Privacy Policy

What does this policy cover?

This privacy policy (“Privacy Policy”) applies to all visitors of the culturecounts.cc website (the “Website”), along with all customers and visitors of services provided by Culture Counts (the “Platform”) which are offered by Culture Counts Pty Ltd and/or any of its affiliates (“Culture Counts” or “we” or “us”). This policy describes how we process your personal information in connection with the Website and the Platform. This includes how we collect information through the use of cookies and related technologies. It also tells you how you can access and update your personal information and describes the data protection rights that may be available under your country’s or state’s laws, a right to object to some processing that we carry out or, where we rely on consent, how to withdraw that consent.

Please read this Privacy Policy carefully. By accessing or using any part of the Website or Platform, you acknowledge you have been informed of and consent to our practices with regard to your personal information and data.

Who we are

We are Culture Counts Pty Ltd. Our website address is https://dev.culturecounts.cc.

At Culture Counts, we believe that successful research and engagement rely on the goodwill of the public. Protecting the privacy of research participants is essential for ongoing goodwill and is vital to our business.

Culture Counts respects your right to privacy and is committed to safeguarding the privacy of our customers and software application users. We adhere to the Australian Privacy Principles established by the Privacy Act 1988 (Cth) and, where applicable, the General Data Protection Regulation (GDPR). This policy sets out how we collect and treat your personal information.

The purpose of our software is to help our customers gather, analyse and present the opinions of the public directly to the people making decisions about the impact and value of those services. Culture Counts encourages our customers to ask members of the public for their opinions on a variety of different matters using our platform. Customers can use our platform to distribute questionnaires and surveys and collect this information.

When different customers using our platform use similar questions in their surveys, Culture Counts seeks to combine this information, to give customers an understanding as to how they compare to their peers. We seek to do this in a way that protects and ensures the privacy and anonymity of survey respondents.

What do we mean by ‘personal information’?

Personal information refers to information we hold which is identifiable as being about you, as an individual. You may be a visitor to our website, a customer of our platform, or a visitor to our platform (hosted by one of our customers). If we hold information that was about you but cannot be linked back to you or used to identify you, this is not personal information. This is referred to as anonymous information. One of the core principals of our platform is to collect anonymous information

What personal information do we collect?

Our Platform

If you are a visitor to our platform, this means you likely completed a survey that was created with and hosted on our platform. If you are a visitor to our platform, we collect the following information:

  • IP Address

  • Information about your device

We keep this information for 14 days through the use of “Logs”.

Logs are files that record events and interactions that occur on our platform. These logs capture a range of data points such as the IP address of your device, the type of device you are using, browser type, the pages you visit, and the time and date of your visit. Logs are essential for diagnosing issues, maintaining the security of our platform, and ensuring that it runs correctly. By analysing logs, we can detect and respond to potential threats, troubleshoot technical problems, and optimise the user experience of the Platform.

Logs are not shared with, or accessible by, our customers. They are stored independently of your survey responses. This is to prevent information about your device from potentially being used to identify you and associated with your survey responses. We do not use log data to track or identify you.

If you are a visitor to our platform completing a survey, you are deliberately and consciously sharing the information you provide with one of our customers. We design and encourage our customers to only collect anonymised data. This means that if you provide information that could be used to identify you, you are at risk of being identified by anyone with access to that data. The exception to this rule is if you provide an email address in your survey response. We separate all email addresses from your other survey responses to prevent you from being identified.

Our Website

Like most website operators, we automatically collect technical information about your device including your device’s internet protocol (IP) address; and information about your visit to our Websites (the referral URL, the content viewed and the content interacted with).

Some of this information is collected using cookies and related technologies. See below for further information on these technologies. We collect this information to better understand how visitors use our websites, to improve our websites and experience for visitors, and to monitor the security of the websites.

Our Customers

Our customers are those that use our platform and enter into a service agreement with us to use it. to fulfill a contract or take steps linked to a contract with you.

Information we require to administer these contracts is provided by our customers. We collect information about our customers when they engage with our platform, our website and engage with us directly (for example, signing up for a newsletter or requesting support).

Information we collect in this regard includes:

  • Your IP address

  • Information about your device

  • Your name

  • Your email address

  • Contact number

  • Billing information (e.g., address, credit/debit card or bank details for direct debit)

We use your personal information to:

  • Administer access to your accounts

  • Manage our customer relationships

  • Process orders, provide our products and services and send you service-related communications

  • Provide you with customer support.

How does Culture Counts use personal information?

You may choose to interact with our website or platform in ways that provide us with your personal information. In some instances, a User ID is generated for form and URL tracking, page views, page pings, and usage counts in order to ascertain product performance and development.

The amount and type of information that Culture Counts gathers depends on the nature of your interaction with us, as well as the amount of information you choose to share. For example, we ask visitors who use our platform to provide their full name and email address. We will also collect the information you provide with us in connection with signing up to a newsletter on our website.

In each case, Culture Counts collects such personal information only insofar as is necessary or appropriate to fulfill the purpose of your interaction with or your request to us. We will not disclose your personal information other than as described in this Privacy Policy.

We may aggregate all information (including your personal information) collected from our website for our own statistical and analytics purposes and share such aggregated information with third parties for our own promotional purposes (e.g. by publishing a report on trends in the usage of our website or platform). In such instances, we make a commitment to anonymise or pseudonymise such data as part of the aggregation process to prevent you being personally identified.

We are not involved in direct marketing and will never sell personal information to marketing companies for direct marketing or any other purposes.

Who has access to my personal information?

Culture Counts will only transfer personal information to third parties when it is required for the delivery of our products and services. Examples of these parties are Government departments, arts or culture organisations and funders, healthcare service providers, and software suppliers.

Culture Counts will not transfer personal details to a client or any third party not directly involved in the delivery of our products and services without the consent of the individual the details relate to.

Service Providers and partners. Culture Counts engages service providers or partners to manage or support certain aspects of our business operations on our behalf. We currently use the following service providers who will handle your personal information:

  • Digital Ocean – cloud server and database hosting

  • Cloudflare – website bot management

  • Campaign Monitor – email campaign service provider

  • Datadog – application monitoring and error tracking

  • Slack – internal communications tool

  • Zendesk – customer support tool

  • Dropbox – cloud file hosting

  • Notion – cloud document

  • Plausible – website analytics

  • Google Maps – location and address finder

  • LinkedIn, Facebook, Google Analytics – for tracking and analysing website usage

  • Stripe – payment processing

Our service providers and partners are required by contract to safeguard any personal information they receive from us and are prohibited from using the personal information for any purpose other than to perform the services as instructed by Culture Counts.

How do we protect the data we collect from misuse?

Culture Counts is committed to ensuring that the information you provide to us is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

Personal information is stored securely and destroyed as soon as it is no longer required for research purposes.

Culture Counts operates servers in Singapore and the United Kingdom.

Cookies and tracking technologies

A cookie is a string of information that a website stores on a visitor’s device, and that the visitor’s browser provides to the website each time the visitor returns. Culture Counts uses cookies to help us identify visitors to our platform.

Visitors to our platform will have a temporary cookie stored on their device, if your browser accepts cookies. This cookie is only used to ensure the platform functions as expected. It is not used to track or identify you personally. This cookie is used to ensure you can navigate between questions within a survey, so that each of your question responses is associated with a single survey response. It also means you can close the survey and reopen it to pick up where you left off. These cookies are set to last for a maximum period of a year.

Customers of our platform will have cookies stored on their device to allow them to navigate our platform and confirm their secure identity when they log in to our platform. If you log out of your account, the login cookies will be removed. Customers can choose to use a ‘Remember Me’ feature when they login to the platform. Customers who use this feature will have a cookie stored on their device for three months.

Visitors to our Website will have cookies stored on their device to gather information regarding visitor activity on the Culture Counts website. This is not used to identify personal details but is collated into aggregate results in order to evaluate and improve our services.

Articles on the website may include embedded content (e.g. videos, images, articles, etc.). This embedded content behaves as if the visitor has visited the other website and may collect data, use cookies, and track interactions.

Culture Counts uses third party systems on our website such as Google Analytics, Plausible, LinkedIn and Facebook.

Global privacy practises and your access rights

Information we collect may be stored and processed in Australia, in accordance with this Privacy Policy but we understand that users from other countries may have different expectations and rights with regard to their privacy. For all website visitors and customers, no matter their country of location, we will:

  • Provide clear methods of unambiguous, informed consent when we do collect your personal information and where required by applicable law

  • Only collect the minimum amount of personal information necessary for the purpose it is collected for, unless you choose to provide us more

  • Offer you simple methods of accessing, correcting, or deleting your information that we have collected, with the exception of information you voluntarily provide that is necessary to retain as is for the integrity of our project code as described further below

  • Provide Website customers notice, choice, accountability, security, and access, and we limit the purpose for processing. We also provide our customers a method of recourse and enforcement

Culture Counts complies with the General Data Protection Regulation (GDPR) for users in the European Economic Area (EEA), Switzerland, and the UK. Where our affiliates within the UK process your personal information or where we process personal information of individuals located in the EEA, Switzerland or the UK, you are entitled to the following rights with regards to your personal information:

  • Right of access to your personal information, to know what information we hold about you

  • Right to correct any incorrect or incomplete personal information about yourself that we hold

  • Right to restrict/suspend our processing of your personal information

  • Right to complain to a supervisory authority if you believe your privacy rights are being violated. In the UK, this will be the Information Commissioner

Additional rights that may apply to you in certain instances:

  • Right of data portability (if our processing is based on consent or a contract and the processing carried out by automated means)

  • Right to withdraw consent at any time (if processing is based on consent). If you ask to withdraw your consent, this will not affect any processing which has already taken place at that time

  • Right to object to processing (if processing is based on legitimate interests)

  • Right to object to processing of personal data for direct marketing purposes

  • Right of erasure of your personal data from our system (“right to be forgotten”) if certain grounds are met

These rights may be limited, for example if fulfilling your request would reveal personal information about another person, or if you ask us to delete information which we are required by law or have compelling legitimate interests to keep.

Where we collect personal information to administer your accounts or your contract with us or to comply with our legal obligations, this is mandatory and we will not be able to manage our relationship with you without this. In all other cases, the provision of requested personal information is optional, but this may affect your ability to participate in certain website-related activities or being able to access and use certain features and services, where the information is needed for those purposes.

You may request details of personal information that we hold about you in accordance with the provisions detailed about or in respect to the Privacy Act 1988 (Privacy Act) and the Australian Privacy Principles under that Act. Users can provide and withdraw consent via clear methods provided on our Platform and Website. Withdrawal of consent may affect the ability to access certain features and services.

To action a request, please follow the contact details in the ‘Contacting Culture Counts About Your Privacy’ section of this Privacy Policy.

International transfer of personal information

Our website is hosted in Singapore, and our Platform is hosted in Singapore and the UK. If you are a Platform customer who has selected to use our UK server, the personal information we collect will be stored on our servers in the UK.

Information processed by our partners and listed previously will be processed in their respective territories. Our employees, contractors and affiliated organisations that process information for us as described above may be located in Australia, the United States or in other countries outside of your home country which may have different data protection standards to those which apply in your home country.

Where personal information is transferred outside of the EEA, Switzerland and UK and where this is to a country which is not subject to an adequacy decision by the EU Commission or considered adequate as determined by applicable data protection laws, we will take steps to ensure your personal information is adequately protected by safeguards such as Standard Contractual Clauses (“SCCs”) approved by the EU Commission or by the UK Government. A copy of the relevant mechanism can be obtained for your review on request by using the contact details in the ‘Contacting Culture Counts About Your Privacy’ section of this Privacy Policy.

Changes to Privacy Policy

Culture Counts may update this Privacy Policy in the future. We may modify this Policy at any time, in our discretion and all modifications will be effective immediately upon our posting of the modifications on our website or other electronic means. Please check back from time to time to review our Privacy Policy.

Contacting Culture Counts about your privacy

The relevant data controller for any personal information processed in connection with our Websites or self-managed installations is Culture Counts Pty Ltd, 162/580 Hay Street, Perth, WA 6000, Australia.

If you have any questions about this Privacy Policy or our privacy and security practices or you wish to make a complaint about our compliance with applicable privacy laws, please contact us at privacy@culturecounts.cc.

We have an appointed  UK representative who can also be contacted at privacy@culturecounts.cc.

If you have questions or concerns about the way we handle your personal information, or would like to exercise your privacy rights, please email us with the subject line “Privacy Concern” at privacy@culturecounts.cc.

In most cases, we will respond within 30 days of receiving your message but please note for a prompt response, we recommend emailing us.