Compliance Information

(1)  
Privacy
Policy

Privacy Notice
Cullum Detuners Investments Limited

We comply with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 to help keep your personal data safe and secure. We understand that when you share your data with us, you trust us to handle it responsibly. By visiting https://cullumgroup.co.uk/, you are accepting and consenting to the practices described in this policy.

This Privacy Policy applies only to your use of our website. Our site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by those other websites. We recommend checking their privacy policies before submitting any personal data.

Our Privacy Notice covers:

1. Who we are
2. What personal data we collect & how
3. What we do with your personal data
4. Who has access to your data
5. How we store your data
6. How long we keep your information
7. Your rights
8. Cookies we use
9. Changes to this policy
10. How to contact us and complain

1. Who we are

Cullum Detuners Investments Limited
Adams Close, Heanor Gate Ind. Park, Heanor, Derby, DE75 7SW
We are the Data Controller of the information you provide. If you have any questions about how your data is handled, you can contact us at: [Insert Data Protection Contact Compliance@cullum.co.uk

2. What personal data we collect and how

We may collect and process the following information:

• Name, email address and phone number (when you submit an enquiry form)
• Technical data such as your IP address, browser type, and operating system (automatically collected)

We only request data that is necessary for us to provide or improve our services.

We use your data when:

• There is a contract between us
• It is in your legitimate interest or ours

3. What we do with your personal data

We may use your data to:

• Fulfil contractual obligations
• Respond to enquiries or requests
• Provide updates or information about our services
• Improve our website’s performance and user experience

We do not sell your personal data. If we want to use your data for any other purpose, we will ask for your consent.

4. Who has access to your data

Your data will only be accessed by authorised employees of Cullum Detuners Investments Limited and select third parties where necessary, such as:

• Subcontractors involved in providing services to you
• Analytics or search engine providers

We may also disclose your data if required by law or in the event of a business sale or restructuring. All third parties we work with are reviewed for their data protection compliance.

5. How we store your data

We take appropriate technical and organisational measures to protect your data. Our systems are reviewed regularly to ensure continued compliance with data protection legislation.

While we take data security seriously, please note that no system is 100% secure, particularly online.

6. How long we keep your data

We keep personal data only as long as necessary to fulfil the purpose for which it was collected. We maintain a data retention schedule and review this regularly.

7. Your rights

You have the right to:

• Access your personal data
• Request correction or deletion
• Object to processing
• Request data portability

To exercise your rights, contact us at: Compliance@cullum.co.uk

8. Cookies we use

Our website uses cookies to improve your experience. These are small text files stored on your device.

We will ask for your consent before placing non-essential cookies. You can manage cookies through your browser settings.

9. Changes to this Privacy Notice

Cullum Detuners Investments Limited reserves the right to update this policy at any time. Any updates will be posted on this page. This notice was last updated on 24/06/2025.

10. How to contact us and complain

If you have any questions or concerns about your data, please contact:
Cullum Detuners Investments Limited
Adams Close, Heanor Gate Ind. Park, Heanor, Derby, DE75 7SW
Email: Compliance@cullum.co.uk

If you are not satisfied with how we handle your data, you can contact the UK Information Commissioner’s Office:
ICO Website: www.ico.org.uk
Address:
Information Commissioner’s Office
Wycliffe House, Water Lane
Wilmslow, Cheshire
SK9 5AF

(2)  
Anti-Bribery

GENERAL ANTI-CORRUPTION AND BRIBERY
OBLIGATIONS

Cullum Group is committed to conducting its
business around the world with the highest degree of integrity and in full
compliance with all applicable laws. This commitment includes a zero-tolerance
approach towards all forms of Bribery and Corruption, and the Group is
committed to maintaining in force appropriate checks and procedures to ensure
that all persons working for or dealing with the Business respect and comply
with this Code of Conduct.

The Business, its directors, employees,
licensees, officers, consultants joint venture partners and agents must not
engage in any form of Bribery or other Corrupt Activities anywhere in the world
nor will the Business request that any third party does so on its behalf. This
prohibition includes, but is not limited to, the payment or receipt of Bribes
by or on behalf of the Business and/or encouraging, asking for or arranging for
anyone else to make or receive Bribes for the Business.

Each subsidiary has a dedicated
Anti-Bribery policy and statement, which has been approved by the Compliance
Officer.

The relevant policy statements are
available to all employees as part of the Company Handbook, and to our customer
base upon written request.

Please direct any enquires to Compliance@cullum.co.uk

(3)  
Corporate
Criminal Offence

The Group enacts
policies and procedures at each subsidiary level, to ensure compliance with the
Corporate Criminal Offence of the Failure to Prevent the Criminal Facilitation
of Tax Evasion (“CCO”).

To support
compliance, all subsidiaries look to:

• Obtain assurances and warranties from suppliers that they have
  reasonable prevention procedures in place – via agreement within our
  defined commercial terms
• Provide training for key staff and being clear about the
  consequences if a person associated with Cullum facilitates tax evasion.
• Provide a pathway for reporting wrongdoing and providing
  protection for whistle-blowers.
• Operate procedures which reduce the opportunity for employees
  to facilitate tax evasion and regularly review these for effectiveness and
  improvement.
• Adopt a zero-tolerance attitude towards the criminal
  facilitation of tax evasion.
• Where internal investigations indicate a person associated with
  any Cullum Group Business has facilitated tax evasion, they will be
  reported to the authorities and the Cullum Group Board of Directors will
  fully support prosecution by such legal authorities.
• Not to use the services of others who are unable to provide
  assurance that they have reasonable prevention procedures in place.

(4)  
Modern
Slavery