Privacy Policy for Culture in the Workplace Questionnaire™

1. Introduction

Welcome to the ODE Consulting® Culture in the Workplace Questionnaire™ (the “Site”).

ODE Consulting® PTE. LTD. (“Company A”, “we”, “us”, or “our”) is committed to protecting your personal data and complying with applicable privacy laws including the Singapore Personal Data Protection Act (PDPA), and the European Union General Data Protection Regulation (GDPR).

This Privacy Policy sets out the basis on which we collect, use, disclose, and process your personal data and applies to all individuals including users of the Site, partners, clients, and associates.

2. Information We Collect

Depending on your interaction with us, we may collect the following categories of Personal Data:

• Identity and Contact Details: Family Name (Last), Given Name (First), business email address.
• Assessment and Survey Data: Responses submitted in questionnaires or surveys, feedback provider details.
• Demographics: Age range, location, industry type (used in anonymised, aggregate form only).

We collect personal data either:

• Directly from you,
• Via your authorised representatives,
• Through online questionnaire submissions, or
• From third-party service providers.

Optional Data: The Site may include additional questions requesting demographic or other personal information. Providing this information is entirely optional, and you may choose to skip these questions without any impact on your participation.

3. Purpose for Collection, Use, and Disclosure

Your personal data may be collected, used, or disclosed for the following purposes:

• To enable participation in assessments, surveys, and training programs;
• To generate and deliver feedback reports;
• To facilitate coaching, development, and learning initiatives;
• To send notifications, updates, and reminders;
• To contact you for feedback, service updates, or performance analytics;
• For identity verification and fraud detection;
• For internal data analytics, program improvements, and research (anonymised);
• To manage client, partner, and customer relationships;
• To comply with applicable laws, regulatory obligations, or law enforcement requirements;
• Any other purpose reasonably related to the above or for which consent was obtained.

4. Legal Basis for Processing

We process personal data only when:

• Consent is given (opt-in basis, as per GDPR and PDPA);
• It is necessary for the performance of a contract;
• There is a legal obligation;
• It is necessary to protect vital interests;
• It is in our legitimate interests, provided these do not override your rights and freedoms (e.g. fraud prevention, service improvement).

5. Use of Assessment Tools

Information gathered through the Site is treated with strict confidentiality. Where applicable, individual responses may be shared with:

• Authorized facilitators or coaches;
• Third-party vendors under strict confidentiality agreements;
• Internal teams for research or improvements (in anonymised format).

6. Opting Out

You may opt out of marketing or non-essential communications at any time by contacting us at: ideas@cultureinworkplace.com.

For data-related withdrawal, correction, or access, see Section 8 below.

7. Cookies

We use session cookies to support functionality of our Site.
We do not use persistent or third-party tracking cookies.

8. Your Rights

Under the PDPA, GDPR, and applicable laws, you have the right to:

• Access your personal data;
• Request correction or update of your data;
• Withdraw consent to data collection and use;
• Request erasure of your data;
• Object to processing, including automated profiling;
• Request data portability (for applicable jurisdictions);
• Lodge a complaint with your local Data Protection Authority.

All requests may be submitted in writing or via email to ideas@cultureinworkplace.com.

9. Accuracy and Retention

We rely on the accuracy of information you provide.
Please inform us of any updates. Personal data will be retained:

• Only as long as necessary to fulfil the purpose,
• Or as required by legal, regulatory, or business purposes.

10. Data Transfers Outside Singapore/EU

If your personal data is transferred outside your home jurisdiction (e.g., EU or Singapore), we will:

• Obtain your explicit consent (where required), and
• Ensure that the recipient country provides comparable protection standards (e.g. EU SCCs, PDPA safeguards).

11. Third-Party and Partner Sites

Our Site may contain links to partner websites or services that operate under their own privacy policies. We are not responsible for the data privacy practices of these third parties.

12. Data Security

We implement robust security measures including:

• Role-based access controls;
• Antivirus protection and secure infrastructure;
• Secure data storage and transmission protocols.

Nonetheless, we acknowledge no digital transmission is 100% secure. We continuously update our protocols in line with industry standards.

13. Children’s Privacy

Our Site is not intended for children under 13, and we do not knowingly collect data from minors.

14. Dispute Resolution and Legal Disclosure

For privacy-related inquiries or complaints, contact ideas@cultureinworkplace.com
We commit to investigating and resolving any data privacy concerns promptly. We may disclose personal data when legally required or to protect our legal rights.

15. Updates to This Privacy Policy

We reserve the right to amend this Policy at any time. Changes will be effective upon posting on our website. Continued use of our Site or services indicates your acceptance of the updated terms.

Effective date: 22/04/2025
Last updated: 22/04/2025
Version: 1.1