PRIVACY NOTICE

INTRODUCTION

This is bulk™’s privacy notice.

bulk™ respects your privacy and is committed to protecting your personal data. This privacy notice will inform you how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below.

• IMPORTANT INFORMATION AND WHO WE ARE
• THE DATA WE COLLECT ABOUT YOU
• HOW IS YOUR PERSONAL DATA COLLECTED
• HOW WE USE YOUR PERSONAL DATA
• DISCLOSURES OF YOUR PERSONAL DATA
• INTERNATIONAL TRANSFERS
• DATA SECURITY
• DATA RETENTION
• YOUR LEGAL RIGHTS

1. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to give you information on how bulk™ collects and processes your personal data through the provision of our products/services and through your use of this website, including any data you may provide when you sign up to any newsletters or publications, purchase products or take part in competitions.

Our products and services and this website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Your data will only be processed in accordance with Data Protection Legislation. Where data is processed by a controller or processor established in the European Union or comprises the data of people in the European Union, Data Protection Legislation includes the General Data Protection Regulation (Regulation (EU) 2016/679) (‘EU GDPR’), the Directive on Privacy and Electronic Communications (2002/58/EC) (as amended) ('the ePrivacy Directive') and any legislation implemented in connection with the aforementioned legislation. In the UK, where we have our headquarters, this includes the Data Protection Act 2018 (‘DPA 2018’), United Kingdom General Data Protection Regulation (‘UK GDPR’) and the Privacy and Electronic Communications (EC Directive) Regulations 2003 (‘PECR’).

Depending on your location, additional legislation might also apply. Unless otherwise stated, we will process your personal data in accordance with Data Protection Legislation as defined above. 

CONTROLLER

bulk™ is the trading name of Sports Supplements Limited which is the controller and responsible for your personal data (collectively referred to as “bulk™”, “we”, “us” or “our” in this privacy notice).

We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, please contact our Data Protection Officer using the details set out below.

CONTACT DETAILS

Our full details are:

Full name of legal entity: Sports Supplements Limited (trading as bulk™)

Full title: Data Protection Officer

Email address: dpo@bulk.com 

Postal address: Unit 1, Gunfleet Business Park, Brunel Way, Colchester, Essex CO4 9QX, UNITED KINGDOM

Data Protection Commission (DPC) regulates data protection in Ireland and can be contacted as follows:

Postal address: 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland

Website: https://www.dataprotection.ie/ 

If you have a complaint or concern about how we manage your personal data we would, however, appreciate the chance to deal with your concerns before you approach the DPC, so please contact us in the first instance.

THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. THE 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 different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, username or similar identifier, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes 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.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback, survey responses and other interactions with us.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us or otherwise update your account details with us online.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not explicitly collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). 

However, we do collect information that could be used to infer Special Categories of Personal Data about you. This includes details that you provide us with when you select your account preferences. Please know that we will not use these preferences to make any inferences about Special Categories of Personal Data about you. These details will only be used to provide you with product recommendations that we think you will like. You have complete control over whether to disclose this information, we do not require it to be provided in order to have access to our website or submit an order for one of our products.

Please note that if you provide us with this information, we will process it on your explicit consent. You can withdraw this consent at any time, by updating your account preferences or by Contacting us to request that we stop processing such information.

IF YOU FAIL 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 fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). 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 use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you: 
• apply for our products or services;
• create an account on our website;
• subscribe to our service or publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us some feedback.
• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.
• Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
• Technical Data from the following parties:

(a)  Google Analytics, which allows us to understand how visitors are interacting with our website, and to allow us to optimise the site to drive better performance.

(b)  Criteo, Emarsys, Facebook, Affiliate Window and Google which use targeting cookies to track referrals from other sites.

(c)  Contact, Financial and Transaction Data from providers of technical, payment and delivery services.

• Contact Data from anyone that refers you via a refer a friend scheme.

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will rely on the following lawful bases to ensure that your personal data is process lawfully:

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.

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.

Compliance with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Consent means processing your personal data where you have provided freely given, specific, informed consent to the processing.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. 

You have the right to withdraw consent to marketing at any time by Contacting us.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please Contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around 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 or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

CAN YOU BE REMOVED FROM OUR MAILING LIST?

bulk™ will send you special offers and promotions by post, email, SMS and RCS when you are an existing customer or where (in the case of a new customer), you have consented to receive such promotions or have otherwise not opted-out. If you do not want to receive offers and promotion by email, you can unsubscribe here or in the link included as part of all marketing communications. We will endeavour to remove you as quickly as possible but it may take time to fully remove you from our email mailing list so you may receive one or two more emails. If you do not want to receive offers and promotions by post, SMS or RCS, let us know at hello@bulk.com. Our postal marketing materials are printed in advance so it can take time for the process to be complete for this medium, so it is possible that you may receive one further communication in such instances.

If your details are included on a recognised “opt-out” list in the jurisdiction in which you are based, bulk™ will make all best endeavours to ensure you do not receive marketing materials from us, unless you have directly requested otherwise.

CAN YOU RE-SUBSCRIBE TO OUR MAILING LIST?

If you have previously asked us not to send offers but have changed your mind please let us know by emailing us at hello@bulk.com. 

COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

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.

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 section 4 above:

• Specific third parties listed in paragraph 3 above.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
• Service providers acting as processors who provide a range of services on our behalf e.g. IT and system administration services; marketing services  (such as our refer a friend partners); ecommerce platforms and support functions; shipment tracking services; website and product review services; accountancy services; communication platforms; and customer relationship management platforms.
• Our network of couriers who help us deliver our products.
• Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• Regulators, law enforcement and other governmental authorities based in Ireland, the United Kingdom and elsewhere who require reporting of processing activities in certain circumstances.

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. We do not sell or provide your data to other companies for their own marketing purposes.

THIRD PARTY PAYMENT PLATFORMS

We use the following third party platforms to process payments made to us:

Klarna

Their privacy notice can be viewed at: https://cdn.klarna.com/1.0/shared/content/legal/terms/0/en_gb/privacy.

Paypal

Their privacy notice can be viewed at: https://www.paypal.com/uk/webapps/mpp/ua/privacy-full. 

DNA TESTING KITS

Our DNA Testing Kits are provided by a third party called GenePlanet. While these products are branded as bulk™, we do not process any Genetic Information (as defined by GenePlanet) relating to you. Any Genetic Information, as derived from samples, or otherwise provided by you, is collected and processed by GenePlanet.

You can find further information on how they process personal data, and the security measures they apply, by visiting their website and reading their privacy notice (https://geneplanet.com/privacy-policy) and data privacy statement (https://geneplanet.com/data-privacy). 

bulk™ will not process any additional categories of personal data as part of this product offering. If you have any further questions regarding this product or would like to exercise your rights, then please contact our DPO using the details in this notice.

6. INTERNATIONAL TRANSFERS

bulk™is headquartered in the United Kingdom (UK) and so it follows that some of the external third parties that we transfer personal data to are based in the UK and not in Ireland. Some additional transfers may take place in the European Economic Area (EEA), such as in Poland and Germany. These countries have been deemed to provide an adequate level of protection for personal data by the European Commission. 

In limited circumstances, your data may be transferred to countries outside Ireland, the UK and the EEA. We will only transfer your personal data outside of these jurisdictions where it is required to process your order, or in order for us to fulfil the purposes that we have documented in the table above. This would include the United States (US). Please also see ‘Disclosures of your personal data’ above. We further ensure a similar degree of protection is afforded to your personal data by ensuring appropriate safeguards are implemented with US third parties, for example where we use certain service providers, we may use specific contracts approved by the European Commission or UK authorities, as relevant, which give personal data the same protection it has in the EEA and the UK.

Please Contact us if you want further information on the specific mechanism used by us when transferring your personal data outside of the EEA/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.

How do you protect the information you hold about me on your internal systems?

We protect your privacy in several ways:

• Access to customer account information is limited to those who need access for the performance of their job.
• We use full login and password controls on our system.
• All full and part-time employees are required to sign a confidentiality clause as part of their terms of employment.
• All calls are recorded and monitored for training and security purposes.
• Confidentiality and database access controls are reviewed periodically and updated as required to further protect our personal data.

• We use other appropriate procedures and technical security measures (such as encryption, anonymisation and archiving techniques) to safeguard your information across all our computer systems, networks and our website.
  
  

If for any reason you are unsure about the personal and account information we are holding in your name, please contact us. We will happily review your file and update the records if required. You can email us at hello@bulk.com. 

8. DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 requirements.

In some circumstances you can ask us to delete your data: please see the Request erasure section below for further information.

In some circumstances we may 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

Under certain circumstances, you have the following 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 (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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) 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.

Have more questions? Submit a request

If you wish to exercise any of the rights set out above, please Contact us.

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 may 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 on the status of your request.

10. CHANGES TO THE PRIVACY NOTICE

Thank you for taking the time to read our privacy notice.

This version was last updated on the 910h August 2022. Historic versions can be obtained by contacting us.

We may change this privacy notice from time to time (for example, if the law changes). We recommend that you check this notice regularly to keep up-to-date.