Last Updated: October 2022
We will periodically update this privacy notice (the "Privacy Notice") and will post any changes on this page.
We take the protection of your data and your privacy seriously and are committed to providing you with a clear understanding of the type of personal information (commonly referred to as "personal data") we collect, how and why we use that information, how we store your personal information and who has access to it. This notice will also inform you of your data protection rights. In the Supplementary Information section of this Privacy Notice, we explain what is meant by “personal information” and other key terms used in this Privacy Notice.
This Privacy Notice describes how we collect, use, share, retain and safeguard personal information that relates to our business clients when using our Ada portal. It sets out your individual rights; we explain these later in the Notice but in summary these rights include your right to know what data is held about you, how this data is processed and how you can place restrictions on the use of your data. This Privacy Notice explains the following:
Who we are and what we do;
What types of personal information we collect and how we receive your information;
How we use this information;
How long we keep your personal information for
How we secure your personal information;
Information sharing and disclosure;
Your data protection rights regarding the personal information you provide to us;
Our responsibility for website links;
Updates; and
How to contact us.
Mulberry Risk Limited is registered in England and Wales with Company number 0735405. Our registered address is 34 Lime St, London, EC3M 7AT.
We are a boutique consultancy company providing actuarial, analytical and capacity management services.
Mulberry Risk acts as a data controller responsible for the processing of your business-related personal information when using our services. Personal information you submit as part of engaging in business and contracting with us to provide the services as described in the Order Form and Terms and Conditions. Please note we do not intend to capture any personal information that pertains to your private life outside operating in a professional working capacity.
Mulberry Risk is registered with the UK Information Commissioner’s Office ("ICO") with registration reference ZB109771.
We collect information such as name and email address (see below for the comprehensive list). This information is usually shared through forms, e-mail or via telephone. Where personal information is collected through our website or our online services in this way, this will be clearly indicated.
We collect information about how you use our website and the device(s) you use to access our site. For detailed information on the cookies we use and the purposes for which we use them see our Cookie Policy.
We also collect information about you if you make use of any of the interactive features within our website that rely on a personalised response, or where you ask us to respond to a query you have, or add your details to one of our alert or subscription services. The information we collect is limited to the details we need to provide the specific service you have asked for. We do not collect sensitive information, such as your political or religious beliefs, ethnic background, sexual preference, health or any other sensitive information.
We will use the personal information collected for the purposes set out in the first column of the table below. The categories of the types of personal information processed as part of the stated purpose are in the second column of the table. In the third column of the table below, we set out the lawful basis we rely on for its use. Note that in some instances we will process your personal information for more than one lawful basis depending on the specific purpose for which we are using your information.
Under data protection law, we are required to advise you of the lawful basis for processing your personal information. For the most part, the processing of your personal information is based either on a) our legitimate interests related to us, namely to provide you with services you have requested or otherwise your customer relationship with us, or b) your consent, where requested.
Purpose/Activity | Types of personal information that will be processed | Lawful basis for processing including basis of legitimate interest |
To conduct the market research study including recording responses and developing a report for our client/survey sponsor; verifying or validating answers you provide, including for internal quality control purposes; and to obtain extended (open-ended) information that helps to provide context for your survey responses – for example, the nature of a complaint that has arisen while using our clients’ products or services. | (a) Name; (b) Email address; (c) Company; (d) Telephone number; (e) Job title; (f) IP address (for online surveys); (g) Other personal information which are shared during the course of a market research interview. | We rely on your consent to process personal information relating to your continued participation in a market research study. To the extent that we make audio or visual recordings of a market research study, our lawful basis is our legitimate interest in creating a record of the discussion to support our creation of an accurate report for our client/survey sponsor. You will always be notified before any recording takes place. You should not participate in a study which involves recording, if you are not happy to be recorded. |
To share your personal information with our client or survey sponsor | (a) Name; (b) Audio or visual recording; (c) Attributed quotations; (d) Job title; | In some cases, we will ask for your consent to share your personal information and responses with a third party in digital (data file), audio or some other format. You are under no obligation to agree to this and you will always be informed who these third parties are (usually the survey sponsor). We would share this personal information on the basis of your consent. |
To manage incentives. | (a) Name; (b) E-mail address; (c) Job title. | Some projects can include an incentive for taking part. Incentives will usually be in the form of a gift voucher or charitable donation. Incentives will only be awarded if a survey or research activity is fully completed. We process this personal information on the basis of your consent. |
To send you information about our services and information which you have requested e.g. newsletters or publications in accordance with your specified preferences. | (a) Name; (b) Email address; (c) Company; | Where you have requested information from us, such as newsletters, publications or event invitations, we send such communications based on your consent. You can ask us to stop such communications at any time by clicking on the unsubscribe link at the bottom of the message. |
To improve and develop our website we conduct statistical analysis on your usage of the website e.g. to enable us to improve our website, offer new features and material etc. | (a) Technical; (b) Usage. | Necessary for our legitimate interest (to define types of clients for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy). |
To deliver relevant content to you and measure or understand the effectiveness of the content we serve to you. | (a) Name; (b) Email address; (c) Company; (d) Usage; (e)Marketing and communications; (f) Technical. | Necessary for our legitimate interests (to study how clients use our service and engage with our content. To develop our service, to grow our business and to inform our marketing strategy). |
To respond to any enquiries or feedback that you send us. To update you with any changes to our terms and conditions/other policies. | (a) Name; (b) Email address; (c) Usage. | It is our legitimate interests to work out which of our products or services may interest you and tell you about them. Our offices outside of the UK will reach out to you with such information based on your consent. |
To share information with our service providers. | (a) Name; (b) Email address; (c) Usage; (d) Marketing and communications; (e) Technical. | It is our legitimate business interest to share your data with trusted third parties who provide us with services relevant to the provision of our website. |
To share information with other third parties, such as regulator and law enforcement agencies. | (a) Name; (b) Email address; (c) Usage; (d) Technical. | We share your data as necessary for compliance with any legal obligation to which we are subject or in order to satisfy our legitimate business interests. |
We store your personal information in accordance with legal, regulatory, financial and best practice business requirements. Once your personal information is no longer necessary, we will securely delete/destroy your data in line with our data retention policies.
All personal information will be archived into storage upon termination of contract and stored for a period of 12 months post termination. Your personal information will be deleted thereafter.
Our standard retention period for personal information relating to market research studies is 3 years.
We maintain appropriate organisational and technological safeguards to help protect against unauthorised use, access to or accidental loss, alteration or destruction of personal information. We also seek to ensure our service providers do the same.
We send personal information collected from research surveys to third party organizations, but only when:
We have your express consent to share the information with a research sponsor for a specified and limited purpose (e.g. to resolve a customer service problem);
We need to share this information to provide you with information you have specifically requested;
We need to respond to court orders or the requests of law enforcement agencies;
We retain a third party to provide us with services, subject to that third party being able to comply with relevant legal requirements and obligations regarding the use of personal information.
Your personal information will also be stored in one or more databases hosted by third parties. These third parties do not have use or access to your personal information for any purpose other than cloud storage or retrieval.
Where required or permitted by law, personal information will be provided to others, such as regulators and law enforcement agencies, for example in response to a court order or a subpoena, or in response to a law enforcement agency’s request, or where we believe it is necessary to investigate, prevent or take action regarding illegal activities, and as otherwise required by law.
For the purposes of meeting the Data Protection Act 2018 territorial scope requirements, the United Kingdom is identified as the named territory where the processing of personal information takes place.
We will transfer personal information concerning you to countries outside the UK. Where we transfer personal information outside of the UK, we either transfer personal information to countries that provide an adequate level of protection (as determined by the Secretary of State), for example the European Union, or we have appropriate safeguards in place. Appropriate safeguards to cover these transfers include standard contractual/data protection clauses issued by the Information Commissioner's Office ("ICO").
If you would like more information on the any of the data transfer mechanisms on which we rely please contact us using the details provided below.
If you wish to stop receiving marketing communications from us then please click on the “unsubscribe” link at the bottom of the relevant mailing. If you wish to opt-out completely then please contact us using the details provided below.
If you would like us to delete your information from our records, please contact us using the contact details below and we will respond within a reasonable time. Please note that we may be required to retain certain information by law and/or for our own legitimate business purpose.
Under data protection law, you have rights (with some exceptions and restrictions) as follows:
Your right to object to processing - You can object at any time and we shall stop processing the information you have objected to, unless we can show compelling legitimate grounds to continue that processing. Furthermore, you can withdraw your consent to our use of your personal information at any time. When you use our website you will be asked to consent to the use of cookies. You may withdraw your consent to our processing of your personal information that has been derived from cookies. If you do withdraw consent, that will not affect the lawfulness of what we have done with your personal information before you withdrew consent; you can also object to our use of your personal information for direct marketing.
Your right of access - you have the right to ask for your personal information and for information about why we are processing it.
Your right to erasure – you have the right to request erasure of your personal information in certain circumstances.
Your right to rectification - request correction or updating of the personal information that we hold about you.
Your right to restriction of processing - request the restriction of our processing of your personal information in some situations. If you request this, we can continue to store your personal information but are restricted from processing it while the restriction is in place.
Your right to data portability - request portability of your personal information that we hold, in certain circumstances.
If you would like to exercise any of these rights in relation to any information we hold about you, please contact us using the contact details provided below. We will consider and respond to your request in accordance with data protection law. If you exercise the rights above and there is any question about who you are, we may require you to provide information from which we can satisfy ourselves as to your identity.
If you have any concerns in relation to our use of your personal information, you can make a complaint to us. Our contact details can be found below.
You can also complain to your local data protection authority about our collection or use of your personal information. In the UK, the local data protection authority is the UK Information Commissioner’s Office ("ICO").
ICO website: https://www.ico.org.uk
This Privacy Notice is limited to the personal information collected by Mulberry Risk Limited. We provide links within our website to other websites, including social media sites such as Facebook, Twitter and LinkedIn. If you follow these links, you should use these sites in conjunction with their applicable user and privacy notices as their data practices fall outside the scope of this Privacy Notice. Further, we have no responsibility for or control over the information collected by any third-party website and we cannot be responsible for the protection and privacy of any information which you may provide on such websites.
This Privacy Notice will be updated from time to time to reflect changes in law, best practice or a change in our practices regarding the treatment of personal information. The date of the most recent revision will appear at the top of this page. If you do not agree to the changes, please do not continue to use our services and please refrain from sharing your personal information with us. You should check this Privacy Notice frequently for updates.
If you have any questions about this Privacy Notice, our approach to privacy or you would like to exercise any of the rights mentioned in this Privacy Notice you can contact our Data Protection Officer in any of the following way:
Address: Data Protection Officer, Mulberry Risk Limited, 34 Lime St, London, EC3M 7AT
Email: oli@mulberryrisk.com.
Supplementary Information
In this Supplementary Information section, we explain some of terminology used in this Privacy Notice.
"Client" – A business with contractual access to the ADA Platform.
“Data controller” – the person or company that controls the purposes and means of processing personal information.
"ICO" – the ICO is the UK's independent body set up to uphold information rights.
"Legitimate interest" – Legitimate interests is one of the six lawful bases for processing personal information. You must have a lawful basis in order to process personal information in line with the 'lawfulness, fairness and transparency' principle.
“Personal information” – commonly known as personal data, and includes any information that relates to you (or from which you can be identified).
“Processing”– means doing anything with data. For example, it includes collecting it, holding it, disclosing it and deleting it.
“Transfer” – sending personal information outside the European Economic Area (e.g. by storing it on equipment located outside the European Economic Area), or allowing someone from outside the European Economic Area to access the personal information.
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