Phone: +44 0303 123 1113
Fax: ++44 01625 524 510
Email: casework@ico.org.uk
We will cooperate with the UK Information Commissioner or the Data Protection
Authority in your country regarding the investigation and resolution of your
complaint, and any specific actions they require for us to comply with our
Privacy Policy or applicable law.
(C) AUSTRALIAN PRIVACY ACT COMPLAINTS
If you live in Australia and have any complaints regarding our compliance with
the Australian Privacy Act, please contact our Privacy Officer at
privacy@cultureamp.com. However, if you are dissatisfied with our handling of
your complaint, you may raise your complaint with the Office of the Australian
Information Commissioner by contacting them at:
https://www.oaic.gov.au/about-us/contact-us.
11. ADDITIONAL INFORMATION.
(A) SENSITIVE PERSONAL DATA
If you send or disclose any sensitive personal information (e.g. information
related to racial or ethnic origin, sex life or physical or mental health
condition) to us when using the Services, you consent to our processing and use
of such sensitive personal data as necessary to provide the Services. If you do
not consent to our processing and use of such sensitive personal information,
you must not submit sensitive personal information to our Services. You may
subsequently modify or withdraw your consent to processing of sensitive personal
data in accordance with applicable laws in certain jurisdictions and according
to Section 8 of this Privacy Policy.
If you do not want your Company to send us sensitive personal information about
you, you must make such request directly to your Company.
(B) COOKIES AND TRACKING TECHNOLOGIES
We and our marketing partners, affiliates, or analytics or service providers,
use technologies such as cookies, beacons, tags, and scripts, to analyze trends,
administer the Website, track users’ movements around the Website, and to gather
demographic information about our user base as a whole. We may receive reports
based on the use of these technologies by these companies on an individual and
aggregated basis. This use does not apply to Respondents or Individual Feedback
Users.
We use cookies to remember users’ settings and preferences, and for session
management. Users can control the use of cookies at the individual browser
level. If you reject cookies, you may still use our Services, but your ability
to use some features or areas of our Services may be limited.
We use Local Storage, such as HTML5, to store content information and
preferences. Third parties with whom we partner to provide certain features on
our Websites or to display advertising based upon your web browsing activity
also use Flash cookies and HTML5 to collect and store information. Various
browsers may offer their own management tools for removing HTML5. To manage
Flash cookies, please click here. This use does not apply to Respondents or
Individual Feedback Users.
We partner with a third party to manage our advertising on other sites. Our
third party partner may use technologies such as cookies to gather information
about your activities on this website and other sites in order to provide you
advertising based upon your browsing activities and interests. If you wish to
not have this information used for the purpose of serving you interest-based
ads, you may opt-out. Click here for more information. If you are located in the
European Union, click here for more information. Please note this does not opt
you out of being served all ads. You will continue to receive generic ads. This
use does not apply to Respondents or Individual Feedback Users.
Please see our Cookie Policy for more information on what cookies and tracking
technologies we use in our Services.
(C) SOCIAL MEDIA WIDGETS
Our Websites may include social media features or widgets, such as the Facebook
Like or Share buttons. Use of these features may collect your IP address, detect
which page you are visiting on our Websites, and set a cookie to enable the
feature to function properly. Your interactions with these features are governed
by the privacy policy of the third party providing these features.
(D) LINKS TO OTHER WEBSITES
Our Websites may include links to other websites (for example, our Slack channel
for people geeks). The privacy practices of those other websites may differ from
Culture Amp’s privacy practices. If you submit personal information to any of
those websites, your personal information is governed by their privacy policy.
We encourage you to carefully read the privacy policy of any website you visit.
(E) TESTIMONIALS
We display Customer or user testimonials and other endorsements on our Websites.
With your consent, we may post your testimonial along with your name. If you
wish to update or delete your testimonial or any other endorsement, please
contact us at privacy@cultureamp.com.
(F) BLOG AND FORUMS
Our Websites offer publicly accessible blogs or community forums. You should be
aware that any information you provide in these areas may be read, collected,
and used by others who access them. To remove your personal information from our
blog or community forum, please contact us at privacy@cultureamp.com. In some
cases, we may not be able to remove your personal information, and in such
cases, we notify you and explain why we are unable to fulfill your request.
(G) CULTURE AMP MOBILE APPLICATION
You can stop all collection of information by the Culture Amp Mobile Application
by uninstalling it. You may use the standard uninstall processes as may be
available as part of your mobile device or via the mobile application
marketplace or network.
12. CULTURE AMP CONTACT DETAILS.
If you have any questions, concerns or complaints about our Privacy Policy or
our data collection or data processing practices, or if you want to report any
data privacy concerns or data security issues, please contact us at the address
below, where we will assist or refer your question, concern or complaint to the
appropriate party.
CULTURE AMP
Email: privacy@cultureamp.com
Attention: Legal Department – Level 2, 29 Stewart Street, Richmond VIC 3121,
Australia
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