Privacy Policy
Last updated: January 1, 2026
This Privacy Policy explains how Hague Global Limited, trading as Pulp ("Company", "We", "Us" or "Our"), collects, uses, stores and shares Personal Data when You visit or purchase products through Our Website, https://www.pulp-incontinence.com.
It also explains Your privacy rights and how applicable data protection laws protect You.
We process Personal Data in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and other applicable UK privacy legislation. Where the EU General Data Protection Regulation (EU GDPR) applies to particular processing activities, We will also comply with its requirements.
Interpretation & Definitions
Interpretation
Words with initial capital letters have the meanings defined below, whether used in singular or plural form.
Definitions
For the purposes of this Privacy Policy:
- Account means an account created for You to access Our Website or certain features.
- Company, We, Us or Our means Hague Global Limited, a private limited company registered in England and Wales under company number 10439216. Registered Office: C/O 6th Floor St Vincent House, 1 Cutler Street, Ipswich, Suffolk, IP1 1UQ, United Kingdom.
- Cookies means small files stored on Your Device that support Website functionality, analytics and other purposes.
- Data Controller means the organisation that determines why and how Personal Data is processed. Hague Global Limited is the Data Controller for the processing described in this Privacy Policy, except where otherwise indicated.
- Device means any computer, mobile telephone, tablet or other device capable of accessing the Website.
- Personal Data means information relating to an identified or identifiable individual.
- Service Provider means a third party that processes Personal Data on Our behalf or provides services supporting Our business.
- Usage Data means information collected automatically through the use of Our Website.
- Website means Pulp, accessible at https://www.pulp-incontinence.com.
- You or Your means the individual accessing or using Our Website.
GDPR & UK GDPR Compliance
We process Personal Data lawfully, fairly and transparently. We collect Personal Data for specified purposes, limit its use to what is necessary, and take appropriate steps to keep it accurate and secure.
As Our Website serves customers in the United Kingdom, the UK GDPR and Data Protection Act 2018 are Our principal data protection framework. EU GDPR requirements may also apply in certain circumstances.
Supervisory Authority
If You have concerns about how We handle Your Personal Data, please contact Us first so that We can investigate.
You also have the right to complain to the Information Commissioner's Office (ICO):
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
United Kingdom
Website: https://ico.org.uk
Telephone: 0303 123 1113
Collecting & Using Your Personal Data
Types of Data Collected
Personal Data
Depending on how You interact with Our Website, We may collect:
- Your first name and last name.
- Your email address and telephone number.
- Your billing and delivery addresses.
- Your order history, purchased products and transaction details.
- Your customer account information.
- Information You provide when contacting customer support.
- Your marketing preferences and consent records.
- Information about Your interactions with Our emails and marketing communications.
- Technical information and Usage Data relating to Your Website visits.
We may receive payment confirmation, transaction identifiers and limited payment-related information from Our payment providers. Full payment card details are handled by the relevant payment processing services.
Information Relating To Product Purchases
Pulp sells incontinence and related personal care products. Information about products You purchase, or information You voluntarily disclose when contacting Us, may in some circumstances reveal or suggest information about Your health.
We do not assume that purchasing a particular product means You have a particular medical condition.
Where information constitutes special category health data under applicable law, We will process it only where an appropriate lawful basis and additional legal condition apply. We do not intentionally collect medical diagnoses or detailed health records through ordinary Website purchases.
Usage Data
Usage Data may be collected automatically when You access Our Website.
This may include:
- Internet Protocol (IP) address.
- Browser type and version.
- Device type and operating system.
- Pages visited and time spent on those pages.
- Referring websites and navigation activity.
- Device identifiers and diagnostic information.
- Interactions with Website content and advertisements.
Some Usage Data may constitute Personal Data where it identifies or can be linked to an individual.
Tracking Technologies & Cookies
We use Cookies and similar technologies, including pixels, tags and scripts, to operate Our Website, understand visitor behaviour, measure advertising performance and support marketing activities.
These technologies may be provided by Us or by third parties, including Shopify, Google Analytics, Google Ads, Meta, Microsoft Advertising and Klaviyo.
Some Cookies are necessary for the operation of Our Website. Others support functionality, analytics or advertising.
Where legally required, We obtain Your consent before using non-essential Cookies or similar tracking technologies.
You can manage or withdraw Your cookie consent through the cookie consent controls available on Our Website.
For more information, please see Our separate Cookie Policy.
Use Of Your Personal Data
We may process Personal Data for the following purposes:
- Providing Our Website and services: To operate and maintain Our Website, provide requested features and ensure its proper functioning.
- Processing orders: To accept payments, fulfil purchases, arrange deliveries, provide order updates and handle returns or refunds.
- Managing customer accounts: To create, administer and maintain customer accounts where available.
- Customer support: To respond to enquiries, complaints, product questions and other requests.
- Transactional communications: To send order confirmations, delivery notifications, refund updates and other necessary service communications.
- Email marketing: To send newsletters, product updates, promotional offers and other marketing communications where permitted by law.
- Website analytics: To understand how visitors use Our Website and improve its functionality and performance.
- Advertising and remarketing: To measure advertising campaigns, understand conversions and display relevant advertisements where permitted by law.
- Fraud prevention and security: To detect suspicious transactions, protect Our Website and prevent misuse.
- Legal and regulatory compliance: To meet tax, accounting, consumer protection and other legal obligations.
- Business administration: To maintain business records, resolve disputes and protect Our legitimate business interests.
- Business transfers: To evaluate or complete a restructuring, merger, acquisition or sale of all or part of Our business.
We will not use Personal Data for purposes incompatible with those described above unless permitted or required by law.
Legal Basis For Processing Personal Data
Under the UK GDPR, We must have a lawful basis for processing Personal Data.
The principal lawful bases We rely upon are:
- Processing orders, payments and deliveries: Performance of a contract.
- Managing customer accounts: Performance of a contract.
- Handling customer service enquiries: Performance of a contract or legitimate interests, depending on the enquiry.
- Maintaining accounting and tax records: Legal obligation.
- Preventing fraud and protecting Website security: Legitimate interests or legal obligation, as applicable.
- Operating essential Website functionality: Performance of a contract or legitimate interests, as applicable.
- Optional analytics Cookies and tracking: Consent, where required.
- Advertising Cookies, pixels and remarketing: Consent, where required.
- Email marketing: Consent or legitimate interests where the applicable UK marketing rules permit.
- Business administration and improvement: Legitimate interests.
Where We rely on legitimate interests, We consider the necessity of the processing and its impact on Your rights and freedoms.
Where We rely on consent, You may withdraw it at any time. Withdrawal does not affect processing lawfully carried out before consent was withdrawn.
For electronic direct marketing, We also comply with the Privacy and Electronic Communications Regulations (PECR), including applicable consent and existing-customer marketing rules.
Sharing Your Personal Data
We may share Personal Data with trusted third parties where necessary for the purposes described in this Privacy Policy.
These may include:
- E-commerce providers: Shopify and associated services supporting Our online store.
- Payment providers: Services that securely process payments and related transactions.
- Delivery and fulfilment providers: Warehousing, logistics and courier companies involved in fulfilling Your orders.
- Analytics providers: Services that help Us understand Website performance and visitor interactions.
- Advertising providers: Google, Meta and Microsoft, where relevant advertising and measurement services are used.
- Marketing providers: Klaviyo and other services used to manage customer communications.
- Professional advisers: Accountants, legal advisers and other professional service providers where necessary.
- Regulatory authorities: Government bodies, courts, law enforcement agencies or other authorities where disclosure is required or permitted by law.
- Business successors: Parties involved in a legitimate merger, acquisition, restructuring or transfer of business assets.
Where third parties act as processors on Our behalf, We require appropriate contractual protections in accordance with applicable data protection law.
Some providers may act as independent controllers for particular activities. Their processing may also be governed by their own privacy policies.
We do not sell customer Personal Data in the ordinary commercial sense of selling customer lists.
Retention Of Your Personal Data
We retain Personal Data only for as long as reasonably necessary for the purposes for which it was collected, including meeting legal, accounting, tax and regulatory obligations.
Our retention periods depend on the type of information and the reasons for processing it.
- Order and transaction records: Generally retained for up to six years after the relevant financial year or transaction, or longer where required by applicable law or an ongoing dispute.
- Customer account information: Retained while an account remains active and for a reasonable period afterwards where necessary for legal, security or administrative purposes.
- Customer service correspondence: Retained for as long as necessary to resolve enquiries, manage complaints and protect legal rights.
- Marketing information: Retained while You remain subscribed or until it is no longer necessary. We may retain limited suppression records to ensure that Your opt-out preferences continue to be respected.
- Analytics and technical information: Retained according to the settings and retention periods of the relevant systems, subject to applicable legal requirements.
- Consent records: Retained where necessary to demonstrate compliance with legal obligations.
We may retain information for longer where required by law, necessary to establish or defend legal claims, or otherwise permitted under applicable data protection legislation.
When Personal Data is no longer required, We will delete it, anonymise it or otherwise dispose of it securely.
International Transfers Of Personal Data
Some of Our Service Providers may process or store Personal Data outside the United Kingdom.
Where Personal Data is transferred internationally, We will take steps to ensure that transfers comply with applicable data protection legislation.
Depending on the destination and circumstances, these protections may include:
- UK adequacy regulations recognising appropriate protection in the destination country.
- The UK International Data Transfer Agreement or UK Addendum to approved contractual clauses.
- Other lawful transfer mechanisms or exceptions permitted by applicable legislation.
Where required, We will assess the protections available for the transferred information and implement additional safeguards where appropriate.
Using Our Website does not, by itself, constitute consent to international transfers.
Security Of Your Personal Data
We take appropriate technical and organisational measures to protect Personal Data against unauthorised access, accidental loss, alteration, disclosure or destruction.
These measures may include secure systems, access controls, encryption where appropriate and the use of reputable service providers.
However, no method of internet transmission or electronic storage can be guaranteed to be completely secure.
If We become aware of a Personal Data breach, We will investigate and take appropriate action, including notifying the ICO and affected individuals where legally required.
Detailed Information On The Processing Of Your Personal Data
E-commerce Platform: Shopify
Our Website operates using Shopify, which provides e-commerce infrastructure and services supporting online transactions, customer accounts, Website functionality and order management.
Shopify may process Personal Data in connection with these services.
Shopify Privacy Policy: https://www.shopify.com/legal/privacy
Analytics: Google Analytics
We may use Google Analytics to understand Website traffic, visitor interactions and Website performance.
Google Analytics may collect information about Your Device, browsing activity and interactions with Our Website through Cookies and similar technologies.
Where required, analytics tracking is subject to Your cookie consent choices.
Google Privacy Policy: https://policies.google.com/privacy
Email Marketing: Klaviyo
We use Klaviyo to support email marketing and customer communications.
Klaviyo may process contact information, marketing preferences, order-related information and interactions with Our emails or Website, depending on the features enabled.
You can unsubscribe from marketing emails using the unsubscribe link included in those communications or by contacting Us.
Klaviyo Privacy Policy: https://www.klaviyo.com/legal/privacy-policy
Payments
Payments made through Our Website are processed using payment services integrated with Shopify.
We do not directly store full payment card numbers or card security codes on Our own systems.
Payment providers may process payment information, transaction details and fraud prevention information in accordance with their applicable privacy notices and legal obligations.
Advertising & Remarketing
We use online advertising services to promote Our products, measure campaign effectiveness and, where permitted, display advertisements relevant to visitor interests.
These services may use Cookies, pixels, conversion tracking, pseudonymous identifiers and other technologies.
Where required by law, non-essential advertising and remarketing tracking will only operate with Your consent.
Google Ads
We use Google Ads for advertising, conversion measurement and remarketing.
Google may process information about interactions with Our Website and advertisements, subject to applicable consent choices and Google's privacy practices.
Google Privacy Policy: https://policies.google.com/privacy
Microsoft Advertising (Bing Ads)
We use Microsoft Advertising to manage advertising campaigns, measure conversions and support remarketing.
Microsoft Privacy Statement: https://privacy.microsoft.com/privacystatement
Meta (Facebook & Instagram)
We use Meta advertising services to advertise Our products and measure advertising performance across Facebook, Instagram and related services.
Meta technologies may process information about Website interactions, subject to applicable privacy and consent settings.
Meta Privacy Policy: https://www.facebook.com/privacy/policy/
Marketing Preferences
You can opt out of Our marketing emails at any time by using the unsubscribe link in an email or contacting Us at help@pulp-incontinence.com.
Opting out of marketing will not prevent Us from sending necessary transactional or service communications, such as order confirmations or delivery updates.
You can also manage non-essential tracking through Our Website's cookie consent controls.
Your Data Protection Rights
Under the UK GDPR, You may have the following rights, subject to applicable legal conditions and exceptions:
- Right of access: Request confirmation of whether We process Your Personal Data and obtain a copy of relevant information.
- Right to rectification: Request correction of inaccurate or incomplete Personal Data.
- Right to erasure: Request deletion of Personal Data where the legal requirements are met.
- Right to restrict processing: Request that We limit certain processing activities.
- Right to object: Object to processing based on legitimate interests and object at any time to processing for direct marketing.
- Right to data portability: Receive certain Personal Data in a structured, commonly used and machine-readable format, where applicable.
- Right to withdraw consent: Withdraw consent where processing relies on it.
- Rights relating to automated decision-making: Exercise applicable rights where decisions based solely on automated processing have legal or similarly significant effects.
These rights are not absolute. For example, We may need to retain transaction records to comply with accounting and tax obligations even after receiving an erasure request.
Exercising Your Rights
To exercise Your data protection rights, please contact Us at:
help@pulp-incontinence.com
We may ask for reasonable information to verify Your identity before responding.
We will normally respond within one month of receiving a valid request, subject to any lawful extension or other applicable requirements.
You will not normally be charged for exercising Your rights, although the law permits fees or refusal in certain limited circumstances.
If You are dissatisfied with Our response, You may complain to the Information Commissioner's Office.
Children's Privacy
Our Website is intended for adults purchasing products for themselves or others.
We do not knowingly seek to collect Personal Data directly from children under the age of 13.
If You believe a child has provided Personal Data to Us without appropriate authorisation, please contact Us so that We can review the circumstances and take appropriate action.
Where applicable, We will comply with additional legal requirements relating to the processing of children's Personal Data.
Links To Other Websites
Our Website may contain links to third-party websites or services that are not operated by Us.
We are not responsible for the privacy practices or content of those third-party websites.
We recommend reviewing the privacy policies of any external websites You visit.
Changes To This Privacy Policy
We may update this Privacy Policy periodically to reflect changes in Our business practices, service providers or legal obligations.
When We make changes, We will publish the updated Privacy Policy on Our Website and revise the "Last updated" date.
Where changes are material, and notification is required or appropriate, We may provide additional notice through Our Website or by email.
We recommend reviewing this Privacy Policy periodically.
Contact Us
If You have any questions about this Privacy Policy or how We process Your Personal Data, You can contact Us using the following details:
Email: help@pulp-incontinence.com
