Effective date: 1 June 2026

Sugar & Partners Limited ("Funnel Engine", "we", "us") operates the Funnel Engine reporting platform and the website at funnelengine.app (together, the "Service"). This policy explains what data we collect, how we use it, who we share it with, and the choices you have. We comply with the New Zealand Privacy Act 2020 and, where applicable, the EU/UK GDPR and the California Consumer Privacy Act.

1. Who we are

Sugar & Partners Limited NZBN 9429030580886, Level 1, 114 Ponsonby Road, Grey Lynn, Auckland 1011. For any privacy question or request, contact us at privacy@funnelengine.app.

2. The data we collect

Account data you give us. Your name, work email, company name, role, and any details you provide when you join the waitlist, create an account, or contact us.

Marketing platform data you connect. Funnel Engine is a reporting tool. When you authorise a connection, we access — on a read-only basis and only to produce your reports and dashboards — performance and insights data from the platforms you choose to connect, which may include:

• Meta (Facebook & Instagram): advertising performance and insights (ad accounts, campaigns, spend, reach, impressions, results) and Page insights (engagement, reach, content performance).

• Google Ads: campaign, ad group, keyword and conversion performance.

• Google Analytics (GA4): traffic, engagement and conversion metrics.

• TikTok Ads, LinkedIn Ads, Reddit Ads: campaign performance and insights.

• Search/SEO: visibility, ranking and organic performance data.

We request the narrowest, read-only access needed to generate reporting. We do not request, and do not use, permissions to create, edit or manage your campaigns.

Report outputs. The dashboards, slides and AI-generated commentary the Service produces from your connected data.

Usage and technical data. Log data, device and browser information, IP address, and cookie identifiers, collected to operate and secure the Service.

3. How we use data

• To set up your account and connect the platforms you choose.

• To pull, blend and present your marketing data as live dashboards and exportable reports.

• To generate AI-assisted commentary and insights on that data.

• To operate, secure, troubleshoot and improve the Service.

• To communicate with you about the Service and respond to your requests.

  
  

We do not sell your data, and we do not use data accessed from connected platforms for advertising or to build profiles unrelated to the reporting you've asked us to produce.

4. AI-generated insights

The Service uses a third-party large-language-model API (Anthropic) to generate written commentary from your performance data. Data sent for this purpose is processed only to return your commentary and is not used by the provider to train its models. AI-generated commentary is provided to assist your analysis and should be reviewed before you rely on or share it.

5. Who we share data with (sub-processors)

We share data only with service providers that help us run the Service, under contracts that require them to protect it and use it only on our instructions:

• Hosting & application: Vercel (United States).

• Database & storage: Supabase (United States).

• AI commentary: Anthropic (United States).

• Report generation: Google APIs (Slides, Sheets, Drive) to build your exports.

• Data connectors: platform APIs listed in section 2, and Supermetrics as an interim data connector (being phased out as direct connections roll out).

Because some providers are in the United States, your data may be transferred and stored outside New Zealand. We take reasonable steps to ensure comparable protection for that data, consistent with the Privacy Act 2020.

We may also disclose data if required by law, or as part of a business sale or restructure, in which case we'll notify you.

6. Google and Meta platform data

Funnel Engine's use of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements. Specifically, data obtained through Google APIs is used only to provide and improve the user-facing reporting features of the Service; is not transferred to others except as necessary to provide those features, to comply with law, or as part of a merger/acquisition; is not used for advertising; is not sold; and is not used to train generalised AI/ML models. Humans do not read this data except where you give consent, for security, to comply with law, or where the data is aggregated and anonymised.

Funnel Engine's use of data from the Meta platforms complies with the Meta Platform Terms and Developer Policies. We delete data obtained from a Meta platform when you disconnect that platform, delete your account, or request deletion (see the Data Deletion page).

7. How long we keep data

We keep account data while your account is active. Connected platform data is retained only as long as needed to provide your live reporting and historical comparisons, and is deleted when you disconnect a platform, close your account, or request deletion. Some records may be retained where required by law.

8. Security

We protect data with access controls, encryption in transit, authenticated API connections, and row-level access restrictions in our database. No system is perfectly secure, but we work to protect your data and limit access to it.

9. Your rights

You can ask to access, correct, export or delete your personal data, and withdraw a platform connection at any time. To make a request, email privacy@funnelengine.app or follow the instructions detailed on the Data Deletion page.

You may also disconnect any platform yourself from within the Service. If you're in the EU/UK or California, you have additional rights under the GDPR/CCPA, including the right to complain to a regulator.

10. Cookies

The website uses essential cookies to function and a limited set of analytics cookies to understand site usage. You can control cookies through your browser settings. We show a consent banner where required for visitors in regions that mandate one.

11. Children

The Service is for business use and is not directed at anyone under 16. We don't knowingly collect data from children.

12. Changes

We may update this policy and will post the new effective date here. Material changes will be notified to account holders.

13. Contact

Sugar & Partners Limited, Level 1, 114 Ponsonby Road, Grey Lynn, Auckland 1011 — privacy@funnelengine.app