Disclaimer and Privacy
Welcome to Bulgin Limited privacy notice.
Bulgin Limited respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to 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. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
1) IMPORTANT INFORMATION AND WHO WE ARE
2) THE 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
6) INTERNATIONAL TRANSFERS
7) DATA SECURITY
8) DATA RETENTION
9) YOUR LEGAL RIGHTS
10) GLOSSARY
11) DISCLAIMER
12) INTELLECTUAL PROPERTY
13) ACCURACY OF INFORMATION
14) COOKIE POLICY
15) WHO TO CONTACT
1) Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how Bulgin Limited collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter or contact us to request information.
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.
Controller
Bulgin Limited is made up of different legal entities, details of which can be found here. This privacy notice is issued on behalf of the Bulgin Limited so when we mention “Bulgin Limited”, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the Bulgin Limited responsible for processing your data. Bulgin Limited is the controller and responsible for this website.
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us legal@Bulgin.com
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority 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.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on 25 April 2018
The data protection law in the UK will change on 25 May 2018. Although this privacy notice sets out most of your rights under the new laws, we may not yet be able to respond to some of your requests (for example, a request for the transfer of your personal data) until May 2018 as we are still working towards getting our systems ready for some of these changes.
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.
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, or personal information, 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, maiden name, last name, username or similar identifier, marital status, 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 and survey responses.
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.
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 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). Nor do we collect any information about criminal convictions and offences.
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, server logs and other similar technologies.
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:
analytics providers such as Google based outside the EU;
Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.
4) How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
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 or regulatory obligation.
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 at legal@Bulgin.com.
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 legal@Bulgin.com 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.
Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new customer (a) Identity
(b) Contact
Performance of a contract with you
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
(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
Necessary for our legitimate interests (to develop our products/services and grow our business)
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 and, in each case, you have not opted out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any company outside the Bulgin Limited of companies for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us legal@Bulgin.com at any time.
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.
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 click here.
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 legal@Bulgin.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 have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
Internal Third Parties as set out in the [Glossary].
External Third Parties as set out in the [Glossary].
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.
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 do not transfer your personal data outside the European Economic Area (EEA).
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 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.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see [Request erasure] 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 rights under data protection laws in relation to your personal data. 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: (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.
If you wish to exercise any of the rights set out above, please contact us legal@Bulgin.com.
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 may 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 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.
10) Glossary
LAWFUL BASIS
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 legal@Bulgin.com
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 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.
THIRD PARTIES
Internal Third Parties
Other companies in the Bulgin Limited acting as joint controllers or processors
External Third Parties
Service providers acting as processors based in the United Kingdom who provide IT and system administration services.
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
11) Disclaimer
This World Wide Website (the “site”) is operated by Bulgin Limited (“Bulgin Limited”). These conditions of use are governed by the laws of England and Wales and you agree that the English courts shall have exclusive jurisdiction in any dispute.
The pages, or parts of pages, containing share price feeds and RNS feeds are provided by the Design Portfolio Online Services from the London Stock Exchange via Digital Look.
The pages, or parts of pages, containing share price information (“the IR website”) are published by Design Portfolio Online Services (“us” or “we”) on behalf of Bulgin Limited and are distinct from those published by Bulgin Limited (“client” website) Please read our conditions of use carefully as by using the IR website you will be taken to have agreed to be bound by them. We reserve the right to vary the conditions of use at any time and will post any variations here. You are advised to review the conditions of use on a regular basis as you will be deemed to have accepted variations if you continue to use the IR website after they have been posted. We take every care and precaution to ensure that information published on the IR website is accurate when posted and regularly updated, but neither we nor Bulgin Limited guarantee its accuracy and we may change the information at any time without notice. WE PUBLISH THE IR WEBSITE “AS IS” WITHOUT ANY WARRANTY OF ANY KIND, EXPRESS OR IMPLIED, AS TO THE OPERATION OF OUR SITE , THE ACCURACY OF THE INFORMATION OR THE PRODUCTS OR SERVICES REFERRED TO ON THE IR WEBSITE (IN SO FAR AS SUCH WARRANTIES MAY BE EXCLUDED UNDER ANY RELEVANT LAW) AND NEITHER WE NOR BULGIN LIMITED SHALL BE LIABLE FOR ANY LOSSES OR DAMAGES THAT MAY RESULT FROM USE OF THE IR WEBSITE AS A CONSEQUENCE OF ANY INACCURACIES IN, OR ANY OMISSIONS FROM, THE INFORMATION WHICH THEY MAY CONTAIN. The information contained in the IR website is not an invitation to invest in the shares, or any other products or services or otherwise deal in these or enter into a contract with Bulgin Limited or any other company. The information provided should not be relied upon in connection with any investment decision.
12) Intellectual property
Your use of this website and any materials downloaded, viewed, copies or printed does not authorise you to use any names or trademarks of Bulgin Limited or its subsidiary companies.
The copyright notice which is displayed in this site indicates that all materials within the site are the intellectual property of Bulgin Limited. Such materials may not be copied save to the extent necessary to view them online. However, you may print complete pages of the site as hard copies for your own personal use.
13) Accuracy of information
Whilst Bulgin Limited uses reasonable endeavours to ensure that the contents of this site are accurate and up to date, it does not accept any liability for any information which may not be accurate. Bulgin Limited is reliant upon third parties for much of the information provided (see below) and reserves the right to change data, references and product specifications at any time.
The contents of this site are for general information and public relations purposes only and do not purport to provide advice, make any offer or otherwise create or lead to the creation of any legally enforceable relationship between Bulgin Limited and you. No reliance should be placed on any statements made on the site, whether for investment purposes or otherwise. Bulgin Limited excludes to the fullest extent permitted by law all liability resulting from your access to the site including (without limitation) any loss (financial or otherwise) or damage resulting directly or indirectly from any such reliance.
Certain hypertext links contained in this site will direct you to websites which are not under the control of Bulgin Limited. Such links are included for your convenience and do not constitute an endorsement by Bulgin Limited of third party products or services. Selection of a link will take you out of this site to other websites which Bulgin Limited has no control over. Bulgin Limited accepts no liability or responsibility whatsoever for any other websites which may be accessed through the Bulgin Limited site, nor does Bulgin Limited endorse or make representations in respect of such websites. All links are used at your own risk. In evoking links to other websites, you agree to accept these conditions of use.
You may not create a link to this website from another website or document without Bulgin Limited’s prior written consent. Persons providing access to this website via links from another website are solely responsible for the content, accuracy, opinions expressed, privacy policies, products or services of, or available through, the source website and for any representations made or impressions created concerning Bulgin Limited.
14) Cookie policy
What are ‘Cookies’?
Cookies are small text files which are downloaded to your computer or mobile device when you visit a website or application. Your web browser (such as Internet Explorer, Mozilla Firefox or Google Chrome) then sends these cookies back to the website or application on each subsequent visit so that they can recognise you and remember things like personalised details or user preferences.
Cookies are very useful and do lots of different jobs which help to make your experience on websites as smooth as possible. For example, they let you move between web pages efficiently, remembering your preferences, and generally improving your experience.
How Cookies are used on Bulgin Limited group websites
We use cookies to understand what pages and information visitors find useful, and to detect problems such as broken links, or pages which are taking a long time to load.We sometimes use cookies to remember a choice you make on one page, when you have moved to another page if that information can be used to make the website work better. For example:
avoiding the need to ask for the same information several times during a session (e.g. when filling in forms), or
remembering that you have logged in, so that you don’t have to re-enter your username and password on every page.
remembering what you have in your shopping basket as you move around the shop
Cookies for Google Analytics
This policy has been updated May 2023 to include the update to Google Analytics 4 (GA4).
This and other Bulgin Limited companies’ websites use Google Analytics which has been upgraded to Google Analytics 4 (GA4), a web analytics service provided by Google, Inc. (“Google”).
Bulgin Limited uses Google Analytics 4 (GA4) which uses “cookies” to recognise you and link the devices you use when you visit our website on your browser or mobile device, log in to your account on our site, or engage with us. Google Analytics 4 allows us to understand how you interact with our site and tailor our advertisements and content to you.
GA4 is the latest iteration of Google’s analytics platform. It collects both website and app data and uses event-based data instead of session-based data, providing a more comprehensive and user-centric approach to analysing website performance, thus improving the customer journey. GA4 also includes privacy controls, enhanced reporting capabilities, and support for cross-device measurement at the property level.
The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and Internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser. However, please note that if you do this you may not be able to use the full functionality of this website. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.
In GA4, IP (Internet Protocol) Anonymisation is enabled by default and cannot be switched off. This means that GA4 will not store the IP addresses of users and cannot track users. From the GDPR perspective, this is considered the most important change in GA4, helping users to comply with the GDPR.
To comply with most privacy laws, including the GDPR, Google doesn’t allow users to collect Personally Identifiable Information (PII) in GA4. It is considered a violation of Google’s Terms of Service to collect PII using GA4, and Google has the right to delete all the data of a user if PII is found.
GDPR Article 4 defines personal data: “Personal data means 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.”
Disabling Cookies
You can prevent the setting of cookies by adjusting the settings on your browser (see your browser Help for how to do this). Be aware that disabling cookies will affect the functionality of this and many other websites that you visit.
15) Who to contact
If you have submitted personal data through the site and would like that information deleted from our records, please contact us at: legal@Bulgin.com.