Culture Hub – Privacy Policy
Last updated: 1st January, 2025
This Privacy Policy explains how Global Business Culture Ltd (“we”, “us”, “our”) collects, uses, and protects your personal data when you use Culture Hub, our online learning platform. We are committed to handling your personal information responsibly, transparently, and in compliance with data protection laws, including the UK General Data Protection Regulation (UK GDPR).
This Policy applies to all users, including individual learners, organizational users, and enterprise clients, unless a separate agreement states otherwise.
1. Who We Are (Data Controller)
We act as the data controller, meaning we determine how and why your personal data is processed. For organizational users, your employer or sponsoring organization may also act as a data controller for data related to your training activity.
2. Personal Data We Collect
2.1 Information you provide directly
- Name
- Email address
- Job title / role (if provided)
- Organization (if applicable)
- Login credentials
- Profile information
- Support queries
2.2 Payment information (via Stripe)
- Payment details are processed securely by Stripe
- We do not store full credit or debit card details
- Stripe provides confirmation of payment and limited billing information
2.3 Automatically collected data
- IP address
- Device and browser type
- Login timestamps
- Course progress
- Assessment scores
- Time spent on activities
- Clickstream data
- Session logs
2.4 Data collected through the AI Culture Assistant
- User prompts and questions
- AI-generated responses
- Usage metrics
Please do not enter sensitive or confidential information into the AI Assistant.
2.5 Organizational license data
- User lists provided by administrators
- Seat assignment information
- Training reports shared with your organization
3. How We Use Your Personal Data
- Provide access to learning materials
- Manage accounts and authentication
- Track course progress and assessments
- Provide organizational reporting
- Deliver AI-generated cultural guidance
- Process payments
- Improve platform performance
- Provide technical support
- Maintain security and prevent misuse
- Comply with legal obligations
We do not use your data for automated decision-making that produces legal or significant effects.
4. Legal Basis for Processing (UK GDPR)
4.1 Contract necessity
To deliver services purchased by you or provided by your organization.
4.2 Legitimate interests
- Platform analytics
- User experience improvements
- Fraud prevention
- Organizational usage reporting
4.3 Consent
Used for optional activities such as marketing communications.
4.4 Legal obligations
Retention of financial or corporate records as required by UK law.
5. Sharing Your Information
5.1 Your organization
- Learner activity
- Completion status
- Course progress
- Assessment scores
- Usage summaries
5.2 Service providers
- LMS hosting providers
- Stripe (payments)
- AI service providers
- IT and analytics partners
We do not sell your personal data.
6. International Data Transfers
Data may be processed outside the UK or EU. Appropriate safeguards such as UK-approved Standard Contractual Clauses are used.
7. Data Retention
- User accounts: up to 24 months after license expiry
- Course and assessment data: up to 24 months
- Financial records: 6 years
- AI Assistant logs: short-term retention
8. Your Privacy Rights
- Access and correction
- Deletion requests
- Restriction or objection
- Data portability
- Withdraw consent
- Lodge a complaint with the ICO
ICO website: https://ico.org.uk/
We respond to requests within one month.
9. Cookies and Tracking
Cookies are used for authentication, session management, analytics, and preferences. Disabling cookies may affect platform functionality.
10. Security
- HTTPS encryption
- Role-based access controls
- Password protection
- Activity logging
- Regular security reviews
11. AI Assistant-Specific Information
- AI interactions are processed by third-party providers
- Prompts may be temporarily stored
- Do not enter personal or confidential data
- AI outputs are not authoritative advice
12. Children’s Privacy
Culture Hub is not intended for users under 18 unless supervised by an organization or guardian.
13. Changes to This Policy
We may update this policy periodically. Significant changes will be communicated via the platform or email.
14. Contact
