Last updated: 12 September 2026
Client Culture Pty Ltd (ABN 88 619 177 132) (“Client Culture”, “we”, “us”, “our”) provides client and employee experience measurement and analytics services to business customers worldwide. This Privacy Policy explains how we collect, use, disclose and protect personal information (also called personal data) when we act as either data controller or data processor/service provider across:
This policy applies to our websites, SaaS platform, professional services and marketing activities. Local addenda in Section 17 set out country-specific rights and obligations.
| Category | Examples | Source |
|---|---|---|
| Identity & contact data | Name, title, role, business email, phone | Client upload; survey respondent entry; website forms |
| Interaction data | Survey scores and free-text feedback; support tickets | Respondent; end-user device |
| Technical data | IP address, browser type, session cookie, server log files | Recorded automatically by the platform |
| Usage analytics | Page views and feature usage, recorded first-party | The platform itself; no third-party analytics or tracking pixels |
| Business profile | Company name, industry segment, relationship tier | Client upload |
| Regulatory IDs (AU only) | ABN/ACN of enterprise contacts | Public registers or client upload |
We do not intentionally collect special-category or sensitive information unless a client instructs us and appropriate safeguards are in place.
| Purpose | Legal basis (UK/EU) | APP compliance |
|---|---|---|
| Deliver SaaS platform & surveys | Contract performance (Art 6-1-b) | APP 3, 6 |
| Improve and secure our services | Legitimate interests (Art 6-1-f) | APP 11 |
| Marketing our products to B2B prospects | Consent or legitimate interests | APP 7 (opt-out) |
| Legal & compliance, fraud prevention | Legal obligation (Art 6-1-c) | APP 6, 11 |
Where we rely on legitimate interests, we have conducted balancing tests to ensure your interests and fundamental rights are not overridden.
Most of our platform uses no third-party AI at all. Dashboards, trend charts, NPS benchmarks and longitudinal reports all run on structured data we hold ourselves.
Custom Reports – draft commentary. When a Client Culture analyst prepares a report, the platform sends the firm's aggregate results for the period – loyalty-driver profile, theme labels, office, division and industry segment names, and a kudos count – to Anthropic under their enterprise data processing agreement, and receives draft commentary. The firm's name is replaced with a neutral reference before sending. No client names, professional names or verbatim comments are sent. Anthropic is contractually prohibited from training on this data, and all transmission is encrypted. The analytical content of every report – themes, interpretations, recommendations – and the selection and attribution of client quotes are done by Client Culture analysts from the platform. AI output is a starting input that accelerates drafting; it is not the deliverable.
Help assistant. If you use the in-platform help assistant, your typed question is sent to Anthropic with a role prompt; no platform data is attached. We record that a question was asked – when, from which page, and its length – but not what it said. Do not include client details in a help question.
EphemeralAI™ is our trademark for AI processing that strips personal identifiers before any model call. It has applied to Custom Reports commentary since 12 September 2026: the firm's name is replaced before the model call, no client, professional or verbatim content is sent, and nothing from the exchange is stored beyond the draft the analyst chooses to keep. Ephemeral Data Retention, below, is the same principle applied to your data.
Verbatim feedback is retained only for the period configured by your firm, then permanently deleted. Aggregate structured data (scores, driver selections, response metadata) persists for trend analysis and contains no free-text content.
We only share personal data:
We do not sell personal information.
Client feedback data is stored in Sydney, Australia (database and application compute), and the independent nightly backup is encrypted before it leaves that region. Processing outside Australia is limited to the sub-processors in Section 6: Anthropic (United States) receives data transiently for Custom Reports draft commentary and help-assistant questions (see Section 5); Resend (Tokyo) delivers email; Upstash (Singapore) holds rate-limiting counters that carry no content; GitHub (United States) holds encrypted backups as ciphertext only. For any international transfer of personal data, we rely on one or more of:
We retain personal data only for as long as necessary to fulfil the purposes described in this policy or to comply with legal obligations.
Our Ephemeral Data Retention framework gives each firm direct control over how long verbatim comments are retained – each firm configures its own retention period, from short windows for firms with strict data minimisation requirements through to extended retention for firms that want longer review windows.
NPS scores, loyalty driver selections and response metadata (dates sent and submitted, and the assigned professional) are retained as structured data for trend analysis and contain no free-text content. They remain linked to the client record for the life of your firm's engagement – that is what lets you see a client's history and act on a falling score – and are de-identified when the engagement ends. Free-text comments are retained only for the period your firm chooses. A daily automated process deletes verbatim comments once they pass your firm's retention period, recording only counts in the audit log – never content. The more privacy-protective setting always wins: shortening the period also removes existing comments older than the new period; lengthening it never restores anything already deleted. Expired staff survey invitations are anonymised by a separate daily cycle.
Contact records are held for the term of the firm's engagement with us. When that engagement ends, the firm may take an export of its data and we then delete or de-identify contact records within 90 days. We will also delete your data within two weeks of receiving a request from you to do so. Archived and backup copies are securely destroyed within 90 days thereafter.
We maintain technical and organisational security aligned with ISO 27001 and SOC 2 control objectives, including:
A full security overview is available at clientculture.com/security.
The platform uses a small number of first-party cookies to:
We do not use third-party tracking pixels or advertising cookies on the platform. Usage analytics (page views, feature usage) are recorded by the platform itself.
You can manage cookies through your browser settings.
Access, rectification, erasure, restriction, portability, object, withdraw consent, complaint to your data protection authority.
Access, correction, anonymity / pseudonymity, complaint to the OAIC.
To exercise any right, email privacy@clientculture.com. We respond within 30 days (21 days for APP access requests).
Our services are directed to business users. We do not knowingly collect data from anyone under 16 years of age.
We do not use personal data for solely automated decisions that have legal or similarly significant effects.
This policy does not cover third-party sites linked from our platform. Please review their privacy notices.
We may update this policy from time to time. Material changes will be notified via email or platform banner and posted on our website with a revised “last updated” date.
For security-related concerns, contact security@clientculture.com.
Privacy Officer / Data Protection Officer
Client Culture Pty Ltd
Email: privacy@clientculture.com
If you believe we have not resolved your concern, you may contact:
Client Culture — independent quality assurance for professional services