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Privacy Policy

Muzulu Privacy Policy

Information about us

Muzulu Limited (Muzulu) is committed to protecting your personal data. This privacy policy sets out how Muzulu (or we or our) looks after your personal data.

See our separate Website Privacy Policy which sets out how Muzulu looks after personal data collected via the website at www.muzulu.com.

Muzulu is the data controller (ICO registration number ZA843493). Muzulu Limited is a private limited company registered in England and Wales under company number 11163025.  Our registered office address is 19 Manor Road, South Hinksey, Oxford OX1 5AS.

This Privacy Policy covers our use of personal data where we act as the controller. We may access personal data in the course of providing services for our customers. In that case, such access will be on behalf of the customer so we will be a processor in respect of that personal data which is not covered by this Privacy Policy. Our access and use of that personal data will instead be governed by the contract we have with the customer.

If you have any queries regarding the processing of your personal data, please contact us at privacy@muzulu.com.

Our processing

We collect personal data from the following:

  • Customers
  • Prospective Customers
  • Prospective Consultants
  • Partners/Suppliers
  • Job applicants

Customers

We hold the following personal data about you:

  • Contact data: name, title, job title/function, email address, telephone number, office/work location/address, organisation you are working for
  • Financial data: billing and payment information
  • Contract information: Documents relating to the services we provide to you and all related communications with you
  • Marketing data: name, email address, telephone number, organisation you are working for, location, your marketing/communication preferences

Prospective customers

We hold the following personal data about you:

  • Contact data: name, job title, email address, telephone number, office/work location
  • Communications: documents relating to the services we can provide to you (e.g. bids, proposals) and all related communications with you (including notes of any discussions)
  • Marketing data: name, email address, telephone number, organisation you are working for, location, your marketing/communication preferences

Prospective Consultants

We hold the following personal data about you:

  • Contact data: name, job title, organisation name, email address, telephone number, location
  • Availability data: details of when you are or may be available to work on projects for Muzulu
  • Skills and experience data: information about your skills and experience relevant to potential projects
  • Communications: all related communications with you (including notes of any discussions)

Partners/Suppliers

We hold the following personal data about you:

  • Contact data: name, job title, email address, telephone number, office/work location
  • Financial data: billing and payment information
  • Contract information: Documents relating to the services we provide jointly and/or you provide to us and all related communications with you

Job applicants

  • Contact data: name, title, job title/function, email address, telephone number, office/work location/address, organisation you are working for
  • Recruitment data: Your application/CV and related information such as employment history, educational or professional background, references, interview notes

Why do we process your personal data?

  • To manage our contract with you/your employer
  • To deliver services to you/your employer
  • To market our services to you unless you have opted out of direct marketing
  • To offer you work on Muzulu customer projects
  • To process your job application
  • To provide you with information about our services
  • To connect you with our partners who may offer services of interest to you
  • To deliver relevant content to you
  • For security and the prevention of fraud and other criminal activity
  • To obtain and maintain insurance coverage, managing risks and/or obtaining professional advice
  • For the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure

 

What is your lawful basis for processing the personal data?

  • Our legitimate interests, namely:
    • the proper administration of our services and business
    • promoting our business and communicating marketing messages and offers to our Customers and Prospective Customers
    • communications with our Customers and Prospective Customers, the maintenance of our business relationships and enabling the use of our services
    • offering the best possible experience for our Customers and Prospective Customers
    • the protection of our services and business, and the protection of others
    • the proper protection of our business against risks; and
    • the protection and assertion of our legal rights, your legal rights and the legal rights of others.
  • Compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person

Do you collect any special category data?

Save for DBS checks which are carried out on prospective employees, we do not intentionally collect any special category data (i.e. sensitive personal data) such as details about your race, ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data.

Where possible, please do not provide special category data to Muzulu.

How is your personal data collected?

We may collect your data directly.  We may also receive information about you from one of Muzulu’s directors or employees, from a third party (e.g. your employer or one of our partners), from publicly available sources and from marketing lists.

How long will you keep the personal data?

We will not keep your personal data for any longer than is necessary bearing in mind the reason for which it was first collected. Your personal data will therefore be kept for the following periods:

  • Prospective customers: The duration of your enquiry and then one year.
  • Prospective consultants: For the period where you wish to be considered for work on Muzulu customer projects. Information will be updated/deleted on an annual basis
  • Customers/Partners/Suppliers: Generally this will be held for the duration of our relationship with you and then 6 years following the end of the relevant financial year after that so that we can maintain appropriate financial and contractual records. For further detail, please contact privacy@muzulu.com.
  • Job Applicants: 9 months from the closing date for applications where your application is unsuccessful.

How and where do you store or transfer my personal data?

We share your personal data with our joint venture company based in Sri Lanka (as detailed below). Transfers of your personal data to our joint venture company will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the competent data protection authorities.

Most of our service providers store personal data outside the UK so their processing of your personal data will involve a transfer of data outside the UK. Where this is the case, we will ensure that it is transferred in compliance with the requirements of the UK GDPR and the Data Protection Act 2018. This may mean transferring to a country which has been deemed by the UK data protection authority to provide an adequacy level of protection for personal data or ensuring that model contract clauses are in place which are approved for use in the UK and which give personal data the same protection it has in the UK.

Do you share my personal data?

We may share your personal data with the following key third parties:

  • Our joint venture company, Muzulu and Inivos Consultancy (PVT) Ltd, Sri Lanka, insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
  • QuickBooks to manage your billing and payment details
  • HubSpot to manage our customer relationships including prospective customers
  • JIRA (Atlassian) to manage support calls
  • Microsoft Corporation (Office 365 applications)
  • Our professional advisers (e.g. lawyers, accountants, insurance brokers) insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.
  • Suppliers as follows: Workshop Marketing Services Ltd (website hosting and marketing), IT services/support, employee screening, recruitment consultants, time recording and call answering services
  • Consultants/sub-contractors involved in the delivery of services to you
  • Partners (e.g. who offer complementary services) – IFS, BOOMI, AccessPay, Xelix, Novacura, ClickLearn, Pagero, Seagull.

In addition to the specific disclosures of personal data set out in this section, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

How do you protect my personal data?

We have put in place appropriate technical and organisational security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

We have put in place procedures to deal with any suspected personal data breach.  Where we are legally required to do so, we will notify you and any relevant regulator/supervisory authority, if there is a breach.

Muzulu has ISO 27001 accreditation and is committed to continuous improvement in its information security practices.

Cookies

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Your rights

You have the following rights in relation to your personal data:

  • The right to be informed, which is what this Privacy Policy is for
  • The right to access the data we hold about you
  • The right to object to direct marketing – by contacting us at privacy@muzulu.com or using the Unsubscribe option
  • The right to object to processing carried out on the basis of legitimate interest
  • The right to erasure (in certain circumstances)
  • The right to data portability – in certain circumstances you can object to the processing of your personal data;
  • The right to have your data rectified if it is inaccurate or incomplete
  • The right to have your data restricted or blocked from processing.

These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://edpb.europa.eu/our-work-tools/general-guidance/gdpr-guidelines-recommendations-best-practices_en and https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.

Please contact us on privacy@muzulu.com if you would like to exercise any of these rights.

You also have the right to lodge a complaint about our processing with a supervisory authority responsible for data protection. In the UK, this is the Information Commissioner’s Office.

Changes to this Privacy Policy

This Privacy Policy will be reviewed and updated on a regular basis. Updates will be made available on this website.

Version: Muzulu Privacy Policy: April 2022 Version

Review: March 2023