Privacy Policy

Welcome to Culture Crunch

Culture Crunch Pty Ltd ("we", "us", "our") is committed to protecting the privacy of individuals who use our leadership development platform. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our services.

Culture Crunch Pty Ltd
ACN: 693 217 971
ABN: 67 693 217 971
Registered Address: 91C Shepherd Street, Bowral, NSW 2576, Australia

We comply with the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) and any applicable state privacy legislation.

Our Privacy Philosophy: Privacy by Minimalism

We believe in collecting only what we need to deliver value. Our approach is "privacy by minimalism" - we deliberately design our platform to work with team-level insights rather than individual performance tracking.

Aged Care Industry Considerations

Culture Crunch is designed specifically for the aged care sector in Australia. We understand the unique privacy requirements of this industry:

Information We Collect

Account Information

• - Name and email address
• - Organisation name and role
• - Contact preferences
• - Payment information (processed securely by third-party providers)

Platform Usage Data

• - Team-level pulse survey responses (aggregated, not individual)
• - Leader self-reflection inputs
• - Program progress and completion data
• - AI Coach interaction logs (for service improvement)

Technical Information

• - Device type and browser information
• - IP address (anonymised after 30 days)
• - Cookies and similar technologies

How We Use Your Information

• Service Delivery: To provide team-level insights and personalised leadership recommendations
• AI Coach Companion: To generate evidence-based micro-actions for leaders
• Platform Improvement: To enhance our algorithms and user experience
• Communication: To send program updates, insights, and relevant information
• Research: To contribute to peer-reviewed organisational science (de-identified only)

AI-Powered Insights

Our AI Coach Companion (ChrisAI) analyses team-level data to provide leadership recommendations. These insights are:

• - Advisory only (not automated decisions affecting employment)
• - Based on aggregated team signals, not individual metrics
• - Designed to support leadership development, not replace human judgment
• - Always subject to leadership context and discretion

You have the right to understand how AI recommendations are generated and to request human review of any AI-generated insight.

Workplace Privacy Notice

Culture Crunch is designed for workplace use. If you are an employee whose organisation uses Culture Crunch:

• Team-Level Only: Your team leader may access team-level insights that include aggregated signals from participation
• Individual Privacy: We do NOT share individual responses, scores, or behavioural data with your employer
• Not Surveillance: Culture Crunch is not a surveillance system and does not constitute workplace surveillance under NSW law
• Complaints: You may raise concerns with us at privacy@culturecrunch.io or your organisation's privacy officer

Privacy Protection for Small Teams

For teams with fewer than 5 members, aggregated data may be reasonably identifiable to individuals. In these cases:

• - We apply additional privacy safeguards
• - Leaders receive summary insights only (no granular breakdowns)
• - Sensitive signals are suppressed if identifiability risk is high
• - We will notify you if your team size creates privacy considerations

Who We Share Data With

We only share data with trusted service providers who process data on our behalf:

• Cloud Hosting: Secure Australian-based infrastructure
• Payment Processing: PCI-compliant payment providers
• Email Delivery: Transactional email services
• Analytics: Privacy-focused analytics tools

All processors are contractually bound to protect your data and comply with Australian privacy standards.

Data Security

We implement industry-standard security measures including:

• - Encryption in transit and at rest
• - Regular security assessments
• - Access controls and authentication
• - Employee security training

While we take security seriously, no system is 100% secure. We encourage you to use strong passwords and protect your login credentials.

Data Breach Notification

If we experience a data breach likely to result in serious harm, we will:

• - Notify affected individuals as soon as practicable
• - Notify the Office of the Australian Information Commissioner (OAIC)
• - Provide details of the breach, likely consequences, and steps being taken

We maintain an incident response plan in accordance with the Privacy Act 1988.

Data Retention

We retain your data for as long as your account is active, plus 90 days for transition support. Upon account deletion:

• Active Data: Removed within 90 days to allow transition/export
• Backup Systems: Removed within 180 days (due to backup rotation)
• Legal Holds: Retained longer only if required by law or legitimate dispute
• Aggregated Analytics: De-identified data may be retained indefinitely for research (cannot be re-linked to you)

Your Rights

Under Australian Privacy Principles, you have the right to:

• - Access personal information we hold about you
• - Request correction of inaccurate information
• - Request deletion of your data (subject to legal requirements)
• - Opt-out of marketing communications
• - Complain to the OAIC if you believe we've breached the APPs

We will respond to access and correction requests within 30 days.

International Data Transfers

Some of our service providers may be located overseas. When we transfer data internationally, we ensure appropriate safeguards are in place to protect your information in accordance with APP 8.

Cookies and Similar Technologies

We use cookies and similar technologies to:

• - Keep you logged in
• - Remember your preferences
• - Understand how you use our platform
• - Improve our services

You can control cookies through your browser settings. Some features may not work properly if cookies are disabled.

Contact Us

For privacy-related questions or to exercise your rights:

Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated via email or platform notification. Continued use of our services after changes indicates acceptance.