Policies

Website Privacy Policy Template (UK GDPR)

1. Who We Are

Cullum Detuners Investments Limited “Cullum Group” is a registered Holding Company within the United Kingdom. It acts as the nominated Data Protection Officer (DPO) for both the Holding company, and all its relevant subsidiaries. The DPO for Cullum Group is also its dedicated Data Controller.

Cullum Detuners Investments Limited – registered office at Adams Close, Heanor Gate Industrial Park, Heanor, DE75 7SW. Registered Number – 02794825.

Email – Compliance@cullum.co.uk

Phone - +44 (0)1773 717341

In addition, each dedicated subsidiary has its own Data Controller, with the relevant contact information below:

Cullum Detuners Limited - registered office at Adams Close, Heanor Gate Industrial Park, Heanor, DE75 7SW. Registered Number – 00549824.

Email – Compliance@cullum.co.uk

Phone - +44 (0)1773 717341

EMS Industries Limited - registered office at 57-58 Brick-Kiln Ln, Stoke-on-Trent, Newcastle ST5 7AS, United Kingdom. Registered Number – 03063438.

Email - Compliance@cullum.co.uk

Phone - +44(0) 1782 510051

 Jade Insulation Limited – registered office at Unit 15-17 Century Park Network Centre, Dearne Lane, Rotherham, South Yorkshire, England, S63 5DE. Registered Number – 07309210.

Email - Compliance@cullum.co.uk

Phone - +44(0) 1709 761170

Thermofuse Pipelines Limited – registered office at Brunel Park Industrial Estate, Harworth, Doncaster DN11 8RW. Registered Number – 03325359.

Email - Compliance@cullum.co.uk

Phone - +44(0) 1302 759400

AGS Noise Control Limited - registered office at Adams Close, Heanor Gate Industrial Park, Heanor, DE75 7SW. Registered Number – 04594070.

Email - Compliance@cullum.co.uk

Phone - +44(0) 1664 568728

2. Information We Collect

We may collect information you provide when contacting us, requesting a quotation or using our website. We may also collect technical information such as your IP address, browser type, pages visited and device information through cookies and analytics.

3. How We Use Your Information

• Respond to enquiries
• Provide our products and services
• Improve our website
• Measure marketing performance
• Meet legal obligations
• Protect our business
• Share information between subsidiaries and holding company, to enable the points above

4. Lawful Bases

We process personal information under one or more of the following lawful bases: consent, contract, legitimate interests and legal obligation.

5. Google Analytics

We use Google Analytics 4 to understand how visitors use our website. Analytics cookies are only used where required following your consent.

6. Google Ads

We may use Google Ads conversion tracking and remarketing to measure advertising performance and display relevant adverts. Marketing cookies are only used where required following your consent. Please refer to Para 16 – “matrix of tools” for further information.

7. Snitcher

We may use Snitcher to identify businesses visiting our website. Snitcher does not identify individual visitors. It analyses business IP addresses and website usage to help us understand interest in our products and services. Snitcher may use the SNID cookie and processes data in accordance with UK GDPR. Please refer to Para 16 – “matrix of tools” for further information.

8. Cookies

Our website uses essential, analytics and marketing cookies. Visitors can manage their cookie preferences using our cookie banner.

9. Sharing Information

We may share information with trusted suppliers who help us operate our website and business. We never sell personal information.

10. International Transfers

Some service providers, including Google, may process information outside the UK. Where this happens, appropriate safeguards are used.

11. Retention

We only retain personal information for as long as necessary to fulfil the purposes for which it was collected or to meet legal obligations.

12. Security

We use appropriate technical and organisational measures to protect personal information.

13. Your Rights

You have rights including access, rectification, erasure, restriction, objection, data portability and, where applicable, withdrawal of consent.

14. Complaints

If you have any concerns about how we use your information, please contact us. You also have the right to complain to the Information Commissioner's Office (ICO).

15. Changes

We may update this Privacy Policy from time to time.

16.Matrix of Tools

Last Updated: Jul 2026

GENERAL ANTI-CORRUPTION AND BRIBERY OBLIGATIONS

The Business is committed to conducting its business around the world with the highest degree of integrity and in full compliance with all applicable laws. This commitment includes a zero-tolerance approach towards all forms of Bribery and Corruption and the Business is committed to maintaining in force appropriate checks and procedures to ensure that all persons working for or dealing with the Business respect and comply with this Code of Conduct.

The Business, its directors, employees, licensees, officers, consultants joint venture partners and agents must not engage in any form of Bribery or other Corrupt Activities anywhere in the world nor will the Business request that any third party does so on its behalf. This prohibition includes, but is not limited to, the payment or receipt of Bribes by or on the behalf of the Business and/or encouraging, asking or arranging for anyone else to make or receive Bribes for the Business.

The Code of Conduct has been formally approved by the Board of Directors of the Business and any breach will be considered by the Business to be a serious offence. 

The detail Code of Conduct is available to all employees as part of the Company Handbook, and to our customer base upon written request.

Corporate Criminal Offence

Cullum enacts policies and procedures to ensure compliance with the Corporate Criminal Offence of the Failure to Prevent the Criminal Facilitation of Tax Evasion (“CCO”).

To support compliance, the business looks to:

• Obtaining assurances and warranties from suppliers that they have reasonable prevention procedures in place – via agreement within our defined commercial terms
• Providing training to our staff and being clear about the consequences if a person associated with Cullum facilitates tax evasion.
• Providing a pathway for reporting wrongdoing and providing protection for whistle-blowers.
• Operating procedures which reduce the opportunity for employees to facilitate tax evasion, and regularly reviewing these for effectiveness and improvement.
• Adopting a zero-tolerance attitude towards the criminal facilitation of tax evasion.
• Where internal investigations indicate a person associated with Cullum has facilitated tax evasion, they will be reported to the authorities and the Cullum Board of Directors will fully support prosecution by such legal authorities.
• Not to use the services of others who are unable to provide assurance that they have reasonable prevention procedures in place.

We look to apply this across all our UK businesses, and associated stakeholder groups.

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Cullum is committed to delivery high quality products, in a safe manner, in line with the fundamental principles of a Nuclear Safety Culture.
We believe that a Nuclear Safety Culture derives from the core values and behaviours resulting from a collective commitment by Business Leadership and all staff members. We strive to demonstrate this every day, and to emphasise the importance of Safety within a Nuclear environment during all stages of work.

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