Privacy Policy

1. Who We Are

CullyAI is an AI-powered market intelligence assistant for commodity traders and agricultural professionals. CullyAI is operated by Cultioo ("we", "us", or "our").

Email: privacy@cultioo.com
Website: https://cullyai.cultioo.com

2. What This Policy Covers

This Privacy Policy explains what personal data we collect when you use CullyAI (the web application at cullyai.cultioo.com and the iOS mobile app), why we collect it, how we use it, and your rights in relation to it.

3. Data We Collect

3.1 Account Data

When you register or sign in, we collect:

• Email address — used as your primary identifier and to send sign-in codes.
• Name — optionally provided via Google Sign-In.
• Secondary email addresses — additional emails you choose to link to your account for login purposes.
• Google account ID — stored if you sign in via Google, to link your Google identity to your account.

3.2 Subscription and Billing Data

If you subscribe to a paid plan, billing is handled by Stripe. We store your Stripe customer ID and your subscription tier (free, pro, or ultra). We do not store credit card numbers or payment details — all payment processing is performed by Stripe.

3.3 Conversation and Message Data

• Conversations — the chats you create, including titles and timestamps.
• Messages — the content of every message you send and AI responses you receive, including charts and exported documents.
• File attachments — images, PDFs, CSV files, and voice recordings you upload. Voice recordings are transcribed to text and not stored after transcription.
• Exported files — spreadsheets, presentations, and documents generated by the AI are stored temporarily (up to 7 days) and then deleted automatically.

3.4 Usage Data

Daily and rolling message counts, used to enforce your plan's usage limits, and session timestamps.

3.5 Device Data

Device name, platform (e.g. "ios", "web"), and last-seen timestamp — recorded when you log in via a registered device to give you visibility of active sessions and allow you to revoke access.

3.6 Authentication Session Data

Short-lived QR session tokens (5-minute expiry, single-use) generated during QR-code login flows. Stored transiently and deleted on expiry or account deletion.

3.7 API Keys

If you generate a personal API key (available on Pro and Ultra plans), we store it to allow authentication.

3.8 Technical and Log Data

Our hosting infrastructure may log IP addresses, HTTP request paths, and timestamps for operational and security purposes. Logs are retained for up to 30 days.

4. How We Use Your Data

We do not use your conversation data to train AI models. We do not sell your personal data to third parties. We do not use your data for advertising.

5. Third-Party Services

Messages you send are transmitted to AI providers to generate responses. Please do not include sensitive personal or financial information beyond what is necessary for your analysis.

6. Data Retention

When you delete your account, we permanently delete your profile, all conversations and messages, devices, secondary emails, and usage records.

7. Security

We protect your data using JWT authentication, HTTPS (TLS) for all communications, and Stripe for payment processing (we never see or store card details). No internet transmission is 100% secure. If you believe your account is compromised, contact us at privacy@cultioo.com immediately.

8. Cookies and Local Storage

CullyAI does not use tracking cookies. The web app stores the following in your browser's local storage:

• Your session token (JWT) — to keep you signed in.
• Your user profile — to display account information without a server round-trip.
• UI preferences (appearance, text size, sort order).
• Pinned conversations and projects — stored locally, not synced to the server.

This data is stored only on your device and is cleared when you log out.

9. Children's Privacy

CullyAI is not directed at children under the age of 16. We do not knowingly collect personal data from children. Contact us at privacy@cultioo.com to request deletion if you believe a child has provided data.

10. Your Rights

Depending on your location, you may have the right to access, correct, delete, restrict, or export your personal data, and to object to certain processing. You can delete your account and all associated data directly in the app via Settings → Delete Account. For other requests, contact us at privacy@cultioo.com. We will respond within 30 days.

If you are in the EEA or UK, you have the right to lodge a complaint with your local data protection authority.

11. International Transfers

CullyAI is operated from servers in the United States (Google Cloud). If you are in the EEA or UK, your data is transferred under Google Cloud's standard contractual clauses.

12. Changes to This Policy

We may update this policy from time to time. The "Last updated" date at the top reflects the most recent revision. Continued use of CullyAI after changes are posted constitutes acceptance.

13. Contact

Cultioo
Email: privacy@cultioo.com
Website: https://cullyai.cultioo.com