Privacy Policy

At Culture Excellence (created, managed and provided by Culture Excellence FZE ("CE FZE", "we", "us" or "our")) we give high priority to confidentiality and data security. This privacy policy applies to our processing of personal data and establishes guidelines for the way CE FZE processes your personal data related to Culture Excellence and provides you with the information that you are entitled to receive under applicable data protection laws. You should read the privacy policy before you hand over your personal data to CE FZE before, during or after any involvement with and/or use of Culture Excellence.

 

1. Contact information and data protection roles

Whether CE FZE acts in the capacity of data controller or data processor depends on your relation to us and / or the company and / or employer you are working with / for. In the below, we will stipulate our roles in relation to the performed data processing activities. When acting as data controller for the processing of your personal data, our contact details are:

  • Company name: Culture Excellence FZE

  • Company license number: 37354

  • Address: Office DSO-DDP-A5-D-FLEX-G001, Building A5, Dubai Silicon Oasis, Dubai, UAE

  • Email: enquiries@culturexcellence.com

2. If you visit https://www.culturexcellence.com and / or https://app.culturexcellence.com and / or https://surveys.culturexcellence.com

2.1 Cookies

2.1.1. Types of personal data

When CE FZE uses cookies on the websites https://www.culturexcellence.com.com and / or https://app.culturexcellence.com and / or https://surveys.culturexcellence.com and in this connection processes your personal data, we act as data controller for such activities. CE FZE may collect the following personal data about you, when you visit our website(s):

  • IP address,

  • MAC address,

  • Browsing History,

  • Information about your use of our website, including click-behaviour,

  • User login email address (applicable to htps://app.culturexcellence.com only).

We use cookies to collect the above-mentioned personal data. You can read more about the use of cookies in our cookie policy, which you can find here.

 

2.1.2. The purpose(s) of the process

Your personal data may be processed for the following purposes:

  • Marketing in general,

  • Product and service development,

  • Statistics and analysis,

  • Providing login access to a user-specific account (applicable to htps://app.culturexcellence.com only),

  • Preventing duplicate survey responses (applicable to https://surveys.culturexcellence.com only).

   

2.1.3. Legal basis for processing

CE FZE processes your personal data on the following basis:

  • Contractual obligations: In certain cases, the processing of your personal data is necessary to fulfil a contract (Article 6(1)(b) of the General Data Protection Regulation),

  • Legitimate interests: We base the processing of your personal data on our legitimate interests in, for example, conducting statistics, analyses, providing support, as well as improving and developing our products and services (Article 6(1)(f) of the General Data Protection Regulation).

When you visit our public website at https://www.culturexcellence.com, we ask for your informed consent to place cookies that are not functional cookies according to the cookie rules. You have the right to withdraw your consent at any time. You can read more about how you change your cookie settings in our cookie policy, which is available here.

When you visit https://app.culturexcellence.com and / or https://surveys.culturexcellence.com, informed consent is assumed to already be granted by virtue of the fact that these websites / URLs are only accessible as part of a Culture Excellence Program, access to which is predicated on:

  • a contract in place between your employer and / or you and either CE FZE and / or an approved CE FZE partner and / or,

  • the acknowledgement of CE FZE’s terms and conditions specified on CE FZE’s websites and / or a CE FZE partner’s website.

As such we do not ask for informed consent when you access https://app.culturexcellence.com and / or https://surveys.culturexcellence.com.

 

2.1.4. Retention period

Cookies are deleted in accordance with our cookie policy, which is available here. However, the information may be stored for a longer period in anonymised form.

 

2.2. Data submitted via webform on https://www.culturexcellence.com

2.2.1. Types of personal data

CE FZE uses forms to enable enquiries by visitors to our website(s). Such enquiries are generally submitted to request further information regarding the process and pricing for implementation of Culture Excellence. These forms require the submission of the following personal data:

  • Name,

  • Email address,

  • Place of work (company name).

 

2.2.2. The purpose(s) of the process

Your personal data may be processed for the following purposes:

  • Contact by a member of the CE FZE team regarding your enquiry.

  • Passing of your personal details to a CE FZE partner if you (during the submission of your enquiry) specified that you or your employer already have a relationship with a specific CE FZE partner, to enable a member of CE FZE partner’s team to contact you regarding your enquiry.

 

2.2.3. Legal basis for processing

CE FZE processes your personal data on the following basis:

  • Legitimate interests: We base the processing of your personal data on our legitimate interests in, for example, responding to an enquiry related to the purchase and implementation of Culture Excellence, or enabling a CE FZE partner to respond to an enquiry related to the purchase and implementation of Culture Excellence (Article 6(1)(f) of the General Data Protection Regulation).

 

2.2.4. Retention period

Your personal data will be stored for 5 years after termination of the partnership (or other relationship) between you or your organisation and CE FZE, unless otherwise specified by you or a representative of your organisation. However, the information can be stored for a longer period in anonymised form.

 

3. If you are a partner supplier, collaborator etc.  

This section contains the policy for CE FZE's processing of personal data of sole proprietorship owners or contacts of suppliers and other business partners working with CE FZE, whereas we act in the capacity as data controller.

   

3.1. Collection of personal data

CE FZE may collect, process, and store your personal data in the following cases:

  • When you, your company or the company you work at enter(s) into an agreement with CE FZE,

  • When you, your company or the company you work for acknowledges CE FZE’s Terms and Conditions (including this Privacy Policy) on CE FZE’s website and / or on a CE FZE partner’s website),

  • When collaborating and communicating with CE FZE.

   

3.2. Types of personal data

CE FZE may collect, process, and store the following types of personal data about you:

  • Name, email address, phone number, and corresponding contact information.

We may receive such information directly from you (primarily through emails and other correspondence with you) or from a third party such as your employer.

     

3.3. The purposes of the processing

Your personal data may be processed for the following purposes:

  • General planning, fulfilment, and the management of collaborations, including contracts,

  • Administration such as the processing of payments, rating evaluations, accounting, auditing, as well as providing support,

  • Responding to enquiries from you.

   

3.4. Legal basis for processing

CE FZE primarily processes your personal data on one or more of the following grounds:

  • Contractual obligations: In certain cases, the processing of your personal data is necessary to fulfil a contract (Article 6(1)(b) of the General Data Protection Regulation).

  • Legitimate interests: We may process your personal data on the basis of our legitimate interests in, for example, managing day-to-day operations in accordance with legitimate and fair business practices, including planning, execution and management of the cooperation or our legitimate interest in, for example, providing support. The processing may also be necessary for our legitimate interest in preventing fraud or establishing, defending, or asserting legal claims (Article 6(1)(f) of the General Data Protection Regulation).

  • Legal obligation: The processing of your personal data will in some cases be necessary for compliance with legal obligations, such as our obligation to prevent illegal activities (Article 6(1)(c) of the General Data Protection Regulation).

3.5. Retention period

Your personal data will be stored for 5 years after termination of the partnership (or other relationship) between your organisation and CE FZE, unless otherwise specified by a representative of your organisation. However, the information can be stored for a longer period in anonymised form.

4. When you register as a user or responded to a culture assessment survey i.e. a Culture Excellence Program (including but not limited to Premium Culture Excellence, the BRCGS Food Safety Culture Excellence Additional Voluntary Module (AVM), the BRCGS Basic sample assessment and the SSAFE assessment)      

4.1. Role of CE FZE

When you register as a user or responded to a culture assessment survey arranged by your employer and CE FZE (“Culture Excellence Program”), CE FZE processes your personal data in the capacity as data processor / sub-processor on behalf of your employer (our customer) who is data controller. CE FZE, thus, works under an instruction only to process certain personal data and for defined purposes of the Culture Excellence Program, which ultimately is to prepare a culture assessment survey report.

The customer decides:

  • Who has access to the Culture Excellence Program Platform data in each site (and / or a group of sites),

  • How long the individuals have access to the data and if the access needs to be revoked / changed,

  • Whether each individual should see all of the reporting data or a sub-set of the reporting data (e.g. qualitative comments are shown or hidden based on customer request).

 

4.2. Collection of personal data

CE FZE may collect, process, and store your personal data in the following cases:

  • When you or your employer register(s) yourself / you as a user for the Culture Excellence Program,

  • When you or your employer register(s) your place of work for the Culture Excellence Program and you provide a response to a survey.

    

4.3. Types of personal data

CE FZE may collect, process, and store the following types of personal data about you:

  • Name and email address

  • Your responses to a Culture Excellence survey (IMPORTANT: The Culture Excellence survey tool does not collect names or email addresses (or other uniquely identifying information such as employee ID), and the standard demographic questions do not include personal details such as age or gender. For the purposes of anonymity, CE FZE asks Customers to not request the CE Survey to be customised to include too many organisational demographic questions (which correspond to data filter functionality on the CE Platform), and as a further back-up, the CE Platform has an anonymity feature that prevents response data being shared if there is a group of less than 5 people who have responded to a question. These steps (along with others, explained within this document) are to prevent the collection and / or dissemination of personal information via the Culture Excellence survey and Culture Excellence platform). As such, as far as is reasonably possible, provided customers and survey respondents adhere to CE FZE’s guidelines, CE FZE anonymises survey responses. Additionally, no IP addresses are collected with or linked to survey responses).

   

4.4. The purposes of the processing

Your personal data may be processed for the following purposes:

  • Enabling the creation and provision of user accounts and logins to the Culture Excellence reporting platform,

  • The creation of Culture Excellence reporting based on survey response data.

 

4.5. Legal basis for processing

CE FZE primarily processes your personal data on one or more of the following grounds:

  • Contractual obligations: In certain cases, the processing of your personal data is necessary to fulfil a contract (Article 6(1)(b) of the General Data Protection Regulation).

  • Legitimate interests: We may process your personal data on the basis of our legitimate interests in, for example, providing Culture Excellence services as requested by customers (Article 6(1)(f) of the General Data Protection Regulation).

 

4.6.  Retention period

As long as necessary for the provision of the Culture Excellence Program, unless a longer retention is required by law. CE FZE retains data until a deadline specified by the customer (customers are given an option of a duration of 5, 10, 15 or 20 years). Customers specify the duration during the provision of the Services; Customers may change their specified duration subject to a 6 month notice period.

5. Background

For more information about our Culture Excellence Program please see our General Terms, which in detail describe purposes and related processing activities.

6. Transmission to other controllers and entrustment to data processors

To achieve the above purposes, we may give third parties access to your personal data, which, based on a contractual relationship with CE FZE, provides relevant services, this could be IT suppliers or other suppliers that process personal data for us. Such suppliers will only process personal data in accordance with our instructions according to the signed data processing agreements.

 In the context of CE FZE's development, the corporate structure may change, e.g., by the total or partial sale of the company. In the case of a partial transfer of assets containing personal data, the processing basis for the related transfer of personal data is, as a rule, Article 6(1)(f) of the General Data Protection Regulation, since CE FZE has an interest in transferring parts of its assets and making commercial/structural changes.

 In addition to what is described above, your personal data is generally not disclosed to a third party without your consent. However, in certain circumstances and under the law, it may be necessary to disclose your personal data to e.g. if we are under a legal obligation to do so.

 If your personal data are transferred to data processors or data controllers established in countries outside the EU/EEA that do not have an adequate level of protection, such a transfer will only take place once a transfer basis is secured. In addition, the transfer will be based on the EU Commission's standard contracts. If you have any questions about the basis for transfers to countries outside the EU/EEA please contact us at enquiries@culturexcellence.com.

7. Your rights

  • You have the right to access the personal data we process about you

  • You have the right to object to our collection and further processing of your personal data

  • You have the right to rectification and deletion of your personal data, however there are certain statutory exceptions, including the Bookkeeping Act

  • You have the right to ask us to restrict the processing of your personal data

  • In certain circumstances, you may also request to receive a copy of your personal data and to transmit the personal data you have provided to us to another data controller (data portability)

  • You can withdraw any consents you may have given at any time. We will then delete your personal data unless we may continue the processing on another basis.

8. Questions and complaints

If you have any questions about this privacy policy or if you wish to complain about the way we process your personal data, please feel free to contact us at email: enquiries@culturexcellence.com.

 If your complaint is not resolved by us and you want to proceed with the case, you can complain to your relevant supervisory authorities: https://edpb.europa.eu/about-edpb/about-e.