Privacy and Cookies Policy

Last updated: November 2022

Summary

This section summarises how we obtain, store and use information about you. It is intended to provide a very general overview only. It is not complete in and of itself and it must be read in conjunction with the corresponding full sections of this Privacy Policy.

This Privacy Policy provides an explanation as to what happens to any Personal Data that you provide to us, or that we collect from you.

By continuing to use our website and services (“Services”), you agree to our Terms and Conditions (“Terms”) and this Privacy Policy for the collection and processing of your Personal Data.

This Privacy Policy sets out our use of any and all Data collected by us in relation to your use of our website, www.culturecuppa.com (“Website”) and/or of Services offered by us under the “Culture Cuppa” umbrella. The Website is operated by Perfect Cuppa English Ltd. under the name of Culture Cuppa, represented by Victoria Rennoldson (“Perfect Cuppa”, “Culture Cuppa”, “we”, “us”, “our”, “ourselves”).

Data Controller: Perfect Cuppa English Limited, registered Company Number: 11339391. The registered address is 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ.

As a business operating in the United Kingdom, we are registered with the Information Commissioner’s Office (“ICO”) under registration number ZB019024.

The person responsible for data protection is Victoria Rennoldson. For any queries relating to the management of your Personal Data please do not hesitate to send us an email at victoria@culturecuppa.com

“Data Controller” shall have the meaning as defined under Article 4 of the EU General Data Protection Regulation 2016/679 (“GDPR”).

“Personal Data” (“Data”) shall have the meaning given to it under Article 4 of the GDPR 2016/679, and which is more particularly defined in this Privacy Policy below.

How we collect or obtain information about you:

when you provide it to us (e.g. by contacting us, subscribing for our newsletter or providing information through our contact form).
from your use of our Website, using cookies

Information we collect:

“Personal Data” has been defined under the GDPR as “any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular, by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.”

Any references to “Personal Data” in this Privacy Policy therefore means information about living individuals, which, alone or in conjunction with other information held by us is capable of identifying them. The GDPR 2016/679, the UK GDPR, The Data Protection Act 2018 and any other national implementing legislation relating to data protection in the UK, regulate our use of your Personal Data (collectively “Applicable Data Protection Law”).

In order to provide our Services or for the purposes of conducting our business we may need the following Data from the individuals we are dealing with (“you”, “yours”, “yourself/yourselves”).

We have tried to cover categories of Data that we generally require while providing Services to our clients or for the purposes of operating our business. However, this is not an exhaustive list.

Name
Contact details and email address
IP address, information from cookies, information about your computer or device (e.g. device and browser type), information about how you use our website (e.g. which pages you have viewed, the time when you view them and what you clicked on and the geographical location from which you accessed our website (based on your IP address).

How we use your information: for administrative and business purposes (particularly to contact you), to improve our business and website, to advertise our services, to connect with you on social media platforms, to provide our services to you and to send you invoices in relation to the same, to analyse your use of our website, and in connection with our legal rights and obligations, and where you have opted in, to send you newsletters and other promotional content relating to our business.

Lawful basis for processing your Data

Consent

In order to avail of our Services, you consent to us obtaining and processing your Personal Data. While dealing with you we may issue Terms of Business or execute a contract outlining the terms and conditions of our engagement with you. The Terms of Business/contract along with this Privacy Policy set out the purposes for which your Personal Data may be obtained and processed by us. By accepting the Terms of Business or by using our Website or by executing a contract with us and by continuing to deal with us you confirm that you have consented to us processing your Personal Data in accordance with our Terms and this Privacy Policy.

Contractual necessity

One of the grounds for obtaining and processing your Personal Data is so that we can perform our Services in line with the scope of work and Terms of Business mutually agreed to by us.

Compliance with legal obligations

We may have to collect Personal Data in order to comply with certain legislative and regulatory requirements relating to client due diligence. Consequently, we may process your Data to carry out identity checks and maintain records of customer due diligence.

We may employ third party service providers for the purposes of carrying out client identity checks. However, we remain the Data Controllers.

Legitimate interests

In circumstances where you are a client or are an employee at Culture Cuppa or Perfect Cuppa English we may have to process your Personal Data to promote and pursue legitimate interests of the public and/or our organisation, and/or yours as our client or employee.

* However, you can object to us processing your Personal Data, on any of these bases at any time and, if you do so, we will stop processing the Personal Data unless we can show compelling legitimate grounds which override your rights and interest such as, without limitation your own health and safety or the health and safety of any other person(s), or the legitimate interest of the our organisation and/or the public or we need the Data to establish, exercise or defend legal claims – see “Your rights” below.

Disclosure of your information to third parties: only to the extent necessary to run our business, to our service providers, where required by law or to enforce our legal rights and obligations.

Do we sell your information to third parties (other than in the course of a business sale or purchase or similar event): No

How long we retain your information: for no longer than necessary, taking into account any legal obligations we have (e.g. to maintain records for tax purposes), any other legal basis we have for using your information (e.g. your consent, performance of a contract with you or our legitimate interests as a business) and certain additional factors.

How we secure your information: using appropriate technical and organisational measures such as storing your information on secure servers, encrypting transfers of data to or from our servers using Secure Sockets Layer (SSL) technology, only granting access to your information where necessary.

Use of cookies: we use cookies on our website including functional and analytical cookies. For more information, please read our cookies policy in the main section below.

Transfers of your information outside the European Economic Area: In certain circumstances, we will transfer your information outside of the European Economic Area, including to the United States of America. Where we do so, we will to the extent possible ensure appropriate safeguards are in place. Where possible, we have also provided links to the respective privacy policies of third parties who receive your Personal Data. We encourage you to read the relevant third-party privacy policies so that you can make an informed decision and exercise your rights in relation to the collection and processing of your Personal Data.

Your rights in relation to your information

to access your information and to receive information about its use
to have your information corrected and/or completed
to have your information deleted
to restrict the use of your information
to receive your information in a portable format
to object to the use of your information
to withdraw your consent to the use of your information
to unsubscribe from our marketing and promotional communications
to complain to a supervisory authority, including to the ICO

Sensitive personal information: we do not knowingly or intentionally collect what is commonly referred to as ‘sensitive personal information’. Please do not submit sensitive personal information about you to us.

Protecting your privacy

At Culture Cuppa and Perfect Cuppa English, we are 100% committed to protecting the privacy and security of our clients and website visitors.

This version of the Privacy Policy reflects changes in data protection law. This page aims to help you understand what information we might collect about you and how we use it.

For all our services, the data controller, i.e. the company that is responsible for your privacy, is Perfect Cuppa English Limited, registered Company Number: 11339391. The registered address is Perfect Cuppa English, 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ.

Any questions regarding this policy and our privacy practices should be sent by email to victoria@culturecuppa.com

Information we collect when you visit our website

We collect and use information from website visitors in accordance with this section and the section titled Disclosure and additional uses of your information.

What we do with the information we gather

We use your information in a number of different ways and what we do depends on the information.

The majority of information stored is captured when an online visitor fills out an enquiry form or signs up to the newsletter – this information is stored in an encrypted format on the webserver and also emailed to Culture Cuppa– this information is only used in response to an enquiry submitted or sign up to the newsletter.

Will only use your personal information for legitimate business purposes to provide the services you have requested from us and, when consented, for marketing purposes. These include some or all of the following:

To provide you with the information, customer service and services that you request from us
To send you messages about your course by text or email
To administer any promotion or competition that you enter via our website(s)
When you consent, to provide you with information about services we offer that are similar to those that you have already purchased or enquired about by email.
When you have opted in, to send you newsletters and other promotional/marketing material and/or communications in relation to our services
To connect with you on social media platforms

Whenever we process Data for these purposes we will ensure that we always keep your Personal Data rights in high regard. You do not have to give us any of this personal information and it is your choice.

We will not share your information for marketing purposes with companies outside of our group.

Web server log information

We use a third-party server to host our website. Our website server automatically logs the IP address you use to access our website as well as other information about your visit such as the pages accessed, information requested, the date and time of the request, the source of your access to our website (e.g. the website or URL (link) which referred you to our website), and your browser version and operating system.

Our server is located in the United Kingdom.

Use of website server log information for IT security purposes
Our third-party hosting provider collects and stores server logs to ensure network and IT security and so that the server and website remain uncompromised. This includes analysing log files to help identify and prevent unauthorised access to our network, the distribution of malicious code, denial of services attacks and other cyber-attacks, by detecting unusual or suspicious activity.

Unless we are investigating suspicious or potential criminal activity, we do not make, nor do we allow our hosting provider to make, any attempt to identify you from the information collected via server logs.

Legal basis for processing: compliance with a legal obligation to which we are subject (Article 6(1)(c) of the General Data Protection Regulation).
Legal obligation: we have a legal obligation to implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk of our processing of information about individuals. Recording access to our website using server log files is such a measure.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: we have a legitimate interest in using your information for the purposes of ensuring network and information security.

Email

When you send an email to the email address displayed on our website we collect your email address and any other information you provide in that email (such as your name, telephone number and the information contained in any signature block in your email).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where your message relates to us providing you with services or taking steps at your request prior to providing you with our services (for example, providing you with information about such services), we will process your information in order to do so).

Transfer and storage of your information
We use a third-party email provider to store emails you send us. Our third-party email provider is Gmail (Google, Inc.). Their privacy policy is available here: https://policies.google.com/privacy

Emails you send us will be transferred and stored outside the European Economic Area on our third-party email provider’s servers in the United States of America. For further information please see the section of this privacy policy titled Transfers of your information outside the European Economic Area.

Contact form

When you contact us using our contact form, we collect the following information: your first name, last name, email address, phone number, where you heard about us from, IP address and any information you include in the message field. We also collect any other information you provide to us when you complete the contact form.

If you do not provide the mandatory information required by our contact form, you will not be able to submit the contact form and we will not receive your enquiry.

Transfer and storage of your information
Messages you send us via our contact form will be stored on our website’s server in the UK but also transferred to our email provider’s server (Gmail) outside the European Economic Area in the United States of America.

For further information about your information being transferred outside the European Economic Area, see the section of this privacy policy below titled “Transfers of your information outside the European Economic Area”.

Phone

When you contact us by phone, we collect your phone number and any information you provide to us during your conversation with us.

Transfer and storage of your information
Information about your call, such as your phone number and the date and time of your call, is processed by our third-party telephone service provider and stored in the United Kingdom.

Information we collect when you interact with our website

We collect and use information from individuals who interact with particular features of our website in accordance with this section and the section titled Disclosure and additional uses of your information.

E-Newsletter

When you sign up for our e-newsletter on our website to receive information on our services, free resources, tips, learning strategies, news & ideas by subscribing via our website or sign up forms, we collect the following information: your first name, last name, email address & where you heard about us from.

Clients who consent to receiving marketing emails will always have the option to unsubscribe at any point via a link at the bottom of every email they receive.

Clients enquiring online are NOT automatically added to a marketing database and will not be sent unsolicited email marketing without first being asked if they would like to opt in to receive marketing material.

Legal basis for processing: your consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: you give your consent to us sending you our e-newsletter by signing up to receive it using the steps described above.

Transfer and storage of your information
We use a third-party service to send out our e-newsletter and administer our mailing list, called Mailer lite. By clicking to submit your data, you acknowledge that the information you provide will be transferred to Mailer lite for processing in accordance with their Privacy Policy and Terms.

Disclosure and additional uses of your information

This section sets out the circumstances in which we will disclose information about you to third parties and any additional purposes for which we use your information.

Disclosure of your information to service providers

We use a number of third parties to provide us with services which are necessary to run our business or to assist us with running our business and who process your information for us on our behalf. These include the following:

Telephone provider (UK),
Email provider (Ireland & USA),
Mailing list provider (USA),
IT service provider (UK),
Web developer (UK), and
Hosting provider (UK),
Freelance trainers (UK, EU or outside of the EEA)
Social Media platforms (UK, USA)

Your information will be shared with these service providers where necessary to provide you with the service you have requested, whether that is accessing our website or ordering services from us.

We do not display the identities of all of our service providers publicly by name for security and competitive reasons. If you would like further information about the identities of our service providers, however, please contact us directly by email and we will provide you with such information where you have a legitimate reason for requesting it (where we have shared your information with such service providers, for example).

Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest relied on: where we share your information with these third parties in a context other than where is it is necessary to perform a contract (or take steps at your request to do so), we will share your information with such third parties in order to allow us to run and manage our business efficiently.

Legal basis for processing: necessary to perform a contract and/or to take steps at your request prior to entering into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: we may need to share information with our service providers to enable us to perform our obligations under that contract or to take the steps you have requested before we enter into a contract with you.

Disclosure of your information to other third parties

We promise to keep your details safe and will never sell your data on to any third party including your name, address, email address or telephone number outside of our company.

We disclose your information to other third parties in specific circumstances, as set out below.

Providing information to Google Inc.
Google collects information through our use of Google Analytics on our website. Google uses this information, including IP addresses and information from cookies, for a number of purposes, such as improving its Google Analytics service. Information is shared with Google on an aggregated and anonymised basis. To find out more about what information Google collects, how it uses this information and how to control the information sent to Google, please see the following page: https://www.google.com/policies/privacy/partners/

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): meeting our contractual obligations to Google under our Google Analytics Terms of Service (https://www.google.com/analytics/terms/us.html).
You can opt out of Google Analytics by installing the browser plugin here: https://tools.google.com/dlpage/gaoptout

Transfer and storage of your information:
Information collected by Google Analytics is stored outside the European Economic Area on Google’s servers in the United States of America.

For further information about the circumstances in which your information is transferred outside the European Economic Area, see the section of this Privacy Policy below titled Transfers of your information outside the European Economic Area.

Sharing your information with third parties, which are either related to or associated with the running of our business, where it is necessary for us to do so. These third parties include our accountants, advisors, business partners, and independent contractors.

Further information on each of these third parties is set out below.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: running and managing our business efficiently.

Accountants
We share information with our accountants for tax purposes. For example, we share invoices we issue and receive with our accountants for the purpose of completing tax returns and our end of year accounts.

Our accountants are located in the United Kingdom.

Advisors
Occasionally, we obtain advice from advisors, such as accountants, financial advisors, lawyers and public relations professionals. We will share your information with these third parties only where it is necessary to enable these third parties to be able to provide us with the relevant advice.

Our advisors are located in the United Kingdom.

Business partners
Business partners are businesses we work with which provide services which are complementary to our own or which allow us to provide services which we could not provide on our own. We share information with our business partners where you have requested services which they provide whether independently from, or in connection with or own services.

Independent contractors
Occasionally, we use independent contractors in our business. Your information will be shared with independent contractors only where it is necessary for them to perform the function we have hired them to perform in relation to our business.

Sharing your information with a prospective or actual purchaser or seller in the context of a business or asset sale or acquisition by us, a merger or similar business combination event, whether actual or potential.

Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): sharing your information with a prospective purchaser, seller or similar person in order to allow such a transaction to take place.

Transfers of your information outside the European Economic Area

Your information will be transferred and stored outside the European Economic Area (EEA) in the circumstances set out below.

We will also transfer your information outside the EEA or to an international organisation in order to comply with legal obligations to which we are subject (compliance with a court order, for example). Where we are required to do so, we will to the extent possible ensure appropriate safeguards and protections are in place.

Email

Information you submit to us by email is transferred outside the EEA and stored on our third-party email provider’s servers. Our third-party email provider is: Gmail. You can access their privacy policy here: https://www.google.com/policies/privacy/

Country of storage: United States of America.

Contact form

Information you submit to us via our contact form is transferred outside the EEA and stored on our third-party hosting provider’s servers. Our third-party email provider is: Gmail. You can access their privacy policy here: https://www.google.com/policies/privacy/

Country of storage: United States of America.

E-Newsletter/ Marketing Communication

Information you submit to us when you sign up for our mailing list is transferred outside the EEA and stored on our third-party mailing list provider’s servers. Our third-party mailing list provider is: Mailer lite. You can access their Privacy Policy and Terms here.

Country of storage: Ireland & United States of America.

Google Analytics

Information collected by Google Analytics (your IP address and actions you take in relation to our website) is transferred outside the EEA and stored on Google’s servers. You can access Google’s privacy policy here: https://www.google.com/policies/privacy/

Country of storage: United States of America.

Testimonials

If you give us feedback, we may use it to improve our services and we may publish it online or offline to promote our business and our services. We will ask for your consent before we publish it.

Social Media

When you share information publicly on the Website or on social media platforms, for example a comment on a blog post or within social media groups, it may be indexable by search engines, including Google, which may mean that the information is made public.

When you participate in group trainings and/or conversations on social media your Personal Data is visible to members of the concerned training group/social media group and to the public in general. Please note that you participate in group trainings and/or social media related activities at your sole discretion, and we shall not be liable for the access and use of your Personal Data by third parties, via social media or otherwise, including circumstances, where third parties contact you or initiate a conversation with you, on social media or otherwise, as a result of your information made available to them via our group training programs, social media groups or any activity you participate in through our social media platforms or by connecting with us on social media.

Cookies

What is a cookie?

Cookies are small text files sent by us to your computer or mobile device. They are unique to your account or your browser.

Session-based cookies last only while your browser is open and are automatically deleted when you close your browser. Persistent cookies last until you or your browser delete them or until they expire.

How do we use cookies?

Most websites you visit will use cookies in order to improve your user experience by enabling that website to ‘remember’ you, either for the duration of your visit (using a ‘session cookie’) or for repeat visits (using a ‘persistent cookie’). This website (https://www.culturecuppa.com) uses persistent cookies to store your unique session identifier on your computer. Your information is not stored on your computer but on the webserver hosting this website, only a unique ID is stored on your computer which allows us to retrieve the correct information from the database.

This website (https://www.culturecuppa.com/) may from time to time use persistent cookies (the small text files stored on your computer) to record your preferences or activity between visits. These cookies do not store personal information about you or your computer and you can clear them at any point by deleting your browser history – for more information about cookies you can visit: http://www.aboutcookies.org/ Culture Cuppa does not share cookies or any of your data with any other company outside of our company

What to do if you do not want cookies to be set?

If you prefer that this website does not store information on your computer or mobile device, it is possible to block some or all cookies, or even to delete cookies that have already been set; but you need to be aware that you might lose some functions on this website. For information on how to control cookies being stored on your computer see: http://www.aboutcookies.org/Default.aspx?page=1

I agreed for this site to store cookies but have changed my mind

If you previously agreed to allow www.culturecuppa.com to store cookies on your computer but have subsequently changed your mind then you can delete the cookies set by this choice. See http://www.aboutcookies.org/Default.aspx?page=1 to learn how to control and remove cookies stored on your computer.

Keeping your information

We will hold on to your information for as long as is needed to be able to provide the services to you that you have requested.

If reasonably necessary or required to meet legal or regulatory requirements we may also keep hold of some of your information as required, even after you have decided to stop using our services.

If you have signed up to receive Culture Cuppa’s marketing communications, then we will only retain your information for as long as we have your consent to send you marketing.

Controlling your personal information

We want to make sure that your personal information is accurate and up to date. If you would like to delete or make changes to your personal details, you can do so by getting in touch.

You have the right under applicable data protection laws to access information held about you and you can do so by contacting us using the details provided below in this policy.

Your rights

You have many rights relating to your personal information:

The right to be informed about how your personal information is being used (like this Privacy Policy)
The right to request access to personal information held about you and a copy of it (“subject access rights”)
The right to obtain, without undue delay, the rectification of inaccurate or incomplete personal data
The right to request that we delete your data, or stop processing it or collecting it, in some circumstances
The right to withdraw consent, unsubscribe and stop direct marketing messages
The right to object to the processing of, Personal Data in certain circumstances, for example, where Culture Cuppa processes Personal Data for legitimate purposes but you do not feel that your interests or fundamental rights and freedoms have been protected
The right to request that we transfer or port elements of your Data either to you or another service provider on your behalf where technically feasible

to object to automated decisions (you can unsubscribe from our marketing automation platform by clicking on the “unsubscribe” link in the footer of any email you receive from us or by emailing us at victoria@culturecuppa.com)
a right to object to processing that is likely to cause or is causing damage or distress.
The right to complain to your data protection regulator, in the UK, the Information Commissioner’s Office (ICO)

If you want to (1) tell us to stop using your Data for direct marketing or withdraw consent from us processing your Personal Data for any of the purposes mentioned in this Notice; (2) exercise your subject access rights; (3) tell us about inaccurate Personal Data you think we hold on you; or (4) object to a use you believe we’re making of your Data which is causing, or is likely to cause damage or distress, or (5) request that we erase your Personal Data, please contact our Data Protection Manager at victoria@culturecuppa.com

Verifying your identity where you request access to your information

Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so.

These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorised access to your information.

How we verify your identity
Where we possess appropriate information about you on file, we will attempt to verify your identity using that information. If it is not possible to identity you from such information, or if we have insufficient information about you, we may require original or certified copies of certain documentation in order to be able to verify your identity before we are able to provide you with access to your information.

We will be able to confirm the precise information we require to verify your identity in your specific circumstances if and when you make such a request.

Links to other websites

Our website may contain links to other websites run by other organisations. This Privacy Policy applies only to our website (https://www.culturecuppa.com) only. We encourage you to read the privacy statements on the other websites you visit. We cannot be responsible for the privacy policies and practices of other sites even if you access those using links from our website.

Changes to our Privacy Policy

From time to time we may change our Privacy Policy to reflect how we are processing your Data. We will always update the Privacy Policy on our website, so please try to read it when you visit the website.

How to contact us

If you have any other questions relating to your online privacy with Culture Cuppa, please contact victoria@culturecuppa.com

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