Privacy Policy
Effective 1th November 2024
Your Privacy Matters
At L10, we believe that a privacy policy should be easy to understand and provide clarity on what data we collect, how we collect it, and how we use it, so that we can continue to earn your trust.
Our mission is to help organisations enhance employee satisfaction, retention, and productivity through AI-powered insights. Central to this mission is our commitment to transparency about the data we collect about you and your organisation, how it is used, and with whom it is shared.
This Privacy Policy applies when you use our Services (described below). We offer our users choices about the data we collect, use and share as described in this Privacy Policy and Cookie Policy.
1. Introduction
L10 is an AI-powered Employee Experience Platform designed for modern organisations. Organisations use our Services to understand and improve employee experience and company culture through continuous feedback and insights. Our Privacy Policy applies to any Member using our Services.
Our registered users (“Members”) create or join organisations (“Organisations”) to engage with their co-workers, respond to daily and periodic surveys, and contribute to enhancing workplace culture. Members are categorised as follows: Admins, who can manage organisation settings, conduct surveys, view analyses, and handle billing; and Members, who can participate in surveys, receive notifications, and view profiles of other organisation members. Additionally, content and data on some of our Services are accessible to non-members (“Visitors”).
Services
This Privacy Policy, including our Cookie Policy applies to your use of our Services.
This Privacy Policy, including our Cookie Policy applies to L10 and other L10-related sites, apps, communications and services ("Services"), including off-site Services, but excluding services that state that they are offered under a different privacy policy.
Data Controllers and Contracting Parties
TeamCulture.ai Limited (operating as "L10") will be the controller of your personal data provided to, or collected by or for, or processed in connection with our Services.
As a Visitor or Member of our Services, the collection, use and sharing of your personal data is subject to this Privacy Policy and other documents referenced in this Privacy Policy, as well as updates.
Change
Changes to the Privacy Policy apply to your use of our Services after the "effective date."
L10 ("we" or "us") can modify this Privacy Policy, and if we make material changes to it, we will provide notice through our Services, or by other means, to provide you the opportunity to review the changes before they become effective. If you object to any changes, you may close your account.
You acknowledge that your continued use of our Services after we publish or send a notice about our changes to this Privacy Policy means that the collection, use and sharing of your personal data is subject to the updated Privacy Policy, as of its effective date.
2. Data We Collect
2.1 Data You Provide To Us
Registration
You provide data to create an account with us.
To create an account, you need to provide an email address and/or Google ID. If you subscribe to our paid services, you will need to provide payment (e.g., credit card) and billing information, which is processed securely through Stripe, Inc.
Organisation Profile
You create an organisation profile and add/remove members.
To create an organisation profile, you need to provide an organisation name. As an organisation profile admin, you may choose to assign members of your organisation as admins. admins and the owner of an organisation profile may choose to change the organisation name, logo, and languages. As an organisation member, you can view the profiles of other members.
Member Profile
You create your own and your team members' profiles (a profile helps others identify you).
Admins have choices about the information included in the profile, such as first and last name, preferred name, pronouns, title, birthday, business unit, department, gender, avatar, area, and country. Only the email address is mandatory for a profile. The profile is visible to all members of the organisation. All of the above information is only available to members of your organisation.
Surveys
You can set up surveys and their questions as organisation admins.
Surveys are designed to gather insights on employee experiences and may include various types of questions to capture relevant feedback. When creating questions for surveys, please ensure that they do not include any personally identifying information about respondents or others.
Survey Responses
You may respond to daily questions and periodic surveys about your employee experience.
All surveys are anonymous, and we advise you not to provide any personally identifying information about yourself or others. You are not required to answer any surveys; however, not participating may limit the insights available to your organisation.
2.2 Data From Others
Invitation to an Organisation
When an organisation admin adds you to their organisation, they provide us with data about you.
When others invite you to join their organisation as a member, they share personal data about you, including your eligibility to access the information of their organisation and respond to surveys. Your profile may be visible to the members of the organisation.
Organisation Resources
Admins of an organisation profile share resources with members within the organisation.
Admins of an organisation profile may share text, web links, and files that include information about the organisational structure, policies and procedures, software and devices, as well as the vision, mission, and values of your organisation. This information is only visible to members of your organisation.
Partners
Partners may provide data to us.
We receive personal data (e.g., your job title) about you when you use the services of our partners, such as employers providing us with your work email address, job title, and other personal information.
Our Affiliates
Our affiliates may provide data to us.
We receive data about you when you use some of the other services provided by us or our affiliates. For example, you may choose to send us information about your strengths assessment.
2.3 Service Use
We log your visits and use of our Services.
We log usage data when you visit our sites, such as when you view or click on content (e.g. learning video) or ads (on or off our sites), perform a search, share and download content, update a profile, answer a survey or join/quit a team. We use log-ins, cookies, device information and internet protocol (“IP”) addresses to identify you and log your use.
2.4 Cookies and Similar Technologies
We collect data through cookies and similar technologies.
As further described in our Cookie Policy, we use cookies and similar technologies (e.g., pixels and ad tags) to collect data (e.g., device IDs) to recognise you and your device(s) on, off and across different services and devices where you have engaged with our Services. We also allow some others to use cookies as described in our Cookie Policy. You can opt out from our use of data from cookies and similar technologies that track your behaviours on the sites of others for ad targeting and other ad-related purposes. For Visitors, the controls are here.
2.5 Your Device and Location
We receive data through cookies and similar technologies.
When you visit or leave our Services (including some plugins and our cookies or similar technology on the sites of others), we receive the URL of both the site you came from and the one you go to and the time of your visit. We also get information about your network and device (e.g., IP address, proxy server, operating system, web browser and add-ons, device identifier and features, cookie IDs and/or ISP, or your mobile carrier). If you use our Services from a mobile device, that device will send us data about your location based on your phone settings. We will ask you to opt-in before we use GPS or other tools to identify your precise location.
2.6 Sites and Services of Others
We get data when you visit other sites that include our ads, cookies and similar technologies.
We receive information about your visits and interaction with services provided by others when you visit others’ services that include our ads, cookies or similar technologies.
2.7 Other
We are improving our Services, which means we get new data and create new ways to use data.
Our Services are dynamic, and we often introduce new features, which may require the collection of new information. If we collect materially different personal data or materially change how we collect, use or share your data, we will notify you and may also modify this Privacy Policy.
3. How We Use Your Data
We use your data to provide, support, personalise and develop our Services.
How we use your personal and organisation data will depend on which Services you use, how you use those Services and the choices you make in your settings. We use the data that we have about you to provide and personalise our Services, so that our Services can be more relevant and useful to you and your organisation.
3.1 Services
Here’s a revised version that improves clarity and flow:Our services are designed to cultivate a connected and engaged workforce while enhancing organisational culture. By leveraging advanced AI, we aim to improve employee satisfaction, retention, and productivity.
By utilising your data, we ensure seamless access to our services while respecting your personal and organisational settings.
Engagement & Feedback
The core of our service is a daily question system delivered to your team members. This approach enables real-time tracking of team sentiment and provides over up to hundreds of touchpoints each year for comprehensive insights. Through continuous monitoring, organisations can identify and prevent workplace issues before they escalate. While daily questions are our recommended approach, we offer flexible scheduling surveys to suit your organisation's needs.
Anonymous & Qualitative Feedback System
We understand the importance of authentic feedback in building a strong organisational culture. Our system ensures complete anonymity for all responses, with an additional option to rephrase responses for enhanced privacy. By combining qualitative and quantitative data analysis, we create a safe environment where team members can share their honest opinions through open-text responses without concern.
Metric Tracker
Organisations can choose to customisable metrics that align with their specific goals and objectives. The system visualises real-time performance metrics, allowing leaders to track cultural indicators across teams and the entire organisation. Through sophisticated analysis, our AI transforms qualitative responses into actionable insights that drive meaningful change.
Multilingual Capabilities
Modern workplaces are diverse and global, which is why our platform supports multiple languages. Our system goes beyond basic translation, attempting to understand informal language and even incomplete responses. This comprehensive language support helps break down communication barriers across global teams, ensuring every employee's voice is heard and understood.
3.2 Communications
We contact you and enable communications between organisation members. We offer settings to control what messages you receive.
We will contact you through email and notices posted on our websites, notifications to your notification inbox, and other ways through our Services, including push notifications. We will send you messages about the availability of our Services, security, or other service-related issues. We also send messages about how to use our Services, organisation updates, reminders, recommendations and promotional messages from us and our partners. You may change your communication preferences at any time. Please be aware that you cannot opt out of receiving service messages from us, including security and legal notices. We also enable communications between you and others through our Services, including Slack and WhatsApp.
3.3 Advertising
We serve you tailored ads both on and off our Services. We offer you choices regarding personalised ads, but you cannot opt-out of seeing other ads.

We target (and measure the performance of) ads to members, teams, organisations and visitors both on and off our Services directly or through a variety of partners, using the following data, whether separately or combined:

  1. Data from advertising technologies on and off our Services, pixels, ad tags, cookies, and device identifiers; Member-provided information (e.g., profile, contact information and title);
  2. Data from your use of our Services (e.g., search history, content you read, tasks you complete, team profiles, organisation profiles, page visits, videos you watch, clicking on an ad, etc.);
  3. Information from advertising partners; and
  4. Information inferred from data described above (e.g., using job titles from a profile to infer industry, seniority, and organisation profiles; using pronoun usage to infer gender; using your feed activity to infer your interests; or using device data to recognise you as a Member).
We will show you ads called sponsored content which look similar to non-sponsored content, except that they are labeled as advertising (e.g., as “ad” or “sponsored”). If you take an action (such as click) on these ads, your action is associated with your name and viewable by others, including the advertiser.
Ad Choices
You can also opt-out specifically from our uses of certain categories of data to show you more relevant ads in settings.
Info to Ad Providers
We do not share your personal data with any third-party advertisers or ad networks except for: (i) hashed IDs or device identifiers (to the extent they are personal data in some countries); (ii) with your separate permission (e.g., in a lead generation form) or (iii) data already visible to any users of the Services (e.g., profile). However, if you view or click on an ad on or off our Services, the ad provider will get a signal that someone visited the page that displayed the ad, and they may, through the use of mechanisms such as cookies, determine it is you. Advertising partners can associate personal data collected by the advertiser directly from you with hashed IDs or device identifiers received from us. In such instances, we seek to contractually require such advertising partners to obtain your explicit, opt-in consent before doing so.
3.4 Marketing
We promote our Services to you and others.
In addition to advertising our Services, we use members’ organisation data and content for promoting intra-organisation communications and engagement, such as by showing other members in your organisations that you have used a feature on our Services.
3.5 Developing Services and Research
We develop our Services and conduct research to improve our Services.
Service Development
We use data, including public feedback, to conduct research and development for our Services in order to provide you and others with a better, more intuitive and personalised experience and help improve organisation culture.
Other Research
We use the personal and team data available to us to research workplace trends, such as the correlation between sentiment and engagement that help organisations to understand their workforce. In some cases, we work with trusted third parties to perform this research, and we publish or allow others to publish workplace culture insights, presented as aggregated data rather than personal data.
Surveys
Polls and surveys are conducted by us and others through our Services. You are not obligated to respond to polls or surveys, and you have choices about the information you provide. You may opt-out of survey invitations.
3.6 Customer Support
We use data to help you and fix problems.
We use data (which can include your communications) to investigate, respond to and resolve complaints and for Service issues (e.g., bugs).
3.7 Insights That Do Not Identify You
We use data to generate insights that do not identify you.
We use your data to produce and share insights that do not identify you. For example, we may use your data to generate statistics about our members, their profession or industry, and organisations, to calculate ad impressions served or clicked on, or to publish visitor demographics for a Service or create demographic workforce insights.
3.8 Security and Investigations
We use data for security, fraud prevention and investigations.
We use your data (including your communications) for security purposes or to prevent or investigate possible fraud or other violations of our User Agreement and/or attempts to harm our Members, Visitors or others.
4. How We Share Information
4.1 Our Services
Any data that you include on your profile and any content you share on our Services will be seen by only members of your organisation, consistent with your settings.
Survey
All organisation surveys are anonymous.
Any data that you share in a organisation survey are associated the organisation (and will be seen by the members of the organisation) and are not associated with your identity.
Personal Profile
Personal Profile is visible to all members of your organisation.
Our services allow you to view and share your personal profile, which includes various details such as your name, profile picture, title, pronouns, date of birth, location, objectives and goals, gender, department, and work email within your organisation.
Additionally, we provide suggestions for tasks and tips that can help you connect more effectively with your organisation. These recommendations are private and not visible to others. You also have the option to create objectives and goals to share with fellow members of your organisation. While these objectives are part of your profile and remain private by default, you can adjust their visibility in your settings if you choose to share them.
Organisation Profile
Organisation Profile is visible to all members of the organisation.
Our services enable the creation of an organisation profile. When you establish an organisation and invite others to join your team, all members can view each other's profiles and access the organisation's information. You have the ability to add or remove admins, who can view survey responses anonymously, conduct culture analysis, and access questions from all surveys, as well as information about the organisation, its settings, and billing details.
Admins can also share various resources—such as text, documents, articles, checklists, pictures, and videos—with the organisation. These resources are exclusively visible to members and are not accessible to others. Furthermore, admins can create organisation surveys and invite members to respond. The survey questions, responses, and analyses are visible only to the organisation's admins, in accordance with the organisation’s settings.
4.2 Survey Response Archival
Regulated Members may need to store survey response outside of our Service.
Some organisation need, for legal or professional compliance, to archive their survey responses, and will use services of others to provide these archival services. We enable archiving of survey responses outside of our Services. Because all surveys are anonymous, no survey responses are associated with a member’s identity.
4.3 Others’ Services
You may link your account with others’ services so that they can provide suggestions to improve your organisation culture. Excerpts from your profile (e.g., name and title) will also appear on the services of others.
Other services may look up your profile. When you opt to link your account with other services, personal data will become available to them. The sharing and use of that personal data will be described in, or linked to, a consent screen when you opt to link the accounts. For example, you may link your Slack account to send and receive notifications, or your email provider may give you the option to upload team resources into its own service. Third-party services have their own privacy policies, and you may be giving them permission to use your data in ways we would not. You may revoke the link with such accounts.
4.4 Related Services
We share your data across our different Services and TeamCulture.ai Limited or L10 affiliated entities.
We will share your personal data with our affiliates to provide and develop our Services. We may combine information internally across the different Services covered by this Privacy Policy to help our Services be more relevant and useful to you and others. For example, we may personalise your tasks or recommendations for improving your team culture based on the analysis of your team and organisation surveys.
4.5 Service Providers
We may use others to help us with our Services.
We use others to help us provide our Services (e.g., maintenance, analysis, audit, payments, fraud detection, marketing and development). They will have access to your information as reasonably necessary to perform these tasks on our behalf and are obligated not to disclose or use it for other purposes.
4.6 Legal Disclosures
We may need to share your data when we believe it’s required by law or to help protect the rights and safety of you, us or others.
It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with you; (3) investigate and defend ourselves against any third-party claims or allegations; (4) protect the security or integrity of our Services (such as by sharing with companies facing similar threats); or (5) exercise or protect the rights and safety of L10, our Members, personnel or others. We attempt to notify Members about legal demands for their personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.
4.7 Change in Control or Sale
We may share your data when our business is sold to others, but it must continue to be used in accordance with this Privacy Policy.
We can also share your personal data as part of a sale, merger or change in control, or in preparation for any of these events. Any other entity which buys us or part of our business will have the right to continue to use your data, but only in the manner set out in this Privacy Policy unless you agree otherwise.
5. Your Choices & Obligations
5.1 Data Retention
We keep most of your personal data and organisational data for as long as your account remains active.
We generally retain your personal data and organisational data for as long as your account remains active or as necessary to provide you with our services. This includes information that you or others provide to us, as well as data generated or inferred from your usage of our services.
Even if you only engage with our services once a year to respond to an annual survey, we will continue to retain your information and keep your profile active unless you decide to close your account. In some cases, we may choose to retain certain information, such as insights about service usage and analysis of surveys, in a depersonalised or aggregated form.
5.2 Rights to Access and Control Your Data
You have the ability to access and delete your personal and organisational data. Additionally, you have various options regarding how your data is collected, used, and shared.
We provide various options regarding the collection, use, and sharing of your data, including the ability to delete or correct information related to your organisational members and organisational information. Our settings allow you to control and manage the personal data we hold about you.
For the personal and organisational data we have, you can request to delete some or all of your data if it is no longer necessary for us to provide services to you. You can also edit certain data through your account and request changes, updates, or corrections in cases where the information is inaccurate.
If you wish to object to or limit the use of your data, you can ask us to stop using all or part of it, especially if we no longer have a legal right to retain it or if your personal data is inaccurate or unlawfully held. Additionally, you have the right to access your data and can request a copy of it.
Visitors can submit these requests by contacting us at contact@L10.tech, and we will review each request in accordance with applicable laws.
5.3 Account Closure
We keep some of your data even after you close your account.
If you decide to close your account, your personal data will typically become invisible to others on our services within 24 hours. For organisation administrators wishing to close the organisation account, the organisational data will generally cease to be visible to others within 24 hours after identity verification. We typically delete information related to closed personal and organisational accounts within 30 days of the account closure, unless otherwise specified below.4o mini
We retain your data even after you have closed your account if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud, enforce our User Agreement, or fulfil your request to "unsubscribe" from further messages from us. We will retain de-personalised information after your account has been closed.
Information you have shared with others (e.g., through uploading team resources updates or messages) will remain visible after you close your account or delete the information from your own profile or mailbox, and we do not control data that other Members have copied out of our Services. Organisation content associated with closed accounts will show an unknown user as the source. Your profile may continue to be displayed in the services of others (e.g., search engine results) until they refresh their cache.
6. Other Important Information
6.1 Security
We monitor for and try to prevent security breaches. Please use the security features available through our Services.
We implement security safeguards designed to protect your data, such as HTTPS and AES-256 encryption. We regularly monitor our systems for possible vulnerabilities and attacks. However, we cannot warrant the security of any information that you send us. There is no guarantee that data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. For more details regarding L10's commitment to invest in its security infrastructures, we invite you to read our Security page.
6.2 Lawful Bases for Processing
We have lawful bases to collect, use and share data about you. You have choices about our use of your data.
We will only collect and process personal data about you where we have lawful bases. Lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you (e.g., to deliver the Services you have requested) and “legitimate interests.”
Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object. If you have any questions about the lawful bases upon which we collect and use your personal data, please contact us at contact@L10.tech.
6.3 Direct Marketing
We currently do not share personal data with third parties for their direct marketing purposes without your permission.
6.4 Contact Information
If you have questions or complaints regarding this Policy, please contact us at contact@L10.tech.
Consent
Where we process data based on consent, we will ask for your explicit consent. You may withdraw your consent at any time, but that will not affect the lawfulness of the processing of your personal data prior to such withdrawal. Where we rely on contract, we will ask that you agree to the processing of personal data that is necessary for entering into or performance of your contract with us. We will rely on legitimate interests as a basis for data processing where the processing of your data is not overridden by your interests or fundamental rights and freedoms.