Privacy policy

This platform is jointly operated by Culture Gem Ltd and Inclusive Change Ltd ("we", "us", "our"). We are the data controllers for the personal data collected through this service.

We collect the following information during exercises:

• Participant data: full name and company name, entered voluntarily at the start of each exercise
• Exercise data: decisions made, time taken, scenario selected, confidence ratings, and outcome metrics
• Search data: search queries and scenario selections (anonymous)
• Admin accounts: email address and authentication data for admin users only

We use personal data for the following purposes:

• To run and personalise the exercise experience
• To generate post-exercise reports and debrief materials
• To analyse trends and improve exercise content (aggregated, anonymised data)
• To manage admin access and user accounts

We process participant data on the basis of legitimate interests — specifically, delivering the training exercise and improving its quality. Admin account data is processed on the basis of contract performance.

Exercise data is shared between Culture Gem Ltd and Inclusive Change Ltd for the purposes described above. We do not sell personal data or share it with third parties for marketing purposes.

We use cloud infrastructure providers to host the platform and store data securely. These providers act as data processors under appropriate agreements.

Exercise session data (including participant names and company names) is retained for up to 12 months after the exercise, after which it is anonymised or deleted. Admin account data is retained for as long as the account is active.

We use the following cookies:

• Authentication cookies: to keep admin users signed in (essential, session-based)
• Preference cookies: to remember your theme choice and accessibility settings (stored locally)

We do not use analytics cookies, advertising cookies, or any third-party tracking.

Under UK GDPR, you have the right to access, correct, delete, or restrict the processing of your personal data. You also have the right to data portability and to object to processing based on legitimate interests.

To exercise any of these rights, please contact us using the details below.

If you have questions about this privacy policy or wish to exercise your data rights, please contact:

• Culture Gem Ltd — privacy@culturegem.co.uk
• Inclusive Change Ltd — privacy@inclusivechange.co.uk