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    Terms & Privacy

    The terms governing use of this site and how we collect, use, and protect your personal data.

    Terms of Use•Privacy Policy

    Terms of Use

    These Terms of Use ("Terms") govern use of this website www.culturegene.ai ("Site"), which is provided by Culture Comes First Limited ("CCF" or "we", "us") with the primary purpose of providing interested persons with access to general information and material about the executive search, interim management, leadership and assessment services offered by CCF and its consultants.

    In certain countries, this Site may also allow the user to view job listings and to apply for those through a portal. Use of this Site and the available information and content shall be governed by these Terms, including any updates or revisions made in accordance with the below provisions.

    All Site information is provided on an "as is" basis and to the best of our knowledge is accurate and complete as at the date of publication. However, we provide no warranties of any kind, including any implied warranties of care and skill, fitness for a particular purpose or non-infringement of third party intellectual property rights. We make no representation or warranty about the accuracy or completeness of any information or that use of the Site will be risk or error free, uninterrupted or completely secure, or that errors or defects will be corrected. Users are advised to undertake routine checks of our Site for latest content and to take appropriate protective measures against viruses and other malicious objects.

    Location

    Where we are able to collect information about your location, you may be provided with a local version of this Site. This will provide you access to locally tailored content, and ensure information is presented in an appropriate local language.

    If you wish to navigate to another version of the Site, you can do so by using the links provided at the top of the page in the navigation bar.

    Job Listings and Applications

    If you use the Site to view and / or apply for a job vacancy, you should be aware that all jobs are listed on behalf of third party clients of CCF who have instructed us to manage a recruitment process on their behalf.

    We expressly do not make any representation or warranty about the accuracy of any information contained in a job listing.

    If you apply for a job, your application will be managed in accordance with a process which we will have agreed with the relevant client.

    Whilst we will use reasonable endeavours to remove expired job listings from the Site, we can give no guarantee that any vacancy listed on this Site remains open at any given time.

    For more detail about the information we collect from job applicants, and how that information is used and managed, please refer to our Privacy Policy.

    Use of this Site

    Users may only use this Site for lawful purposes. Users must not under any circumstances seek to undermine the security of the Site or any information submitted to or available through it. In particular, users must not seek to access, alter or delete any information to which the user does not have authorised access, seek to overload the system via spamming or flooding, take any action or use any device, routine or software to crash, delay, damage or otherwise interfere with the operation of this Site or attempt to decipher, disassemble or modify any of the software, coding or information comprised in the Site.

    Users are solely responsible for any information submitted to this Site and should ensure details supplied are true, accurate, up-to-date and not misleading or likely to mislead or deceive. Nor should users supply information that is discriminatory, obscene, offensive, defamatory or otherwise illegal, unlawful or in breach of any applicable legislation, regulations, guidelines or codes of practice or the copyright, trademark or other intellectual property rights of any person in any jurisdiction. Users are also responsible for ensuring that all information, data and files are free of viruses or other routines or engines that may damage or interfere with any system or data prior to being submitted to this Site. We reserve the right to remove any information supplied by a user from the website at our sole discretion, at any time and for any reason without being required to give any explanation.

    Limitation of Liability

    CCF shall not be liable, and hereby excludes liability, for any loss, damage or injury (including any special, exemplary, indirect, incidental, consequential damages, costs or associated legal fees) that may be suffered as a result of access to or use of the Site or content to the fullest extent permitted by law. Our sole and exclusive liability for any reason shall be to discontinue access to or use of the Site or relevant content.

    Intellectual Property

    Unless otherwise stated, all content on the Site (including artwork, graphics, photographs, images, screen shots, text, downloadable files, video clips, trademarks, logos, product names, slogans, and compilations of the foregoing) (collectively, "Content") is owned or controlled by CCF and its licensors and may be protected by UK and international copyright, trade mark and other intellectual property laws. Users are expected to respect these laws and limit the download and use of Content for personal, non-commercial purposes only in accordance with these Terms. Users must not copy, modify, reproduce or use Content for any other purpose without our prior written consent, which may be withheld at our absolute discretion.

    Currency of Content

    CCF updates the information on this Site regularly and we reserve the right to delete, modify or supplement content at any time. Users are advised to undertake routine checks of the Site for the latest content. We may also revise and update these Terms from time to time. Any revisions will be effective when we publish an updated version of these Terms on our website. Access or use of the Site following updates to these Terms constitutes acceptance of those updated terms. Users who do not accept these Terms should not access or use the Site.

    We may, at our sole discretion and at any time, discontinue, restrict or prevent use of the Site, with or without notice. CCF will have no liability to users if access to the Site is discontinued.

    Corporate Information

    Culture Comes First Ltd, 727-729 High Road, London, N12 0BP

    These Terms shall be governed by and construed in accordance with the laws of England and Wales. By using this Site, users agree to submit any dispute arising from use of the matters covered by these Terms to the exclusive jurisdiction of the courts of England and Wales.

    General Provisions

    These Terms constitute the entire agreement between the user and CCF regarding the use of the Site. This is a legally binding agreement which is accepted by the user as a condition of use of the Site. The Terms operate to the fullest extent permissible by law, provided that any provision that is unlawful, void, or unenforceable, shall be severed, but without affecting the validity and enforceability of any remaining provisions. Any failure by CCF to act with respect to any breach shall not constitute a waiver of CCF's right to act with respect to future or similar breaches.

    Privacy Policy

    Your privacy is important to us. This privacy policy explains how we process personal data, when (i) you visit this site and (ii) when you interact with our global businesses delivering search, interim management, consulting and assessment Services, including how it affects our website: www.culturegene.ai and (iii) when you engage with us on the Services that we provide. It also includes information about how we process personal information as a result of us providing our Services to third parties (i.e. our clients).

    Who we are

    We are Culture Comes First (CCF) Limited. We are a registered company in the United Kingdom with a registration number of 10711552 and our registered office is at 727-729 High Road, London, N12 0BP.

    CultureGene is a global executive search and consulting business specialising in search, interim management and leadership and assessment and management consultancy Services ("our Services"). We identify individuals to fill roles with client organisations in parts of business and public life.

    CCF ("we", "us") is committed to keeping your information secure and managing it in accordance with our legal responsibilities, under the privacy and data protection laws applicable wherever we operate in the world, as well as the Data Protection Act 2018 and UK GDPR along with the General Data Protection Regulation (Regulation (EC) 2016/679 ("GDPR") in the European Union ("EU").

    Our standards exceed those of the Association of Executive Search and Leadership Consultants, of which we are a member.

    We keep this Privacy Policy under regular review and update it from time to time.

    This policy was last updated in April 2026.

    Who this policy applies to

    This policy applies to you whether you are a candidate for one of our clients, an individual we are assessing as an employee of one of our clients, a client or whether you are a source or a referee in respect of a candidate or an employee of one of our clients.

    Additionally, this policy will apply to you if you attend one of our events or have subscribed to receive information about our Services or any of our marketing materials.

    For the purposes of this policy:

    • candidate(s) means an individual who is a candidate, applicant, potential candidate, employee of a client;
    • client(s) means any business, firm, organisation, government body or individual that mandates us to perform any of our Services;
    • a referee is a person who provides a personal or work reference in respect of a candidate; and
    • a source is a person who provides us with information or intelligence about a candidate.

    Gathering information

    Our clients expect that we identify the best individuals to fill roles within their organisations. So, we need to research systems, online databases and other information sources, and talk to many individuals. Besides our clients, these will include referees and sources to help inform our decision-making process.

    The nature of our work means we are required to process personal data quickly, confidentially and often without reference to the data subject. Accordingly, we process such data in accordance with the Data Protection Laws, regularly using our legitimate interest where it is not possible or feasible to speak directly with the data subject. Beyond this, we will seek consent in the circumstances explained later in this policy document.

    We collect information from candidates directly when you upload your CV or resume to our candidate portal or when you send this to us via email or post. We also collect information from you when you speak with a CCF employee in any office around the world.

    We also collect information from you in automated ways, including through the use of cookies and similar technologies (see the "Analytics" and "Cookies" sections of this policy) as well as through the use of tracking pixels and tokens in our email communications (e.g. to understand whether you have opened a marketing email from us).

    How we use your personal data

    Candidate

    We use the personal data we collect from you for a number of purposes:

    • Processing job applications, in partnership with our clients, on whose behalf we are instructed to help fill a job vacancy. This means that if you apply for a specific job, we may pass your details to the relevant client to proceed with the application. As a result, you may receive further direct correspondence from them.
    • Searching for relevant candidates for confidential recruitment assignments where our client is not initially named. If we believe you are suitable for a specific role, we may pass your basic details on to the relevant client. If that client agrees that you might be suitable, we will then discuss this with you in more detail. You might be interviewed for the role by one of our consultants. If successful, you might be shortlisted for interview by our client.
    • From time to time, we conduct mapping or research exercises on behalf of our clients to enable them to understand a particular market. Here, we may include certain aspects of your personal data. You will not be contacted by any third party about this unless we first obtain your consent.
    • For the performance of a contract we have concluded with you as an individual, most likely an assessment or coaching programme.
    • For equality monitoring purposes, to understand the diversity of our applicant pool, but only if admissible under the applicable law. (This information is anonymised and aggregated).
    • Improving the service we offer. For example, you may be asked to complete one of our online satisfaction surveys.
    • For direct marketing purposes, to understand how you use and interact with our recruitment Services, our website and previous communications we have sent you, and to then send you information on our Services, white papers, newsletters, events and so forth which we believe will be relevant to your expressed or inferred interests, or which would generally be relevant to someone in your position. You may opt out from receipt of marketing materials at any time by writing to us.

    We will only use your information in accordance with this Policy, or where we are required or authorised by law to disclose your information to others, or have your permission to do so.

    Please be aware that we are not responsible for the data processing activities of others, such as our clients.

    Client

    We will use client data to perform our Services to you and other legitimate business purposes such as marketing.

    Source and Referee

    We will use source and referee data to perform our Services, in particular, to enable us to obtain your opinions on a candidate.

    We may also use this information to enable us to market our Services to you as a potential client. We may as well invite you to become a candidate in respect of the provision of our Services.

    The type of personal data we collect and process

    In all cases, we collect and process personal data about you, including your name, address, telephone number and email address.

    Candidate

    If you proceed with a job application, or should we consult you about a role, you may be required to submit additional personal data. For example, date of birth, education and career history and curriculum vitae (CV), or resume. Your CV or resume may contain employment history, education, professional qualifications, memberships, details of papers written, references and referees, amongst other things.

    Based on your explicit consent, we will also process any relevant psychometric assessments, psychological tests, or results from such assessments or tests.

    From time to time, we may ask you to provide information relating to protected characteristics, such as your race or marital status. We do this for equal opportunity monitoring purposes and from time to time online, but only if that's admissible under local law. This information is always anonymised and aggregated and will not be revealed to third parties without your specific consent.

    We might also collect personal data from third-party databases and other public sources.

    Client

    As well as basic contact information we will also collect information about your role and other information provided to us by your organisation.

    Source and Referee

    As well as basic contact information we will also collect information regarding your credentials as a source, details of your relationship/knowledge of a candidate and your opinions of that individual. We may obtain this information directly from you or publicly available information.

    What we do

    For certain roles, we may run an advertisement to which you may respond, either electronically or via mail. Other roles may involve one of our researchers or consultants calling you to discuss the details. Then, we will either inform you verbally that we will process your personal data or send you a Data Privacy Notice. Both will direct you to this Privacy Policy.

    Besides filling particular leadership vacancies, we also process personal data when we conduct market intelligence exercises to map out particular business sectors or functions to help clients understand the available talent.

    Sensitive data

    From time to time, we will seek your consent to process personal data in respect of certain specific and limited purposes. We will always do this before processing any sensitive personal data: racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, data concerning health or sex life and sexual orientation, genetic and/or biometric data. We encourage you not to provide us with sensitive personal data unless it is specifically requested, and we have your consent.

    Local agreements

    In certain countries, we will not collect personal data from you unless you have specifically agreed to this. Your agreement might come via an electronic tick-box on our website or other electronic channels, or via other similar measures required by local privacy and data protection laws.

    We may also provide Services to our clients in certain countries that entail the assessment and coaching of their employees. Here, depending on the specific assignment, we will either process your personal data to meet the legitimate interests pursued by the client or act on their behalf, in accordance with their instructions. If our Services include any psychometric assessments or psychological tests, and we're not acting on behalf of your employer, we will obtain your specific consent.

    In some locations, we provide Services to individuals, such as assessment and coaching. Here, we will process personal data for the performance of the contract with you. If our Services include any psychometric assessments or psychological tests, we will obtain your specific consent.

    Your right to object and to have your data erased

    You are not obliged to provide any personal data to us. However, please note that this may mean we will not be able to consider you in respect of any of our Services.

    Remember, you may withdraw any consent you have previously given, at any time, and you have the right to ask us to stop processing any personal data and to have it erased if we no longer have a lawful reason to continue processing your data. You also have the right to object to any processing of your data that we carry out on a 'legitimate interest' basis, or to processing carried out for direct marketing purposes.

    In these circumstances, we reserve the right to maintain basic personal data such as your name and address. This is to ensure your personal data isn't processed by us in the future.

    Please note that no automated decisions, such as computerised candidate profiling, are made on the basis of the information we collect.

    Newsletters and other communications

    If you would like to receive one of our newsletters, we will ask you to provide us with your name, email address, job title, company name and country of residence.

    When you have indicated you would like to receive newsletter(s) from us, we may send email alerts and bulletins about our Services and any roles that might interest you.

    You can unsubscribe from our electronic marketing messages by following the "unsubscribe" instructions included in our communications. Also, you may change your preferences and cease receiving direct marketing from us through your email account settings.

    From time to time, we may contact you with updates on our Services, terms of business or simply to ensure that the data we hold is current, relevant and up to date.

    Satisfaction surveys

    If you take part in a user satisfaction survey, we may ask you to provide us with personal data, including your name, email address, and your views and opinions.

    Providing information to others

    To help us run this website, and to provide executive search Services, interim management services or assessment Services in certain countries, we work closely with trusted partners with whom we need to share personal data.

    We will share information only as anticipated within this Privacy Policy and, wherever appropriate, limit disclosure to information in aggregated form, to avoid or limit identifying you personally.

    Where we share information with such a third party, you will not be contacted by them, unless we have obtained your prior consent.

    Third parties

    We may also provide information to third party service providers who process information on our behalf. This is to help run some of our internal business operations, including email distribution, marketing, IT Services and customer Services. As part of our agreements with them, these third parties are required to process such data securely and only in accordance with our instructions.

    Web-based contact and submission tools

    Certain interactive tools made available on our website (for example, contact, enquiry or submission forms) do not themselves collect, store, or process any personal data on our servers. When you submit information through such a tool, your name, email address, and LinkedIn URL are transmitted via Resend, our email delivery service, which acts as a data processor on our behalf under Article 28 of the UK GDPR and EU GDPR. Resend retains this information for a maximum of 30 days, after which it is automatically deleted from their systems. The legal basis for this processing is your consent (Article 6(1)(a) GDPR), which you provide by submitting the form, together with our legitimate interest in responding to your enquiry (Article 6(1)(f) GDPR). You may exercise your rights of access, rectification, erasure, restriction, objection and data portability in relation to this processing by contacting us at the address given at the end of this policy.

    International transfers

    Your information may also be shared with organisations located elsewhere in the world including, without limitation, in the United States of America. As their privacy laws may not match your home country's standards, we'll only make a transfer if we have first implemented any safeguards, most commonly the 'standard contractual clauses', which are required by applicable law. You have a right to request a copy of any safeguards we use to transfer your personal data to third countries.

    We may sometimes be required to disclose information about you to law enforcement bodies, agencies or third parties, under a legal requirement or court order. We will act responsibly and take account, where possible, of your interests when responding to these requests.

    If you are concerned about these arrangements to disclose or share personal data with third parties, you should contact us and ask us not to process your personal data.

    Keeping information secure

    We invest significant resources to protect your personal data, from loss, misuse, unauthorised access, modification or disclosure. However, no system can be 100% secure, and so we cannot be held responsible for unauthorised or unintended access that is beyond our reasonable control.

    Information about others

    If you provide us with information about other individuals, like details of a referee or personal contact, you must ensure they've agreed to this. We would advise you to keep a record of their agreement and provide them with a copy of, or link to, this Privacy Policy.

    Keeping your records

    We keep your personal data for as long as required to provide our Services, and in accordance with legal, tax and accounting requirements. Where your personal data is no longer required, we will ensure it is disposed of in a secure manner. Where required by law, we will notify you when this has happened.

    Access rights

    In some jurisdictions, you may have the right to request copies of your personal data held by us. If you think any of that data is inaccurate, you may also ask us to correct it. You may also have a right, in certain circumstances, to require us to stop processing your personal data. Also, you have the right to ask us to transfer your personal data to someone you nominate for your own purposes.

    To get in touch with us about any of this, please email or write to us at the address below. Please note that we may request proof of identity. We will respond to your requests within the time frame that applies in the country concerned.

    In certain circumstances, in countries where it is required or permitted by law, we might not be able to provide you with access to some of your personal data. Wherever possible, we will notify you of the reasons for this.

    About our websites

    This Privacy Policy applies to our websites too, where we process personal data within and through this website.

    The primary purpose of our websites is to provide you with information regarding the Services provided by CCF and consultants. In certain countries, you may use a site to view and apply for jobs.

    In some countries, you may be able to set up a user account. You will be asked to register a username and password so you can gain secure access to your account. The CCF branded microsite on which you access your account may be owned separately from this site but obeys all aspects of this Privacy Policy.

    We use the personal data we collect from you on our website for additional purposes such as personalising the look and feel of the website to fit the personal preferences inferred from how you've used the site.

    We may disclose or share personal data with third parties as outlined above to operate the website and provide our executive search Services, our interim management Services, as well as assessment Services in certain countries. If you are concerned about these arrangements, you should not use the website and contact us to ask us not to process your personal data.

    Finally, we might also use your data to help our clients understand who is making use of our website and how their job vacancies are being viewed.

    Updating your account and preferences

    If you register an account with us, or with a local partner who provides a job application portal on our behalf, please do keep your details up to date, and notify us of any changes to your personal data. You can do this by updating your user preferences through your account login, or by contacting us using the details below.

    Analytics

    We use analytics tools and cookies on this website to help deliver our online Services, identify any service issues, improve our Services, provide content tailored to users' personal preferences, and to monitor site traffic and usage.

    These tools may be provided by third-party service providers and may include the collection and tracking of certain data and information regarding the characteristics and activities of visitors to our website. We may disclose data, including personal data, to certain third-party Services providers in order to obtain such Services.

    One of these providers is Google Analytics. More information about the ways in which they collect and process your personal data can be found here: www.google.com/policies/privacy/partners

    You can opt-out of Google Analytics here: tools.google.com/dlpage/gaoptout

    We also use Hotjar in order to better understand our users' needs and to optimise our service and experience. Please note that Hotjar does not store identifiable personal data but stores a pseudonymised user profile. Neither Hotjar nor us will ever use this information to identify individual users or to match it with further data on an individual user.

    Cookies

    Cookies are small computer files which are downloaded onto your device when you browse the web. They collect information about the way in which you navigate and use this website and the wider web. This information may allow us to identify you or your approximate location. Cookies also help us provide you with a more personal experience, like a local version of the website in a local language. Information from cookies also allows us to make improvements to our Services.

    We only collect "session" cookies, which are not usually stored after your browsing session has ended. These are used to establish your approximate location and to serve up the website in an appropriate language. (IP address collection happens during this process.)

    You may delete and block all cookies, or just certain types of cookies, via your browser settings. However, if you choose to block or delete cookies, this may affect the functionality of the website.

    Third party websites

    This Policy only applies to this website. If you land on our site from other websites or move to other ones from our website, you should read their separate privacy policies.

    Complaints procedure

    If you have a complaint about how we have handled your personal data, contact us using the details below, and we will investigate your complaint. Please use the same contact details to instruct us to cease processing your personal data.

    Contacting us

    If you have any questions about this Privacy Policy, or would like to exercise your rights with respect to your personal data, please contact us at data.administrator@culturegene.ai, or write to:

    Culture Comes First Ltd, 727-729 High Road, London, N12 0BP