CABAL PRIVACY POLICY

INTRODUCTION

Welcome to Cabal's Privacy Policy.

Cabal values your privacy and is dedicated to safeguarding your personal data. This policy outlines how we handle your personal data when you visit our Website (regardless of your location) and informs you of your privacy rights and how the law protects you.

1. Important Information and Who We Are

PURPOSE OF THIS PRIVACY POLICY

This policy provides details on how Cabal collects and processes your personal data when you use our website at www.joincabal.com and its associated sub-domains (the “Website”). This includes any data you provide when subscribing to our newsletter, purchasing a service, or participating in a competition.

Our Website is not intended for children, and we do not knowingly collect data related to minors.

It is important that you read this policy alongside any other privacy notices or fair processing statements we provide when collecting or processing personal data. This policy supplements those notices and does not override them.

CONTROLLER

Cabal MC Ltd t/a Cabal (Company Number 15932193) (referred to as "Cabal", "we", "us" or "our" in this policy) acts as a data processor concerning the personal data provided by our clients.

We have appointed a data privacy manager to oversee inquiries regarding this policy. For any questions or requests related to your legal rights, please contact the data privacy manager using the details below.

CONTACT DETAILS

Legal Entity: Cabal MC Ltd (Company Number 15932193)
Data Privacy Manager: Dan Joyce
Email: dan@joincabal.com
Postal Address: 147a Hoxton Street, London, N1 6QG

You have the right to file a complaint with the Information Commissioner's Office (ICO), the UK’s supervisory authority for data protection (www.ico.org.uk). However, we would appreciate the opportunity to address your concerns before you approach the ICO, so please contact us first.

CHANGES TO THIS POLICY AND YOUR DUTY TO INFORM US OF CHANGES

Ensuring the accuracy and currency of your personal data is crucial. Please notify us of any updates to your personal information during your relationship with us.

THIRD-PARTY LINKS

Our Website may contain links to third-party websites, plug-ins, and applications. Clicking on these links or enabling such connections may allow third parties to collect or share your data. We do not control these websites and are not responsible for their privacy policies. When leaving our Website, we encourage you to review the privacy policies of any site you visit.

2. The Data We Collect About You

Personal data refers to any information that identifies an individual. This does not include anonymous data, where personal identifiers have been removed.

We may collect, use, store, and transfer various types of personal data, including:

Identity Data: Name, username, or similar identifiers.
Contact Data: Address, email address, and phone number.
Financial Data: Bank account and payment card details.
Transaction Data: Details of payments made to or from you and purchases from us.
Technical Data: IP address, login details, browser type and version, time zone settings, browser plug-ins, operating system, and platform.
Profile Data: Username, password, purchase history, interests, preferences, feedback, and survey responses.
Usage Data: Information on how you use our Website and services.
Marketing and Communications Data: Preferences regarding marketing from us and third parties.

We also collect Aggregated Data, such as statistical or demographic insights, which may be derived from personal data but does not directly identify individuals. If we combine Aggregated Data with personal information in a way that identifies you, we will treat it as personal data.

We do not collect Special Categories of Personal Data (e.g., race, religion, health data, or criminal history) unless we have your explicit consent.

IF YOU FAIL TO PROVIDE PERSONAL DATA

If you are required to provide personal data by law or under a contract with us and you fail to do so, we may not be able to fulfil our obligations (e.g., providing services). In such cases, we will inform you at the relevant time.

3. How We Collect Your Data

We use various methods to collect data, including:

Direct interactions: When you fill in forms, contact us via post, phone, or email, or provide personal data when:
- Applying for our services.
- Creating an account.
- Subscribing to our services or events.
- Requesting marketing communications.
- Entering a competition or providing feedback.
Automated technologies: As you use our Website, we may automatically collect Technical Data through cookies, server logs, and similar technologies.
Third parties and public sources:
- Technical Data from the following parties:
  - analytics providers;
  - advertising networks; and
  - search information providers.
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
- Identity and Contact Data from data brokers or aggregators.
- Identity and Contact Data from publicly available sources such as Companies House.

4. How We Use Your Personal Data

We only use your personal data where permitted by law. Typically, we rely on the following grounds:

Contractual necessity: When we need to perform a contract with you.
Legitimate interests: Where necessary for our business operations, provided your rights do not override these interests.
Legal or regulatory compliance: When required by law.

We generally do not rely on consent as a legal basis for processing your personal data except for third-party marketing communications via email, where you can withdraw consent at any time.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You may withdraw any consent given to receive direct marketing communications from us by contacting us.

PROMOTIONAL OFFERS FROM US

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you. We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You may withdraw any consent given to receive direct marketing communications from us by contacting us.

You will receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

THIRD PARTY MARKETING

We will not share your personal data with external companies for marketing purposes without your explicit consent.

OPTING OUT

You can stop receiving marketing messages by following the opt-out links in emails or by contacting us. This does not apply to personal data provided for service-related transactions.

You can adjust your browser settings to refuse or alert you about cookies. However, some parts of our Website may not function properly if cookies are disabled.

CHANGE OF PURPOSE

We will only use your personal data for the original purpose unless we determine that another purpose is compatible with it. If we need to process your data for an unrelated reason, we will inform you and explain the legal basis.

5. Disclosures of Your Personal Data

We may share your personal data with third parties for the purposes set out in paragraph 4, including:

Service providers such as HubSpot, AWS, Google, Xero, GoCardless, and Stripe.
Business partners in the event of a merger, sale, or acquisition. If a change of ownership happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require third parties to respect data security and process personal data strictly according to our instructions.

6. International Transfers

Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data Retention

How long will you use my personal data for? We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us. In some circumstances you can ask us to delete your data: see Erasure Request below for further information. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. Your Legal Rights

You have rights under data protection laws relation to your personal data, including:

Requesting access, correction, or erasure of your data (commonly known as a "data subject access request").
Request correction of the personal data that we hold about you.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

This Privacy Policy was last updated on 1 January 2025.