CULLINAN GROUP - Privacy Policy Platform
This privacy policy describes how Cullinan Group PTE. LTD. (hereinafter "Cullinan", "we", "us") collects and processes personal data on or in connection with its platform and in the context of our (customer) relationship. The Cullinan platform is an intermediary platform designed to facilitate connections between users and expert service providers who specialise in providing convenience retailing services (the "Platform"). Services ordered through the Platform are performed by Cullinan expert partners. If such expert partners process personal data in the context of such services, they will process such personal data in accordance with their own privacy policy. We recommend contacting such expert partners directly if you have any questions about this.
You are typically:
- a Cullinan client, Cullinan partner or Cullinan expert partner; or
- a user of Cullinan’s Platform, authorised by a client, partner or expert partner of Cullinan, or by Cullinan itself, to use the Platform.
Users may be an employee, independent service provider, client or other representative of Cullinan, a Cullinan client, a Cullinan partner or a Cullinan expert partner. In the latter case, Cullinan has entered into an agreement with the Cullinan client, Cullinan partner or Cullinan expert partner of whom you are a customer or for whom you work (as applicable) to allow you to access or use our Platform and related services.
We consider the protection of your privacy important and wish to inform you (as a user of our Platform) about how we process your personal data in order to enable you to maintain control over your personal data:
- Cullinan takes appropriate measures to protect your personal data in accordance with applicable data protection laws, including the Privacy Act 1988 and its amendments, such as the Privacy Amendment (Enhancing Privacy Protection) Act 2012 (collectively referred to as the “Applicable Data Protection Legislation”).
- Cullinan is an entity subject to the Australian Privacy Principles (APPs) under the Privacy Act 1988 and complies with these principles in the handling of personal information.
Please read this privacy policy carefully. It not only describes your rights, but also how to exercise them. By using our Platform, sharing your personal data, and/or agreeing to this statement, you acknowledge that you have read and agree to the way we collect and process your personal data.
Cullinan is a private limited company incorporated.
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Company name |
Cullinan Group PTY LTD |
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Company number |
UEN 201427716H (6 SHENTON WAY, #38-01, OUE DOWNTOWN, Singapore 068809) |
Cullinan acts, depending on the processing activities it carries out under this privacy policy - as:
- Controller: this is the party who determines the purpose and means of the processing activity; or
- Processor: this is the party acting on behalf of and on the instructions of a controller (i.e. a Cullinan client, partner or expert partner, as applicable).
Cullinan has appointed a contact person responsible for data protection whom you can contact for questions regarding this privacy policy, your privacy and about how Cullinan processes your personal data.
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Contact |
privacy@cullinangroup.com |
Depending on the data you share with us and the functionalities you use on our Platform, Cullinan processes different categories of personal data.
If we process personal data, this may include the data below:
- Identification and contact details (such as: first name and surname, telephone number, e-mail address, company name, job title, (company) address, company registration and tax number (if applicable));
- Login details (such as the details used to log in to the Cullinan platform including username and password);
- Account data (such as data used to create an account on the Cullinan platform such as username, company name and other information uploaded to your account to personalise it, including all documents, data and other information, such as photos, that you yourself (or the Cullinan client, Cullinan partner or Cullinan expert partner of which you are a client or for which you work) upload, make available or share on the Platform or that are generated by or result from your use of our Platform or services, e.g. by using the interactive functionalities on the Platform);
- Payment data (such as data required to process payments for the use of services and Platform (as applicable) and for our business administration, such as (bank) account number, credit card details, summary of outstanding payments, payment history);
- Professional details (such as profession, company you work for, job title, (business) address, company registration and tax number);
- Technical data (such as information about your computer, mobile and other devices (such as your IP address, user ID, operating system, browser type);
- Usage data (such as information about your use of our Platform, including history, log files, date, time, location, frequency, duration of pages viewed, consent preferences, information about consent(s) you have given (such as the date and time of your consent)); and
- Any other categories of personal data as identified below in Article 4.
In principle, the personal data we process are obtained directly from you or are automatically collected by us (in the case of technical or usage data).
Depending on your use of our Platform, our services, the information you share with us and our (customer) relationship, Cullinan processes personal data for the purposes specified in this Article 4 (if and to the extent applicable to your situation). Please note that our Platform and services may evolve and more features may be added from time to time. In that case, the overview in the tables below may also evolve and will be updated where necessary in accordance with Article 16, seeking your additional consent if required.
For certain processing purposes, Cullinan requires your consent. The consent you give is always free and without charge, and you have the right to withdraw it at any time. You can withdraw your consent by sending an e-mail to privacy@cullinangroup.com. The withdrawal of your consent does not affect the processing of personal data carried out prior to such withdrawal or our processing activities based on another legal ground.
This Article 4.2 describes the purposes for which we process your personal data in the capacity of data controller, such as when you use our Platform or in the context of our (customer) relationship.
The controller (i.e. in this case Cullinan) is the party that determines the purposes and means of the processing activities.
In this scenario, you are typically:
- a Cullinan client, Cullinan partner or Cullinan expert partner;
- a user of the Platform authorised by a client, partner or expert partner of Cullinan to use the Platform;
- a client, employee, independent service provider, or other representative of a Cullinan client, partner, expert partner or Cullinan itself.
Cullinan may process your personal data as a data controller for the following purposes:
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Purpose |
Category of personal data |
Legal grounds |
Retention period |
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Registering and creating a user account on the Platform, and to ensure that you can log in to the Platform via your user account and use the Platform. For these processing activities you are typically an employee, freelancer, consultant or other representative of Cullinan, a Cullinan client, Cullinan partner or Cullinan expert partner who has entered into a commercial agreement with Cullinan to use the Platform and has invited you to do so. For more information on how we process your personal data through our Platform, please refer to Article 4.3 below. |
- Identification and contact details - Login and account details - Professional details - Technical data |
Performance of a contract |
- For as long as necessary to perform the agreement concluded between Cullinan and the organisation on whose behalf you use the Platform. - In any case, your personal data will be deleted no later than (i) two years after the termination of the agreement with your organisation or (ii) two years after your last login to the Platform. Please note that, in certain cases, the organisation that gives you permission to use the Platform may request the deletion of your user account before the above retention periods have been observed (e.g. if you are no longer employed by this organisation). - If your organisation requests the deletion of your account, we will, in principle, delete your account within thirty (30) days. |
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Performance of Cullinan's accounting and (business) administration (including tracking payments and outstanding balances) as well as managing our (customer) relationship and handling any complaints. |
- Identification and contact details - Payment data - Any additional information you share with us (in connection with a query, complaint or dispute) |
Performance of a contract or legitimate interest (as applicable) |
- Up to 10 years after the end or termination of our (customer) relationship; or - For as long as necessary to pursue the legitimate interests of Cullinan. |
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To comply with our legal obligations (including responding to requests from data subjects, respecting your (consent) preferences, complying with our anti-money laundering and know-your-customer obligations and protecting the rights of others). |
- Identification and contact details - Website user data - Payment data - Technical data - Any additional information you share with us in connection with a query, complaint or dispute - Other personal data (this depends on the relevant legal obligation) |
Legal obligation |
- Up to 10 years after the expiry or termination of our relationship; or - As long as required by law. |
For more information about the specific retention period, you can always contact us by e-mail at: privacy@cullinangroup.com
This Article 4.3 describes the purposes for which we process your personal data in the capacity of processor when you use our Platform at the invitation of a Cullinan client, partner or expert partner.
Cullinan primarily processes personal data through the Platform as a processor, as determined by and under the instructions of Cullinan’s clients, partners or expert partners. The processor (i.e. in this case Cullinan) is the party that acts on behalf of and under the instructions of a controller (i.e. in this case Cullinan’s clients, partners or expert-partners).
In this scenario, you are typically:
- a user of the Platform authorised by a client, partner or expert partner of Cullinan to use the Platform; or
- a client, employee, independent service provider, or other representative of a Cullinan client, partner, expert partner or Cullinan itself.
The processing activities that take place through the Platform depend on the functionalities and features included in the licence purchased by the Cullinan client, partner or expert partner who authorised you to use the Platform. This may differ for different Cullinan clients, partners and expert partners to suit their internal operations. This section therefore only describes in a generic way the personal data that might be processed through the Platform. For more information about the specific processing activities, we recommend you to contact the Cullinan client, partner or expert partner who authorised you to use the Platform directly. The relevant Cullinan client, partner and/or expert partner is obliged to inform you in more detail about the processing activities they carry out through the Platform.
Cullinan may process your personal data as a processor for the following purposes:
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Purpose |
Category of personal data |
Legal grounds |
Retention period |
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For the provision, operation and use of the Platform as part of our services acting as an intermediary platform. Depending on the use of the (interactive) functionalities and functions, different personal data may be processed, e.g. for: - sending, answering and completing service and information requests to/from other platforms; - facilitating and coordinating interaction between different actors involved in testing, inspection, and similar services (between clients and contractors and other persons and intermediaries); - managing ordered expert services and objects (for customers); - processing payment of ordered expert services via the Platform (if applicable); - etc. As part of these activities, personal data may be shared with other Platform users. If you would like more information on which personal data are processed and for what purposes when using a particular feature, please contact privacy@cullinangroup.com. |
- Identification and contact details - Account data - Professional details - User data - Payment data - Technical data - Any other information or data you provide/upload or that are generated as a result of your use of the Platform |
Performance of a contract |
- The retention period varies from as long as the duration of a Platform visit, to as long as necessary for the performance of the agreement concluded between Cullinan and the organisation on whose behalf you use the Platform. - In any case, your personal data will be deleted no later than (i) 5 years after the termination of the agreement with your organisation or (ii) 5 years after your last login to the Platform. Please note that, in certain cases, the organisation that gives you permission to use the Platform may request the deletion of your user account before the above retention periods have been observed (e.g. if you are no longer employed by this organisation). - If your organisation requests the deletion of your account, we will, in principle, delete your account within thirty (30) days. |
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Provision of assistance and support, and to answer questions related to (the use of) the Platform, in order to provide you with information and enable communication with you. |
- Identification and contact details - Account data - Professional details - Any other personal data shared or provided during our contact and/or provision of the support services |
Performance of a contract |
- For as long as necessary to contact you and/or to provide support services. - In any case, your personal data will be deleted no later than 5 years after the termination of the agreement. |
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To provide you with information about how to use the Platform and to enable communication with you. |
- Identification and contact details - Account data - Professional details - Any other personal data shared or provided during our contact |
Performance of a contract |
- For as long as necessary to contact you. - In any case, your personal data will be deleted no later than 5 years after the termination of the agreement or 5 years after our last contact. |
For more information about the specific retention period, you can always contact us by e-mail at: privacy@cullinangroup.com.
In relation to the above processing activities, we process your personal data on the legal ground determined by the organisation that authorised your use of our Platform and on whose behalf you use the Platform, including to enable us to fulfil our contractual obligations under the commercial licence agreement. The applicable legal ground is determined by the organisation that authorised your use of our Platform. If you would like more information on the legal grounds for processing, we recommend that you contact the organisation directly, which as the data controller, is responsible for including such legal grounds in its own privacy policy.
When you share personal data of third parties with us, you guarantee that you have informed those third parties and have obtained their consent, or that you have another legal ground to share that third party's personal data with us.
Our Platform may use cookies and similar technologies. For more information, please refer to the applicable cookie statement on our Platform where applicable.
To fulfil the purposes described above in Article 4, it is sometimes necessary for us to share your personal data with the following third parties:
§ Service providers (who are responsible for hosting our Platform, our IT infrastructure and security, payment services, e-mail and communication providers, etc.);
§ Other users of the Platform with whom you wish to connect or who need to know the relevant personal data in the context of the expert services ordered via the Platform;
§ Our professional advisers (such as lawyers, accountants, insurers, and auditors);
§ Consultants, freelancers, independent service providers and other subcontractors engaged by Cullinan to provide services to Cullinan in connection with its Platform;
§ Supervisory authorities (upon request of the relevant entity); and/or
§ Third parties to whom we wish to sell, transfer or merge (parts of) our shares, business or assets.
As indicated above, expert services ordered through the Platform are performed by Cullinan expert partners. If such expert partners process personal data in the context of such services, they will process such personal data in accordance with their own privacy policy. We recommend contacting such partners directly if you have any questions about this.
Upon request, we will inform you as soon as possible about the third parties with whom your personal data have been shared by providing you with a more detailed list.
In addition, we may disclose your personal data if required by law, or if we determine in good faith that such disclosure is necessary during a legal dispute or to protect our rights.
Our processors and subprocessors always act under our responsibility. If we engage subprocessors, this will always be done in accordance with a processor agreement that meets the requirements of the Applicable Data Protection Legislation and protects your personal data in the best possible way. If we share your personal data as described above, we will provide appropriate safeguards to protect its integrity and confidentiality.
Your personal data will only be provided to (sub)processors, employees and other third parties on a need-to-know basis, limited to the extent necessary for the performance of their services.
In principle, we do not transfer your personal data to countries outside Australia, unless you are located outside Australia and visit our Platform or website outside Australia. We may also transfer your personal data to countries outside Australia via our processors or subprocessors. In that case, we will only transfer your personal data outside our Australian-based cloud infrastructure in compliance with the Applicable Data Protection Legislation and subject to appropriate safeguards.
Please contact us if you would like more information about the specific mechanisms we use for transferring personal data to countries outside the Australia.
Cullinan may use your personal data for direct marketing purposes. This allows Cullinan to keep you informed about its products, updates, events, etc. If applicable, you will in principle always provide your express consent in advance (unless this processing can be based on Cullinan's legitimate interests). You can withdraw your consent at any time and free of charge, and you can object to the processing of your personal data for direct marketing purposes, including profiling.
You have the right at any time to object, free of charge, to the processing of your personal data for direct marketing purposes (including profiling), insofar as it relates to such direct marketing, by sending an e-mail to: privacy@cullinangroup.com.
We retain personal data only for as long as reasonably necessary to fulfil the purposes and in accordance with the retention periods set out in Article 4 of this privacy policy, including to comply with legal, regulatory, tax, accounting or reporting obligations. We may retain personal data for a longer period in the event of a complaint or if we reasonably believe that a legal dispute is likely to arise regarding our relationship.
After that, personal data may still be present in our backups or archives, but will no longer be actively processed in a file. Such backups or archives are automatically deleted in accordance with our backup and archiving policy.
The applicable retention periods are listed in the table under Article 4.
We have implemented appropriate technical and organisational measures, safeguards and guarantees to protect your personal data in accordance with the Applicable Data Protection Legislation, in particular to protect your personal data from loss, misuse, or unauthorised alteration or destruction.
If you would like more information about the specific measures we have implemented, please contact us by sending an e-mail to: privacy@cullinangroup.com.
Despite the measures we take, you should be aware that there are always risks associated with sending personal data over the internet. The security and protection of your personal data can never be fully guaranteed, nor can we guarantee that unauthorised third parties will never be able to bypass these measures or use your personal data for improper purposes.
Within the limits of the Applicable Data Protection Legislation, we support:
§ Right of access: you have the right to obtain confirmation from us as to whether or not we process your personal data and to access the personal data we hold about you, and to request a copy.
§ Right to rectification: if you notice that we process incorrect or incomplete personal data about you, you have the right to request that they be rectified or completed.
§ Right to erasure (or "right to be forgotten"): in certain cases, you have the right to obtain erasure of your personal data (e.g. if your personal data are no longer necessary for the purposes for which we collected them).
§ Right to object: in certain cases, you have the right to object to the processing of your personal data.
§ Right to restriction of processing: in certain cases, you can ask us to restrict the processing of your personal data (e.g. while we verify the accuracy of your personal data and amend them if necessary).
§ Right to data portability: in certain cases, you have the right to obtain your personal data in a structured, commonly used and machine-readable form, and to transfer it (or have it transferred) to another data controller.
Exercising your rights is, in principle, free of charge. Only in case of unreasonable or repeated requests do we reserve the right to charge a reasonable administrative fee. We always inform you of the amount before we charge it.
You can exercise your rights by contacting us at: privacy@cullinangroup.com.
To help you as efficiently as possible, we always ask you to specify which right you wish to exercise and to describe your request as clearly as possible. Please note that in some cases we will request additional information to make sure we deliver the information to the right person.
If you contact us to exercise your rights, we will reply within one month. Exceptionally, this period may be extended (up to a maximum of (3) three months), but we will inform you of the reasons why within one month.
If you believe that our processing of your personal data does not comply with the Applicable Data Protection Legislation, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State where you habitually reside, work or where the alleged breach of the Applicable Data Protection Legislation occurred.
The Data Protection Authority for Australia is:
Office of the Australian Information Commissioner (OAIC)
Website: https://www.oaic.gov.au
Phone: 1300 363 992
Email: enquiries@oaic.gov.au
Address: GPO Box 5218, Sydney NSW 2001, Australia
However, we would appreciate the opportunity to resolve your concerns before you contact OAIC. We therefore kindly ask that you contact us at privacy@cullinangroup.com first.
Our Platform may contain links to third-party applications and websites. If you are redirected to another website, platform or application via our Platform, different terms and conditions, privacy and cookie statements may apply. Cullinan is not responsible for the content of these applications and websites and is not responsible for the privacy standards and practices of such third parties. We recommend that you read the relevant privacy and cookie statements of these third parties before accepting their cookies and visiting their applications and/or websites, to ensure that your personal data is adequately protected.
If we have lawfully transferred your personal data to a third party (who is not one of our (sub)processors), we are not liable for any unlawful processing or use by that third party.
In any case, Cullinan is only liable for the damage caused by the processing of personal data if it failed to comply with the specific obligations of the Applicable Data Protection Legislation. Under no circumstances shall Cullinan be liable for any special, incidental, indirect or consequential damages or losses.
We may update this statement at any time. Any changes we make to this statement will be announced on our Platform and/or website. The date of the most recent version is visible at the bottom and/or top of this policy. Please review this statement regularly to be aware of any changes that may affect you.
Amended versions of this privacy statement will come into force fourteen (14) days after publication on the Platform and/or the website (as applicable) and will, if necessary, always be submitted for approval. If amendments are required to comply with a legal obligation, such amendments will take effect immediately.
This Privacy Policy is governed by the laws of the jurisdiction in which the relevant services are provided.
Where required by applicable law, including data protection laws such as the GDPR or the Australian Privacy Act, you may have the right to bring a claim before the courts or supervisory authorities of your country of residence. Unless otherwise required by mandatory law, any disputes arising in connection with this Privacy Policy shall be subject to the exclusive jurisdiction of the courts of Singapore or Australia.
Last updated: 14 April 2026
