Privacy Policy

The privacy of customers personal data is important to Bull Exports. This Policy describes the rules according to which Bull Exports processes the personal data of any person using the Bull Exports’s website bullexports.com, mobile apps and any services offered by Bull Exports.

1. General Definitions

Bull Exports

Service provider who needs to process customer’s personal data for the provision of service. It’s registered under the name Bull Exports.

Customer

Any person who is using Bull Exports’s website, app or any services provided by Bull Exports.

GDPR

Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.

Policy

This privacy policy.

Personal Data

Any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Personal Data processed by Bull Exports is described under Section 3.

Processing

Any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Controller

A person who alone or jointly with others, determines the purposes and means of the Processing of Personal Data.

The Controller of the Customer’s Personal Data is: Bull Exports.

Processor

A person who Processes Personal Data on behalf of the Controller.

In the course of provision of Service, Bull Exports may act as Processor by Processing Personal Data on behalf of its Customer or Customer’s legal entity. However, this Policy shall not regulate the Bull Exports’s actions as Processor.

Service

Any services provided by Bull Exports via website bullexports.com and Bull Exports mobile apps.

 

2. Policy Applicability

This Policy applies to Personal Data Processing where Bull Exports acts as a Controller. Any personal data Processing conducted on behalf of the Customer or his legal entity is subject to an additional data processing agreement signed between Bull Exports and the legal person controlled by the Customer.

 

3. Personal Data being collected

Bull Exports processes the following Personal Data about the Customer:

    1. Personal Details – full name (surname and given name), gender, personal identification code, date of birth, nationality, contact postal address, e-mail address, mobile phone number, bank where the personal bank account exists;
    2. Identification Data – data retrieved from the copy of a passport, such as document number, issue date, expiry date and issuing entity, photo, URL of a Portfolio or LinkedIn profile;
    3. Verification Data – data which Bull Exports collects for the purpose of conducting Customer due diligence under applicable anti-money laundering laws. For Service, Bull Exports collects data concerning whether the Customer is politically exposed and whether the Customer is subject to any international financial sanctions. The foreing is collected and Processed by Bull Exports in the course of provision of Service, if the Customer wishes to use third party banking services;
    4. Background Data – data Bull Exports collects and Processes for the purpose of conducting Customer adverse media checks via open sources;
    5. Profile Data – Customer’s Google profile data, such as name, e-mail address, language preference and profile picture;
    6. Payment Data – data concerning payments for Bull Exports’s Service and state fees, such as account number (IBAN), account holder name, bank name, transaction details, If the Customer chooses to pay for the Service by credit card or by PayPal, his/her payment details are not stored by Bull Exports and therefore cannot be accessed by Bull Exports.
    7. Business related Data – in the course of providing Service Bull Exports collects and Process data concerning the field of activity the Customer wishes to act via virtual company, in the course of providing Service Bull Exports collects and Process the business description, incl. planned services and service volumes of the company being established by Service;
    8. Device Data – information regarding the device on which the Customer is using the Bull Exports’s website/app, including the device’s model, name or any other identifier and the IP address;
    9. Preference Data – Customer’s preferences in the Bull Exports’s website/app;
    10. Customer Support Data – communication between Bull Exports and the Customer (inquiries submitted via the website, email, social media or chat);
    11. Usage Data – data about Customer’s interaction in Bull Exports’s website/app.



4. Sources of Personal Data Collection
 

Majority of Customer’s Personal Data Processed by Bull Exports is collected directly from the Customer. However, Bull Exports may collect Customer’s Personal Data also from third party sources, such as databases of financial sanctions and people subject to international financial sanctions and databases of politically exposed people. Some of these databases are publicly available and some of them are not.

5. Purposes for collecting and Processing Customer’s Personal Data

Personal Data collected by Bull Exports is processed for the purposes established in the law or as described herein, including but limited for the following purposes:

    1. Contractual Purpose – Bull Exports needs to Process Customer’s Personal Data in order to enter into service agreement with the Customer and to provide Service to Customer;
    2. Compliance Purpose – Bull Exports needs to Process Customer’s Personal Data in order to perform obligations under applicable laws, such as to comply with anti-money laundering requirements, and combat fraud, ensure the fulfilment of international financial sanctions, comply with the lawful inquiries and orders of public authorities with whom Bull Exports is obligated to cooperate;
    3. Analytical Purpose – Bull Exports needs to Process Customer’s Personal Data in order to manage, analyse and improve the Service, website and app;
    4. Marketing Purpose – Bull Exports needs to Process Customer’s Personal Data in order to send relevant promotional information to the Customer about Bull Exports services and the related offerings by third parties we work with, if the Customer has granted an explicit consent to use his/her Personal Data for this purpose;
    5. Personalization Purpose – Bull Exports needs to Process Customer’s Personal Data in order to personalize the Service and the content provided to the Customer;
    6. Communication Purpose – to contact the Customer for administrative purposes such as customer service, address technical or legal issues related to the Service provided, or share updates and notifications about the Service;

Bull Exports shall not use Customer’s Personal Data for any other purpose incompatible with the purposes outlined above or required, permitted or authorized by law.

Customer is not subject to statutory obligation which obligates Customer to provide Personal Data described herein to Bull Exports. The collection of certain Personal Data referred herein may be required under the law and/or inevitably necessary for the provision of service to the Customers (such as data necessary for the verification of the Customer). Failure to provide data may result in adverse consequences, such as, Bull Exports’s inability to comply with our obligations under law. The Customer is welcome to ask for clarifications regarding the obligation to submit any specific Personal Data and also about possible consequences arising from the failure to provide the Personal Data.

 

6. Automated decision making

Bull Exports is providing Bull Exports Service as well as Bull Exports Service for the Customers active in the certain field of activities. Not all fields of activities are supported by Bull Exports’s services. Bull Exports is using automated decision making in the pre-contractual Processing in order to establish sufficiently whether the Customer is eligible to use Bull Exports’s services.

Automated decision making refers to a decision which is taken solely on the basis of automated Processing of Customer’s Personal Data. This means Processing using, for example, software code or an alrithm, which does not require human intervention.

During onboarding process, the Customer is being asked for the field of activity of the service provided in course of using Bull Exports’s services. The automated decision making is necessary for entering into agreement with Bull Exports. The automated decision making is used in order to accept or reject the Customer’s application to enter into a service agreement with Bull Exports. In case the field of activity which the Customer wishes to act is not supported by Bull Exports’s services, then the Customer’s application will be rejected. Upon rejection, Bull Exports will inform the Customer by e-mail about the reasoning for rejection.

The Customer is entitled to request human intervention or object to the decision by contacting Bull Exports.

 

7. Legal grounds for Processing

Bull Exports is relying on the following legal grounds when Processing Customer’s Personal Data:

    1. Processing is necessary for the performance or entry into a contract between Customer and Bull Exports (GDPR article 6 (1) (b)), Bull Exports is Processing Personal Data for Contractual Purpose under contract entered into between Bull Exports and Customer;
    2. Processing is necessary for compliance with a legal obligation to which Bull Exports is subject (GDPR article 6 (1) (c)). Bull Exports is Processing Personal Data for Compliance Purpose under legal obligations to which Bull Exports is subject to;
    3. Processing is necessary for the purposes of the legitimate interests pursued by Bull Exports (GDPR article 6 (1) (f)). Bull Exports is Processing Personal Data for Analytical or Personalization Purpose under legitimate interest;
    4. Customer has granted a consent to the Processing of his Personal Data (GDPR article 6 (1) (a)). Bull Exports is Processing Personal Data for Marketing Purpose under Customer’s consent.

8. Transfer of the Personal Data

Bull Exports may transfer Customer’s Personal Data to third parties, such as:

    1. legal and regulatory authorities (e.g. commercial register) whom Bull Exports is obligated to disclose Customer’s Personal Data under the law;
    2. server hosts who host Bull Exports’s servers;
    3. identification service providers who help Bull Exports verify Customer’s identity and acquire Verification Data;
    4. communication service providers who facilitate e-mails, calls, SMS messages and other communication between Bull Exports and the Customer;
    5. customer support and customer management service providers;
    6. marketing service provider;
    7. Bull Exports’s partner bank who providing banking services to the Customer or to the legal entity controlled by the Customer or any other financial service provider;
    8. Bull Exports’s affiliate. i.e. any company that directly or indirectly controls Bull Exports; any company that is directly or indirectly controlled by Bull Exports; or any company that is controlled, directly or indirectly, by the ultimate parent company of Bull Exports. Control shall mean owning more than fifty percent of the voting rights in a company or otherwise having the power to vern the financial and the operating policies or to appoint the management of a company;
    9. other parties involved with the provision of Bull Exports’s Service (accountants, auditors, lawyers, IT systems suppliers and support, or any other outsourcing providers).

Bull Exports has taken steps to ensure that these data recipients protect the confidentiality and security of Personal Data, and to ensure that Personal Data is Processed only for the provision of Service and in compliance with applicable law.

Such third parties may be located in countries outside of the European Economic Area (“EEA”) whose privacy regulations may differ and which are not subject to adequacy decisions of the European Commission. In those countries the security of the Personal Data (inc. protection against misuse, unauthorized access, disclosure, alteration or destruction) may not be ensured as it is secured in the European Union, due to the lack of adequate data protection level.

For example, Bull Exports may transfer Customer’s Personal Data to the US, in which case Bull Exports shall ensure that the recipient of the Personal Data is certified in accordance to the EU-US Privacy Shield entered by and between the US Department of Commerce and the European Commission. To learn more about the Privacy Shield program, please visit https://www.privacyshield.v/

When transferring collected Personal Data outside of the EEA, Bull Exports shall ensure the application of the appropriate safeguards. If the Customer wishes to receive a copy, please contact us as instructed below.

 

9. Security

Bull Exports will take appropriate legal, organisational, and technical measures to protect Personal Data consistent with applicable privacy and data security laws. Security measures shall be applied in order to protect Personal Data from involuntary or unauthorized Processing, disclosure or destruction.

Upon transferring Personal Data to third parties, Bull Exports will apply the following safeguards:

    1. Bull Exports enters into a data processing agreement with the relevant third party;
    2. Bull Exports makes sure that such third party undertakes to implement appropriate technical and organizational measures ensuring the Processing of Customer’s Personal Data in accordance with this Policy and applicable law;
    3. Bull Exports makes sure that (a) the third party is established in a jurisdiction which the European Commission has recognized as ensuring an adequate level of personal data protection, or (b) the Processing of Customer’s Personal Data is subject to other appropriate safeguards stipulated in the GDPR.



10. Integrity and retention of the Personal Data

Bull Exports will retain Personal Data for the period required or permitted by applicable law, but no longer than it is reasonably necessary in order to achieve the purposes for which the Personal Data was collected.

Bull Exports takes reasonable steps to ensure that the Personal Data we Process is reliable for its intended use, accurate, and complete as necessary to carry out the purposes described herein.

 

11. Customer’s rights in regarding to the collection of Personal Data

Customer has the following rights in relation to the Processing of his Personal Data:

    1. Request information – Bull Exports has provided all information which the Customer has right to receive in this Policy. The valid version of the Policy is available in Bull Exports’s website at any time.
    2. Right to access – Customer has the right to ask Bull Exports to provide a copy of Customer’s Personal Data which Bull Exports Process.
    3. Right to Rectification – Customer has the right to ask Bull Exports to rectify Personal Data in case the data is incorrect or incomplete.
    4. Right to Erasure – Customer has the right to ask Bull Exports to erase Personal Data, unless Bull Exports is obliged to continue Processing Customer’s Personal Data under law or under a contract between the Customer and Bull Exports, or in case Bull Exports has other lawful grounds for the continued Processing of Personal Data.
    5. Right to Restriction – Customer has the right to ask Bull Exports to restrict the Processing of his Personal Data in case the data is incorrect or incomplete or in case his Personal Data is Processed unlawfully.
    6. Right to Data Portability – Customer has the right to ask Bull Exports to provide the Customer or, in case it is technically feasible, a third party, his Personal Data, which the Customer has provided to Bull Exports and which is Processed in accordance with Customer’s consent or a contract between the Customer and Bull Exports.
    7. Right to Object – Customer has the right to object to Processing his Personal Data in case there is a reason to believe that Bull Exports has no lawful grounds for Processing the Personal Data.
    8. Right to withdraw Consent for the Processing of Personal Data – Customer is entitled to withdraw the consent granted for the Processing of Personal Data et any time. Withdrawal does not affect the lawfulness of the Processing conducted before the withdrawal.
    9. Right to File Complaints – Customer has the right to file complaints regarding Processing of his Personal Data.

In order to exercise any rights referred herein the Customer is required to submit a written application to Bull Exports (Bull Exports’s contact details can be find under Section 16). Bull Exports has the right to decline this application by justifying the reasons for the refusal.

According to the article 12(3) of GDPR, Bull Exports is obligated to respond to the application within 1 month. However, Bull Exports will make its best efforts to respond to Customer’s request within 1 week.

 

12. Right to amend this Policy

Bull Exports is entitled to unilaterally amend this Policy from time to time. Upon amending the Policy, Bull Exports will notify the Customer about the terms by e-mail. In case the new terms refer to Processing of Customer’s Personal Data for any new purpose, which requires Customer’s consent, then Bull Exports will not Process Personal Data for such new purpose, before it has received respective consent

 

13. Contact Information

Should the Customers have any questions regarding this Policy or Processing of Personal Data, they are welcome to contact Bull Exports with requests, inquiries or any complaints via email: info@bullexports.com.

 

14. Confirmation

By accepting this Policy, the Customer confirms that he has familiarized himself with this Policy, understood it and agree to its terms.

Last updated: November 26, 2020