March 2025
Welcome to ScultureAI Limited’s Privacy Policy (“Privacy Policy”).
At ScultureAI Limited (“we”, “us”, or “our”) we are committed to protecting and respecting your privacy and Personal Data in compliance with the United Kingdom General Data Protection Regulation (“GDPR”), the Data Protection Act 2018 and all other mandatory laws and regulations of the United Kingdom.
If you are a U.S. resident, our policies and procedures on the collection, use and disclosure of your information when you use our services are also intended to respect those protections afforded to you by United States law, including without limitation, applicable state legislation.
This Privacy Policy explains how we collect, process and keep your personal data safe. The Privacy Policy will tell you about your privacy rights and how the applicable law protects you, and our obligations regarding your privacy.
If you use our App and services through an organisation (like your employer), that organisation is the Data Controller and is responsible for ensuring compliance with applicable privacy laws. In these circumstances, ScultureAI acts as a Data Processor and we process your data in accordance with the Data Controller’s instructions and in line with the Data Processing Agreement we have signed with them.
For information on how your Personal Data is handled in such situations, please refer to the privacy notice provided by your employer or relevant organisation.
In some cases, ScultureAI acts as a Data Controller; this is where we collect and process business contact information from corporate clients, such as names, job titles, and email addressed to allow us to manage the account, provide service updates and send marketing communications.
The rest of this policy applies to (a) where we act as a Data Controller as described above, or (b) where you access our website or use our App or products independently.
This Privacy Policy applies to your use of:
The individuals from which we may gather and use data can include:
and any other people that the organisation has a relationship with or may need to contact.
ScultureAI Limited is your Data Controller and responsible for your Personal Data. We are not obliged by the GDPR to appoint a data protection officer and have not voluntarily appointed one at this time. Therefore, any inquiries about your data should either be sent to us by email to privacy@old-sai.mywebsi.co.uk or by post to 35 Ballards Lane, London, N3 1XW, United Kingdom.
You have the right to make a complaint at any time to the Information Commissioner’s Office (“ICO”), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
“Personal Data” means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together below. Not all of the following types of data will necessarily be collected from you but this is the full scope of data that we collect and when we collect it from you:
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.
We use “cookies” and similar tracking technologies to track activity on our App and Site and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze our services. For more information regarding our use of cookies and similar tracking technologies, please visit our Cookies Policy page or contact us for more information.
There are a number of justifiable reasons under the GDPR that allow collection and processing of Personal Data. The main avenues we rely on are:
“Legitimate Interest”: We might need to collect certain information from you to be able to meet our legitimate interests – this covers aspects that can be reasonably expected as part of running our business, that will not have a material impact on your rights, freedom or interests. Examples could be your address, so that we know where to deliver something to, or your name, so that we have a record of who to contact moving forwards.
Our services do not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us at privacy@old-sai.mywebsi.co.uk. If we become aware that we have collected Personal Data from anyone under the age of 13 without verification of parental consent, we take steps to remove that information from our servers.
You will receive marketing and new content communications from us if you have created an account and have chosen to opt into receiving marketing communications. We may also collect your name and email address if you attend one of our events or you fill out a form on our website (or a third-party website), for example to download our insights and research. From time to time, we may make suggestions and recommendations to you about goods or services that may be of interest to you. Please see paragraph 4.4 below for details of how to opt out of marketing communications.
We will use data from your interaction with our App to produce insights and research, and to improve our App and Services. This data will be de-identified and aggregated to ensure it cannot be traced back to you. Your data will be anonymised and combined with other users’ data, so you cannot be identified or singled out.
We will only use your Personal Data when the law allows us to.
Set out below is a table containing the different types of Personal Data we collect and the lawful basis for processing that data. Please refer to section 2.2 for more information on the lawful basis listed in the table below.
Examples provided in the table below are indicative in nature and the purposes for which we use your data may be broader than described but we will never process your data without a legal basis for doing so and it is for a related purpose. For further enquiries please contact us.
PRIVACY TABLE | |||
Activity/purpose | Type of data | Lawful basis for processing data | Retention period |
To register you for, and provide you with, the website version of our App including our “Try it Now” feature or similar | Profile/Identity Data Contact Data
Content of emails used to trial the website ‘Try it Now’ feature or similar tools
| Consent | 7 years from the date you cease being an active user of the App or Service or the end of our contractual relationship with you |
To manage our relationship with you including:
| Profile/Identity Data Contact Data Marketing and Communications Data Customer Support Data | 1. Necessary to comply with a legal obligation 2. Necessary for our legitimate interests (to keep our records updated and manage our relationship with you) | 7 years from the date you cease being an active user of the App or Service, or the end of our contractual relationship with you (which ever is latest) . |
To administer and protect our business, Site, App and Services (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | Profile/Identity Data Contact Data Technical Data | Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security) | 7 years from the date when the Site, App or Services are no longer in use . |
To use your coaching input for the delivery of our coaching tool
| Data within Emails and internal messages processed by us when you interact with our App
| Necessary for our legitimate interests (to allow us to deliver coaching to you )
| Coaching Input is deleted within ten (10) minutes of the end of a coaching interaction.
|
To use your feedback on our coaching recommendations to improve the App and our Services | Feedback on the App output in the form of “likes or dislikes” or other feedback mechanisms | Necessary for our legitimate interests (to allow us to improve the App) | 6 months from date of response |
To use surveys to gather feedback to improve the App and understand how people interact with it | Email address
Survey responses | Necessary for our legitimate interests to allow us to improve the App and our services. | 6 months from date of response |
To use data analytics to improve our Site, App, Services, customer relationships and experiences and to measure the effectiveness of our communications | Technical Data Usage Data
| Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) | [5 years] from the date of the earliest record being analysed (where possible we will pseudonymised or anonymized data)
|
To send you relevant marketing communications about products or services that may be of interest to you | Profile/Identity Data Contact Data Marketing and Communications Data | Consent | Until the earlier of you opting out of marketing communications or 2 years |
To manage your role application when you submit your details via our “Join the Team” (or similar) feature on the website or apply by other means. | Profile/Identity Data Contact Data
Information contained in your CV, application or correspondence | Consent | Rejected job applicants ( Six months after applicant is notified of rejection. Successful job applicants – 7 years after employment ceases.
|
We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Under certain circumstances, you have the following rights under data protection laws in relation to your Personal Data:
If you wish to make a request under any of these rights, please contact us at privacy@old-sai.mywebsi.co.uk.
We are concerned with keeping your data secure and protecting it from inappropriate disclosure. Any Personal Data collected by us is only accessible by a limited number of employees who have special access rights to such systems and are bound by obligations of confidentiality. If and when we use subcontractors to store your data, we will not relinquish control of your Personal Data or expose it to security risks that would not have arisen had the data remained in our possession. However, unfortunately no transmission of data over the internet is guaranteed to be completely secure. It may be possible for third parties not under our control to intercept or access transmissions or private communications unlawfully. While we strive to protect your Personal Data, we cannot ensure or warrant the security of any Personal Data you transmit to us. Any such transmission is done at your own risk. If you believe that your interaction with us is no longer secure, please contact us.
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, if your request is clearly unfounded, we could refuse to comply with your request.
We may need to request specific information from you to help us confirm your identity and ensure you have the right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
You can ask us to stop sending you marketing messages at any time by using the unsubscribe link in our marketing emails or by emailing us at privacy@old-sai.mywebsi.co.uk.
Where you opt out of receiving these marketing messages, we will continue to retain other Personal Data provided to us as a result of interactions with us not related to your marketing preferences.
We may share non-Personal Data with third parties.
We may share your Personal Data with third party service providers and subcontractors or affiliates, only to the extent necessary to deliver our Services. We only share personal data with these third parties if they agree to strict contractual terms to keep our data secure, confidential and use it pursuant to our instructions.
We periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant processing of personal information. As at the date of this policy our appointed data processors include Prospect Global Ltd (trading as Sopro) Reg. UK Co. 09648733. You can contact Sopro and view their privacy policy here: http://sopro.io. Sopro are registered with the ICO Reg: ZA346877 and their Data Protection Officer can be emailed at: dpo@sopro.io.
We may also share Personal Data with interested parties in the event that we anticipate a change in control or the acquisition of all or part of our business or assets or with interested parties in connection with the licensing of our technology.
If ScultureAI Limited is sold or makes a sale or transfer, we may, in our sole discretion, transfer, sell or assign your Personal Data to a third party as part of or in connection with that transaction. Upon such transfer, the Privacy Policy of the acquiring entity may govern the further use of your Personal Data. In all other situations your data will still remain protected in accordance with this Privacy Policy (as amended from time to time).
We may share your Personal Data at any time if required for legal reasons or in order to enforce our terms or this Privacy Policy.
This App or Site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our App or Site, we encourage you to read the privacy policy of every app or website you visit.
We provide AI-powered coaching tools that analyse text and interactions to generate coaching and insights for our users. When you interact with our App, we use AI to analyse text in real time to produce insights based on behaviours and language identified from the text. We use third party AI models to process the text you submit but they do not retain this text beyond a short time after the session.
Our AI tools do not make automated decisions that have any legal or significant effects on individuals. They provide coaching suggestions and insights, but any actions based on those insights are the responsibility of the individual using the tool.
We do not use your personal data to train or improve our AI tools. Where we use third party APIs such as Google Workspace, Slack, or Microsoft Graph APIs we ensure they do not use your personal data to develop, improve, or train foundation models. The data accessed through these APIs is strictly used to provide and improve our services and is handled in compliance with all relevant privacy and data protection regulations.
If you have questions about how we use AI to process your personal data, please contact privacy@old-sai.mywebsi.co.uk.
We will only retain your Personal Data for as long as reasonably necessary to fulfill the purposes we collected it for or as otherwise set out in the Privacy Table above. We may retain your Personal Data for a longer period than usual in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
Some of our external third party vendors are based outside the UK (particularly the USA) so their processing of your Personal Data may involve a transfer of data outside the UK.
If we transfer your Personal Data outside of the UK, we ensure a similar degree of protection is afforded to it by ensuring safeguards are implemented. Specifically, including for transfers to the USA, we may use specific contracts approved by the UK which give Personal Data the same protection it has in the UK.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the updated or new Privacy Policy on this page. We will let you know via email and/or a prominent notice within our App or Site, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes.
Should you discover that this policy’s terms do not adequately account for those privacy protections afforded you by the applicable laws of the jurisdiction where you reside, please contact us at privacy@old-sai.mywebsi.co.uk. We will investigate your position as appropriate and provide feedback. Should we determine that our personal data privacy practices require modification given your circumstances, we will promptly attend to the matter.
By using our App, Site or Services, you consent to the collection and use of data by us as set out in this Privacy Policy. Continued access or use of the App, Site or Services will constitute your express acceptance of any modifications to this Privacy Policy.
