1. Introduction

1.1 We are committed to safeguarding the privacy of our website visitors and service users. In this policy, we explain how we handle your personal data and the measures we take to protect your information.

1.2 By using our website and agreeing to this policy, you consent to the use of cookies in accordance with the terms outlined here. Cookies help us enhance your browsing experience and improve our services.

2. How We Use Your Personal Data

2.1 In this section, we explain:

(a) The general categories of personal data we may process.
(b) The source and specific categories of data we may process if not obtained directly from you.
(c) The purposes for which we may process personal data.
(d) The legal bases on which we process your data.

2.2 Usage Data:

We may collect and process data related to your use of our website and services, referred to as “usage data.” This data may include:

• Your IP address.
• Geographical location.
• Browser type and version.
• Operating system details.
• Referral sources (how you arrived at our site).
• Length of visit and the pages viewed.
• Website navigation paths.
• Information about the timing, frequency, and patterns of your website usage.

The source of this data is our analytics tracking system, which helps us gather insights into user behaviour.

Purpose of Processing:
This usage data is processed to:

• Analyse the way visitors interact with our website.
• Identify areas for improvement to enhance user experience.
• Monitor the performance of our website and services.

Legal Basis:
The legal basis for this processing is either your consent (where applicable) or our legitimate interests in improving our website and services.

2.3 Account Data

We may collect and process account data provided by you or your employer. This account data may include:

• Your name.
• Your email address.

Purpose of Processing:
Account data may be processed for the following purposes:

• To operate our website and services efficiently.
• To ensure the security and integrity of our website and services.
• To maintain back-ups of our databases to protect against data loss.
• To communicate with you regarding our services, updates, or any queries you may have.

Legal Basis:
The legal basis for processing account data is:

• Your consent, where applicable.
• Our legitimate interests in ensuring the proper administration and security of our website and business.
• The performance of a contract between you and us, or taking steps, at your request, to enter into such a contract.

2.4 Profile Data

If you create or manage a personal profile on our website, we may process the following data:

• Your name and contact information (address, telephone number, and email address).
• Profile pictures.
• Gender.
• Date of birth.
• Relationship status.
• Interests and hobbies.
• Educational background.
• Employment details.

Purpose of Processing:
Profile data may be processed to:

• Enable your use of our website’s features and services.
• Monitor your interaction with our website and services to improve functionality.
• Provide a personalised experience by tailoring content or services based on your preferences.

Legal Basis:
The legal basis for processing profile data is:

• Your consent, where explicitly provided.
• Our legitimate interests in maintaining the proper administration of our website and business.
• The performance of a contract between you and us, or taking steps, at your request, to enter into such a contract.

2.5 Publication Data

We may process information that you post for publication on our website or through our services. This publication data may include:

• Content you upload or submit for public display, such as comments, reviews, articles, or other user-generated content.

Purpose of Processing:
Publication data may be processed to:

• Enable your content to be published on our website or through our services.
• Administer our website, ensuring its smooth functionality and compliance with policies.

Legal Basis:
The legal basis for processing publication data is:

• Your consent, where explicitly given.
• Our legitimate interests in maintaining and managing the proper administration of our website and services.
• The performance of a contract between you and us, or steps taken at your request to enter into such a contract.

2.6 Enquiry Data

We may process information contained in any enquiry you submit regarding our goods or services. Enquiry data may include:

• Your name, email address, phone number, and any additional information you provide in your enquiry.

Purpose of Processing:
Enquiry data is processed to:

• Respond to your questions or requests about our goods or services.
• Offer, market, or sell relevant goods or services to you.

Legal Basis:
The legal basis for processing enquiry data is:

• Your consent, where explicitly provided.

2.7 Transaction Data

We may process information related to transactions, including the purchase of goods or services through our website or directly with us. Transaction data may include:

• Your contact details (name, email, phone number, and address).
• Your card or payment details.
• Transaction details, such as items purchased, dates, and amounts.

Purpose of Processing:
Transaction data is processed to:

• Supply the purchased goods or services.
• Maintain proper records of transactions for accounting and legal purposes.

Legal Basis:
The legal basis for processing transaction data is:

• The performance of a contract between you and us, or steps taken at your request to enter into such a contract.
• Our legitimate interests in ensuring the effective administration of our website and business.

2.8 Notification Data

We may process information you provide to us for the purpose of subscribing to email notifications and/or newsletters. This notification data may include:

• Your name.
• Your email address.

Purpose of Processing:
Notification data may be processed to:

• Send you email notifications or newsletters that you have subscribed to or requested.
• Provide updates about our services, offers, or other relevant content based on your preferences.

Legal Basis:
The legal basis for processing notification data is:

• Your consent, explicitly provided when subscribing to notifications or newsletters.
• The performance of a contract between you and us, or steps taken at your request to enter into such a contract.

2.9 Correspondence Data

We may process data contained in or related to any communications you send to us. Correspondence data may include:

• The content of your communication, such as emails, messages, or inquiries.
• Metadata associated with the communication, such as timestamps, IP addresses, and technical information generated when using our website contact forms.

Purpose of Processing:
Correspondence data is processed to:

• Respond to your inquiries, questions, or concerns.
• Maintain records of communications for future reference or administrative purposes.

Legal Basis:
The legal basis for processing correspondence data is:

• Our legitimate interests in managing our website and business communications effectively and ensuring proper record-keeping.

2.10 Legal Claims Data

We may process any personal data identified in this policy if it is necessary for the establishment, exercise, or defense of legal claims. This processing may occur in:

• Court proceedings.
• Administrative procedures.
• Alternative dispute resolution or out-of-court procedures.

Purpose of Processing:
Legal claims data is processed to:

• Protect and assert our legal rights.
• Safeguard your legal rights or the legal rights of others.

Legal Basis:
The legal basis for processing legal claims data is:

• Our legitimate interests in ensuring the protection and enforcement of our legal rights, as well as the legal rights of our users and third parties.

2.11 Risk Management and Insurance Data

We may process your personal data where it is necessary for:

• Obtaining or maintaining insurance coverage for our business operations.
• Managing potential risks to our business.
• Seeking professional advice to ensure compliance, risk mitigation, or legal protections.

Purpose of Processing:
This data is processed to ensure the proper protection of our business against potential risks, liabilities, or operational issues.

Legal Basis:
The legal basis for processing this data is our legitimate interests, namely the protection and proper management of our business.

2.12 Compliance and Vital Interests Data

We may process your personal data in circumstances where:

• It is necessary to comply with a legal obligation to which we are subject.
• It is necessary to protect your vital interests or the vital interests of another individual.

Purpose of Processing:
This data may be processed to:

• Meet regulatory, statutory, or legal requirements.
• Protect the health, safety, or well-being of individuals in situations where immediate action is required.

Legal Basis:
The legal basis for this processing is compliance with legal obligations or safeguarding vital interests in exceptional circumstances.

2.13 Data of Other Individuals

Please do not provide personal data belonging to another person unless we specifically request or prompt you to do so.

Purpose of this Request:
This is to ensure compliance with data protection laws and to avoid processing unauthorised data from third parties.

3. Providing Your Personal Data to Others

3.1 Group Companies

We may share your personal data with any member of our group of companies. This includes:

• Our subsidiaries.
• Our ultimate holding company.
• All subsidiaries of our holding company.

Purpose of Disclosure:
This sharing is limited to what is reasonably necessary for the purposes outlined in this policy and in accordance with the legal bases described.

3.2 Insurers and Professional Advisers

We may disclose your personal data to our insurers and professional advisers.

Purpose of Disclosure:
This is done to:

• Obtain or maintain insurance coverage.
• Manage risks associated with our business operations.
• Seek professional advice for business, compliance, or legal matters.
• Establish, exercise, or defend legal claims, whether in court proceedings or through administrative or alternative dispute resolution methods.

3.3 Payment Service Providers

Financial transactions related to our website and services may be managed by third-party payment service providers.

Purpose of Disclosure:
We will only share transaction data that is necessary to:

• Process your payments.
• Issue refunds.
• Handle complaints or queries related to payments or refunds.

You can review the privacy policies and practices of our payment service providers via the following links:

• Monzo Privacy Policy

3.4 Third-Party Suppliers

We may share your enquiry data with selected third-party suppliers of goods or services listed on our website.

Purpose of Disclosure:
This is done to facilitate the provision of goods or services relevant to your enquiry. We ensure that such disclosures are necessary and limited to the scope of your enquiry.

3.5 Compliance and Legal Requirements

In addition to the specific disclosures mentioned above, we may share your personal data in the following circumstances:

• Legal Obligations: Where disclosure is required to comply with a legal obligation, regulation, or statute to which we are subject.
• Vital Interests: Where disclosure is necessary to protect your vital interests or the vital interests of another individual.
• Legal Claims: Where disclosure is necessary to establish, exercise, or defend legal claims, whether in court proceedings, administrative processes, or out-of-court resolutions.

4. International Transfers of Your Personal Data

4.1 Overview of Transfers Outside the EEA

In this section, we explain the situations in which your personal data may be transferred to countries outside the European Economic Area (EEA). These transfers may occur where it is necessary for the operation of our business, the delivery of our services, or the functionality of our website.

4.2 Offices and Facilities

Our business operations and those of our group companies are based in the United Kingdom. Your personal data may be processed in the United Kingdom to support our services and ensure proper functionality of our systems and website.

4.3 Website Hosting Facilities

The hosting facilities for our website are located in the United Kingdom. Any personal data collected through our website is stored and processed within these hosting facilities to ensure data security and compliance with applicable laws.

4.4 Publication of Personal Data Online

If you submit personal data for publication on our website or services (e.g., user-generated content or comments), this data may be accessible globally via the internet.

Acknowledgment of Global Availability:
You acknowledge that once published, your personal data may be accessed and used by individuals or entities around the world. While we take steps to protect your privacy, we cannot prevent the misuse or unauthorised use of such publicly accessible data.

5. Retaining and Deleting Personal Data

5.1 Retention Policy Overview

This section outlines our policies and procedures for retaining and deleting personal data. These policies are designed to ensure compliance with applicable legal requirements regarding the duration for which personal data is stored and the conditions under which it is deleted.

5.2 General Retention Principle

We will not retain personal data for longer than is necessary to fulfil the purposes for which it was collected or for which it is being processed. The length of time we retain data depends on the nature of the data and its intended use.

5.3 Retention Periods

We will retain your personal data as follows:

1. General Retention Period:

• Personal data categories will be retained for a minimum period of six years following the date of final correspondence with you.
• Data will be retained for a maximum period of 15 years following the date of the final correspondence.

These retention periods are designed to support business needs, ensure compliance with legal requirements, and provide sufficient time for resolution of disputes or other claims.

5.4 Exceptions to Standard Retention Policies

In some circumstances, we may retain your personal data beyond the standard retention periods outlined above. These exceptions include:

1. Compliance with Legal Obligations:

• Where retention is necessary to comply with a legal obligation, such as record-keeping requirements or regulatory mandates.

2. Protection of Vital Interests:

• Where retention is required to protect your vital interests or those of another natural person, such as in cases of safety or health-related concerns.

6. Amendments

6.1 Policy Updates

We may revise and update this policy periodically by publishing a new version on our website. These updates reflect changes in our practices, legal requirements, or operational needs.

6.2 Your Responsibility to Stay Informed

We encourage you to review this page periodically to stay informed about any updates or changes to this policy. By continuing to use our website or services after changes have been made, you are agreeing to the updated terms of this policy.

6.3 Notifications of Changes

When significant changes are made to this policy, we may notify you in one or more of the following ways:

• Email Notifications: You may receive an email informing you of the updated policy and the changes made.
• On-Site Notifications: Changes may be communicated via the private messaging system on our website.
• Dedicated Forms: Updates may also be made accessible through the “Delete My Data” page or similar forms on our website, ensuring you can take actions such as data deletion requests if required.

8. Your Rights

8.1 Overview of Your Rights

This section summarises the rights granted to you under applicable data protection laws. Some of these rights are complex, and this summary does not include every detail. For a comprehensive understanding, we encourage you to consult the relevant laws and official guidance from regulatory authorities.

8.2 Your Principal Rights

Under data protection law, you are entitled to the following rights:

(a) The Right to Access: You have the right to know whether we process your personal data and, if we do, access to that data along with additional information.
(b) The Right to Rectification: You can request that inaccurate or incomplete personal data about you be corrected or completed.
(c) The Right to Erasure: In specific circumstances, you can request the deletion of your personal data.
(d) The Right to Restrict Processing: You can request that we limit the processing of your personal data in certain situations.
(e) The Right to Object to Processing: You can object to the processing of your personal data, particularly in cases involving direct marketing.
(f) The Right to Data Portability: You can request the transfer of your personal data to another organization or to you in a structured, commonly used, and machine-readable format.
(g) The Right to Complain to a Supervisory Authority: If you believe we have violated your data protection rights, you can lodge a complaint with a regulatory authority.
(h) The Right to Withdraw Consent: Where we rely on your consent for data processing, you have the right to withdraw that consent at any time.

8.3 The Right to Access

You are entitled to confirmation about whether we process your personal data. If we do, you can request:

1. Access to your personal data.

2. Additional information, such as:

• The purposes of processing.
• The categories of personal data involved.
• The recipients or categories of recipients of the personal data.

Copy of Your Data:
We will provide a copy of your personal data, with a fee of GBP 10 currently applicable. However, we may charge a reasonable fee for additional copies if your request is excessive or repetitive. This is subject to ensuring that the rights and freedoms of others are not adversely affected.

8.4 The Right to Rectification

If you identify inaccuracies in your personal data, you can request:

• That the inaccurate data be corrected.
• That incomplete data be completed, taking into account the purposes for which it is being processed.

8.5 The Right to Erasure (Right to Be Forgotten)

In certain situations, you can request that we erase your personal data without undue delay. These situations include:

• The data is no longer necessary for the purposes for which it was collected or processed.
• You withdraw your consent for consent-based processing.
• You object to processing under applicable legal rules.
• The data was unlawfully processed.
• The data is being processed for direct marketing purposes.

Exclusions:
There are general exclusions to the right to erasure. We may retain your personal data if processing is necessary for:

• Exercising the right to freedom of expression and information.
• Compliance with a legal obligation.
• Establishing, exercising, or defending legal claims.

8.6 The Right to Restrict Processing

You have the right to request a restriction on the processing of your personal data in certain circumstances, including:

• Accuracy Dispute: If you contest the accuracy of your personal data, processing will be restricted until the data’s accuracy is verified.
• Unlawful Processing: If the processing is unlawful, but you prefer restriction over erasure.
• Data No Longer Needed: If we no longer require the personal data for processing purposes, but you need it to establish, exercise, or defend legal claims.
• Pending Objection Verification: If you object to processing (see section 8.7), processing will be restricted while the objection is verified.

Implications of Restriction:
While your personal data is restricted, we may continue to store it. However, we will only process the data:

• With your explicit consent.
• For establishing, exercising, or defending legal claims.
• To protect the rights of another person (natural or legal).
• For important public interest reasons.

8.7 The Right to Object to Processing Based on Legitimate Interests

You have the right to object to the processing of your personal data if the legal basis for the processing is:

• Public Interest: The performance of a task carried out in the public interest or in the exercise of official authority vested in us.
• Legitimate Interests: The processing is necessary for the legitimate interests pursued by us or a third party.

Outcome of Objection:
If you make such an objection, we will cease processing your personal data unless:

• We can demonstrate compelling legitimate grounds for the processing that override your rights, freedoms, and interests.
• The processing is necessary for the establishment, exercise, or defense of legal claims.

8.8 The Right to Object to Direct Marketing

You have an absolute right to object to the processing of your personal data for direct marketing purposes, including profiling related to direct marketing.

Outcome of Objection:
If you object, we will cease all processing of your personal data for direct marketing purposes immediately.

8.9 The Right to Object to Processing for Research or Statistical Purposes

You may object to the processing of your personal data for scientific or historical research purposes or statistical purposes if the processing affects your particular situation.

Exception:
We may continue processing your data if the processing is:

• Necessary for performing a task carried out for reasons of public interest.

8.10 The Right to Data Portability

Where the legal basis for processing your personal data is:

(a) Consent; or
(b) Performance of a Contract (or steps taken at your request prior to entering into a contract),

and the processing is carried out by automated means, you have the right to:

• Receive your personal data in a structured, commonly used, and machine-readable format.
• Request that we transfer your personal data directly to another data controller where technically feasible.

Exceptions:
This right does not apply where it would:

• Adversely affect the rights and freedoms of others.

8.11 The Right to Lodge a Complaint

If you believe our processing of your personal data violates data protection laws, you have the legal right to lodge a complaint with a supervisory authority responsible for data protection.

Where to Lodge a Complaint:
You may submit your complaint to:

• The EU member state of your habitual residence.
• Your place of work.
• The location where the alleged infringement occurred.

For further assistance, we encourage you to contact us before lodging a formal complaint to allow us to address your concerns.

8.12 The Right to Withdraw Consent

If the legal basis for our processing of your personal data is consent, you have the right to withdraw that consent at any time.

Effect of Withdrawal:

• Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
• Once consent is withdrawn, we will cease processing your personal data for purposes that rely on consent unless there is another legal basis for processing.

8.13 Exercising Your Rights

You may exercise any of your rights in relation to your personal data by providing us with written notice.

How to Contact Us:
Please direct any written requests or inquiries to our designated data protection contact at Contact@hulkmarketing.co.uk.

9. About Cookies

9.1 What Are Cookies?

A cookie is a small file containing an identifier (a string of letters and numbers) that is sent from a web server to a web browser. This file is stored by the browser and sent back to the server whenever the browser requests a page from the server.

Cookies help websites recognise users, remember preferences, and enhance user experience.

9.2 Types of Cookies

Cookies can be classified as either:

1. Persistent Cookies:

• These cookies are stored by the web browser and remain valid until their set expiry date, unless manually deleted by the user before that date. Persistent cookies are often used to remember user preferences or log-in details for future visits.

2. Session Cookies:

• These cookies are temporary and expire automatically at the end of the user session when the web browser is closed. They are primarily used to track user activity during a single session.

9.3 Personal Information and Cookies

Cookies typically do not contain information that directly identifies you personally. However, the information stored in and obtained from cookies may be linked to personal information that we maintain about you.

Purpose of Linking Cookies to Personal Data:
This connection allows us to:

• Provide personalised content or services.
• Remember your preferences or settings.
• Enhance the functionality of our website and improve user experience.

10. Cookies That We Use

10.1 We use cookies to support various functions on our website and improve your browsing experience. The purposes for which we use cookies include:

(a) Authentication

• Cookies are used to identify you when you visit our website and as you navigate through it.
• This ensures a seamless and secure browsing experience.

(b) Status

• Cookies help us determine if you are logged into your account on our website.
• This allows us to manage session functionality and provide relevant user experiences.

(c) Personalisation

• Cookies store information about your preferences.
• This enables us to personalise the website and tailor content to suit your interests.

(d) Security

• Cookies are used as part of our security measures to:
  • Protect user accounts from unauthorised access.
  • Prevent fraudulent use of login credentials.
  • Safeguard the integrity of our website and services.

(e) Advertising

• Cookies help us display advertisements that are relevant to your interests.
• These cookies may track your interaction with ads to improve their relevance over time.

(f) Analysis

• We use cookies to analyse the usage and performance of our website and services.
• This helps us gather insights into user behaviour, optimise functionality, and improve overall service quality.

(g) Cookie Consent

• Cookies are used to store your preferences regarding the use of cookies on our website.
• This ensures that your choices about cookie usage are respected across your browsing sessions

Cookies Used by Our Service Providers

11.1 Service Provider Cookies

Some of our service providers use cookies to deliver their services, and these cookies may be stored on your device when you visit our website. These cookies are managed by the respective service providers and are subject to their privacy policies.

11.2 Google Analytics

We use Google Analytics to analyse the usage of our website.

• How It Works: Google Analytics collects information about your interaction with our website using cookies, such as the pages you visit, the duration of your visit, and how you navigate the site.
• Purpose: The information gathered is used to create reports about the performance and usage of our website, helping us to optimise and improve your experience.
• Privacy Policy: For more information on how Google processes this data, please review their privacy policy at Google Privacy Policy.

11.3 Google AdSense

We publish Google AdSense interest-based advertisements on our website.

• How It Works: These ads are tailored to your interests based on your browsing behaviour on our website and other websites across the internet. Google uses cookies to track your activities and preferences to deliver relevant advertisements.
• Purpose: This ensures that advertisements displayed on our website are aligned with your interests and enhance your browsing experience.
• Opting Out: If you wish to opt out of personalised advertisements, you can visit Google’s Ads Settings or refer to their privacy policy for additional options.

Managing Cookies

12.1 How to Manage Cookies

Most web browsers allow you to control and manage cookies by providing options to block or delete them. The methods for doing so vary depending on the browser and its version. Below are links to the relevant cookie management instructions for popular browsers:

(a) Google Chrome: Learn how to block, delete, or manage cookies in Chrome.
(b) Mozilla Firefox: Instructions for enabling or disabling cookies in Firefox.
(c) Opera: Find information on managing cookies in Opera.
(d) Internet Explorer: Steps for managing cookies in Internet Explorer.
(e) Safari: Guide to managing cookies in Safari.
(f) Microsoft Edge: Information on cookie settings in Microsoft Edge.

By visiting these links, you can find up-to-date instructions for blocking or deleting cookies in your preferred browser.

12.2 Impact of Blocking Cookies

Blocking all cookies may negatively affect the usability of many websites, including ours. Features that rely on cookies, such as personalised content or seamless navigation, may no longer function as intended.

12.3 Website Functionality

If you choose to block cookies, certain features on our website may become unavailable or function less effectively. For example, logging in, remembering your preferences, or accessing personalised content may be impacted.

13. Our Details

13.1 Ownership

This website is owned and operated by Hulk Marketing Ltd.

13.2 Registration Information

We are registered in England and Wales under registration number 15931335, and our registered office is located at:
9 Mackenzie St, Slough SL1 1XQ.

13.3 Principal Places of Business

We operate from the following office locations:

• London Office: Tower 42, 25 Old Broad St, London EC2N 1HN – Contact: 020 8865 1917.
• Slough Office: 9 Mackenzie St, Slough SL1 1XQ – Contact: 01753 318 308
• Birmingham Office: Lewis Building, 35 Bull St, Birmingham B4 6AF – Contact: 0121 339 5365
• Manchester Office: Peter House, Oxford St, Manchester M1 5AN – Contact: 0161 726 5295

13.4 Contacting Us

You can reach us using any of the following methods:

(a) By Post: Write to our registered office at 9 Mackenzie St, Slough SL1 1XQ – Contact: 01753 318 308.
(b) Using Our Website Contact Form: Submit your inquiries via the contact form available on our website.
(c) By Phone: Use the contact numbers listed above for each office.
(d) By Email: Contact us at our main email address: Contact@hulkmarketing.co.uk.

We are committed to responding to all inquiries promptly and addressing your questions or concerns effectively.

14. Data Protection Officer

14.1 Contact Information

Our Data Protection Officer (DPO) is responsible for overseeing questions related to this Privacy Policy and ensuring compliance with data protection regulations. You can contact our DPO using the following details:

Name: Muhammad Sajid
Company: Hulk Marketing Ltd
Address: 9 Mackenzie St, Slough SL1 1XQ
Email: Sajid@hulkmarketing.co.uk
Phone: 07577764436