Privacy policy

This policy explains how Pulse Fulfilment Limited (“Pulse”, “we”) uses personal information in Pulse CRM, the system we use to manage our relationships with customers of our fulfilment services. We are the data controller for the information described here.

Who this covers

• People at businesses that enquire about, apply for or use our fulfilment services, including the directors and contacts named on an account opening form.
• Suppliers, couriers and other contacts we correspond with about a customer’s orders.
• Pulse Fulfilment staff who use the system.

What we collect

• Business details you give us: company name, registered and trading addresses, registration and VAT numbers, bank details, trade references and the contacts for accounts and warehouse matters.
• Director details: name, email address, telephone number, home address and date of appointment, as entered on the account opening form.
• Identity and address documents you upload, such as a passport copy and a bank statement or utility bill, which we are required to hold as a fulfilment house approved under HMRC’s Fulfilment House Due Diligence Scheme.
• Your electronic signature on our agreement, and the evidence that goes with it: the time, the IP address and browser used, and the one-time code sent to your email to confirm it was you.
• Emails between you and us, and the queries, orders and deliveries we handle for you.
• Notes our staff make about calls and meetings.

How we use it

• To assess and open your account, agree terms and set you up in our warehouse and accounting systems.
• To carry out the due diligence the law requires of us, including verifying your UK VAT number with HM Revenue & Customs. We send HMRC only the VAT number and keep their answer as evidence of the check.
• To provide our services, answer your queries, and manage orders, deliveries and invoices.
• To keep records that show we have met our legal obligations.

Our legal bases are: performing our contract with you or taking steps at your request before entering into it; complying with legal obligations, including the Fulfilment House Due Diligence Scheme and VAT and customs law; and our legitimate interest in running our business and preventing fraud.

Who we share it with

• HM Revenue & Customs, to verify VAT numbers, and where the law requires us to produce records.
• Our accounting system (Xero) and warehouse system (Mintsoft), which hold your business details, agreement documents and orders so we can invoice you and ship your goods.
• Couriers and suppliers, to the extent needed to resolve a query about your orders.
• Our hosting provider, Microsoft Azure, which stores the system and its data on our behalf.

We do not sell personal information or share it for marketing by others.

Where it is kept and how it is protected

Pulse CRM runs on Microsoft Azure. Data is encrypted in transit and at rest, mailbox and integration credentials are encrypted a second time by the system itself, and staff passwords are never stored. Access is by named staff account with a role that limits what each person can see and change, and security-relevant events are logged and reported to our administrators as they happen.

How long we keep it

Account opening records, identity documents, signed agreements and VAT verification evidence are kept for the life of your account and for six years after it closes, which is the period HMRC may ask us to produce them for. Enquiries that do not become an account are kept for up to two years. Deleted records sit in a recycle bin for 30 days before they are removed.

Your rights

You can ask for a copy of the personal information we hold about you, ask us to correct it, and in some circumstances ask us to delete it or limit how we use it. Where we rely on legitimate interests you may object. We may have to keep information the law requires us to keep even if you ask us to delete it, and we will tell you if so. You can also complain to the Information Commissioner’s Office at ico.org.uk.

Contact

Write to Pulse Fulfilment Limited, Unit 3-4 Ocean Park, Dock Road, Wallasey, CH41 1HW, or email us at the address on our website, marking your message for the attention of the data protection lead.