Privacy Policy

Effective October 27, 2026

Who we are

Kulin & Co. ("Kulin", "we", "us") is a performance marketing and creative agency. We plan, build and run paid advertising for our clients' brands. Kulin is operated by Collaboration Betters The World, doing business as KULIN, 1122 4th Street SW, Suite 1410, Calgary, Alberta T2R 1M1, Canada. We are responsible for the personal information described in this policy.

What this policy covers

This policy explains how we collect, use, share and protect information when:

• you visit kulinco.com;
• you are a client, a prospective client, or someone who works with us on a client's behalf;
• we work in our clients' advertising accounts on platforms such as Meta (Facebook and Instagram), Google and TikTok. This includes through Kulin Ad Ops, our internal tool that connects to Meta's Marketing API.

When we handle data inside a client's advertising accounts, we do so on that client's behalf and under our agreement with them. The client's own privacy policy governs how their customers' information is handled.

What we collect

From clients and the people we work with: names, work email addresses, phone numbers, job titles and the content of our messages and meetings. We also keep billing details for the business, and the brand materials clients give us: copy, images, videos and landing pages.

From our website: what you send us through a contact form or by email. [If kulinco.com uses analytics or cookies, name them here and say what they record, for example pages visited and approximate location.]

From advertising platforms, on our clients' behalf: information about the client's ad accounts and campaigns. This covers account, campaign, ad set and ad names, IDs and settings; the creative, copy and landing pages in each ad; delivery status; and results such as spend, impressions and conversions. We also receive the IDs of the Facebook Page and Instagram account an ad runs under, and of the posts the ads create.

We do not collect the personal profiles of people who see or interact with our clients' ads. Platforms report ad results to us in aggregate.

How we use it

We use this information to:

• build, launch, manage and improve our clients' advertising;
• report results to our clients;
• communicate with clients and prospects, and run our agreements, billing and accounts;
• keep our systems and our clients' accounts secure;
• meet our legal obligations.

We use a client's data only for that client. We do not sell personal information, and we do not use one client's data for another client.

Who we share it with

• The client it belongs to, in our reports and in their own ad accounts.
• Service providers who work for us under contract. These include Google (Google Workspace and Google Cloud, where our tools run and our working files are kept), Slack, ClickUp, Notion and Air. They also include AI services that help us analyze results and draft reports, such as Anthropic and Google. They may use the information only to provide their service to us.
• Our parent and affiliated companies in the CBTW group, for the same purposes and under this policy.
• Authorities, when the law requires it. We review each request and disclose only what is required.
• A buyer or successor, if all or part of our business is sold or reorganized. This policy keeps applying to the information.

Data we receive from Meta

Kulin Ad Ops is our internal tool. Only Kulin staff use it, and it is not offered to anyone else. It connects to Meta's Marketing API with a token issued to Kulin's own business account. It reaches only the ad accounts, Facebook Pages and Instagram accounts that clients have shared with Kulin in Meta Business Manager.

• What it receives: the ad account, campaign, ad set and ad information described under "What we collect", including results such as spend, and the IDs of the Pages, Instagram accounts and posts the ads run under. It does not receive the profiles, friends, messages or other personal information of Facebook or Instagram users.
• What it does with it: it uploads a client's approved images and videos and creates their ads, paused, for our team to review in Ads Manager. It then reads back what it created to check it matches what the client approved. It also reuses an ad's existing post in further ads, so its engagement stays in one place.
• Where it goes: our working files in Google Workspace, and our internal Slack alerts, which can include an ad set's name. We never sell Meta data, share it with other clients, or use it to build profiles of people.
• How long we keep it: as described under "How long we keep it" below. We delete it sooner if the client, or Meta, asks.

We follow Meta's Platform Terms and Developer Policies for all data we receive through Meta's tools.

How long we keep it

We keep client and advertising information for as long as we work with the client. We delete it within 90 days after the engagement ends, unless the law requires us to keep it longer. Invoices and accounting records, for example, are kept for the period tax law requires. Messages sent through our website are kept for as long as we need them to respond and follow up.

How we protect it

Access is limited to Kulin staff and service providers who need it for their work. Our tools run inside business accounts protected by sign-in controls. Access tokens for advertising platforms are stored in those accounts and never shared. No system is perfectly secure, but we take reasonable steps to protect information from loss, misuse and unauthorized access.

Where it is stored

Kulin is in Canada. Some of our service providers store information in the United States or other countries, where it is protected under our agreements with them. Authorities in those countries may be able to access it under their own laws.

Your rights

You can ask to see the personal information we hold about you, have it corrected, or withdraw consent you have given us. Withdrawing consent may limit what we can do for you. Depending on where you live, you may have other rights, such as asking us to delete or restrict your information. We answer each request within 30 days.

If you're a customer of one of our clients, please contact that client first. We'll help them answer you.

If you're not satisfied with our answer, you can complain to the Office of the Privacy Commissioner of Canada or, in Alberta, the Office of the Information and Privacy Commissioner of Alberta.

Deleting your data

To ask us to delete your information, including any data we received about you or your business through Meta (Facebook and Instagram) or another platform:

1. Email logan@kulinco.com with the subject "Data deletion request".
2. Say who you are and, for a business, which ad accounts, Pages or Instagram accounts the request covers.
3. We confirm we received it within 5 business days. We delete the data within 30 days and confirm when it's done, unless the law requires us to keep part of it. If so, we tell you which part and why.

Clients can also remove Kulin's access at any time in Meta Business Manager, under Business settings > Partners. Our tool loses access to those accounts straight away.

Children

Our services are for businesses. We don't knowingly collect personal information from children.

Changes to this policy

We may update this policy as our services or the law change. The effective date at the top says when it last changed. We tell clients directly about any significant change.

Contact us

Questions, requests and complaints go to our privacy officer:

Logan Edgelow, KULIN (Collaboration Betters The World)
1122 4th Street SW, Suite 1410, Calgary, Alberta T2R 1M1, Canada
logan@kulinco.com