Country Navigator Limited (“we”, “us”, “our”) is committed to protect and respect your privacy.

This privacy policy (“Privacy Policy”) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding the processing of your personal data.

Data Controller

The data controller is Country Navigator Limited, Ashcombe House, 5 The Crescent, Leatherhead, Surrey, England.

Legal basis for processing

The legal basis for processing your personal data is “legitimate interest”. You have a legitimate interest in having more insight in different cultures around the world and we need your personal data to provide you with specific information about this.

In some cases, we may seek for consent from you for example if we process sensitive data. If this is the case, we will make sure we obtain a valid consent from you and we will also provide you the possibility to withdraw your consent at any time you wish.

You have the right to withdraw your consent to us processing your personal data, at any time, by contacting us as set out at the end of this Privacy Policy.

We may send push notifications or emails from time to time in order to update you about any service updates, events and promotions we may be running. If you no longer wish to receive these communications, please disable these in the settings on your device or please opt out by clicking the “unsubscribe” link at the bottom of any email. Once you do this, you will no longer receive any emails from us.

Information you provide to us

When you register for Country Navigator you will provide us the following personal data:

·       Name

·       Email address

Purpose:

Your email address and your password are used to enable either a plain-text or SSL encrypted secure logon, depending on your point of entry to Country Navigator.

We may also record one or more demographic values such as business unit or region. You are not obliged to provide this information.

When you use Country Navigator generally

Each time you visit Country Navigator, we store a record of your use of the relevant platform in our database. If you are a corporate user, we will make this information available to your organisation on an aggregated and anonymised level.

When you complete the Cultural Profile

When you complete the self-assessment questionnaire, we store your answers in our database in order to generate and provide you with a cultural profile. We will not make this information available to your organisation.

When you post comments, contribute tips or share experiences

If these features are available to your account, and if you make use of them, we store your written contributions against your user account in our database. Unless you have chosen to post anonymously (if this option is available), when displayed within Country Navigator your contributions will be headed by your full name.

When you use the “Recommend”, “share” or “Invite a Colleague” features

If these features are available to you, use of these features may require you to provide an email address to identify the recipient of the email that is generated by Country Navigator. We do not collect, and store email addresses provided in this way in the Country Navigator database, although a temporary record of the email address may be stored in the server’s mail log. We do not use email addresses collected in this way for any other purpose than sending a one-off email as requested by you through use of the relevant feature.

Where we store your personal data

Our services are global and your information (including personal data) may be stored and processed in any country where we have operations or where we engage service providers, and we may transfer your information to countries outside of your country of residence, which may have data protection rules that are different from those of your country of residence.

The personal data that we collect from you may therefore be transferred to, and stored at, a destination outside the European Economic Area (“EEA“) or the UK. It may also be processed by staff operating outside the EEA or the UK who work for us or for one of our suppliers or partners. Such staff or subcontractors may be engaged in, among other things, the fulfilment of your order, the processing of your payment details or the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing outside of the EEA or the UK.

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy. In particular, this means that your personal data will only be transferred to a country that provides an adequate level of protection (for example, where the European Commission has determined that a country provides an adequate level of protection), or where the recipient is bound by standard contractual clauses according to conditions provided by the European Commission (“Standard Contractual Clauses”).

Country Navigator is accessible via the internet and may potentially be accessed by anyone around the world. Other users may access Country Navigator from outside the EEA or the UK. This means that where you chose to post your data on Country Navigator, it could be accessed from anywhere around the world and therefore a transfer of your data outside of the EEA or the UK may be deemed to have occurred. You consent to such transfer of your data for and by way of this purpose.

Security of your information

We protect the quality and integrity of your personal data and we have implemented appropriate technical and organisational measures to do so. We have implemented security policies, rules and technical measures to protect the personal data that we have under our control from:

  • Unauthorized access
  • Improper use or disclosure
  • Unauthorised modification
  • Unlawful destruction or accidental loss

All our employees and data processors, who have access to and are associated with the processing of personal data, are required to respect the confidentiality of our visitors’ personal data.

All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of Country Navigator, you are responsible for keeping this password confidential. We ask you not to share any password with anyone.

Data retention

We retain personal data for as long as necessary for the relevant activity for which it was provided or collected. This will be for as long as we provide access to Country Navigator to you, your account with us remains open or any period set out in any relevant contract you have with us. However, we may keep some data after your account is closed or you cease using Country Navigator for the purposes set out below.

After you have closed your account or ceased using Country Navigator for a period of at least 90 days, we usually delete personal data, however we may retain personal data where reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, maintain security, prevent fraud and abuse, resolve disputes, enforce our Terms and Conditions, or fulfil your request to “unsubscribe” from further messages from us.

We will retain de-personalised information after your account has been closed.
Please note: After you have closed your account or deleted information from your account, any information you have shared with others will remain visible. We do not control data that other users may have copied from Country Navigator. Your profile may continue to be displayed in the services of others (e.g. search engine results) until they refresh their cache.

Links to other websites

Country Navigator may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

1.1            Your rights

You have the right to request:

  • Access to your personal data.
  • Rectification or deletion of your personal data.
  • A restriction on the processing of your personal data.
  • Object to the processing of your personal data.
  • A transfer of your personal data (data portability).

You can make a request in relation to any of the above rights by contacting us as set out at the end of this Privacy Policy. We will respond to such queries within 30 days.

Complaints

If you have any complaints about our use of your personal data please contact us as set out at the end of this Privacy Policy or contact the following data protection supervisory authority.

For individuals located in the EU: your local data protection authority in the country in which you are located.

Our EU DPO is: Hans van der Linden (privacy@countrynavigator.com)

For all other individuals: The Information Commissioner’s Office at, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England (“ICO”).

Age of users

Country Navigator is not intended for and shall not be used by anyone under the age of 16.

Changes to our privacy policy

Any changes we may make to our Privacy Policy in the future will be posted on this page. Please check back frequently to see any updates or changes to our Privacy Policy.

This Privacy Policy was last updated on 12th of August 2020 and replaces any other Privacy Policy previously applicable from this date.

Contact

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to:

By post: Privacy Queries, Country Navigator, Ashcombe House, 5 The Crescent, Leatherhead, Surrey, England. By email: privacy@countrynavigator.com