Privacy Policy

Effective date: 1 July 2026

This Privacy Policy explains how Independent Culture Limited, a company registered in England and Wales under company number 16023491, with its registered office at Flat 420, The Beaux Arts Building, 10–18 Manor Gardens, London, England, N7 6JW, trading as “HumanCulture” (“we”, “us”, or “our”), collects, uses, and protects personal data when you use our predictive content-intelligence platform and related services (the “Services”).

It should be read alongside our Terms of Service. We are committed to handling personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

1. Who We Are and Our Role

For personal data about our own account holders and website visitors — such as the people who sign up for and administer a HumanCulture account — we act as the data controller.

For personal data contained in the social-media and audience data that the Services collect from connected platforms on a customer's behalf (“Third-Party Content”), our customer is the data controller and we act as their data processor, processing that data only on their instructions and as described in our Data Processing Addendum. This Privacy Policy describes our practices as a controller; our obligations as a processor are set out in that Addendum.

Data protection contact: hello@humanculture.com. You can reach us at this address with any question or request about your personal data.

We are registered with the UK Information Commissioner's Office (ICO), registration number ICO:00010734498.

2. Personal Data We Collect

We collect and process the following categories of personal data:

  • Account and identity data: Name, work email address, job title, organisation name, and login credentials of account holders and Authorised Users.
  • Billing data: Billing contact details and subscription records. Card payments are handled by our payment provider; we do not store full card numbers.
  • Usage and device data: How you interact with the Services, log data, IP address, browser and device information, and cookie identifiers.
  • Connected-platform data
  • Communications: Records of your correspondence with us, including support requests and feedback.

We do not seek to collect special-category personal data, and you must not upload such data to the Services unless lawfully permitted to do so.

3. How and Why We Use Personal Data

We use personal data for the following purposes, relying on the lawful bases shown:

  • Providing, operating, and supporting the Services: Performance of our contract with you
  • Taking payment and managing subscriptions: Performance of our contract; legal obligation
  • Securing the Services and preventing misuse: Legitimate interests (keeping the Services safe)
  • Improving the Services and developing our models and benchmarks, using aggregated and de-identified data: Legitimate interests (improving our product)
  • Communicating with you about the Services and responding to requests: Performance of our contract; legitimate interests
  • Sending marketing about our Services, where permitted: Consent, or legitimate interests where allowed by law
  • Meeting legal and regulatory obligations: Legal obligation

Where we rely on consent, you can withdraw it at any time. Where we rely on legitimate interests, you can object, and we will stop unless we have compelling grounds to continue.

4. Data From Connected Social-Media Platforms

The Services let you connect third-party social-media platforms so that we can collect data on your behalf and generate Insights. When you connect a platform, you authorise a secure token to pass between that platform and the Services; we use it only to access the data needed to provide the Services to you.

We process connected-platform data solely to provide the Services to you. We do not sell this data, we do not use it for advertising, and we do not use it for any purpose prohibited by the platform it came from. We handle it in accordance with the relevant platform's developer and data-use policies.

5. How We Share Personal Data

We do not sell personal data. We share it only as follows:

  • Service providers (sub-processors): we use trusted third parties to help us run the Services — for example cloud hosting and infrastructure, analytics, customer-support tooling, and payment processing. They act on our instructions under contract and may only use the data to provide their service to us.
  • Legal and safety: where required by law, regulation, or valid legal process, or to protect our rights, users, or the security of the Services.
  • Business transfers: if we are involved in a merger, acquisition, or sale of assets, personal data may transfer to the successor, subject to this Policy.

A current list of the categories of sub-processors we use is available on request from our data protection contact.

6. Where We Store and Process Data

We host and process personal data within the United Kingdom and the European Economic Area (EEA). We do not transfer personal data outside the UK and EEA in the ordinary course of providing the Services. If this changes in future, we will put appropriate safeguards in place — such as UK-approved standard contractual clauses or an adequacy decision — and update this Policy.

7. How Long We Keep Data

We do not set a fixed expiry date for account and service data while your account remains active. We keep personal data for as long as it is reasonably needed to provide the Services, maintain security, comply with legal obligations, resolve disputes, enforce our agreements, and support product improvement using aggregated or de-identified data. If you ask us to delete personal data, or if your account is closed, we will delete or anonymise it within a reasonable period unless we need to retain it for one of those purposes. Third-Party Content connected through social-media platforms is deleted or anonymised on disconnection, termination, or your instruction, except where retention is required by law or needed to protect the Services.

8. How We Protect Data

We maintain appropriate technical and organisational measures designed to protect personal data against unauthorised access, loss, or misuse — including access controls, encryption in transit, and support for two-factor authentication. No system is completely secure, but we work to protect your data and will notify you and the ICO of a personal-data breach where we are legally required to do so.

9. Your Rights

Under UK data protection law you have the right to:

  • access the personal data we hold about you;
  • ask us to correct inaccurate or incomplete data;
  • ask us to delete your data in certain circumstances;
  • restrict or object to our processing in certain circumstances;
  • data portability, where processing is based on consent or contract and is automated; and
  • withdraw consent at any time, where we rely on it.

To exercise any of these rights, contact us at hello@humanculture.com. Where the data relates to Third-Party Content for which one of our customers is the controller, we will refer your request to that customer or assist them in responding.

You also have the right to complain to the ICO (ico.org.uk), though we would welcome the chance to address your concern first.

10. Cookies

We use cookies and similar technologies to operate the Services, remember your preferences, keep the Services secure, and understand how they are used. You can control non-essential cookies through your browser settings or any cookie controls we provide. Disabling some cookies may affect how the Services work.

11. Children

The Services are intended for business users and are not directed at children. We do not knowingly collect personal data from anyone under 18. If you believe a child has provided us with personal data, contact us and we will delete it.

12. Changes to This Policy

We may update this Policy from time to time. We will post the updated version with a new effective date and, where changes are material, give you reasonable notice by email or in-product notice. Continued use of the Services after a change takes effect means you accept the updated Policy.

13. How to Contact Us

For any question about this Policy or your personal data, contact our data protection contact at hello@humanculture.com, or write to us at: Independent Culture Limited, Flat 420, The Beaux Arts Building, 10–18 Manor Gardens, London, England, N7 6JW.