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Privacy policy tools for AI tools

Please read the following privacy policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle your Personal Identifiable Information. This privacy policy concerns the use of our AI tools. 

Updated on 19-04-2026 and covers our AI tools.

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Data Controller and Contact Information

The Data Controller responsible for the processing of your personal data is The Culture Factor Oy with business iD 1652415-9
If you have any questions or concerns regarding this policy, or wish to exercise any of your rights, please contact our Data Protection Officer (DPO) at:
Email: info@theculturefactor.com

How We Use Your Data in the AI Agent

  • The core of our service involves the use of personal data to provide tailored insights while upholding user privacy.

  • Personalized Advice: While subscribed, the AI uses your Culture Compass data to provide tailored insights.

  • Model Training/Privacy: We never use your name or contact information to train our AI.

  • Continuous Improvement: We use survey answers and AI interactions in anonymous, aggregated formats to improve the system.

  • Demographic Protection: Your specific demographic answers are fully detached from this process to ensure your identity remains protected.

Legal Basis for Processing Personal Data

We will only process your personal data where we have a lawful basis to do so under Article 6 of the General Data Protection Regulation (GDPR). Our legal bases for processing your data are:

  • Contractual Necessity (GDPR Art. 6(1)(b)): We process your Culture Compass data to provide you with Personalized Advice and interactive advice via the AI agent. This processing is necessary to fulfill our contract with you as a subscriber.

  • Legitimate Interests (GDPR Art. 6(1)(f)): We process survey answers and AI interactions in anonymous, aggregated formats for Continuous Improvement of the system. Our legitimate interest is to ensure the quality, security, and performance of our AI platform and services.

  • Consent (GDPR Art. 6(1)(a)): Where we rely on your explicit agreement, such as for any non-essential updates or services mentioned in the checkbox of the compass, we will obtain your consent. You have the right to withdraw this consent at any time.

Data Retention and Deletion

We will only retain your personal data for as long as necessary to fulfill the purposes for which it was collected, including for satisfying any legal, accounting, or reporting requirements.

  • Subscription Data: Your access to Culture Compass data used for personalized advice is automatically revoked the moment your subscription ends. We will delete or anonymize this data shortly thereafter, unless a longer retention period is required by law.

  • Anonymized Improvement Data: Data used for Continuous Improvement, such as survey answers and AI interactions used in anonymous, aggregated formats, is permanently anonymized and used exclusively for model training. This anonymous data, which no longer constitutes personal data, may be retained indefinitely.

Third-Party Sharing and Sub-processors

We may share your personal data with the following categories of third-party service providers who act as sub-processors:

  • AI Platform Providers (for hosting and operating the AI agent).

  • Cloud Hosting and Storage Providers.

  • Analytics Providers (using anonymized data only).

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.


International Data Transfers

If your personal data is transferred to, and stored at, a destination outside the European Economic Area (EEA), we ensure a similar degree of protection is afforded to it by implementing at least one of the following safeguards:

  • We will transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.

  • We will use specific contracts approved by the European Commission which give personal data the same protection it has in Europe (Standard Contractual Clauses).


Your Data Protection Rights (GDPR)

As an individual located in the European Economic Area (EEA), you have the following rights concerning your personal data, which you may exercise by contacting us through the details provided above:

  • Right of Access (Art. 15): The right to obtain confirmation as to whether or not personal data concerning you are being processed, and access to the personal data.

  • Right to Rectification (Art. 16): The right to have inaccurate personal data rectified, and to have incomplete personal data completed.

  • Right to Erasure (Art. 17): The right to request the deletion of your personal data (The Right to be Forgotten).

  • Right to Restriction of Processing (Art. 18): The right to restrict the processing of your personal data under certain conditions.

  • Right to Data Portability (Art. 20): The right to receive the personal data concerning you in a structured, commonly used, and machine-readable format.

  • Right to Object (Art. 21): The right to object to the processing of your personal data, particularly when based on legitimate interest

  • Automated individual decision-making, including profiling (Art. 22): The right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

Right to Lodge a Complaint

You have the right to lodge a complaint at any time with a Supervisory Authority in the European Union, particularly in the Member State of your habitual residence, place of work, or the place of the alleged infringement. We encourage you to contact us first so we may attempt to resolve your concern.


Limitation of Liability and AI Disclaimer

The AI platform used for giving personalized Culture Compass interactive advice is trained on 40+ years of organisational experience and anonymized data. It has been meticulously vetted for providing practical advice. Despite all the data and stress testing we have done, it might however still at times give bad information.

  • Kindly use your own judgement when considering the real life application of the advice provided.
  • In case of doubt, contact us for human advice and coaching.

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