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
Service provider who needs to process customer’s personal data for the provision of service. It’s registered under the name Bull Exports.
Any person who is using Bull Exports’s website, app or any services provided by Bull Exports.
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.
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.
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.
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.
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.
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:
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:
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:
8. Transfer of the Personal Data
Bull Exports may transfer Customer’s Personal Data to third parties, such as:
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.
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:
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:
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: firstname.lastname@example.org.
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