Privacy Policy

Culmo Pty Ltd (ABN 80 692 960 455) ("Culmo", "we", "us", "our") is an AI automation agency based in Melbourne, Australia. We build and operate automated systems for local service businesses.

We are committed to protecting the privacy of everyone who visits our website, enquires about our services, or whose information is processed through the systems we build and operate on behalf of our clients.

This Privacy Policy explains what personal information we collect, why we collect it, how we use and protect it, and your rights in relation to it.

We handle personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

If you have any questions about this policy, contact us at: hello@culmo.io

1. Who This Policy Applies To

This policy applies to:

• Visitors to the culmo.io website
• Individuals who enquire about or engage Culmo's services
• Individuals whose personal information is collected or processed through automated systems that Culmo builds and operates on behalf of its clients (for example, patients or customers of a business using a Culmo review generation or voice agent system)

If you are a customer or patient of a business that uses Culmo's technology, the business you engaged with (our client) is the primary data controller for your information. Culmo acts as a data processor on their behalf. If you have questions about how your information is being used, we recommend contacting that business directly. You are also welcome to contact us at hello@culmo.io.

2. What Information We Collect

Website and enquiry data

When you visit culmo.io or interact with our website, we may collect:

• Your name, email address, and phone number if you submit an enquiry, complete a contact form, or book a strategy call via our scheduling tool (Calendly)
• Information you provide during an on-site chat interaction, including your business name, the nature of your enquiry, and any other details you choose to share
• Technical data including your IP address, browser type, device type, pages visited, and time spent on the site — collected automatically via cookies and analytics tools
• Any other information you voluntarily provide when communicating with us

Client system data

Culmo builds and operates automated systems for businesses. Depending on the system, this may involve processing personal information about the clients' customers, patients, or contacts. This can include:

• Names, mobile phone numbers, and email addresses used for automated SMS review requests and appointment reminders (processed via Twilio)
• Appointment and booking records (integrated with practice management systems including Cliniko and similar platforms)
• Customer enquiry and qualification data collected via automated voice agents (inbound call audio, transcripts, and booking details — applicable to clients using the Culmo Voice Agent system)
• Lead and contact data stored in client CRM systems
• Customer responses to automated outreach, including review submissions and opt-out requests
• Any personal information passed through Culmo's automation infrastructure (n8n, Supabase) as part of a client's operating system

What we do not collect

We do not collect sensitive information such as health records, financial account details, government identifiers, or payment card information through our website. Note that some client systems (for example, systems built for medical or allied health businesses) may process appointment or treatment pathway data on behalf of the client — this is governed by the client's own privacy obligations and the data processing agreement between Culmo and that client.

3. Why We Collect This Information

We collect and use personal information for the following purposes:

• To respond to enquiries and communicate with prospective clients
• To schedule and conduct strategy calls and client meetings
• To deliver, operate, and improve the automation systems we build for clients
• To send automated communications on behalf of clients (review requests, appointment reminders, follow-up messages) where the client has obtained appropriate consent from their customers
• To process and qualify leads through automated voice and chat systems on behalf of clients
• To maintain our CRM and business records
• To comply with our legal obligations
• To improve the performance of our website and services

We will not use your personal information for any purpose that is incompatible with the purpose for which it was collected without your consent.

4. How We Share Your Information

Culmo does not sell personal information. We do not share personal information with third parties for their own marketing purposes.

We share personal information only in the following circumstances:

With third-party service providers (sub-processors)

Culmo uses the following third-party tools and platforms to deliver its services. Each is engaged under appropriate terms and handles data only as directed by Culmo:

Where personal information is transferred to service providers located outside Australia, we take reasonable steps to ensure it is handled in accordance with the Australian Privacy Principles.

With clients

Where Culmo processes personal information on behalf of a client (for example, customer data processed through a review generation or voice agent system), that information is accessible to the relevant client as the primary data controller.

When required by law

We may disclose personal information where required by law, court order, or regulatory authority.

5. Automated Decision-Making and AI Processing

Culmo's systems use artificial intelligence to automate certain functions, including:

• Qualifying inbound leads via voice agents and chat agents
• Generating personalised review request messages
• Classifying customer sentiment from responses
• Drafting automated replies to customer reviews

AI-generated outputs are used to facilitate communication and workflow automation. Significant decisions affecting individuals are not made solely on the basis of automated processing without human oversight at the client level.

If you have concerns about how AI has been used to process your information in a Culmo-operated system, contact us at hello@culmo.io.

6. Voice Agent Data

For clients using the Culmo AI Voice Agent system, inbound calls to the client's business number may be answered and processed by an AI voice agent. This may involve:

• Real-time audio processing to understand and respond to the caller
• Generation of a call transcript and summary
• Extraction of booking details and qualification information
• Routing or logging of the interaction in the client's CRM or calendar system

Where required by law or good practice, clients using the Voice Agent are responsible for ensuring callers are informed that they may be speaking with an automated system. Call data is retained only as long as necessary for the purposes for which it was collected.

7. SMS and Outreach Compliance

Automated SMS messages sent through Culmo's systems are dispatched on behalf of clients and are governed by the Spam Act 2003 (Cth).

• All outreach is sent only to individuals from whom the relevant client has obtained appropriate consent
• Every automated message includes a clear opt-out mechanism (STOP/START)
• Opt-out requests are processed automatically and permanently within the relevant system
• Culmo does not initiate unsolicited commercial messaging on its own behalf

8. Data Security

We take reasonable steps to protect personal information from misuse, interference, loss, and unauthorised access, modification, or disclosure.

Security measures include:

• Encrypted data transmission (HTTPS/TLS) across all Culmo web properties and integrations
• Access controls limiting system access to authorised personnel
• Secure cloud infrastructure via Supabase and Vercel
• Regular review of sub-processor security practices

No method of transmission over the internet is completely secure. While we take the protection of personal information seriously, we cannot guarantee absolute security.

9. Data Retention

We retain personal information for as long as necessary to fulfil the purposes for which it was collected, or as required by law.

• Website enquiry and CRM data: retained for the duration of the business relationship and up to 7 years thereafter for legal and accounting purposes
• Client system data (review requests, voice agent, appointment reminders): retained in accordance with the data processing terms agreed with each client, and deleted or de-identified upon request or at the end of the engagement
• Analytics data: retained in accordance with the default retention settings of the relevant analytics platform (typically 14–26 months)

10. Your Rights

Under the Australian Privacy Principles, you have the right to:

• Request access to the personal information we hold about you
• Request correction of inaccurate or incomplete information
• Make a complaint about how your information has been handled
• Opt out of direct marketing communications at any time

To exercise any of these rights, contact us at hello@culmo.io. We will respond within a reasonable timeframe and in accordance with our obligations under the Privacy Act.

If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.

11. Cookies and Tracking

Our website uses cookies and similar technologies to:

• Remember your preferences and session information
• Analyse website traffic and usage patterns (via Google Analytics or equivalent)
• Support the functionality of on-site chat and booking tools

You can control cookies through your browser settings. Disabling cookies may affect the functionality of certain features on the site.

12. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will update the "Last reviewed" date at the top of this page. We encourage you to review this policy periodically.

Continued use of our website or services after any update constitutes acceptance of the revised policy.

13. Contact

Culmo Pty Ltd
Melbourne, Victoria, Australia
Email: hello@culmo.io
Website: culmo.io