Privacy and Personal Data Protection Policy

This Policy explains what personal data INBULK processes, for what purposes and on what legal bases, to whom the data may be transferred, how long it is retained, and how a data subject may exercise their rights. Reviewing this Policy does not constitute general consent to all types of processing: consent is requested separately only where it is the necessary legal basis.

1. General provisions and scope

1.1. This Privacy and Personal Data Protection Policy (the “Policy”) applies to the processing of personal data when visiting the inbulk.com website, using the app.inbulk.com web application, creating and maintaining an Account, undergoing identification and verification, and using the trading, service, logistics, documentary, communication, analytical and other actually available functions of the INBULK.COM Platform.

1.2. The Policy applies to website visitors, Signatories, directors, beneficial owners, employees and representatives of User-companies, drivers, contact persons of counterparties and Service Providers, candidates for cooperation, recipients of notifications and other individuals whose personal data is lawfully processed through the Platform.

1.3. The Platform is intended for B2B interaction. It is not intended for use by children or by individuals for private consumer purposes.

1.4. Processing is carried out in accordance with the data protection law applicable to the relevant Platform Operator and to the relevant processing: the national data protection law of the country in which that Platform Operator is registered (it is stated in the Country Addendum that names the Platform Operator), Regulation (EU) 2016/679 (GDPR) where its territorial scope is met, the UK GDPR in the relevant part, and other applicable data protection requirements.

2. Owner / controller of personal data

2.1. The Platform is operated by several legal entities of the INBULK Group, each within the rights granted by the Platform rightsholder. The Platform Operator that is the owner (controller) of personal data in respect of the processing operations whose purposes and essential means it determines is determined as follows:

• for a User-company and the individuals who act on its behalf or are added to its Account, the Platform Operator is the INBULK Group entity named by the Country Addendum applicable to the User-company’s country of registration and recorded in its Statement of Accession;
• for a website visitor, a person completing a contact form or another person who is not connected with a User-company, the Platform Operator is the INBULK Group entity named on the Platform Operators page for the country from which that person interacts with the Platform or, where that country cannot be determined, the entity named for all other countries.

The current list of the Platform Operators, with their names, registration details, registered offices and contact details, is published on the Platform Operators page: https://help.inbulk.com/en/operators . In this Policy, “INBULK” means the Platform Operator that is the controller in respect of the relevant processing.

2.2. INBULK acts as controller, in particular, for the registration and administration of Accounts, verification of persons and companies, access management, security, maintenance of system logs, performance of its own legal obligations, user support, operation of the website, analytics and communications.

2.3. Where a User-company uploads or transfers through the Platform the personal data of its employees, representatives, drivers, clients, suppliers or other persons and independently determines the purposes of such processing, that User-company is a separate owner/controller of such data. INBULK processes such data in order to provide the functionality of the Platform and may at the same time act as an independent controller in respect of security, compliance, evidencing of operations, compliance with legal requirements and protection of rights.

2.4. The INBULK Group entities may provide each other with shared functions, in particular technical support, information security, compliance, operational coordination and document management, on the basis of intra-group arrangements that set out the permitted purposes, confidentiality and security of the data. This does not change who the controller is under clause 2.1. A data subject may send a request to any of the contacts stated in Section 22; where necessary, it is forwarded to the responsible Platform Operator.

3. Terms used in the Policy

• “Platform” — the INBULK.COM software and technical complex, including the website, the web application, Accounts, software modules, databases, integrations, APIs and other actually available digital services.
• “INBULK Group” — the Platform Operators and other legal entities under common control with them that participate in operating the Platform.
• “User-company” — a legal entity, individual entrepreneur or other business entity on whose behalf individuals act on the Platform.
• “Authorised user” — an identified individual, in particular a director, Signatory, manager, trader, logistician, accountant, dispatcher, driver or other employee or representative added to the Account.
• “Account” — the digital environment of a User-company in which the profile, employees, roles, access rights, documents, operations, messages, settings and system records are stored.
• “Data subject” — an individual to whom the personal data relates.
• “Personal data” — any information about an identified individual or an individual who can be identified directly or indirectly.
• “Processing” — any operation with personal data, including collection, recording, organisation, use, alignment, transfer, storage, restriction, erasure or destruction.
• “KYC/KYB check” — verification of an individual, representative, company, beneficial owners, documents, authority, sanctions and other risks.
• “Third-party provider” — an independent person that supplies INBULK with technology, data or services, in particular hosting, communications, verification, electronic signature, registry, payment, insurance, logistics or analytical services.
• “GPS data” — data on the location and movement of a vehicle or a driver’s device that may be transmitted during an active Trip. Other capitalised terms not defined in this Policy have the meanings established by the Accession Agreement and the Platform Terms of Use, where this is necessary to understand the context of data processing.

4. Categories of data subjects

• Website visitors and persons completing the “Book a demo”, “Join network” or other contact forms;
• Signatories, directors, founders, beneficial owners and other persons whose data is used for registration, verification and execution of documents;
• Authorised users added by a company to the Account;
• Employees, representatives, contact persons, drivers, dispatchers, carriers and other participants in trading, service and logistics operations;
• Contact persons of counterparties, Service Providers, partners and Third-party providers;
• Persons who contact support, submit claims, data requests or other enquiries.

5. What personal data we process

5.1. Registration and contact data. First name, surname, patronymic where applicable, position, company, business email address, telephone number, country, language, correspondence address, contact settings.

• Role and authority data. Position, technical role, access rights, legal authority, limits, approvals, grounds of representation, powers of attorney, decisions of management bodies, history of granting and revoking access.
• KYC/KYB and compliance data. Passport and other identification data, date of birth, citizenship, address, data of the Signatory, directors and beneficiaries, constituent and registration documents, tax numbers, results of checks against registries, sanctions, PEP, reputational and fraud risks.
• Identification and electronic signature data. Certificate identifiers, information about the signatory, date and time of signing, signature validation result, electronic time stamps and system identifiers. INBULK does not request and does not store private keys of electronic signatures.
• Account and security data. Login, password hash, one-time codes, multi-factor authentication data, IP address, device, browser, sessions, login history, action logs, access attempts, security settings.
• Trading and service operation data. Orders, Bids, Business, proposals, negotiations, Service Orders, operational statuses, data on counterparties, goods, routes, places and deadlines, prices, documents, instructions and the persons who performed the relevant actions.
• Communications and content. Chat messages, comments, emails, records of enquiries, attached files, call recordings — where recording is enabled and the person has been duly notified — as well as communication metadata.
• Logistics and driver data. Driver’s name and contacts, driving licence details or other documents to the extent necessary, information about the vehicle and trailer, route, addresses, arrival time, operational statuses, photos and Trip documents.
• GPS and telematics data. Current location, coordinates, route, speed or direction of movement, signal transmission time, data source and estimated time of arrival — where the relevant functionality is active.
• Consignment notes, e-consignment notes and other documents. Details of the consignor, consignee, carrier, driver, vehicle, cargo, weight, route, signatures, photos or scans of paper documents, electronic versions and change history.
• Financial and payment data. IBAN, bank name, Payer and recipient, accounts, amounts, currency, payment purpose, statuses and confirmations from the bank or payment provider. Full payment card details, where used, are processed by the relevant payment provider and not by INBULK, unless expressly stated otherwise.
• Website technical data. IP address, cookies, device and browser identifiers, referrer, pages and events, approximate location by IP, language, operating system, date and time of the visit.
• Marketing data. Marketing consent or opt-out, communication channels, interaction with emails and campaigns, professional interests and selected language.

5.2. INBULK does not ask for special categories of personal data unless this is necessary for a specific lawful purpose. Data on health, religious or political beliefs, sex life, genetic data or other excessive information should not be uploaded to ordinary profiles, chats and documents.

5.3. Where an identification function involves a photograph, video, selfie or automated comparison of a face with a document, a separate interface informs, before such a check begins, of the relevant provider, the data involved, the purpose and the legal basis. Biometric templates are processed only where there is a proper legal basis and are not used for other incompatible purposes.

6. Sources of data

• directly from the data subject during registration, signing, an enquiry, completion of a form or use of the Platform;
• from the User-company that invites an employee, representative or driver, assigns a role and transfers the data necessary for an operation;
• from counterparties, Service Providers, carriers, freight forwarders, terminals, banks, insurers and other participants in the relevant operation;
• from official state, corporate, sanctions, judicial, licensing and other lawfully accessible registries and sources;
• from providers of identification, electronic signature, KYC/KYB, sanctions screening, payments, GPS/telematics, email/SMS and other integrated services;
• automatically from the device, browser, server logs, cookies and other technologies during use of the Platform.

7. Purposes and legal bases of processing

7.1. INBULK does not rely on a single general consent for all processes. Depending on the specific operation, performance of a contract or steps prior to entering into it, a legal obligation, legitimate interest, consent or another basis provided by law applies.

• Registration, Account, authentication and access. Legal basis: Performance of the Agreement or steps prior to entering into it; legitimate interest in providing a B2B service and managing access.
• Adding employees, representatives and managing roles. Legal basis: Performance of the Agreement with the User-company; legitimate interest of the company and INBULK in organising corporate access. For an employee who is not a party to the Agreement, the basis “performance of a contract with the data subject” does not apply automatically.
• KYC/KYB, verification of authority, sanctions, PEP, fraud and risks. Legal basis: Legal obligation — where it is imposed on the relevant participant; steps prior to entering into a contract; legitimate interest in security, compliance and fraud prevention.
• Electronic signature, recording of actions, operations and evidence. Legal basis: Performance of contracts; legal obligation; legitimate interest in confirming the expression of will, protecting rights and resolving disputes.
• Trading, Auctions, Business, Service Requests and Service Orders. Legal basis: Performance of the Agreement and of the specific operation; legitimate interests of the participants in conducting B2B interaction.
• Logistics, GPS, SMS, Trip, consignment notes and e-consignment notes. Legal basis: Performance of a transport or service Order; legitimate interest in coordination, safety, monitoring of deadlines and confirmation of performance; legal obligation in respect of transport documents where applicable.
• Payments, invoices, accounting and tax records. Legal basis: Performance of a contract; compliance with legal obligations; legitimate interest in financial control and protection against fraud.
• Support, claims and disputes. Legal basis: Performance of a contract; legitimate interest in support, protection of rights and evidencing; legal obligation.
• Security, logs, backups, prevention of abuse. Legal basis: Legitimate interest in protecting the Platform, users and data; legal obligations in the field of security.
• Necessary cookies. Legal basis: Legitimate interest and/or the necessity of providing an expressly requested digital function.
• Analytical, functional and marketing cookies. Legal basis: Prior consent, where required by applicable law.
• Marketing communications. Legal basis: Prior consent or another basis expressly permitted by law, with a mandatory opt-out option.
• Disclosure to public authorities. Legal basis: Compliance with a legal obligation or protection of vital interests in exceptional cases.

7.2. Where processing is based on legitimate interest, INBULK assesses the necessity of the processing, the expectations of the data subject and the possible impact on their rights. The data subject has the right to object to such processing in accordance with Section 18.

7.3. Where processing is based on consent, the consent must be freely given, specific, informed and unambiguous. It may be withdrawn without affecting the lawfulness of processing carried out before the withdrawal.

8. Mandatory and optional data

8.1. Mandatory fields are marked in the interface. Without the data required for identification, verification, security, granting access or performing a specific operation, INBULK may be unable to create an Account, complete verification, provide the relevant function or perform a Service Order.

8.2. Optional data is provided voluntarily. Refusal of marketing, optional cookies or a consent-based function does not deprive the user of access to the basic functions for which such consent is not required.

9. Data of employees, representatives, drivers and other third parties

9.1. A User-company that adds or invites an employee, representative or driver must, before transferring the data:

• have a lawful basis for transferring and using the data;
• provide the person with information about the processing, including a link to this Policy;
• transfer only the data necessary for the role, access or specific operation;
• keep the data up to date and revoke access promptly when authority ends;
• not use the Platform for covert or excessive monitoring of employees.

9.2. The Platform may send the invited person an email or SMS with a link to create a profile, confirm contacts and review the Policy. Until the necessary identification is completed, access may be limited.

9.3. Where a User-company uploads documents or contact details of other persons, it warrants that such data has been obtained lawfully and is not excessive. This does not relieve INBULK of its own obligation to comply with the law in processes where INBULK determines the purposes and means of processing.

10. Visibility of data on the Platform and transfer to other Users

10.1. Part of the professional information may be available to other Users for finding a counterparty, negotiations, conducting an Auction, forming a Business, Service Request, Service Order or performing a Trip. The scope of visibility depends on the role, module, access settings and the person’s participation in the relevant operation.

10.2. Document data, KYC/KYB, bank details, GPS data, consignment notes, messages and other restricted materials are made available only to persons who need them for verification, the relevant operation, execution of a document or exercise of a lawful function.

10.3. Professional contact details that a User makes available to other participants may be used by them as separate controllers. INBULK does not permit the use of such data for spam, mass scraping, sale of databases or incompatible marketing.

10.4. A User must not place documents, personal telephone numbers, passport, bank or other data in open fields unless the relevant module is intended for their secure transfer.

11. Recipients and third-party providers

• INBULK Group entities and units. Other Platform Operators and INBULK Group entities — technical support, compliance, operational coordination, document management and other shared functions — only where there is a lawful basis and the necessary access (clause 2.4).
• Other Users and participants in an operation. Counterparties, Service Providers, carriers, freight forwarders, terminals, elevators, laboratories, surveyors, insurers, banks and other persons within a specific Business, Service Order or Trip.
• KYC/KYB, electronic identification and signature. Providers of document and identity verification, electronic signature, sanctions and PEP screening, official and commercial registries.
• Hosting, cloud and information security. Providers of servers, databases, backup, monitoring, logging, attack protection and technical support.
• Email, SMS and communications. Providers of email, SMS, messengers, telephony and service notifications.
• Payments and financial services. Banks, payment providers, insurance companies, providers of financial security and accounting services.
• Logistics and telematics. Carriers, GPS/telematics providers, mapping services and persons who create or sign consignment notes / e-consignment notes.
• Analytics and embedded content. Google Analytics 4, Microsoft Clarity, as well as YouTube and TradingView when the relevant embedded content is loaded — subject to cookie settings and consent where required.
• Professional advisers. Lawyers, auditors, accountants, consultants, insurers and experts on terms of confidentiality.
• Public authorities and courts. In cases provided by law, on the basis of a proper request or to protect rights.
• Corporate transactions. A potential buyer, investor or successor in the event of reorganisation, raising investment, sale of assets or the business — with appropriate confidentiality safeguards.

11.2. Third-party providers receive only the data reasonably necessary for the relevant function. Where a provider processes data on behalf of INBULK, the relationship is documented with terms on confidentiality, security, permitted purposes and deletion or return of the data.

11.3. Certain recipients, in particular banks, insurers, independent KYC providers, counterparties or public authorities, may act as independent controllers and process the data under their own policies and legal obligations.

12. International data transfers

12.1. Due to the international nature of the Platform, personal data may be processed in the countries in which the Platform Operators are registered, in the European Economic Area, the United Kingdom, the United States of America and other countries where INBULK Group entities, providers, users or participants in a specific operation are located.

12.2. Where a transfer is subject to restrictions under the GDPR, the UK GDPR or the data protection law of the country of the relevant Platform Operator, INBULK applies an appropriate mechanism: an adequacy decision, the European Commission’s standard contractual clauses, the relevant UK mechanism, binding corporate rules, a mechanism provided by the law of the Platform Operator’s country or a derogation permitted by law, and, where necessary, supplementary technical and organisational measures.

12.3. Where a User independently selects a foreign counterparty or Service Provider and sends data to them within an operation, that User must also assess its own role and comply with the applicable requirements for international transfers.

13. GPS data, SMS messages, consignment notes and e-consignment notes

13.1. GPS and telematics

13.1.1. GPS data may be collected from the driver’s device, the vehicle or an integrated telematics system only during an active Trip or another expressly defined operational period.

13.1.2. GPS data is used to display location, route, deviations and estimated time of arrival, to coordinate loading/unloading, for safety, support and the handling of operational discrepancies.

13.1.3. Access to GPS data is granted only to authorised participants in the Trip and to employees who need such access. The Platform must not use GPS for continuous tracking of a person outside an active Trip.

13.1.4. The User-company or Service Provider that assigns a driver ensures the lawful basis and proper information of the driver. Where consent is required under applicable law, it is requested separately; in employment relationships consent is not used formally where it cannot be freely given.

13.2. SMS and service messages

13.2.1. The Platform may send to a confirmed telephone number one-time codes, notifications about invitations, security, a Trip, a Service Order, a time-limited special price offer, documents or another operational event.

13.2.2. An SMS may contain a secure link. Information in plain text is limited to the minimum necessary. Service messages are not marketing and may be sent without marketing consent where they are necessary for an expressly requested function or for security.

13.3. Consignment notes and e-consignment notes

13.3.1. For the creation, verification, signing and storage of consignment notes / e-consignment notes, data of the consignor, consignee, carrier, driver, vehicle, cargo, route, weight, responsible persons, signatures and document history is processed.

13.3.2. Consignment notes, photos or scans of a paper consignment note, electronic versions and statuses are available to the participants in the relevant Service Order or Trip and may be transferred to public authorities, banks, insurers and other persons where this is necessary to perform the operation or comply with the law.

13.3.3. When photographing a consignment note, the user must avoid capturing third parties and documents unrelated to the operation.

14. Cookies, analytics and embedded services

14.1. The Platform uses cookies, local storage, pixels, logs and similar technologies. They may be:

• necessary — for login, security, session persistence, routing, language and cookie settings;
• functional — for remembering selected parameters and personalising the interface;
• analytical — for usage statistics, diagnostics and service improvement;
• marketing — for campaign measurement and personalisation of marketing communications, where such technologies are actually used;
• related to embedded content — for example, YouTube videos or TradingView market widgets.

14.2. Google Analytics 4 may receive technical identifiers, events, device information and approximate location. Microsoft Clarity may generate heat maps and recordings of page interaction. Fields that may contain passwords, payment or identification documents must be masked or excluded from the analytical record.

14.3. Necessary cookies are set without separate consent to the extent permitted by law. Other categories are activated after prior consent, where such consent is required. A user may change their choice in the cookie settings or in the browser. Withdrawal of consent does not affect the lawfulness of prior processing.

14.4. The retention periods and the specific list of cookies are shown in the banner or the cookie settings centre and may be updated as the actually connected services change.

15. Automated processing, profiling and AI features

15.1. The Platform may automatically check the format of documents and details, match data against registries, generate sanctions or risk indicators, detect suspicious activity, calculate a Match Score, estimated time of arrival or other analytical indicators.

15.2. Such results are auxiliary. INBULK does not take a decision producing legal or similarly significant effects for an individual solely on the basis of automated processing, unless this is expressly notified before such a process begins and the right to human intervention, explanation and challenge is ensured.

15.3. Where a User activates an AI assistant or another function that requires sending a request to an external technology provider, the interface or separate terms inform of the relevant processing. A User must not enter excessive passport, banking or special category data or trade secrets into an AI function unless this is an expressly necessary and protected scenario.

16. Retention periods

16.1. Data is retained only for the period necessary for the relevant purpose, performance of a contract, requirements of accounting, tax, transport, sanctions and other legislation, and the protection of rights. Where a longer period is established by law for a specific category, that period applies.

• Contact forms and demo requests. Retention period: Up to 24 months after the last substantive interaction, if no contractual relationship has arisen.
• Incomplete registration or draft verification. Retention period: Up to 12 months after the last activity, unless longer retention is required for security or evidencing.
• Account, profile and access rights. Retention period: For the duration of the relationship and up to 3 years after closure of the Account; certain logs and documents may be retained longer.
• Agreement, Business, Service Orders, invoices, acts and system confirmations. Retention period: Not less than the period established by applicable accounting, tax and contract law; as a rule, up to 5 years after completion of the relevant operation or relationship, and in the event of a dispute — until its final resolution.
• KYC/KYB and compliance files. Retention period: For the duration of the relationship and up to 5 years after its end, where such a period is justified by law, sanctions or risk control; unnecessary copies are deleted earlier.
• Consignment notes, e-consignment notes and logistics documents. Retention period: For the periods established by transport, accounting and tax law; as a rule, up to 5 years after completion of the Trip or operation.
• GPS data. Retention period: During an active Trip and up to 12 months after its completion. In the event of a claim, insurance event, investigation or dispute, the relevant fragment may be retained until the case is closed.
• SMS/email delivery logs and one-time codes. Retention period: Logs — up to 12 months; one-time codes — only until expiry and for the technically necessary security period.
• Chats, enquiries and support. Retention period: Up to 3 years after closure of the enquiry, or longer if the materials relate to an operation or dispute.
• Security and access logs. Retention period: Up to 24 months, unless a longer period is required for incident investigation or by law.
• Marketing consent/opt-out. Retention period: Until withdrawal; a minimal record of consent or opt-out may be retained for up to 3 years to demonstrate compliance.
• Cookies and analytics. Retention period: In accordance with the periods stated in the cookie settings centre and the actual settings of the relevant service.

16.2. After the period ends, data is deleted, anonymised or isolated from ordinary use. Backups are purged during the scheduled overwrite cycle, unless their further retention is required for security or by law.

17. Security of personal data and incidents

17.1. INBULK applies technical and organisational measures proportionate to the risks, in particular role-based access segregation, multi-factor authentication, encryption of data in transit, logging, backup, monitoring, provider vetting, response procedures and staff training.

17.2. Access is granted on a need-to-know basis. Authorised users must protect their password, one-time codes, devices and electronic signature keys, must not share them with others and must report suspicious access immediately.

17.3. No system can guarantee absolute security. In the event of a security breach, INBULK assesses the risk, takes measures to limit the consequences and notifies the supervisory authority and/or the data subject within the time limits and in the cases provided by applicable law. Where the GDPR applies, notification of the supervisory authority is made, where feasible, no later than 72 hours after the breach is discovered, where such notification is mandatory.

18. Rights of data subjects

18.1. Depending on the applicable law, a data subject has the right:

• to know the sources, location, purpose and legal bases of the processing;
• to obtain confirmation of the processing and access to their personal data;
• to require rectification of inaccurate data or completion of incomplete data;
• to require erasure of the data where there is no lawful basis for further processing;
• to require restriction of processing in the cases provided by law;
• to receive the data in a structured, commonly used and machine-readable format and transmit it to another controller, where the right to portability applies;
• to object to processing based on legitimate interest, and to object unconditionally to direct marketing;
• to withdraw consent at any time, where processing is based on consent;
• not to be subject to a decision based solely on automated processing producing legal or similarly significant effects, except in the cases provided by law;
• to lodge a complaint with the supervisory authority competent for the relevant Platform Operator (in particular, the Ukrainian Parliament Commissioner for Human Rights for a Platform Operator registered in Ukraine, or the UAE Data Office for a Platform Operator registered in the United Arab Emirates), a competent EU/EEA data protection authority, the ICO in the United Kingdom or another competent authority, and to apply to a court.

18.2. A request may be sent to [email protected] or through an available Account tool. The request should state the name, contact for a reply, the User-company where applicable, the substance of the request and the data necessary to locate the record.

18.3. To protect the data, INBULK may request confirmation of identity and of a representative’s authority. A request is handled without undue delay; where the GDPR applies — as a rule, within one month, with the possibility of an extension by up to two further months taking into account the complexity and number of requests, of which the data subject is informed.

18.4. The right to erasure is not absolute. Data may be retained where it is necessary to comply with a legal obligation, for accounting or transport records, protection of rights, handling of a dispute, security or other lawful purposes.

18.5. Where the data has been uploaded by a User-company and INBULK acts primarily on its instructions, INBULK may forward the request to the relevant User-company or cooperate with it in order to respond properly.

19. Service and marketing communications

19.1. Service messages concern security, login, invitations, verification, operations, Service Orders, Trips, documents, payments, a time-limited special price, changes to legal documents and technical operation of the Platform. Opting out of all such messages may not be possible while the Account is active, but a User may manage optional channels and notification types.

19.2. Marketing communications are sent separately on the basis of prior consent or another basis permitted by law. They may be opted out of via the link in the message, the Account settings or by contacting [email protected].

19.3. Opting out of marketing does not stop the sending of necessary service and security messages.

20. Data of minors

20.1. The Platform is not intended for persons under 18 years of age. If INBULK reasonably establishes that the data of a minor has been provided without a proper basis, such data will be deleted or the processing will be restricted, unless otherwise required by law.

21. Changes to the Policy and language versions

21.1. INBULK may update the Policy in connection with changes in legislation, functionality, data categories, providers or security procedures. The date of the edition is stated at the beginning of the document.

21.2. Users are informed of material changes affecting the rights of data subjects or introducing a new purpose of processing through the Account, email, a banner or another available channel before the changes take effect, where this is necessary.

21.3. Where consent is required for new processing, continued use of the Platform does not replace such consent; it is requested separately.

21.4. The Policy is drawn up in English and may be translated into other languages. Unless expressly provided otherwise for a specific localised version, the English edition prevails.

22. Contacts on data protection matters

Regarding the processing of personal data, the exercise of rights or reporting an incident, you may contact:

• the Platform Operator that is the controller under clause 2.1, at the registered office stated on the Platform Operators page: https://help.inbulk.com/en/operators ;
• email: [email protected] (common for all Platform Operators);
• through an available Account tool.

Please do not send a password, one-time code, private electronic signature key or a full copy of a document in your enquiry unless INBULK has separately requested it through a secure channel.

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