1. Who we are?
Mule Management Limited (Mule Management) is a data protection compliance consultancy, specialising in helping small businesses implement, demonstrate accountability and compliance for data protection legislation – e.g. the Data Protection Act 2018 and the General Data Protection Regulation (GDPR). We also provide GDPR implementation and cyber awareness workshops and online training.
This privacy notice explains how we use any personal information we collect about you when you use our services and this website.
Mule Management is committed to ensuring your privacy is protected. Should we ask you to provide certain information by which you can be identified when using our services or this website, then you can be assured that it will only be used in accordance with this privacy notice.
For the purpose of the Data Protection Act 2018 and the General Data Protection Regulation (GDPR), the data controller is Mule Management Limited. Mule Management Limited is a registered Data Controller with the Information Commissioner’s Office (ICO) under registration number ZA273264.
Mule Management Limited is registered in England & Wales. Company Registration No. 05998200. Registered address at 164-166 High Road, Ilford, Essex, IG1 1LL. VAT Registration Number 894268866.
2. What information do we collect about you?
We collect, process and retain personal information about you only when you:
- submit your information to us using the “Contact Us” form
- directly contact us by phone
- enter into a contract with us to provide you with consultancy, training or project management services
- provide feedback
- register to attend a live workshop or online training
This information can include:
- phone number
- email address
- request(s) or requirement(s)
- client location
- visiting IP address
Unless a person voluntarily submits personal information to us (for example, by sending us an e-mail, completing a contract, or completing the contact form), we cannot personally identify an individual.
We use the information only for the purpose you provided to us.
It may include:
- responding to your enquiry/request
- providing you with the service(s) we’ve been contracted to deliver
3. How will we use the information about you?
We collect information about you to process your enquiry or manage the service we provide for you.
We will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it longer than is necessary.
This is what we do for the following:
- Prospects: We use your personal information to respond to any general enquiries you may have made to us via our contact us form, email, telephone or any other method of communication. We will use this information to follow-up your enquiry.
- Clients: We use your personal information so that we can deliver the service(s) you’ve contracted us to deliver for you. This may include delivering live training.
- Contractors & Associates: We use (or used) your personal information to process your payments for services provided, and to manage your service performance.
- Job Applicants: We use your personal information to assess your suitability for the role you have applied for and potentially shortlist you for the job role. All the information you provide us will only be used for progressing your job application, or to fulfil legal or regulatory requirements if necessary.
- Website Visitors: We use your information collected from the website to personalise your repeat visits to our website. Mule Management will not share your information for marketing purposes with any other company.
4. Our legal grounds for processing your information
We may rely on one or more of the following legal grounds to process your personal information:
- Contract: Article 6(1)(b) of the GDPR, which relates to the processing necessary in the performance of a contract or to take steps at your request, before entering a contract. We will use if you become a client, contractor or associate.
- Consent: Article 6(1)(a) of the GDPR, which relies on your freely-given consent at the time you provide your personal information to us. We will always make it clear what your information will be used for and provide a link or reference to our privacy notice and the ability to opt-out of communications or withdraw consent. We will use this when we ask your consent to use any testimonials for our marketing purposes.
- Legal Obligation: Article 6(1)(c) of the GDPR, which relates to processing necessary for compliance with a legal obligation to which we must comply with. For example, sharing contractor’s personal information with HMRC.
- Legitimate Interests: Article 6(1)(f) of the GDPR, which relates to our legitimate interests communicating with our clients, and prospects to introduce them to services, or market similar services that would be of interest and benefit to them.
5. How long is your personal information retained?
We have data retention policies and procedures designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of your personal information. Personal information that we process for any purpose or purposes will not be kept for longer than is necessary.
Generally, personal information at Mule Management is retained for a maximum period of 2 years unless required for specific legal or regulatory purposes. For example, client information will be kept for 6 years after the client agreement has expired.
For a copy of our data retention schedule email our Data Compliance Manager at email@example.com
6. Where we store your information?
We store personal information in digital format on secure cloud servers and systems hosted in the European Union (EU) and the United States (US). Where data is stored on servers located in the US we rely on the Privacy Shield Framework and/or model clauses to transfer this information. Access to personal information is highly restricted internally for approved business purposes only.
Any personal information collected in paper form (e.g. contracts, feedback forms, registration sheets, etc.) are securely filed at our office location in the UK.
7. Keeping personal information secure and disclosing your information
Transmitting information over the internet is generally not completely secure. We have procedures and security in place to keep personal information secure once it is in our systems.
We will not share personal information with any 3rd party organisation for market research, marketing, or commercial purposes without specific consent from you.
We use data processors who are third parties who provide elements of services for us. We have contracts in place with our data processors. This means they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from us. They will hold it securely and retain it for the period we instruct.
8. Your Data Subject Rights
You can exercise your data subject rights and utilise our Data Subject Access Request (DSAR) procedure.
Your rights are as follows:
- You have the right to ask for a copy of your personal information.
- You have the right to have your personal information rectified. If you find your personal information we hold is inaccurate or incomplete, you can request to see this personal information, rectified.
- You have the right to have your personal information deleted. Though it should be noted this is not an absolute right.
- You have the right to demand the restriction of the data processing of your personal information. This may include, but not limited to the use of data for direct marketing purposes.
- You have the right to receive your personal information in a structured, commonly used and machine-readable format (e.g. PDF or CSV) and to request the transmittance of your data to another controller;
- You have the right to object to the data processing. This is not an absolute right and only applies under certain circumstances;
- You have the right to withdraw a given consent at any time to stop data processing that is based on your consent.
For more information on your induvial rights under the GDPR click here.
Please make any of the requests outlined above by contacting our Data Compliance Manager by email to: firstname.lastname@example.org or in writing to the Data Compliance Manager, Mule Management Limited, 164-166 High Road, Ilford, Essex, IG1 1LL.
In the event that you wish to complain about how we have handled your personal information, please contact the Client Support Manager at email@example.com
Our Client Support Manager will then investigate your complaint and work with you to resolve the matter.
If you still feel that your personal information has not been handled appropriately according to the law, you can contact the Information Commissioner’s Office in the UK here: https://ico.org.uk/concerns/ and file a complaint with them.
9. Changes of Business Ownership and Control
Mule Management may sometimes expand or reduce its business, this may involve the sale of certain divisions or the transfer of control of certain divisions to other parties. Personal information provided by prospects, clients/participants, and employees will be transferred along with that division and the new owner or newly controlling party (if necessary to that division) will, under the terms of this notice, be permitted to use the personal information for the purposes for which it was supplied by you.
If any personal information submitted by prospects or clients/participants will be transferred in such a manner, you will not be contacted about this in advance or then after by ourselves.
Our Service does not address and is not directed towards anyone under the age of 13. We do not knowingly collect personal information from anyone under the age of 13. If you are a parent or guardian and you are aware your Children has provided us with Personal Information, please contact us. If we become aware we have collected Personal Information from children without verification of parental consent, we take steps to remove that information from our systems.
Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. This information is used to track visitor use of the website and to compile statistical reports on website activity.
For further information visit www.aboutcookies.org or www.allaboutcookies.org.
You can set your browser not to accept cookies and the above websites tell you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result.
Our website contains links to other websites. This privacy notice does not cover the links within this site linking to other websites. We encourage you to read the privacy statements on the other websites you visit.
13.Changes to our privacy notice
We keep our privacy notice under regular review and we will place any updates on this web page. This privacy notice was last updated on 26th September 2019.
14.How to contact us
Please contact us if you have any questions about our privacy notice or information we hold about you by emailing our Data Compliance Manager at: firstname.lastname@example.org or write to us at c/o Data Compliance Manager, Mule Management Limited, 164-166 High Road, Ilford, Essex, IG1 1LL.