Website Privacy Policy

This privacy policy explains how Culture Gem Ltd collects, uses, stores, and protects your personal data when you use our website. It has been approved by the board of Culture Gem Ltd.

If you are experiencing difficulty with any content on our website or require assistance with any part of our site, please contact us during normal business hours as detailed below and we will be happy to assist.

Who we are

The data controller responsible in accordance with the purposes of the UK General Data Protection Regulation (UK GDPR) and other data protection regulations is:

Culture Gem Ltd
27 Old Gloucester Street
London WC1N 3AX
United Kingdom
08000434364
info@culturegem.co.uk

How to contact us about data protection

If you have any questions about how we handle your personal data, please contact us:

Culture Gem Ltd
Email: info@culturegem.co.uk

General information on data processing

On this page, we provide you with information regarding the processing of your personal data on our website.

How we collect and use your personal data will depend on how you interact with us or the services you use. We only collect, use or share your personal data where we have a legitimate purpose and a legal basis for doing so.

What do we mean by 'legal basis'?

• Consent (Art. 6(1)(a) UK GDPR) — You have given us your consent to process your personal data for the specific purpose we have explained to you. You have the right to withdraw your consent at any time.
• Contract (Art. 6(1)(b) UK GDPR) — We need to use your data to fulfil a contract you have with us. Alternatively, it's necessary to use your data because we have asked you to, or you have taken yourself, specific steps before entering that contract.
• Legal Obligation (Art. 6(1)(c) UK GDPR) — We need to use your data to comply with the law.
• Vital Interests (Art. 6(1)(d) UK GDPR) — Processing your data is necessary to protect your vital interests or of another person.
• Public Task (Art. 6(1)(e) UK GDPR) — Using your data is necessary for the performance of a task carried out in the public interest, or because it is covered by a task set out in law.
• Legitimate Interests (Art. 6(1)(f) UK GDPR) — Processing your data is necessary to support a legitimate interest we or another party has, only where this is not outweighed by your own interests.

Please note where your data is processed under the performance of a contract or for a legal obligation, if you do not provide the data requested, we may be unable to provide you with our services.

Data sharing and international transfers

As explained throughout this Privacy Policy, we use various service providers to help us deliver our services and keep your data secure. When we use these service providers, it is necessary for us to share your personal data with them.

We have agreements in place with all our service providers that we share your data with that oblige them to protect your data.

Sharing with trusted delivery partners

Culture Gem works with a network of trusted specialist partners who deliver certain services on our behalf or alongside us. Where a service you enquire about is delivered by one of our partners, we may share your contact details and enquiry information with the relevant partner for the purpose of delivering that service.

We will only share your data with a delivery partner where it is necessary to fulfil the service you have enquired about. All delivery partners are contractually bound to protect your data and use it only for the agreed purpose. We do not sell or share your data for marketing purposes with any third party.

The legal basis for this sharing is Art. 6(1)(b) UK GDPR (performance of a contract or pre-contractual steps) and Art. 6(1)(f) UK GDPR (legitimate interests in delivering the services you have requested).

Where your personal data is shared outside the UK, we ensure that your personal data is given an equivalent level of protection, either because the jurisdiction to which your data is transferred has an 'adequate' data protection standard according to the UK Government, or by using another safeguard such as an enhanced contractual agreement, i.e. the International Data Transfer Agreement. You can request a copy of the contractual agreements we have concluded with our service providers for these purposes by sending an email to the email address provided in this Privacy Policy.

Your rights

When your personal data is processed, you are a data subject within the meaning of the UK GDPR and have the following rights:

1. Right of access (Art. 15 UK GDPR)

You may request the data controller to confirm whether your personal data is processed by them. If such processing occurs, you can request information including:

• Purposes of processing
• Categories of personal data being processed
• Recipients or categories of recipients to whom the personal data have been or will be disclosed
• Planned storage period or the criteria for determining this period
• The existence of the rights of rectification, erasure or restriction or opposition
• The existence of the right to lodge a complaint with a supervisory authority
• If applicable, origin of the data (if collected from a third party)
• If applicable, existence of automated decision-making including profiling
• If applicable, transfer of personal data to a third country or international organization

2. Right to rectification (Art. 16 UK GDPR)

You have a right to rectification and/or modification of the data, if your processed personal data is incorrect or incomplete. The data controller must correct the data without delay.

3. Right to the restriction of processing (Art. 18 UK GDPR)

You may request the restriction of the processing of your personal data under the following conditions:

• If you challenge the accuracy of your personal data for a period that enables the data controller to verify the accuracy
• The processing is unlawful, and you oppose the erasure of the personal data and instead request the restriction of their use
• The data controller no longer needs the personal data for the purpose of processing, but you need it to assert, exercise or defend legal claims
• If you have objected to the processing and it is not yet certain whether the legitimate interests of the data controller override your interests

4. Right to erasure ("Right to be forgotten") (Art. 17 UK GDPR)

If you request from the data controller to delete your personal data without undue delay, they are required to do so immediately if one of the following applies:

• Personal data is no longer necessary for the purposes for which they were collected or processed
• You withdraw your consent and there is no other legal basis for processing
• You object to the processing and there are no longer overriding legitimate grounds
• Your personal data has been processed unlawfully
• The personal data must be deleted to comply with a legal obligation
• Your personal data was collected in relation to information society services pursuant to Art. 8(1) UK GDPR

The right to deletion does not exist if the processing is necessary:

• To exercise the right to freedom of speech and information
• To fulfil a legal obligation required by the law
• For reasons of public interest in the field of public health
• For archival purposes of public interest, scientific or historical research purposes or for statistical purposes
• To enforce, exercise or defend legal claims

5. Right to data portability

You have the right to receive your personal data given to the data controller in a structured and machine-readable format. In addition, you have the right to transfer this data to another person without hindrance.

6. Right to object

For reasons that arise from your particular situation, you have, at any time, the right to object to the processing of your personal data pursuant to Art. 6(1)(e) or 6(1)(f) UK GDPR; this also applies to profiling based on these provisions.

If the personal data relating to you are processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data in regard to such advertising; this also applies to profiling associated with direct marketing.

7. Right to complain to a supervisory authority

You have the right to complain to the ICO if you are unhappy with how we have used your data. The ICO's address: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF. Helpline number: 0303 123 1113. ICO website: https://www.ico.org.uk

Data processing when you load our website

1. Description and scope of data processing

Each time our website is accessed, our system automatically collects data and relevant information from the computer system of the calling device. The following data is collected:

• Information about the browser type and the version used
• The user's operating system
• The Internet service provider of the user
• Date and time of access
• Websites from which the user's system accessed our website
• Websites the user's system accessed through our website

This data is stored in the log files of our system. Not included are the IP addresses of the user or other data that enable the assignment of the data to a user.

2. Purpose of data processing

The storage in logfiles is done to ensure the functionality of the website. The data is also used to optimize the website and to ensure the security of our IT systems. An analysis of the data for marketing purposes does not take place.

3. Legal basis for data processing

The legal basis for the temporary storage of data and logfiles is Art. 6(1)(f) UK GDPR.

4. Duration of storage

The data will be deleted as soon as it is no longer necessary for the purpose of its collection. If the data is stored in log files, this is the case after seven days at the latest.

5. Exercising your rights

The collection of data for the provision of the website and the storage of the data in log files is absolutely necessary for the operation of the website. The user can object to this. Whether the objection is successful is to be determined within the framework of a balancing of interests.

Use of cookies

1. Description and scope of data processing

When you visit our website, we use technical tools for various functions, in particular cookies, which can be stored on your device. When you visit our website for the first time and at any time later, you have the choice of whether you generally permit the setting of cookies or which individual additional functions you would like to select. You can make changes in your browser settings or via our consent banner.

We use essential cookies, which are required for the technical structure of the website. Without these cookies, our website cannot be displayed correctly or the support functions are not possible. The following data is stored and transmitted in essential cookies:

• Language settings
• Entered search terms
• Frequency of page views
• Use of website functionalities

We use cookies on our website that are classed as 'non-essential'. Non-essential cookies are cookies which are used for purposes beyond the basic functioning of a website. The following data will be processed through the use of non-essential cookies:

• Internet user location
• Date and time of the website request
• Tracking of the surfing behavior

2. Purpose of data processing

The purpose of using essential cookies is to ensure the functionality of our website. The use of non-essential cookies is carried out for the purpose of improving the quality of our website, its content and thus our reach.

3. Legal basis for data processing

The legal basis for the processing of personal data using non-essential cookies is Art. 6(1)(a) UK GDPR. The legal basis for the processing of personal data using essential cookies is Art. 6(1)(f) UK GDPR, legitimate interests.

4. Exercising your rights

You can revoke consent to the use of cookies and manage your consent preferences at any time via the cookie consent banner on our website.

Google Analytics

1. Description and scope of data processing

This website uses Google Analytics 4, a web analytics service provided by Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland. Google Analytics uses cookies and similar technologies to analyse how visitors use our website. The information generated (including your truncated IP address) is transmitted to and stored by Google on servers that may be located outside the UK.

Google Analytics 4 collects the following data:

• Pages visited and time spent on each page
• Referral source (how you arrived at our website)
• Your approximate geographic location (city level, derived from truncated IP address)
• Device type, browser, and operating system
• Screen resolution and language settings
• Interactions with site features (e.g. button clicks, form submissions)

IP anonymisation is enabled by default in Google Analytics 4, meaning your full IP address is never stored.

2. Purpose of data processing

We use Google Analytics to understand how visitors interact with our website so that we can improve its content, structure, and user experience. We do not use Google Analytics for advertising or remarketing purposes.

3. Legal basis for data processing

The legal basis for the use of Google Analytics is your consent pursuant to Art. 6(1)(a) UK GDPR, which you provide through our cookie consent banner. Analytics cookies are only set after you have given your consent.

4. Duration of storage

Google Analytics data is retained for 14 months. After this period, data is automatically deleted on a monthly rolling basis. Cookies set by Google Analytics expire after 2 years of inactivity.

5. Exercising your rights

You can withdraw your consent at any time via the cookie consent banner on our website. You can also prevent the collection of data by Google Analytics by:

• Adjusting your cookie settings via our cookie consent banner
• Installing the Google Analytics Opt-out Browser Add-on
• Disabling cookies in your browser settings

For more information about how Google processes your data, see the Google Privacy Policy and Google Analytics data safeguards.

Contact by email

1. Description and scope of data processing

You can contact us via the email address provided on our website. In this case the personal data of the user transmitted with the email will be stored. The data will be used exclusively for the processing of the conversation.

2. Purpose of data processing

If you contact us via email, this also constitutes the necessary legitimate interest in the processing of the data.

3. Legal basis for data processing

The legal basis for the processing of data transmitted in the course of sending an email is Art. 6(1)(f) UK GDPR. If the purpose of the email contact is to conclude a contract, the additional legal basis is Art. 6(1)(b) UK GDPR.

4. Duration of storage

The data will be deleted as soon as it is no longer necessary to achieve the purpose for which it was collected. For personal data sent by email, this is the case when the respective conversation with the user has ended. The additional personal data collected during the sending process will be deleted after a period of seven days at the latest.

5. Exercising your rights

You have the possibility to withdraw consent to the processing of your personal data at any time. If you contact us via email, you can object to the storage of your personal data at any time by contacting us at info@culturegem.co.uk. In this case, all personal data stored while establishing contact will be deleted.

Contact form

1. Description and scope of data processing

A contact form is available on our website, which can be used for electronic contact. If you make use of this option, the data entered in the contact form will be transmitted to us and stored securely in our database. When sending the message the following data will also be stored:

• Contact name
• Email address
• Company name
• Phone number (optional)
• Website (optional)
• Country (optional)
• Service interest
• Message content
• GDPR consent confirmation
• Marketing consent preference
• Date and time of submission

Your GDPR consent is required before we can process your enquiry. Submissions are stored securely and are not publicly accessible. Only authorised Culture Gem personnel can access enquiry data.

2. Purpose of data processing

The processing of the personal data from the form serves us exclusively for the purpose of establishing contact. The other personal data processed during the sending process serve to prevent misuse of the contact form and to ensure the security of our information technology systems.

3. Legal basis for data processing

The legal basis for the processing of data transmitted while sending a contact form is Art. 6(1)(f) UK GDPR. If the purpose of the contact is to conclude a contract, the additional legal basis is Art. 6(1)(b) UK GDPR.

4. Duration of storage

The data will be deleted as soon as they are no longer necessary to achieve the purpose for which they were collected. For the personal data from the contact form and those sent by email, this is the case when the respective conversation with the user has ended.

5. Exercising your rights

If you contact us via the contact form or via email, you can object to the storage of your personal data at any time by contacting us at info@culturegem.co.uk. In this case, all personal data stored while establishing contact will be deleted.

Corporate web profiles on social networks

YouTube

YouTube LLC, 901 Cherry Ave., San Bruno, CA 94066, United States.

On our company profile we provide information and offer YouTube users the possibility of communication. If you carry out an action on our YouTube company profile (e.g. comments, contributions, likes etc.), you may make personal data (e.g. clear name or photo of your user profile) public.

Our corporate profile in social networks is used for communication and information exchange with (potential) customers. We use the company's profile for products and services information and advertisement.

The legal basis for processing personal data for the purpose of communicating with customers and interested parties is Art. 6(1)(f) UK GDPR. We store your activities and personal data published on our YouTube corporate profile until you withdraw your consent. For further information: YouTube Privacy Policy

LinkedIn

On our LinkedIn company page we provide information and offer users the possibility of communication. The corporate profile is used for job applications, information, public relations, and active sourcing.

The legal basis for processing is Art. 6(1)(f) UK GDPR. For further information: LinkedIn Privacy Policy

Local storage and accessibility preferences

Our website uses your browser's local storage (not cookies) to remember certain preferences:

• Cookie consent preference — whether you have accepted or rejected optional cookies
• Accessibility settings — your preferred text size, contrast, font, motion, cursor, and link styling preferences

This data is stored locally on your device only and is never transmitted to our servers. You can clear this data at any time through your browser settings. The legal basis is Art. 6(1)(f) UK GDPR (legitimate interest in providing a functional, accessible website).

Hosting

The website is hosted on cloud infrastructure provided by our hosting provider. The servers automatically collect and store information in server log files, which your browser automatically transmits when you visit the website. The stored information is:

• Information about the browser type and the version used
• The user's operating system
• The Internet service provider of the user
• Date and time of access
• Websites from which the user's system accessed our website
• Websites the user's system accessed through our website

This data will not be merged with other data sources. The data is collected on the basis of Art. 6(1)(f) UK GDPR. The website operator has a legitimate interest in the technically error-free presentation and optimization of the website. Contact form submissions are stored in a secure database with row-level security controls that prevent unauthorised access.

Changes to this privacy policy

We may update this privacy policy from time to time to reflect changes in our practices or for regulatory reasons. The "Last updated" date at the top of this page indicates when this policy was last revised. We encourage you to review this page periodically.

This privacy policy has been created with the assistance of DataGuard.