At Pulpex we respect your privacy and are committed to protecting your personal data.
the law protects you.
1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE PERSONAL DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED?
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
1. Important information and who we are
This website is not intended for children and we do not knowingly collect data relating to children.
Who we are – Pulpex as Controller
Full name of legal entity: Pulpex Limited
Email address: email@example.com
Postal address: 64 New Cavendish Street, London, W1G 8TB
Telephone number: +44 20 3393 6490
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the regulatory body in the UK for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
It is important that the personal data we hold about you is accurate and current. Please do keep us informed if your personal data changes during your relationship with us.
2. The PERSONAL data we collect about you
Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer (“Process”) different kinds of personal data about you which we have grouped together as follows:
Identity Data - this includes your first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data – this includes your billing address, delivery address, email address and telephone numbers.
Technical Data – this includes your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
Usage Data – this includes information about how you use our website, products and services.
Marketing and Communication Preferences Data – this includes your preferences in receiving marketing from us and our third parties, and your communication preferences.
We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data can be derived from your personal data but it is not considered to be personal data as it does not directly or indirectly reveal your identity.
If you decline to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you do not wish to provide that data when requested, it is probable that we will not be able to perform the contract we have, or are trying to enter into. In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. How is your personal data collected?
We collect personal data from and about you:
Directly from you. You may give us information such as your Identity and Contact Data by creating an account, filling in forms on our website, or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
subscribe to our service or publications;
request marketing to be sent to you;
enter a competition, promotion or survey; or
give us feedback or contact us.
From third parties or publicly available sources. We collect personal data about you from various third parties and public sources as set out below:
Technical Data from the following parties:
analytics providers such as Google;
advertising networks; and
search information providers.
Contact Data from providers of technical services.
Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register.
4. How we use your personal data
We will only process your personal data as permitted by law. We will use your personal data for the following reasons :
Where we need to perform the contract we are about to enter into, or have entered into, with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal obligation.
Click here to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data. However, we will get your consent before sending third party direct marketing communications to you via email or text message, or to process any special category data. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we process your personal data
We have set out below, in a table format, a description of the ways in which we may use your personal data and the legal basis we rely on to do so. We have also identified what our legitimate interests are where appropriate.
We may process your personal data using more than one lawful basis, depending on the specific purpose for which we are using it. Please contact us if you would like details about the specific legal ground we are relying on to process your personal data where more than one basis has been set out in the table below.
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new client/investor
(a) Identity (b) Contact
Performance of a contract with you
To process and deliver your order for services including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us
(a) Identity (b) Contact (c) Marketing and Communications
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
(a) Identity (b) Contact (c) Profile (d) Marketing and Communications
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Identity (b) Contact (c) Technical
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
(a) Technical (b) Usage
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you
(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications
Necessary for our legitimate interests (to develop our products/services and grow our business)
How and when we use “special category” sensitive personal information
"Special categories" of sensitive personal information, such as information about your health, racial or ethnic origin, sexual orientation or preferences, require higher levels of protection. We are required to have further justification for processing this type of personal information. We have in place an appropriate safeguards policy document which we are required by law to maintain when processing such data.
We may process special categories of personal information in the following circumstances:
In limited circumstances, with your explicit consent.
Where we need to carry out our legal obligations or exercise rights in connection with our business.
Where it is needed in the public interest, such as for equal opportunities monitoring.
Occasionally, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else's interests) and you are not capable of giving your consent, or where you have already made the information public.
Situations in which we will use your sensitive personal data
In general, we will not process particularly sensitive personal information about you unless it is necessary for performing or exercising obligations or rights in connection with our business. In exceptional circumstances, there may be other reasons for us processing this, such as where it is in the public interest to do so.
We provide you with choices regarding certain uses of your personal data, in particular for marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us and you have not opted out of receiving that marketing. You may opt out of marketing at any time.
We will get your express opt-in consent before we share your personal data with any third party for their own marketing purposes.
Automated decision making and profiling
We may use your personal data for the purposes of automated decision making or profiling but will notify you beforehand to provide you detailed information in relation to the auto-decision logic used and about the significance and the consequences for you of any automated decision-making or profiling.
Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:
1. Where we have notified you of the decision and given you 21 days to request a reconsideration.
2. Where it is necessary to perform any contract with you and appropriate measures are in place to safeguard your rights.
3. In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.
If we make an automated decision on the basis of any sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.
We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.
Opting out of marketing or changing your marketing preferences
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at
+44 20 3393 6490 or by email using firstname.lastname@example.org.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at +44 20 3393 6490 or by email using email@example.com.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.
External Third Parties as set out in the Glossary
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International transfers
We may transfer your personal data outside of the UK.
Some of our external third parties service providers are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.
Whenever we transfer your personal data out of the UK, we will ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK. These countries include: Andorra, Argentina, Canada, Faroe Islands, Guernsey, Israel, Isle of Man, Jersey, New Zealand, Switzerland, and Uruguay; and
where we use service providers in countries other than those listed above, we will ensure that we use specific contractual terms approved by the under the UK GDPR which give personal data the same protection it has in the UK.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers (including Contact and Identity Data) for six years after they cease being customers for tax and legal purposes.
In some limited circumstances you can ask us to delete your data: see your legal rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
9. Your legal rights
In addition to the right to be informed, under certain circumstances you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
Request access to your personal data (Subject Access Request ‘SAR’).
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
External Third Parties
Service providers based worldwide who provide IT and system administration services.
Professional advisers including lawyers, bankers, auditors and insurers based worldwide who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities in the UK who require reporting of processing activities in certain circumstances.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
If you want us to establish the data's accuracy.
Where our use of the data is unlawful but you do not want us to erase it.
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Be notified in respect of any automated decision-making or profiling in respect of your personal data.
Request meaningful information about the auto-decision logic used in any automated decision-making or profiling and about the significance and the consequences of any automated decision-making or profiling.
Object to automated decision-making or profiling of your personal data.