This policy also explains your choices about how we use information about you. Your choices include how you can object to certain uses of information about you and how you can access and update certain information about you.
If you do not agree with this policy, do not access or use our services or interact with any other aspect of our business.
The following points under this Section 1 is intended to help you understand:
- In this policy, Cultural Business Consulting, Inc, “we”, “us” and “our” refers to Cultural Business Consulting, Inc, and any of our corporate affiliates. We offer a wide range of services, not limited to; training, coaching, facilitating, and other related Business and Personal services. To provide our services, it will be necessary to obtain some Personal information such as Name, Contact Details and other such details that identify you and your family (where applicable). including hosting this information in our data-centers. We refer to all of these services, websites and data-hosting systems such as web and mobile based applications as “services” in this policy.
- In this policy, Data Protection Laws refers to any applicable data protection or privacy laws or regulations including the European Union General Data Protection Regulation (EU GDPR) 2016/679, the UK Data Protection Act 2018, the Japanese Act on the Protection of Personal Information (APPI) 2015, and any laws that implement, supersede, replace or override any of those laws or regulations, and the terms “personal data”, “data controller”, “data processor”, “data subject”, “personal subject” and “processing” have the meanings given to those terms in the applicable Data Protection Laws from time to time.
- Your privacy is important to us, and so is being transparent about how we collect, use, and share information about you. We are committed to safeguarding the privacy of our website visitors and service users.
- This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.
- For more information about us, see Our Details (Section 20).
How we use your personal data
- In this Section 2 we have set out:
- the general categories of personal data that we may process;
- in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
- the purposes for which we may process personal data; and
- the legal basis of the processing.
- We may process data about your use of our website and services (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
- We may process your account data (“account data”). The account data may include your name and email address. The source of the account data is you or your employer. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you.
- We may process your information included in your personal profile when you register, or are registered for an account (For example, by your employer), create or modify your profile, set user preferences, sign-up for or make payments through our website or services. (“profile data”). The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is consent through the performance of a contract between you or your employer, and us and/or taking steps, at your or your employers request, to enter into such a contract.
- We may process information contained in any inquiry you submit to us regarding our services (“inquiry data”). The inquiry data may be processed for the purposes of offering, marketing and selling relevant products and/or services to you. The legal basis for this processing is consent.
- We may process information that you provide to us for the purpose of subscribing to our email notifications and/or alerts and/or newsletters (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications, and/or alert and/or newsletters. The legal basis for this processing is consent through the performance of a contract between you or your employer, and us and/or taking steps, at your or your employers request, to enter into such a contract.
- We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. Our website and/or service will generate the metadata associated with communications made using the website and/or service contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and/or services and/or business and/or communications with users.
- We may process information we receive about you from companies that own, are owned or operated by Cultural Business Consulting, Inc., in accordance with their terms and policies. (“company group data”). The company group data may include the communication content and metadata associated with the communication. The company group website and/or service will generate the metadata associated with communications made using the website and/or service contact forms. The company group data may be processed for the purposes of communicating with you, between company group members and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and/or services and/or business and/or communications with you and/or your employer, users and company group members.
- We may process information we receive about you from our global network of partners who provide consulting, implementation, training and other services around our services. (“partner data”). Some of these partners also help us to market and promote our products, generate leads for us, and resell our products. We receive information from these partners, such as billing information, billing and technical contact information, company name, what Cultural Business Consulting, Inc., services you have purchased or may be interested in, evaluation information you have provided, what events you have attended, and what country you are in. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and/or services and/or business and/or communications with you and/or your employer, users and our partners.
- We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
- We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
- In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
- Please do not supply any other person’s personal data to us, unless we prompt you to do so.
- Automated decision-making
- This automated decision-making will involve monitoring how you use the services available, and may be directed by you and/or your employer, and individuals working under contract with Cultural Business Consulting, Inc to service client-based requests. This is limited to selections you and/or your employer have made; the length of time and how you have been using either our staff or customer portal including not logging off, or without a legally stated period of required inactivity whilst still being logged on.
- This automated decision-making may include sending notifications to alert users on working hours, legally specified rest or break periods; and to monitor performance, risks and adherence to any compliance or standards the company is obligated, legally or otherwise to maintain or attain.
- We will use your personal data for the purposes of automated decision-making in relation to: recommending connecting with other users or contacts within our services, that you or they have specified an interest in through the selection of keywords, phrases, events, mutual interests through consent to use our services and those of our group, partners and third-party service providers.
- The significance and possible consequences of this automated decision-making are providing recommendations you have previously stated or selected interest in, and providing you and/or your employer with user action history, and proof of providing you with any obligations they have to alert you to taking legally specified rest or break periods, or suspending use of the services for a period of time equivalent to the break or rest period, or however your employer may deem suitable. Some of these settings and preferences are available to be set by you directly in your user preferences, others by your employer through their administrative console.
Providing your personal data to others
- We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy. Information about our group of companies can be found at https://www.pagegold.com
- We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
- We may disclose your personal data such as name, address, contact information and relocation details to our suppliers or subcontractors insofar as reasonably necessary for carrying out our legitimate business you or your employer has contracted us to provide.
- Financial transactions relating to our website and services may be handled by our payment services providers, which is conducted through their payment gateway. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers’ privacy policies and practices via their links on our website or your customer portal under ‘Payments’.
- In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
International transfers of your personal data
- In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
- We and our other group companies have offices and facilities in the UK, US and Japan. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the same level of data protection as specified in this policy.
- The hosting facilities for our website and services are situated in the UK, US and Japan. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the same level of data protection as specified in this policy.
- Our Inbound and Outbound Agents and their contracted suppliers or vendors, are situated in the country you move or relocate from and to, and other countries as necessary to carry-out our legitimate business with you or your employer. Some of these locations act as gateways for the relocation and related services and may vary depending on the type of service provided and what services are or are not available for each part of the relocation process. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the same level of data protection as specified in this policy.
- You acknowledge that personal data that you submit for publication through our website or services, such as testimonials or recommendations, may be available via the internet and around the world. We cannot prevent the use (or misuse) of such personal data by others.
Retaining and deleting personal data
- This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
- Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. After such time, we will either delete or anonymize your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible
- We will retain your personal data for as long as your account is active and a reasonable period thereafter in case you decide to re-use our services or ask for additional services under your current contract with us or by your employer.
- Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
- We may update this policy from time to time by publishing a new version on our website.
- You should check this page occasionally to ensure you are happy with any changes to this policy.
- We may notify you of significant changes to this policy by email.
- In this Section 8, we have summarized the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
- Your principal rights under data protection law are:
- the right to access;
- the right to rectification;
- the right to erasure;
- the right to restrict processing;
- the right to object to processing;
- the right to data portability;
- the right to complain to a supervisory authority; and
- the right to withdraw consent.
- You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. If requested in electronic format it will be provided as a CSV file, a commonly used format that can be opened in all standard spreadsheet or word processor applications. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can access your personal data from your account when you are logged in to the services you registered for, or by requesting a copy from the postal or email address provided in section 20, Our Details. Where we provide the services under contract with an organization (For example, your employer), that organization controls the information processed by the services. For more information regarding data controllers and who they might be, please see Notice to End Users (Section 19), which provides further information on this matter.
- You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
- In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims.
- In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
- You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.
- You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
- You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
- To the extent that the legal basis for our processing of your personal data is:
- consent; or
- that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
- If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
- To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
- You may exercise any of your rights in relation to your personal data by written notice to us, in addition to the other methods specified in this Section 8.
Third party websites
- Our website and the services include hyperlinks to, and details of, third party websites.
- We have no control over, and are not responsible for, the privacy policies and practices of third parties.
Personal data of children
- Our website and services are targeted at persons over the age of 18 unless otherwise stated in a legal contract between an organization and ourselves to provide them with the services in accordance with local laws. (For example, a work experience course for a student age 16 or above, or a minor who is the child of a parent or legal guardian whose data is being legally processed for immigration, move, relocation or other such similar services.)
- If we have reason to believe that we hold personal data of a person under that age without legal reason in our databases, we will delete that personal data.
- Please let us know if the personal information that we hold about you needs to be corrected or updated.
Acting as a data processor
- In respect of data provided or entered by organizations under contract with us, we do not act as a data controller; instead, we act as a data processor.
- Insofar as we act as a data processor rather than a data controller, this policy shall not apply. Our legal obligations as a data processor are instead set out in the contract between us and the relevant data controller.
- A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
- Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
- Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
Cookies that we use
Cookies used by our service providers
- Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
- https://support.google.com/chrome/answer/95647?hl=en (Chrome);
- https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
- http://www.opera.com/help/tutorials/security/cookies/ (Opera);
- https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
- https://support.apple.com/kb/PH21411 (Safari); and
- https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
- Blocking all cookies will have a negative impact upon the usability of many websites.
- If you block cookies, you will not be able to use all the features on our website or the services.
- We have made every effort to ensure that third-party links in this policy have been validated upon publication of this policy. However, we are not responsible for the ongoing validation of the links provided for third parties in this policy. We will check them from time to time and update them if possible, when required.
Notice to End Users
- According to the European Union General Data Protection Regulations (EU GDPR) and other Applicable Data Protection Laws, such as those mentioned in the Introduction (Section 1.2) you are entitled to know the identity of your “data controller” i.e. the legal entity which determines why and how your personal data is processed, and you should be aware that your relevant data controller may vary, depending on how you are receiving services from us. For example:
- Staff, Consultants and Advisors: We act as your data controller handling your personal information in order for you to carry out your duties as described in your agreement with us.
- Direct Individuals: If you are engaging us directly to provide services for you and your family (where applicable), then your relevant data controller is likely to be us providing those services to you.
Statutory and regulatory disclosures
- This website is owned and services operated by Cultural Business Consulting, Inc, registered in the State of California under corporate number C3763753. you can find the online version of the register at: http://www.sos.ca.gov/business-programs/business-entities/
- If you have questions or concerns about this policy or how your information is handled, please direct your inquiry to the relevant office below, which we have appointed to be responsible for facilitating such inquiries.
PO Box 12195,
CA 92658 US
You can contact us:
- by post, to the postal addresses given above;
- using our website contact form https://www.culturalbusinessconsulting.com/contact;
- by telephone, on the contact number published on our website; or
- by email, using the email address: [email protected]
This is the end of this policy. © Cultural Business Consulting, Inc 2019