Privacy Policy

What we collect

• Contact form submissions – name, email, and message when you reach out to us
• Survey responses – NPS scores, comments, and driver selections submitted by your clients or employees, collected on behalf of your firm
• Platform usage – basic analytics to improve the service (page views, feature usage). We do not use third-party tracking pixels
• Account information – name, email, role, and firm association for authenticated platform users

How we use your data

• Deliver survey programs and feedback reports to your firm
• Generate anonymised insights and analytics using AI (see below)
• Improve and maintain the platform
• Respond to your enquiries

We do not sell, rent, or share your personal information with third parties for marketing purposes.

Ephemeral Data Retention

Our Ephemeral Data Retention framework gives each firm direct control over how long verbatim comments are retained – each firm configures its own retention period, from short windows for firms with strict data minimisation requirements through to extended retention for firms that want longer review windows.

NPS scores, loyalty driver selections and response metadata (dates sent and submitted, and the assigned professional) are retained as structured data for trend analysis and contain no free-text content. They remain linked to the client record for the life of your firm's engagement – that is what lets you see a client's history and act on a falling score – and are de-identified when the engagement ends. Free-text comments are retained only for the period your firm chooses. A daily automated process deletes verbatim comments once they pass your firm's retention period, recording only counts in the audit log – never content. The more privacy-protective setting always wins: shortening the period also removes existing comments older than the new period; lengthening it never restores anything already deleted. Expired staff survey invitations are anonymised by a separate daily cycle.

AI processing

Most of our platform uses no third-party AI at all. Dashboards, trend charts, NPS benchmarks, and longitudinal reports all run on structured data we hold ourselves.

Custom Reports – the one live AI feature

AI assists with early-stage drafting tasks only – surfacing relevant quotes from verbatim feedback, providing starting data points for charts, and producing rough first-draft text. Aggregate scores, loyalty driver selections, and verbatim feedback are sent to Anthropic under their enterprise data processing agreement. Anthropic is contractually prohibited from training their models on this submitted data, and all transmission is encrypted. The analytical content of every report – themes, interpretations, recommendations – is developed and finalised by Client Culture analysts. AI output is a starting input that accelerates drafting; it is not the deliverable.

Full anonymisation isn't compatible with the analytical task – themes drawn from verbatims need the verbatims, not redacted approximations – so Custom Reports relies on Anthropic's enterprise DPA's anti-training and confidentiality protections. Pseudonymisation is being rolled out: client, firm and professional names and identifying details are replaced with neutral references before content is sent to the AI provider, with real identities resolved only within Client Culture systems. The foundations shipped in August 2026; full rollout is gated on quality verification against real report output, and until then report prompts are not pseudonymised.

EphemeralAI™, our trademark for AI processing that strips personal identifiers before any model call, is held in reserve for future features where it is practical.

Data retention

• Survey verbatim comments – retained according to your firm's chosen retention period and deleted automatically by a daily process once that period passes
• Anonymised themes and scores – retained for ongoing analytics and benchmarking
• Account data – retained while your firm's account is active, deleted on request
• Contact form data – retained only as long as needed to respond to your enquiry

Sub-processors

We use a small number of trusted third-party services to operate the platform. All sub-processors are contractually bound to protect your data.

Neon, Vercel, and Resend all operate on Amazon Web Services infrastructure; client feedback data is stored in the AWS Sydney region. Details of downstream sub-processors are available in each provider's own trust documentation.

Custom reports for firms (NPS analysis, verbatim summaries, longitudinal trend reports) are prepared in Google Workspace (Slides, Sheets, Drive) on a Client Culture business account. Survey data including verbatim feedback is processed within these tools during report preparation.

Your rights

Depending on your jurisdiction, you may have the right to:

• Access the personal information we hold about you
• Request correction of inaccurate information
• Request deletion of your personal information
• Object to or restrict certain processing
• Withdraw consent where processing is based on consent

To exercise any of these rights, contact privacy@clientculture.com.

Regional compliance

Client Culture operates under the Australian Privacy Act 1988 and the Australian Privacy Principles (APPs). For clients in the United Kingdom and European Economic Area, we also comply with UK GDPR and EU GDPR respectively. Regional addenda covering specific obligations are included in our full privacy policy.

Questions?

For privacy enquiries, contact privacy@clientculture.com. For security-related concerns, contact security@clientculture.com.