This privacy notice tells you what to expect us to do with your personal information.

• Contact details
• What information we collect, use, and why
• Lawful bases and data protection rights
• Where we get personal information from
• How long we keep information
• Who we share information with
• Sharing information outside the UK
• How to complain

Contact details

Email

enquiries@cultureshockscotland.com

What information we collect, use, and why

We collect or use the following information to provide and improve products and services for clients:

• Names and contact details
• Addresses
• Gender
• Pronoun preferences
• Occupation
• Payment details (including card or bank information for transfers and direct debits)
• Financial data (including income and expenditure)
• Transaction data (including details about payments to and from you and details of products and services you have purchased)
• Usage data (including information about how you interact with and use our website, products and services)
• Information relating to compliments or complaints
• Records of meetings and decisions
• Account access information
• Website user information

We collect or use the following personal information for the operation of client or customer accounts:

• Names and contact details
• Addresses
• Purchase or service history
• Account information, including registration details
• Marketing preferences
• Technical data, including information about browser and operating systems

We collect or use the following personal information for information updates or marketing purposes:

• Names and contact details
• Addresses
• Profile information
• Marketing preferences
• Purchase or account history
• Website and app user journey information
• IP addresses
• Company information

We also collect or use the following information for information updates or marketing purposes:

• Racial or ethnic origin
• Political opinions
• Religious or philosophical beliefs
• Trade union membership
• Genetic information
• Health information
• Sex life information
• Sexual orientation information

We collect or use the following personal information for recruitment purposes:

• Contact details (eg name, address, telephone number or personal email address)
• Date of birth
• National Insurance number
• Copies of passports or other photo ID
• Employment history (eg job application, employment references or secondary employment)
• Education history (eg qualifications)
• Right to work information
• Details of any criminal convictions (eg Disclosure Barring Service (DBS), Access NI or Disclosure Scotland checks )

We collect or use the following personal information for dealing with queries, complaints or claims:

• Names and contact details
• Address
• Payment details
• Account information
• Purchase or service history
• Witness statements and contact details
• Relevant information from previous investigations
• Customer or client accounts and records
• Financial transaction information
• Information relating to health and safety (including incident investigation details and reports and accident book records)
• Correspondence

Lawful bases and data protection rights

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.

Which lawful basis we rely on may affect your data protection rights which are in brief set out below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

• Your right of access – You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. You can read more about this right here.
• Your right to rectification – You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. You can read more about this right here.
• Your right to erasure – You have the right to ask us to delete your personal information. You can read more about this right here.
• Your right to restriction of processing – You have the right to ask us to limit how we can use your personal information. You can read more about this right here.
• Your right to object to processing – You have the right to object to the processing of your personal data. You can read more about this right here.
• Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. You can read more about this right here.
• Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. You can read more about this right here.

If you make a request, we must respond to you without undue delay and in any event within one month.

To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

Our lawful bases for the collection and use of your data

Our lawful bases for collecting or using personal information to provide and improve products and services for clients are:

• Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

Our lawful bases for collecting or using personal information for the operation of client or customer accounts are:

• Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

Our lawful bases for collecting or using personal information for information updates or marketing purposes are:

• Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
• As a marketing agency it may be necessary for us to collate and categorise personal information for the benefit of growing our or our clients business, assessing market size, devising marketing strategy and segmentation of customer groups. We will always take the utmost care with personal data in-line with our legal and ethical obligations, ensuring it is protected and used fairly. This information may be publicly available, purchased from legitimate providers or provided by consent.

Our lawful bases for collecting or using personal information for recruitment purposes are:

• Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:

• Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

Where we get personal information from

• Directly from you
• Regulatory authorities
• Publicly available sources
• Previous employment
• Market research organisations
• Credit reference agencies
• Providers of marketing lists and other personal information
• Suppliers and service providers

How long we keep information

We will retain personal information for up to 6 months from the date it was last modified or updated. If a data subject requests that we delete their information we will action this within 30 days and confirm deletion in writing.

Who we share information with

Data processors

Database Software

This data processor does the following activities for us: Store and process client and marketing information for business purposes

Data Analysis

This data processor does the following activities for us: Collate, analyse and report on data for marketing and business purposes

Accounting

This data processor does the following activities for us: Store and process supplier and client data for payment processing and bookkeeping.

Others we share personal information with

• Debt collection agencies
• Other financial or fraud investigation authorities
• Professional or legal advisors
• Organisations we’re legally obliged to share personal information with
• Publicly on our website, social media or other marketing and information media
• Suppliers and service providers
• Professional consultants

Sharing information outside the UK

Where necessary, our data processors may share personal information outside of the UK. When doing so, they comply with the UK GDPR, making sure appropriate safeguards are in place.

For further information or to obtain a copy of the appropriate safeguard for any of the transfers below, please contact us using the contact information provided above.

Organisation name: Zoho

Category of recipient: Database Software

Country the personal information is sent to: USA and EU

How the transfer complies with UK data protection law: Data Bridging Agreement

How to complain

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.

The ICO’s address:           

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113

Website: https://www.ico.org.uk/make-a-complaint

Last updated

10 October 2024