Privacy Policy

CULLEN INTERNATIONAL is the data controller for the processing of personal data occurring when visiting its website and using its services.

Société anonyme de droit belge CULLEN INTERNATIONAL

Siège social établi en Belgique, à 1160 Bruxelles (Auderghem), Clos Lucien Outers, 11-21, boîte 1

n° B.C.E. : 0429.199.165

n° T.V.A. : BE0429.199.165

email: administration@cullen-international.com

phone: +32 2 73 87 200

1. enabling the technical operation of the website
2. improving the website and the services provided by Cullen International
3. allowing access to the client area of the website and for the delivery of Cullen International services to clients
4. statistical reasons (for instance to check use of website and of specific publications)
5. marketing of our own services (including the sending of the weekly highlights)
6. administrative purposes (including billing)
7. liability issues (for instance, monitor use of website by clients to check abnormal behaviour)
8. complying with by law (e.g. law enforcement, merger or tax issues such as billing information to be used for tax auditing)
9. answering users’ requests and enquiries

Personal data are collected when you are navigating through the website and using the services offered by Cullen International including the data provided when registering on the website services.

You may be invited to provide personal data and other information (on your organisation for instance) when registering for conferences/trainings, answering surveys, subscribing to newsletters, downloading samples, applying for a job, or using the collaborative and interactive tools available on the website.

Should we use your personal data to send you information about Cullen International events or developments which we believe may be of interest to you, we will always give you an opportunity to tell us that you do not wish to receive such information and we will respect this instruction (please refer to paragraph dedicated to “Your rights” to find out how to proceed if you want to object to the processing of your personal data for marketing purposes) in accordance with the applicable rules.

The legal basis for processing your personal data -depending on the categories of the processed data- as detailed below are:

Article 6.1 (a) when the data subject has given consent to the processing of his or her personal data for one or more specific purposes

Article 6.1 (b) when data processing is necessary for the performance of a contract to which the data subject is party or to take steps at the request of the data subject prior to entering into a contract

Article 6.1 (c) when data processing is necessary for compliance with a legal obligation to which the controller is subject

Article 6.1 (f) when data processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

The legitimate interests pursued by Cullen International are the delivery of the best possible experience when navigating through the website and the promotion and delivery of its services.

Cullen International does not process special categories of personal data.

Each time the website is accessed, it automatically collects and processes data and information from the system of the accessing computer(s) such as:

• Internet protocol
• IP address (statistical purpose)
• URL of the referring website from which the file was requested
• Date and time of access
• Browser type and operating system
• The page visited by you
• Access status (file transferred, file not found, etc.)
• Duration

The legitimate interest pursued by the data controller is the legal basis for processing this data.

The data are stored on log files.

• Personal data needed for creating the client’s user account (name, address, email, etc.)
• Personal data needed for creating and using the login system for accessing Cullen International’s services (client’s ID & IP address & password)
• Personal data processed for administrative and billing purposes
• Personal data processed for archiving purposes
• Personal data processed according to any legal duty
• IP address (statistical purpose)
• Cookies (placed on client’s computer)
• Personal data processed when completing online forms
•  
• Personal data processed when using the AI-powered Regulatory intelligence Assistant (RiA), i.e. questions you enter and the answer generated, feedback,…
• Personal data processed for sending Cullen International’s alerts and weekly highlights

The legal basis for processing this personal data is usually the performance of the contract (for clients) but also the legitimate interest of the controller (for certain invited users)

Cullen International SA use cookies to keep our site reliable, secure, and personalised.

When you accept cookies, this makes the site better by remembering your preferences and enhancing your experience with Cullen International SA.

Cookies are small text files which a website may place on your computer or device when you visit a site. The cookie will help the website, or another website, to recognise your device the next time you visit. Web beacons, pixels or other similar files can also do the same thing.

Cookies serve many functions. For example, they can help us to remember your username and preferences, analyse how well our site is performing, or allow us to recommend content we believe will be most relevant to you.

The majority of websites use cookies to collect and retain personal information about their visitors. Most cookies collect general information, such as how visitors arrive at and use our sites, the device they are using, their internet protocol address (IP address), what pages they are viewing and their approximate location.

All our cookies are essential for the smooth operation of our website and if you disable them, you will not be able to get the best experience and enjoy all the functionalities of the website. These cookies are used for the following main purposes:

• access: to identify subscribers and ensure access to subscription-only pages
• performance: to monitor the performance of the website, to provide clients with a high-quality experience (for instance to track error messages and to determine improvements)
• functionality: to allow us to remember your preferences

We use third party cookies to help us monitor traffic on our website, to improve site functionality and to monitor compliance with our terms & conditions and copyright policy. The cookies collect information in a way that does not identify anyone.

To understand our client engagement and help us improve our customer experience, we are using Zoho technology.

https://www.zoho.com/pagesense/cookie-policy.html

You can decide to manage cookies via your browser settings. Cullen International requires a technical session cookie to work. By default, Cullen International does not store cookies on your device. At regular intervals and for your comfort only, you will be asked whether the cookies should remain on your device at the end of the session.

If you consent to store the cookies on your computer, you can also change your mind, and simply clear the cache of your browser. The cookies will be removed.

The website is hosted by Amazon AWS Europe.

We share some of the collected personal data with our hosting service provider and other technical providers and solely to the extent necessary for the technical operation of the website and for marketing and development of our own services.

Cullen International may also need to disclose your personal data in connection with the sale or transfer of all or part of the business or if required or permitted by law.

Failing to provide the personal data needed to navigate through the website and use the Cullen International SA services could lead to the impossibility of accessing our website and services.

Personal data is deleted as soon as the purpose of the processing is achieved.

Longer data retention may occur when required by law and for liability and archiving purposes.

Category of Data	Example	Retention Period	Justification for Retention
Billing information	Masked details of most recently used payment method	7 years	For regulatory reasons we are required to retain accounting records for 7 years.
Website access	Number of website views per service	7 years	To monitor behaviours by clients /users
Business intelligence/development	Web activity	36 months (then aggregated + non-personally identifiable)	To improve and maintain performance, personalise our services and to develop our services and products.
Customer service queries	General enquiries	7 years	To provide a case history to assist us to answer your queries.
Communication history	Email stating that subscription is up for renewal	7 years	So that we have a record of what communications we have sent to you, to better assist your queries
Site features	Portfolio tool information	Lifetime of the account	To improve your experience of our products and services
Subscription information	Account information relating to a Cullen International	7 years post-subscription	To enable us to fulfil your contract with us.

It is sometimes necessary for us to keep some personal information for longer periods of time, for example:

• If there is a legal requirement to retain it;
• To ensure we do not contact you if you have asked us not to.

Subscribers with beta trial access to RiA, our AI-powered Regulatory intelligence Assistant, can explore Cullen International’s analyst-authored content for answers to specific questions.  RiA is developed internally by Cullen International.  To optimise the reliability and purity of RiA’s AI-generated answers, its research capability is contained within the Cullen International platform.  RiA processes the question, then searches our platform for, and retrieves links to the most suitable Cullen International content before delivering an answer to the specific question based purely on the Cullen International subscribed content, plus it identifies all relevant Cullen International research.

These AI-generated answers are provided for information only. They do not constitute legal advice. Although RiA’s answers are based on our human-authored intelligence, these answers do not replace the expert research and analytical work of our Cullen International analysts. We strongly recommend clients refer to the underlying reports, or contact your Cullen International analyst, before relying on an AI-generated answer.

What data we process:

When you use RiA through your individual user account, we process the questions you enter and the answers generated; the reports referred to in answers; any feedback you give; requests to access a report outside your subscription; and technical data such as date and time of use and connection logs.

Personal data about other people and confidential information, should never be included in your questions to RiA.

Why we process data and on what legal basis: 

1. To provide the assistant as part of your organisation’s subscription/beta trial: performance of the subscription contract or, where the contract is with an organisation, our legitimate interest in delivering the subscribed service.
    
2. To review and analyse questions and answers to improve the assistant and our content, normally at account level or in aggregated form: our legitimate interest in improving our services.
    
3. To handle a request to access a report outside of your subscription; an account manager may contact the requesting user: our legitimate interest in responding to such a request and managing our business relationship.
    
4. To ensure security, prevent misuse and enforce our terms of use, including unauthorised automated access: our legitimate interest in protecting our services and content.

We do not use the assistant to take decisions about individuals that have legal or similarly significant effects. Our service providers do not use submitted questions to train their own AI models. We do not share the content of individual users’ questions with their organisation.

Who has access: 

Authorised Cullen International representatives, on a need-to-know basis. We also use cloud hosting and AI infrastructure service providers acting on our behalf, under contractual data protection obligations. Personal data is processed within the European Economic Area.

How long we keep it: 

Questions and answers linked to a user are kept for 36 months, then deleted or kept only in anonymised, aggregated form. Access requests are kept with our client records for 7 years.

Your rights: 

Users have the rights described in section X of this policy. In particular, users may object at any time to the use of their questions to improve the assistant by contacting privacy@cullen-international.com. This does not affect your use of RiA.

You have rights as an individual in relation to personal data we process. These rights include:

1. the right to request from the data controller access to and rectification or erasure of personal data or restriction of processing concerning the data subject or to object to processing as well as the right to data portability;
2. withdraw consent where it is the legal basis of the data processing (this does not affect the lawfulness of past data processing);
3. lodge a complaint with a supervisory authority; except when forbidden by the GDPR or any other applicable law or any judiciary injunction;
4. the right to object to direct marketing.

To exercise your rights, please contact Cullen International :

1. by letter (mail) send to 1160 Brussels (Auderghem), Clos Lucien Outers, 11-21, boîte 1;
2. by email at the following address: privacy@cullen-international.com

 

Last updated: 12 November 2026. Previous versions are available on request.