NULO PRIVACY POLICY

Last Updated: June 17, 2025

This privacy policy sets out how Nulo uses and protects your personal data. This privacy policy is provided in a layered format so you can click through to the specific areas set out below.



This privacy policy gives you information about how Nulo Inc., collects and uses your personal data through your use of our website (https://nulo.com/), including any data you may provide when you submit an enquiry, leave a review or when you sign up to our newsletter.

The Nulo website is not intended for children and we do not knowingly collect data relating to children.

Nulo Inc. is the controller and responsible for your personal data (referred to as "Nulo", "we", "us" or "our" in this privacy policy). If you have any questions about how we process your personal data or this policy, please contact us at privacy@nulo.com.


"Personal data" means any information about an individual from which they can be directly or indirectly identified.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity / Profile Data includes your name, any alias used by you, any personal data included in reviews you leave about our products on our website (including any images you choose to upload with your review) or any questions or answers you provide about our products on our website.


  • Contact Data includes your email address, and your telephone number(s).


  • 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, mobile network information, device type and ID and other technical information about the devices you use to access our website.


  • Usage Data includes information about how you interact with and use our website and adverts.


  • Marketing and Communications Data includes information about your marketing preferences, information about your engagement with our marketing and other communications (for example, whether you open emails that we send you) and any feedback or survey responses you share with us.


We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.


We use different methods to collect data from and about you including through:

Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by phone, email or otherwise. This includes personal data you provide when you:

  • request marketing to be sent to you;


  • write a review on our website, ask or answer any product questions on our website; or


  • give us direct feedback or contact us.


Automated technologies or interactions. As you interact with our website, any of our adverts or communications (such as emails) we send you, we will automatically collect Technical Data about your equipment, browsing actions, usage and patterns. We collect this personal data by using cookies, pixels, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.

Third parties. We also collect Technical Data from certain third parties, including analytics providers and advertising networks (such as social media platforms). 



The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

  • Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.


  • Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) 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).


  • Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.


  • Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to our email newsletter.


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 the various categories of 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.

Purpose/Use

Type of data

Legal basis

To manage our relationship with you, which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Dealing with your requests, complaints and queries

Identity

Contact

Marketing and Communications

(a) Performance of a contract with you where you enter into our website user terms.

(b) Necessary to comply with a legal obligation where you make a request as per your legal rights set out in this policy.

(c) Necessary for our legitimate interests to keep our records updated and manage our relationship with you.

To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).

Identity

Contact

Technical

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).

To deliver relevant website content, online advertisements and marketing communications to you and to measure or understand the effectiveness of the advertising and marketing we serve to you.

Identity

Contact

Usage

Marketing and Communications

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 improve our website, products/services, customer relationships and experiences and to measure the effectiveness of our communications and marketing.

Technical

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 send you marketing communications via email our newsletter or by SMS. 

Identity

Contact

Technical

Marketing and Communications

When you proactively sign up to receive our newsletter, you are consenting to our use of your email address or phone number for the purposes of sending you direct marketing. 

Direct marketing

We may process your personal data to send you our newsletter or other direct marketing on the basis of your consent (which you may withdraw at any time after giving it, as described below).

We will get your consent before we share your personal data with any third party for them to send you theiir own direct marketing.

Opting out of marketing

You can ask us to stop sending you marketing communications at any time by updating your email or marketing preferences and clicking unsubscribe.

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes, for example relating to updates to our Terms and Conditions or checking that your contact details are correct.

Cookies

For more information about the cookies we use and how to change your cookie preferences, please see cookie policy here https://nulo.com/cookie-policy/ or contact us for further information at privacy@nulo.com.


We will share your personal data where necessary with the parties set out below for the purposes described in the table above.

  1. companies that provide services to us in respect of our website; such as, website developers, IT support and companies that review and approve any reviews you post about our products


  2. companies that assist in our marketing, advertising and promotional activities or analytics and search engine providers that assist us in the improvement and optimisation of our website, advertising and marketing campaigns, such as Google, Facebook, Microsoft, Pricespider, Shopify, TikTok, The Trade Desk, and Vimeo;


We may also share your personal data with third parties to whom we may choose to sell, transfer or merge parts of our business or our assets or government and regulatory authorities where we are required to do so. 


Nulo is headquartered in the U.S., therefore your personal data may be used, stored and/or accessed by staff or suppliers in the U.S. or in other countries outside the UK and the European Economic Area (EEA) personal data.

Where we transfer your personal data outside the UK or the EEA, we will take appropriate measures to ensure that the recipient protects your personal data adequately in accordance with this the laws that apply to us.  

These measures may include the following:

  1. ensuring that there is an adequacy decision by the UK Government in the case of transfers of personal data relating to individuals in the UK, or by the European Commission in the case of transfers of personal data relating to individuals in the EEA; or


  2. where we have in place standard model contractual arrangements with the recipient which have been approved by the European Commission or the UK Government. These model contractual clauses include certain safeguards to protect the personal data;


Further details on the steps we take to protect your personal data in these cases is available from us on request by contacting us by email at privacy@nulo.com at any time.


When you provide your personal data to us, your personal data may be transferred over the internet.  Although we make every effort to protect the personal data which you provide to us, the transmission of information over the internet is not completely secure. As such, you acknowledge and accept that we cannot guarantee the security of your personal data transmitted to our website and that any such transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to prevent unauthorised access to it.

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. 


We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.

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, regulatory, tax, accounting or other requirements.

In some circumstances you can ask us to delete your data: see below for further information.

In some circumstances we will 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.


You have certain rights in relation to your personal data. If you would like further information in relation to these or would like to exercise any of them, please contact us via email at privacy@nulo.com at any time. You have the following rights:

  • Right of access.  You have a right of access to any personal data we hold about you.  You can ask us for a copy of your personal data; confirmation as to whether your personal data is being used by us and details about how and why it is being used.


  • Right to update your information.  You have a right to request an update to any of your personal data which is out of date or incorrect.


  • Right to delete your information.  You have a right to ask us to delete any personal data which we are holding about you in certain specific circumstances.  You can ask us for further information on these specific circumstances by contacting us using the details in section 10.
    We will pass your request onto other recipients of your personal data unless that is impossible or involves disproportionate effort.  You can ask us who the recipients are, using the contact details below.


  • Right to restrict use of your information: You have a right to ask us to restrict the way that we process your personal data in certain specific circumstances.  You can ask us for further information on these specific circumstances by contacting us using the details in section 10. 
    We will pass your request onto other recipients of your personal data unless that is impossible or involves disproportionate effort.  You can ask us who the recipients are using the contact details below.


  • Right to stop marketing: You have a right to ask us to stop using your personal data for direct marketing purposes.  If you exercise this right, we will stop using your personal data for this purpose.


  • Right to data portability: You have a right to ask us to provide your personal data to a third party provider of services.  This right only applies where we use your personal data on the basis of your consent or performance of a contract; and where our use of your information is carried out by automated means.


  • Right to object:  You have a right to ask us to consider any valid objections which you have to our use of your personal data where we process your personal data on the basis of our or another person's legitimate interest.  


We will consider all such requests and provide our response within a reasonable period (and in any event within one month of your request unless we tell you we are entitled to a longer period under applicable law). Please note, however, that these rights are not always absolute; some of them only apply in certain circumstances and even where a right applies, there may be some personal data that is exempt from such requests; for example, if we need to keep using personal data to comply with our own legal obligations or to establish, exercise or defend legal claims.  

If an exemption applies, we will tell you this when responding to your request.  We may request you provide us with information necessary to confirm your identity before responding to any request you make.  


If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways:

Data Controller details:

Email address: privacy@nulo.com

Postal addresses: Please see contact details below. 

Our EU office:

Nulo NL BV. 

Amstelplein 54, 26e etage,  

Amsterdam, 1096 BC, 

Netherlands 


Our UK office:

Nulo U.K. Ltd

Building 3, City West Business Park, 

Gelderd Road, 

Leeds, 

West Yorkshire, 

LS12 6LX, 

United Kingdom



You have the right to make a complaint at any time to a data protection authority. If you are in the UK, you can contact the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). If you are in the EU, you can find contact details for the relevant EU authority at https://www.edpb.europa.eu/about-edpb/about-edpb/members_en. We would, however, appreciate the chance to deal with your concerns before you approach a data protection authority, so please contact us in the first instance.


We keep our privacy policy under regular review. Older versions can be obtained by contacting us.

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, for example a new address or email address.


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 policy of every website you visit.