Mulberri – Digital Procurement for Measurable Savings Turning Spend Data Into Profits Smarter Sourcing for Stronger Ebitda Where AI Meets Procurement Performance Simplifying Spend. Amplifying Performance.

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Privacy Policy

Updated – 9 January 2025

Mulberri LTD (“Mulberri”, “we”, “us”, or “our”) values your privacy and is committed to handling personal information responsibly, transparently, and in accordance with all applicable data protection laws. This Privacy Policy explains, in full detail, how we collect, use, process, disclose, protect, and retain your personal information when you visit our website https://mulberri.com/

 (“Website”), contact us through any channel, or engage with our marketing and communication activities.

This Privacy Policy complies with:

  • The United Kingdom General Data Protection Regulation (UK GDPR)
  • The European Union General Data Protection Regulation (EU GDPR)
  • The California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA)
  • Applicable U.S. state and federal privacy laws
  • Global industry standards for data protection

By accessing or using our Website, you acknowledge that you have read, understood, and agreed to the practices described in this Privacy Policy.

1. Interpretation and Definitions

1.1 Interpretation

Capitalized terms have meanings assigned below. The definitions apply whether they appear in singular or plural form.

1.2 Definitions

  • “Account” – A unique account created for you to access our services. (Note: Mulberri does not currently operate user accounts.)
  • “Affiliate” – Any entity that controls, is controlled by, or is under common control with Mulberri. “Control” means ownership of at least 50% of voting rights.
  • “Company” – Refers to Mulberri LTD.
  • “Cookies” – Small files placed on your device to store browsing data, track website usage, or enhance your experience.
  • “Personal Data” – Any information relating to an identified or identifiable individual. This includes both direct identifiers (name, email) and indirect identifiers (IP address, behavioral data).
  • “Service Providers” – Third-party companies or individuals that process data on our behalf for purposes such as hosting, analytics, advertising, or communication.
  • “Usage Data” – Data collected automatically from your interactions with the Website, such as browser details, device type, pages viewed, and session metrics.
  • “You” or “User” – Any individual who accesses or interacts with the Website.

2. About Mulberri

Mulberri LTD is a procurement-focused digital solutions company operating in multiple jurisdictions.

2.1 Registered Address (UK Headquarters)

Mulberri LTD
71–75 Shelton Street
Covent Garden
London, WC2H 9JQ
United Kingdom

2.2 U.S. Correspondence Address

1178 Broadway
3rd Floor #3976
New York, NY 10001
United States

2.3 Contact Information

Email:
[email protected]

Contact Page:
https://mulberri.com/contact/

Phone (USA): +1 212 660 0049

Phone (UK): +44 203 355 9088

Mulberri is the Data Controller of Personal Data collected through the Website.

3. Types of Data We Collect (Fully Expanded)

Mulberri collects Personal Data and Usage Data, both of which may be subject to GDPR, CCPA/CPRA, and other applicable laws.

3.1 Personal Data Provided Voluntarily

We may collect the following data when you provide it to us:

  • Full name
  • Email address
  • Phone number
  • Company name
  • Job title
  • Information provided through message fields or custom enquiry fields
  • Business-related information shared during conversations
  • Any additional detail voluntarily provided when requesting information, booking a demo, or contacting us

We collect this data through:

  • Contact forms
  • Newsletter subscription forms
  • Demo or meeting scheduling forms
  • Direct email or phone communication
  • LinkedIn outreach, messaging, or form submissions
  • Other voluntary interactions

3.2 Usage Data Collected Automatically

When you use our Website, we collect technical information to improve performance and security:

  • IP address (Internet Protocol)
  • Browser type, version, and configuration
  • Device type (desktop, mobile, tablet)
  • Operating system and device identifiers
  • Geographic region (approximate, based on IP address)
  • Date and time of access
  • Pages visited and time spent on each page
  • Clickstream data (navigation paths and interactions)
  • Referring and exit pages
  • Website diagnostic logs
  • Cookie preferences and tracking identifiers

3.3 Cookies and Tracking Technologies

We use Cookies, pixels, tags, and scripts to:

  • Analyze website performance
  • Enable marketing and retargeting
  • Customize user experience
  • Track aggregated usage patterns

Technologies in use include:

  • Google Analytics
  • Google Tag Manager
  • LinkedIn Insight Tag
  • Meta Pixel

Cookie Categories (Expanded)

a. Essential Cookies

Required for website functionality, such as form submissions, load balancing, and security.

b. Functionality Cookies

Store preferences (e.g., language, region, browsing settings).

c. Analytics Cookies

Help us measure traffic, user behavior, and performance trends.

d. Marketing Cookies

Enable personalized advertising and measure ad effectiveness across LinkedIn, Meta, and Google.

You can adjust cookie settings using our cookie banner or through browser configuration. Some cookies may persist until manually deleted.

4. How We Use Your Personal Data

Mulberri processes Personal Data for the following purposes, each explained in full detail:

4.1 Service Delivery, Support, and Communication

  • Responding to enquiries and contact requests
  • Scheduling demos, calls, or meetings
  • Communicating about Mulberri services or solutions
  • Providing promotional materials upon request

4.2 Marketing, Advertising, and Outreach

  • Sending newsletters, updates, thought leadership, and service announcements
  • Conducting LinkedIn, Meta, and Google retargeting campaigns
  • Measuring campaign performance, audience engagement, and conversion rates
  • Reaching out to professionals on LinkedIn based on legitimate business interests

You may opt out at any time.

4.3 Website Analytics and Optimization

  • Monitoring Website performance and engagement
  • Improving content layout, UI/UX, and navigation
  • Identifying user behavior patterns to improve relevance
  • Detecting slow-loading pages or errors

4.4 Security, Fraud Prevention, and Compliance

  • Protecting the Website from cyber threats
  • Detecting unusual or malicious behavior
  • Maintaining audit logs
  • Ensuring compliance with national and international regulations

5. Legal Basis for Processing (Detailed GDPR Explanation)

Under GDPR, Mulberri relies on the following legal grounds:

5.1 Consent

Used for:

  • Email marketing
  • Newsletters
  • Non-essential cookies and tracking
    Users may withdraw consent at any time.

5.2 Legitimate Interests

Used for:

  • B2B outreach
  • Analytics and website performance measurement
  • Improving services
  • Maintaining business operations
    We balance our interests against user rights before relying on this basis.

5.3 Contractual Necessity

Used when:

  • You request a meeting, demo, or information
  • We must process data to fulfill a request

5.4 Legal Obligations

Used when:

  • Responding to lawful governmental requests
  • Retaining information for tax or audit purposes

6. Aggregated, De-Identified, and Non-Personal Data

Mulberri may collect, process, or create anonymized or aggregated data that cannot identify an individual. Examples include:

  • Aggregated website metrics
  • Anonymized audience segments
  • Statistical summaries for internal reporting

This data is not considered Personal Data.

7. How We Share Your Information

Mulberri does not sell Personal Data.

We may share Personal Data with:

7.1 Service Providers (Fully Listed Examples)

  • Cloud hosting (AWS, Azure, or Google Cloud)
  • CRM platforms (HubSpot)
  • Email and communication providers
  • Analytics providers (Google, LinkedIn, Meta)
  • Productivity services (Google Workspace, Microsoft 365)
  • Security vendors
  • Professional advisors and auditors

All Service Providers are bound by contracts requiring confidentiality and security.

7.2 Business Transfers

Personal Data may be transferred if Mulberri is involved in:

  • Merger
  • Acquisition
  • Sale of assets
  • Corporate restructuring
  • Bankruptcy process

Users will be notified where legally required.

7.3 Compliance with Laws

We may disclose Personal Data to:

  • Law enforcement
  • Courts
  • Regulators
  • Government authorities

This occurs only when required or permitted by law.

8. International Data Transfers (Fully Detailed)

Mulberri operates globally. Your Personal Data may be transferred to the United States or other jurisdictions where data protection laws differ.

To safeguard your information, Mulberri uses:

  • EU Standard Contractual Clauses (SCCs)
  • UK International Data Transfer Addendum (IDTA)
  • Technical and organizational safeguards (encryption, access controls)

By using the Website, you expressly consent to cross-border data transfers.

9. Data Retention (Detailed Retention Practices)

Mulberri retains Personal Data only for as long as necessary for:

  • The purpose for which it was collected
  • Ongoing communications with prospects
  • Legal, regulatory, tax, or audit requirements
  • Internal analytics and reporting

Retention periods vary depending on data type:

  • Enquiry data: retained until no longer necessary
  • Marketing data: retained until you unsubscribe
  • Website analytics data: retained per provider settings

Once no longer needed, data is permanently deleted or anonymized.

10. Security of Your Information (Detailed Security Measures)

Mulberri uses advanced safeguards to protect data, including:

  • SSL encryption for data transmission
  • Encryption-at-rest for sensitive data
  • Multi-factor authentication for administrative accounts
  • Role-based access controls
  • Firewalls and intrusion detection systems
  • Regular third-party security audits
  • Continuous monitoring for vulnerabilities
  • Secure cloud architecture with redundancy and backups

Despite robust measures, no system is 100% secure. We follow industry best practices to mitigate risks.

11. Your Rights Under GDPR (Fully Expanded Details)

UK and EU residents have the following rights:

  • Right of Access: Request a copy of your Personal Data.
  • Right to Rectification: Correct inaccurate or incomplete data.
  • Right to Erasure: Request deletion where legally permitted.
  • Right to Restrict Processing: Limit how your data is used.
  • Right to Object: Object to processing based on legitimate interests.
  • Right to Withdraw Consent: At any time for marketing or cookies.
  • Right to Data Portability: Receive data in machine-readable format.
  • Right to Lodge a Complaint: With your local authority.

UK Supervisory Authority (ICO):

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
SK9 5AF
Website: https://ico.org.uk

To exercise rights, email:
[email protected]

12. Your Rights Under CCPA/CPRA (Expanded California Rights)

California residents have:

  • Right to Know what information is collected, used, shared, or sold.
  • Right to Access specific pieces of Personal Data.
  • Right to Delete Personal Data, subject to legal exceptions.
  • Right to Correct inaccurate information.
  • Right to Opt Out of “Sharing” for advertising (Mulberri does not sell data).
  • Right to Limit Use of Sensitive Data (Mulberri does not collect sensitive data).
  • Right to Non-Discrimination for exercising rights.

Requests may be submitted to:
[email protected]

13. Opt-Out Choices

Users may opt out of:

  • Marketing emails (via “unsubscribe”)
  • Cookies and tracking
  • Retargeting advertising
  • Processing requests under GDPR/CCPA

14. Children’s Privacy

Mulberri does not knowingly collect Personal Data from anyone under the age of 16. If such data is discovered, it will be deleted promptly.

15. Third-Party Links

Our Website may include links to third-party websites. Mulberri is not responsible for their content or privacy practices. Users are encouraged to read the privacy policies of external websites.

16. Changes to This Privacy Policy

Mulberri may update this Privacy Policy periodically. Updates will be posted with a revised “Last Updated” date. Significant changes may also be communicated through email or Website notices.

Continued use of the Website after changes constitutes acceptance of the updated Privacy Policy.

17. Contact Us

For questions or to exercise your rights, contact:

Email: [email protected]
Contact Page: https://mulberri.com/contact/

 

UK Office:
71–75 Shelton Street
Covent Garden
London, WC2H 9JQ

US Office:
1178 Broadway
3rd Floor #3976
New York, NY 10001