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Privacy Policy

How FlightGTM Limited (trading as Cull) collects, uses, and protects personal information through cullhq.com. Aligned to the New Zealand Privacy Act 2020, UK/EU GDPR, the Australian Privacy Act 1988, and the California Consumer Privacy Act (as amended by the CPRA).

Last updated: 29 April 2026

01

Who we are

This website (cullhq.com) is operated by FlightGTM Limited, a New Zealand company (number 9345957) with its registered office at Kendons Scott Macdonald Limited, Level 3, 6 Show Place, Addington, Christchurch 8024, New Zealand. We trade as Cull.

For personal information collected through this website, FlightGTM Limited is the data controller (UK/EU GDPR), the agency holding the personal information (NZ Privacy Act 2020), the APP entity (Australian Privacy Act 1988), and the business (CCPA/CPRA).

02

What this policy covers

This policy covers the personal information we collect when you visit cullhq.com or interact with us through the site — contact-form submissions, meeting bookings, and email correspondence.

It does not cover personal information processed inside the Cull Engine product itself. That is governed by a separate Product Privacy Notice and Data Processing Agreement provided to subscribers at sign-up. If you’re a subscriber and want a copy, email info@cullhq.com.

03

What we collect

Information you give us

When you submit our contact form, we collect: your name, email address, role, company website, and any markets you tell us about. When you book a call via Calendly, we receive: your name, email address, your selected time, and any answers you give to Calendly’s booking questions. If you email us directly, we receive whatever you send.

Information collected automatically

When you visit cullhq.com, our hosting provider (Vercel) logs standard server information: IP address, request time, page requested, referring URL, and user-agent string. These logs are used to operate the site and detect abuse. They’re retained for up to 30 days.

Analytics

We use Plausible Analytics, a privacy-first, cookieless analytics service. Plausible measures aggregate visitor numbers, top pages, and traffic sources. It does not set cookies, does not track you across other sites, and does not collect any personal information that could identify you individually. More on Plausible’s data practices at plausible.io/data-policy.

What we don’t do

We do not buy personal information from data brokers. We do not enrich website visitors against third-party databases. We do not run reverse-IP lookups to identify you. We do not run advertising pixels — no Meta, no LinkedIn, no Google Ads tags.

04

Why we collect it and our legal basis

Purpose Information used Legal basis (UK/EU GDPR)
Respond to your enquiry Contact-form submissions, email correspondence Legitimate interests; pre-contractual steps at your request
Schedule and run meetings you’ve booked Calendly booking data Pre-contractual steps at your request
Send sales follow-ups about Cull where you’ve enquired Contact details you submitted Legitimate interests; you can opt out at any time
Operate and secure the website Server logs Legitimate interests
Comply with legal obligations Any of the above Legal obligation

For people outside the UK/EU, we collect personal information for the purposes above and only use it in ways consistent with what you’d reasonably expect when contacting a B2B SaaS vendor.

05

Who we share it with

We use a small number of vetted service providers. They process your information on our behalf, under written agreements:

Provider Purpose Location
Vercel Inc. Website hosting United States
Airtable, Inc. Storing contact-form submissions and managing follow-ups United States
Calendly, LLC Meeting booking United States
Google LLC (Google Workspace) Email and document storage United States
Plausible Insights OÜ Cookieless website analytics European Union (Estonia)

We do not sell your personal information. We do not share it with third parties for their own marketing.

We may disclose personal information if compelled to by law, to enforce our terms, or to protect our rights, property, or safety (or those of others).

06

International transfers

We’re based in New Zealand and the United Kingdom. Some of our service providers (above) are based in the United States. When we transfer personal information outside your country, we rely on:

  • UK/EU visitors: the UK International Data Transfer Addendum, EU Standard Contractual Clauses, or the EU–US / UK–US Data Privacy Framework where the recipient is certified.
  • NZ visitors: contractual safeguards consistent with Information Privacy Principle 12 of the NZ Privacy Act 2020.
  • Australian visitors: contractual safeguards consistent with Australian Privacy Principle 8.

For a copy of the relevant transfer mechanism, email info@cullhq.com.

07

How long we keep it

Information Retention
Contact-form submissions and email correspondence Until you ask us to delete it, or three years after your last interaction with us — whichever is sooner
Calendly booking data Two years from the meeting date
Server logs 30 days
Aggregate analytics (Plausible) No personal data; aggregate metrics retained indefinitely

We may keep some information longer where required by law (tax, accounting) or to defend a legal claim.

08

Your rights

Depending on where you are, you have some or all of the following rights over the personal information we hold about you:

  • Access — ask for a copy of the personal information we hold.
  • Correction — ask us to correct information that’s wrong or out of date.
  • Deletion — ask us to delete your information (the “right to be forgotten” under UK/EU GDPR).
  • Restriction — ask us to stop using your information in certain ways.
  • Objection — object to our processing on the basis of legitimate interests.
  • Portability — ask for your information in a machine-readable format.
  • Withdraw consent — at any time, where we rely on consent.
  • Opt out of sale or sharing — under CCPA/CPRA. We do not sell personal information.
  • Non-discrimination — under CCPA/CPRA. Exercising your rights will not result in worse service.

To exercise any of these rights, email info@cullhq.com. We’ll respond within 30 days, or within the period your local law allows.

09

Cookies

cullhq.com does not currently set any cookies. See our Cookie Policy for the detail.

10

Children

cullhq.com is not directed at children. We do not knowingly collect personal information from anyone under 16. If you believe a child has given us personal information, email info@cullhq.com and we’ll delete it.

11

Security

We use industry-standard technical and organisational measures to protect your information: encrypted transport (TLS), access controls on the systems that hold your data, and vetted service providers. No system is perfectly secure — if you believe your information has been compromised, email info@cullhq.com immediately.

12

Changes to this policy

We’ll update this policy from time to time. The “Last updated” date at the top will reflect the most recent change. Material changes will be notified by a banner on the site for 30 days, or by email where we hold one for you.

13

Complaints and how to contact us

For any privacy question, request, or complaint, email info@cullhq.com.

If you’re not satisfied with our response, you can complain to your local data protection authority:

  • New Zealand: Office of the Privacy Commissioner — privacy.org.nz
  • United Kingdom: Information Commissioner’s Office — ico.org.uk
  • Australia: Office of the Australian Information Commissioner — oaic.gov.au
  • United States (California residents): California Privacy Protection Agency — cppa.ca.gov

14

Governing law

This policy is governed by the laws of New Zealand. This does not deprive you of any mandatory protections under your local data protection law.