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Website Privacy Policy

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 

www.culturegem.co.uk 

How to contact the data protection officer 

The designated data protection officer is: 

DataCo International UK Limited 

Suite 1,3rd Floor Suite 1, 11 - 12 St James's Square, 

London, United Kingdom 

SW1Y 4LB 

Telephone: +442035146557 

Email: privacy@dataguard.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. For further information on how to withdraw consent, please see the ‘Exercising your rights’ subsections in the subsequent sections of this Privacy Policy. 

  • 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 you’re 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. For example, to prevent you from serious physical harm. 

  • 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, for example, for a statutory function. 

  • 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 app. 

 

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. 

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 the following information from the data controller: 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 with meaningful information about the logic involved, the scope and the effects to be expected. 

  • 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 of your personal data. 

  • The processing is unlawful, and you oppose the erasure of the personal data and instead request the restriction of their use instead. 

  • The data controller or its representative no longer need the personal data for the purpose of processing, but you need it to assert, exercise or defend legal claims; or 

  • If you have objected to the processing pursuant 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 concerning you is no longer necessary for the purposes for which they were collected or processed. 

  • You withdraw your consent on which the processing is based pursuant to and where there is no other legal basis for processing the data. 

  • You object to the processing of the data and there are no longer overriding legitimate grounds for processing, or you object pursuant to Art. 21 (2) UK GDPR. 

  • Your personal data has been processed unlawfully. 

  • The personal data must be deleted to comply with a legal obligation in Union law or Member State law to which the data controller is subject. 

  • Your personal data was collected in relation to information society services offered 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 of the Union or Member States to which the data controller is subject, or to perform a task of public interest or in the exercise of public authority delegated to the representative. 

  • 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 by the data controller who was initially given the data. 

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 and/or believe that the processing of the personal data concerning you violates the applicable law. 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. The session is complete when the collection of data for the provision of the website is accomplished. 

If the data is stored in log files, this is the case after seven days at the latest. Storage beyond this is possible. In this case, the IP addresses of the users are deleted or alienated so that an assignment of the calling client is not possible. 

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 manager. Cookies are text files or information in a database that are stored on your hard drive and assigned to the browser you are using so that certain information can be passed to the entity that sets the cookie. 

We use essential cookies, which are required for the technical structure of the website. 

Without these cookies, our website cannot be displayed (completely 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 

  • Customization of advertisements to the user 

  • Tracking of the surfing behavior 

  • Linking the website visit with other social media platforms 

 

2. Purpose of data processing 

The purpose of using essential cookies is to ensure the functionality of our website. Some functions of our website cannot be offered without the use of cookies. For these, it is necessary that the browser is recognised even after a page change. 

We need essential cookies for the following purposes: 

  • Storage of language settings 

  • Storage of search queries 

  • Functionality of the 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 and profitability. By setting these cookies, we learn how the website is used and can thus constantly optimise our offer. These cookies serve us particularly for the following purposes: 

XSRF-TOKEN 

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 UK GDPR. The legal basis for the processing of personal data using essential cookies is Art. 6 (1) (f) UK 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 at the following link: www.culturegem.co.uk 

 

Contact via 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 e-mail is Art. 6 (1) (f) UK GDPR. Our legitimate interest is to optimally answer your request that you send by e-mail. 

If the purpose of the email contact is to conclude a contract, the additional legal basis for the processing 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 conversation ends when it can be concluded from the circumstances that the matter in question has been conclusively resolved. 

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 their personal data at any time. If you contact us via email, you can object to the storage of his personal data at any time, by the following means: 

contact 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. 

When sending the message the following data will also be stored: 

  • Email address 

  • Last name 

  • First name 

  • Date and time 

 

2. Purpose of data processing 

The processing of the personal data from the form as well as if you contact us by mail 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 an email is Art. 6 (1) (f) UK GDPR. Our legitimate interest is to provide you with the best possible response to the request you send to us via the contact form. If the purpose of the email contact is to conclude a contract, the additional legal basis for the processing 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. The conversation ends when it can be inferred from the circumstances that the facts in question have been conclusively clarified. 

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 

If you contact us via the the contact form or via e-mail, you can object to the storage of your personal data at any time, by the following means: 

contact 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. However, as we generally or to a large extent have no influence on the processing of your personal data by Youtube, we cannot make any binding statements regarding the purpose and scope of the processing of your data. 

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 

 

Publications on the company profile can contain the following content: 

  • Information about products 

  • Information about services 

  • Advertisement 

 

Every user is free to publish personal data. 

As far as we process your personal data in order to evaluate your online behavior, to offer you sweepstakes or to conduct lead campaigns, this is done on the basis of your express declaration of consent, Art. 6 (1) (a), Art. 7 UK GDPR. The legal basis for processing personal data for the purpose of communicating with customers and interested parties is Art. 6 (1) (f) UK GDPR. Thereby, our legitimate interest is to answer your request optimally or to be able to provide the requested information. If the aim of contacting you is to conclude a contract, the additional legal basis for the processing is Art. 6 (1) (b) UK GDPR. 

We store your activities and personal data published on our Youtube corporate profile until you withdraw your consent. Furthermore, we comply with the statutory retention periods. 

We process data from our corporate web profile in our own systems as well. The data is stored there for the following period: 1 calendar year 

You can object at any time to the processing of your personal data that we collect within the framework of your use of our corporate web profiles and assert your rights as a data subject mentioned the"Your rights" section of this privacy policy. Please send us an informal email to info@culturegem.co.uk. For further information on the processing of your personal data by Youtube and the corresponding objection options, please click here: 

YouTube: https://policies.google.com/privacy?gl=DE&hl=en 

 

Twitter: 

Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, Ireland 

On our company profile we provide information and offer Twitter users the possibility of communication. If you carry out an action on our Twitter company profile (e.g. comments, contributions, likes etc.), you may make personal data (e.g. clear name or photo of your user profile) public. However, as we generally or to a large extent have no influence on the processing of your personal data by Twitter, we cannot make any binding statements regarding the purpose and scope of the processing of your data. 

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 

  • Publications on the company profile can contain the following content: 

  • Information about products 

  • Information about services 

  • Advertisement 

 

Every user is free to publish personal data. 

 

As far as we process your personal data in order to evaluate your online behavior, to offer you sweepstakes or to conduct lead campaigns, this is done on the basis of your express declaration of consent, Art. 6 (1) (a), Art. 7 UK GDPR. The legal basis for processing personal data for the purpose of communicating with customers and interested parties is Art. 6 (1) (f) UK GDPR. Thereby, our legitimate interest is to answer your request optimally or to be able to provide the requested information. If the aim of contacting you is to conclude a contract, the additional legal basis for the processing is Art. 6 (1) (b) UK GDPR. 

We store your activities and personal data published on our Twitter corporate profile until you withdraw your consent. Furthermore, we comply with the statutory retention periods. 

We process data from our corporate web profile in our own systems as well. The data is stored there for the following period: 1 calendar year 

You can object at any time to the processing of your personal data that we collect within the framework of your use of our corporate web profiles and assert your rights as a data subject mentioned the"Your rights" section of this privacy policy. Please send us an informal email to info@culturegem.co.uk. For further information on the processing of your personal data by Twitter and the corresponding objection options, please click here: 

Twitter: https://twitter.com/de/privacy 

Use of corporate profiles in professionally oriented networks

1. Scope of data processing 

We use corporate profiles on professionally oriented networks. We maintain a corporate presence on the following professionally oriented networks: 

LinkedIn 

 

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

We do not have any information on the processing of your personal data by the companies jointly responsible for the corporate profile. Further information can be found in the privacy policy of: LinkedIn: https://www.linkedin.com/legal/privacy-policy 

 

If you carry out an action on our company profile (e.g. comments, contributions, likes etc.), you may make personal data (e.g. clear name or photo of your user profile) public. 

2. Legal basis for data processing 

The legal basis for the processing of personal data for the purpose of communication with customers and interested parties is Art. 6 (1) (f) UK GDPR. Our legitimate interest is to answer your request optimally or to be able to provide the requested information. If the aim of contacting you is to conclude a contract, the additional legal basis for the processing is Art. 6 (1) (b) UK GDPR. 

 

3. Purpose of the data processing 

Our corporate web profile serves to inform users about our services. Every user is free to publish personal data. 

 

4. Duration of storage 

We store your activities and personal data published via our corporate web profile until you withdraw your consent. In addition, we comply with the statutory retention periods. 

 

5. Exercising your rights 

You can object at any time to the processing of your personal data that we collect within the framework of your use of our corporate web profiles and assert your rights as a data subject mentioned the"Your rights" section of this privacy policy. Please send us an informal email to the email address stated in this privacy policy. 

 

You can find further information on objection and removal options here: 

LinkedIn: https://www.linkedin.com/legal/privacy-policy 

 

Hosting 

The website is hosted on servers of a service provider commissioned by us. 

Our service provider is: Wix.com Ltd., 40 Namal Tel Aviv Street, Tel Aviv 6701101, Israel 

 

For further information on the processing of personal data by Wix.com please see: https://www.wix.com/about/privacy 

The servers automatically collect and store information in so-called 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 his website - and server log files are therefore recorded. 

The server of the website is geographically located in the USA. 

 

Content delivery networks 

WIX 

1. Description and scope of data processing 

On our website we use functions of the Content Delivery Network of WIX of the provider Wix.Com (UK) Limited, Tower Bridge House, St Katharine's Way, London E1W 1DD, United Kingdom . A Content Delivery Network (CDN) is a network of regionally distributed servers connected via the Internet to deliver content, especially large media files such as videos. WIX provides web optimization and security services that we use to improve the load times of our website and to protect it from misuse. When you visit our website, a connection is established to the servers of WIX to retrieve e.g. content. This allows personal data to be stored and evaluated in server log files, the user's activity (e.g. which pages have been visited) and device and browser information (e.g. IP address and operating system). 

 

2. Purpose of data processing 

Using the features of WIX serves to deliver and accelerate online applications and content.

 

3. Legal basis for data processing 

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 his website - and server log files are therefore recorded. 

 

4. Duration of storage 

Your personal information will be stored as long as necessary to fulfil the purposes described in this Privacy Policy or as required by law. 

 

5. Exercising your rights 

You can find further information on the processing of personal data by WIX here: https://www.wix.com/about/privacy

 

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

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