Last updated: August 13th, 2019
Who we are
Our Privacy Notice applies to all products and services offered by What Culture Limited (a company incorporated in England with company registration number 07243682 and whose registered office address is 7th Floor, Baltic Place, South Shore Road, Gateshead, NE8 3AE), but excludes any products or services that have separate privacy notices which do not incorporate this Privacy Notice.
How we collect information
To the extent permissible under applicable law, we collect information about you and any other party whose details you provide to us when you:
- complete online forms;
- take part in surveys;
- enter any competitions or prize draws;
- download information such as white papers or other publications or participate in any other interactive areas that appear on our website;
- interact with us using social media;
- provide your contact details to us when accessing any websites or services we make available or when you update those details; and
- contact us offline, for example by telephone, email or post.
We also collect information from your devices (including mobile devices) and browsers you use to access and use any of our websites or services (for example, we may collect the device identification number and type, location information and connection information such as statistics on your page views, traffic to and from the sites, referral URL, ad data, and your IP address) and we will ask for your permission before we do so. We may do this using cookies or similar technologies (as described below).
We may enhance personal information we collect from you with information we obtain from third parties that are entitled to share that information; for example, information from data management platforms, but in each case as permitted by applicable laws.
If you intend giving us personal information about someone else, you are responsible for ensuring that you comply with any obligation and consent obligations under applicable data protections laws. In so far as required by applicable data protection laws, you must ensure that beforehand you have their explicit consent to do so and that you explain to them how we collect, use, disclose and retain their personal information or direct them to read our Privacy Notice.
How we use your information
To the extent permissible under applicable law, we use your information to:
- provide any information and services that you have requested or services that you have ordered;
- compare information for accuracy and to verify it with third parties;
- provide, maintain, protect and improve any products, services and information that you have requested from us;
- manage and administer your use of products and services you have asked us to provide;
- manage our relationship with you (for example, customer services and support activities);
- monitor, measure, improve and protect our content, website, and services and provide an enhanced, personal, user experience for you;
- undertake internal testing of our website, systems and services to test and improve their security and performance. In these circumstances, we would anonymise any information used for such testing purposes;
- provide you with any information that we are required to send you to comply with our regulatory or legal obligations;
- detect, prevent, investigate or remediate, crime, illegal or prohibited activities or to otherwise protect our legal rights (including liaison with regulators and law enforcement agencies for these purposes);
- contact you to see if you would like to take part in our customer research (for example, feedback on your use of our products and services);
- to monitor, carry out statistical analysis and benchmarking, provided that in such circumstances it is on an aggregated basis which will not be linked back to you or any living individual;
- deliver targeted advertising, marketing or information to you;
- deliver joint content and services with third parties with whom you have a separate relationship (for example, social media providers); and
- provide you with location based services (for example, advertising and other personalised content), where we collect geo-location data.
Our website, (including mobile applications) and services may contain technology that enables us to:
- check specific information from your device or systems directly relevant to your use of the websites, or services against our records to make sure the websites, or services are being used in accordance with our end-user agreements and to troubleshoot any problems;
- obtain information relating to any technical errors or other issues with our website and services;
- collect information about how you and users use the functions of the features of our website and services; and
- gather statistical information about the operating system and environment from which you access our applications or services.
You can manage your privacy settings within your browser or our website and services (where applicable).
We may combine your data, and the data of others to produce anonymous aggregate data. This data is for analytical purposes to assess the effectiveness of our services. If said data were to include any data that could be personally identifiable to any person, we would treat the aggregate data as personal data and process it in the same way as any other personal data.
In addition to the purposes described in this section, we may also use information we gather to identify you when visiting our websites, deliver targeted advertising, marketing or information to you which may be useful, based on your use of the website or services or any other information we have about you (depending on the websites or services, you may able to configure these features to suit your preferences). Subsequent sections of this Privacy Notice provides further details on how we will do this. We may also use your information to provide services and perform analytics regarding the effectiveness of these services, and to help us fulfil technical support requests.
We may monitor and record our communications with you, including e-mails and phone conversations. Information which we collect may then be used for training purposes, quality assurance, to record details about our website and services you order from us or ask us about, and in order to meet our legal and regulatory obligations generally.
We will only use your personal information for the purposes for which it was collected, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
We do not collect any sensitive personal information about you, such as details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, or information about your health and genetic and biometric information.
We encourage parents and guardians to observe, participate in, and/or monitor and guide their online activity. We do not knowingly collect any Personal Identifiable Information from children under the age of 13. If you think that your child provided this kind of information on our website, we strongly encourage you to contact us immediately and we will exercise our best efforts to promptly remove such information from our records.
Types of Data We Collect (General)
In order to support the operation of our websites and services, various types of personal information is provided by or requested from the users of the websites. The following table outlines the personal information we collect, and how it is used by us.
IP Address: This is collected automatically when you use our website, and is used when delivering relevant advertisements to you, and to determine the effectiveness of such advertisements. We also use this for analytical purposes, such as determining the geographical origin of any traffic we receive to our websites.
Email Address: This is collected during user-elected registration and is used to register your account and to receive relevant service related email correspondence. Your email address is not used for advertisement purposes (except if you elect to be added to any mailing lists we may make available), and is not shared with any other party unless we are legally bound to do so. This may also be collected if you decide to contact us for technical support or to receive/provide feedback about us or our services.
Your name: This is collected during user-elected registration and is used to register your account. This is also used to attribute provided content to you, when producing invoices for said content. This is not shared with any other party unless we are legally bound to do so.
Your address and postal / ZIP code: These are collected during user-elected opt-in to receive payments for article contributions, and are used in the generation of invoices relating to any content you provide to us. This data is only collected when a user wishes to be paid for their content, and is not requested prior to this.
Your Country of residence: This data is manually entered after registration, and allows us to ensure that any invoices created on your behalf are paid out correctly, allowing us to take regional tax and VAT regulations into account when issuing payments. This also allows currency conversions to be conducted properly when issuing payments.
Profile information: This data is manually entered after registration, and is used to allow users to tell other users about themselves in order to personalise their account and experience on the website.
Social Media profiles (Facebook, Twitter, Skype): This data is manually entered after registration, and allows us to show links to your social media profiles within the content that you write, allowing other users of the site, and yourself, to share your content with others. These social media profiles are not shared with any other party except via the above mechanism, at the optional discretion of the user.
User Role: This data is stored against the user to help determine the set of actions that a particular user is eligible to perform when using our website.
Permissions: In addition to the above, these are specific permissions attached to each user outside of their general user role, and allows us to further customise the level of access a particular user has to various website functions.
Fees Information: This is stored against the user and allows us to determine how much to pay a particular user when invoices are generated on their behalf for content provided to us.
Categories: This is a set of website categories (Gaming, TV, etc.) that are stored against the user and help us determine that kinds of content each user regularly submits to us.
Application and Employment Data: If you apply to work for What Culture Limited or become an employee, we may collect personal information necessary to process your application and employment. This will generally include the personal information described in this policy in addition to National Insurance Number (or applicable alternative), and details of your bank account to receive any due salary and/or benefits. We may also collect information relating to your employment history and appropriate references.
Payment Information: In addition to the purpose provided above, we will also collect your payment details when you elect to provide them, for the satisfaction of any invoices that we create for any content or services you provide to us.
Log Files: These are created automatically by our web server, and contains information such as your IP address, browser types, dates/times and referring pages. This information is not linked to any other personally identifiable data, and is used to ensure the service we deliver is reliable and relevant, and to assist in the identification and remedy of site faults.
Types of Date We Collect (YouTube APIs)
In addition to the user data specified above, the website collects the following information from users that have been given access to the areas of the website that directly interacts with or makes use of the various YouTube APIs. Other information is collected to form a video upload which is not specific to the YouTube API, such as the source of the video (adaptation from an existing article or original content, playlist, etc.) which is used by the website only, and is not used with calls to the YouTube APIs.
Our website interacts with YouTube via its APIs, and makes use of YouTube API services. By using these services, users are agreeing to be bound by the YouTube Terms of Service, which can be found at https://www.youtube.com/t/terms.
Video Title: This is provided by the user when preparing an upload to YouTube, and allows the content to be uploaded to be identified.
Video Description: This is provided by the user when preparing an upload to YouTube, and allows the content to be properly described before upload.
Video Privacy Status: This is provided by the user when preparing an upload to YouTube, and allows the user to set the visibility of a YouTube upload once it has been completed. Options include public, unlisted, and private.
Thumbnail: This is provided by the user when preparing an upload to YouTube, and ensures that the video will have a proper thumbnail when it is uploaded to YouTube.
Channel: This is provided by the user when preparing an upload to YouTube, and is used to ensure that the video content is published to the correct area of YouTube when it is uploaded.
Video File: This is the media file uploaded to our website, which is then sent along with the other data about the video.
Video ID: This is used for existing videos to update information about them, such as a new title or description, and to uniquely identify a video that is requested to be deleted.
View Count: This is collected automatically for each video uploaded via our system, and is used as the basis for analytics in order to assess the popularity of our content and trends.
Minutes Watched: This is collected automatically for each video uploaded via our system, and is used as the basis for analytics in order to assess the popularity of our content and trends.
View Duration: This is collected automatically for each video uploaded via our system, and is used as the basis for analytics in order to assess the popularity of our content and trends.
View Percentage: This is collected automatically for each video uploaded via our system, and is used as the basis for analytics in order to assess the popularity of our content and trends.
Estimated Revenue: This is collected automatically for each video uploaded via our system, and is used as the basis for analytics in order to assess the popularity of our content and trends.
CPM: This is calculated automatically for each video uploaded via our system (using view counts and estimated revenue), and is used as the basis for analytics in order to assess the popularity of our content and trends.
Data in the above table is not shared externally (except between ourselves and YouTube when uploading or changing any YouTube content that originated from our website), and is shared internally amongst those employees who have been given access to see and use this information. Only the employees who have been deemed to have a legitimate business need to access the data are allowed to see and/or use it. Members of the public that sign up to use our services are not able to see this information, unless we, in our discretion, believe it presents a reasonable business need to provide that information to them. This may apply, for example, if we enlist the services of Freelance individuals who require the data to carry out their work.
In addition to our normal procedure for deleting stored data, users can revoke access to their data as it relates to the YouTube API by visiting the Google security settings page at https://security.google.com/settings/security/permissions.
Users may contact the website owner or developer with questions or complaints about our privacy practices as related to the use of YouTube APIs.
As part of its operation, our website interacts with the YouTube APIs in order to upload, update and delete YouTube videos on the channels made available from within the website. The website also interacts with the YouTube APIs in order to obtain analytical data such as view counts, watched duration, average duration percentage, and so on. Furthermore, the website periodically interacts with the YouTube APIs in order to keep any analytical data previously gathered up to date and complete.
We may obtain information through mobile applications that you install on your mobile devices. These mobile applications may be our own mobile applications or those belonging to third parties. Where the mobile application belongs to a third party, you must read that third party’s own privacy notice as it will apply to your use of that third party mobile application. We are not responsible for such third party mobile applications and their use of your personal information.
Mobile applications may provide us with information related to a user’s use of that mobile application and use of our applications and services accessed using that mobile application. We may use such information to provide and improve the mobile application or our own services. For example, activity undertaken within a mobile application may be logged.
Sharing your information
We may share your information with:
- customer relationship management software to provide you with any information, products or services that you have requested;
- our service providers and agents (including their sub-contractors) or third parties which process information on our behalf (e.g. internet service and platform providers, advertising agencies, agency trading desks, supply side platforms and data management platforms) so that they may help us to provide you with the products, services and information you have requested or which we believe is of interest to you;
- partners, including website and mobile app publishers, resellers and developers that may help us to provide you with the products, services and information you have requested or which we believe is of interest to you;
- third parties where you have a relationship with that third party and you have consented to us sending information (for example social media sites or other third party application providers);
- third parties for marketing purposes (e.g. our partners and other third parties with whom we work and whose products or services we think will interest you);
- credit reference and fraud prevention agencies;
- law enforcement agencies so that they may detect or prevent crime or prosecute offenders;
- any third party in the context of actual or threatened legal proceedings, provided we can do so lawfully (for example in response to a court order);
- any third party in order to meet our legal and regulatory obligations, including statutory or regulatory reporting or the detection or prevention of unlawful acts;
- our own professional advisors and auditors for the purpose of seeking professional advice or to meet our audit responsibilities;
- another organisation if we sell or buy (or negotiate to sell or buy) any business or assets;
- another organisation to whom we may transfer our agreement with you; and
- Government departments where reporting is mandatory under applicable law.
We may share non-personally identifiable information about the use of our website, applications, products or services publicly or with third parties but this will not include information that can be used to identify you.
We may also share your personal information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies.
We will require all third parties to respect the security of your personal information and to treat it in accordance with the law. We will not allow any elected third-party to use your personal information for their own purposes and will only permit them to process your personal information for specified purposes and in accordance with our instructions.
From time to time, we may use your information to contact you with details about our products and services which we feel may be of interest to you. We may also share your information with other companies and carefully selected third parties so that they (or we) may contact you with information about their products or services which we feel may be of interest to you. You have the right at any time to stop us from contacting you for marketing purposes. You may also request at any time that we do not share your information with third parties referred to in this paragraph. If you wish to exercise these rights you can do so by selecting your contact preferences at the point where you provide us with your information on our websites or services, using any preference centres we give you access to or by sending us an email to email@example.com. You can also unsubscribe from any email marketing using the links provided in the emails we send to you.
Your information and your rights
If you are based within the EEA or within another jurisdiction having similar data protection laws, in certain circumstances you have the following rights:
- the right to be told how we use your information and obtain access to your information;
- the right to have your information rectified or erased or place restrictions on processing your information;
- the right to the transfer of your personal data to you or to a third party;
- the right to object to the processing of your information e.g. for direct marketing purposes;
- the right to the restriction of processing of your personal data;
- the right to have any information you provided to us on an automated basis returned to you in a structured, commonly used and machine-readable format, or sent directly to another company, where technically feasible (“data portability”);
- where the processing of your information is based on your consent, the right to withdraw that consent subject to legal or contractual restrictions;
- the right to object to any decisions based on the automated processing of your personal data, including profiling; and
- the right to lodge a complaint with the supervisory authority responsible for data protection matters (e.g. in the UK, the Information Commissioner’s Office).
- the right to withdraw consent at any time where we are relying on consent to process your personal data
If you request a copy of your information you may be required to pay a statutory fee.
If we hold any information about you which is incorrect or if there are any changes to your details, please let us know by so that we can keep our records accurate and up to date.
If you withdraw your consent to the use of your personal information for purposes set out in our Privacy Notice, we may not be able to provide you with access to all or parts of our website and services.
We will retain your personal information for the duration of our business relationship and afterwards for as long as is necessary and relevant for our legitimate business purposes, in accordance with our data retention, marking and destruction policy or as otherwise permitted applicable laws and regulation. Where we no longer need your personal information, we will dispose of it in a secure manner (without further notice to you).
Changes to our privacy notice
We may change our Privacy Notice from time to time. However we will not reduce your rights under this Privacy Notice. We will always update this Privacy Notice on our website, so please try to read it when you visit the website (the ‘last updated’ reference tells you when we last updated our Privacy Notice).
Security and storage of information
We will keep your information secure by taking appropriate technical and organisational measures against its unauthorised or unlawful processing and against its accidental loss, destruction or damage. We will do our best to protect your personal information but we cannot guarantee the security of your information which is transmitted to our website or services or to other website, applications and services via an internet or similar connection. If we have given you (or you have chosen) a password to access certain areas of our websites or services please keep this password safe – we will not share this password with anyone.
In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach. In the event that we are required by law to inform you of any unauthorized access to your personal information we may notify you electronically, in writing, or if permitted by law, by telephone. We will also notify any applicable regulator of a breach where we are legally required to do so.
Our websites permit you to create an account, or have the facility for an account to be created on your behalf. When this happens, you will be prompted to create a password. You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else that has obtained your password, whether or not such access or use has been authorized by you. You should notify us of any unauthorized use of your password or account. If you believe your account has been compromised, please contact us at firstname.lastname@example.org.
We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including the fulfillment of the contract, the initiation of a contract, or for the purposes of satisfying any legal, accounting, or other regulatory reporting requirements.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
Transfers outside of the European Economic Area
Personal information in the European Union is protected by data protection laws but other countries do not necessarily protect your personal information in the same way.
Our website and some of our applications or services or parts of them may also be hosted in the United States or otherwise outside of the EEA (which means all the EU countries plus Norway, Iceland and Liechtenstein) (“EEA”) and this means that we may transfer any information which is submitted by you through the website or the application or service outside the EEA to the United States or to other territories outside of the EEA. When you send an email to us, this will also be stored on email servers which are hosted with Google and therefore may be outside of the EEA.
We may use service providers based outside of the EEA to help us provide our website and services to you and this means that we may transfer your information to service providers outside the EEA for the purpose of providing our advertising and services to you.
We take steps to ensure that where your information is transferred outside of the EEA by our service providers and hosting providers, appropriate measures and controls are in place to protect that information in accordance with applicable data protection laws and regulations. In each case, such transfers are made in accordance with the requirements of Regulations (EU) 2016/679 (the General Data Protection Regulations or “GDPR”) and may be based on the use of the European Commission’s Standard Model Clauses for transfers of personal data outside the EEA.
By using our website, products or services or by interacting with us in the ways described in this Privacy Notice, you consent to the transfer of your information outside the EEA in the circumstances set out in this Privacy Notice. If you do not want your information to be transferred outside the EEA you should not use our website, applications or services.
Our Advertising Partners
Note that we have no access to or control over these cookies that are used by third-party advertisers.
Other sites and social media
If you follow a link from our website or service to another site or service, this notice will no longer apply. We are not responsible for the information handling practices of third party sites or services and we encourage you to read the privacy notices appearing on those sites or services.
Our websites or services may enable you to share information with social media sites, or use social media sites to create your account or to connect your social media account. Those social media sites may automatically provide us with access to certain personal information retained by them about you (for example any content you have viewed). You should be able to manage your privacy settings from within your own third party social media account(s) to manage what personal information you enable us to access from that account.
For more information on how to manage cookies in your browser, please consult the documentation for that browser. For your convenience, we have provided links to this information for some of the more popular web browsers:
Google Chrome (https://support.google.com/chrome/answer/95647)
Cookies, Analytics and Traffic Data
Our cookies may be session cookies (temporary cookies that identify and track users within our websites or services which are deleted when you close your browser or leave your session in the service) or persistent cookies (cookies which enable our websites or services to “remember” who you are and to remember your preferences within our websites or services and which will stay on your computer or device after you close your browser or leave your session in the application or service).
We use the following different types of cookies:
Strictly necessary cookies
These are cookies which are needed for our websites or services to function properly, for example, these cookies allow you to access secure areas of our website.
Performance cookies and analytics technologies
These cookies collect information about how visitors and users use our websites, applications and services, for instance which functionality visitors use most often, and if they get error messages from areas of the websites, applications or services. These cookies don't collect information that identifies a visitor or user. All information these cookies collect is aggregated and therefore anonymous. We only use these cookies to improve how our website, applications and services work.
Targeting or advertising cookies
These cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertisers, advertising agencies or ad servicing technologies. They remember that you have visited a website and this information is shared with other organisations such as advertisers.
Web beacons and parameter tracking
IP Address and traffic data
We keep a record of traffic data which is logged automatically by our servers (both our web site servers and our ad serving technologies), such as your Internet Protocol (IP) address, device information, the website that you visited before ours and the website you visit after leaving our site. We also collect some site and service statistics such as access rates and page views. We are not able to identify any individual from traffic data or site statistics.
How to disable cookies
You may be able to configure your browser or our website or the websites of our partners to restrict cookies or block all cookies if you wish, however if you disable cookies you may find this affects your ability to use certain parts of our website, or services. For more information about cookies and instructions on how to adjust your browser settings to accept, delete or reject cookies, see the www.youronlinechoices.co.uk website. To change your cookie preferences you may be able to use our consent manager which can be found here.
If you have any queries about how we treat your information, the contents of this notice, your rights under local law, how to update your records or how to obtain a copy of the information that we hold about you, please write to our Data Protection Officer at What Culture Limited, 7th Floor, Baltic Place, South Shore Road, Gateshead, NE8 3AE, or send an email to email@example.com
If you are based in the European Union you also 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.