Privacy Policy

1. Who we are

Nuela Ltd is a UK-based business operations and technology consultancy working with organisations in the UK and internationally.

Nuela Ltd is the data controller for personal information we collect and use in running our business.

Company

Nuela Ltd

Company number

16287957

Registered office

257–258 Upper Street, Northway House – Diamond And Co, London N1 1RU

Website

nuela.co.uk

Privacy enquiries

privacy@nuela.co.uk

2. Information we may collect

Depending on how you interact with Nuela, we may collect:

• Identity and contact information, such as your name, job title, organisation and work email address.
• Business information you provide when making an enquiry, applying for a Friction Finder, speaking with us or discussing a potential engagement.
• Booking and correspondence information, including appointment details and communications with us.
• Commercial and engagement information needed to develop proposals, enter into agreements, manage client relationships, invoice for services and deliver our work.
• Technical information generated when you use our website or interact with technologies used to operate it.

We may also receive professional contact information from publicly available business sources, referrals, introductions and professional networking.

Please do not submit passwords, financial account information, personal information about customers or employees, or other confidential or sensitive information through our general website forms or Friction Finder application unless we have specifically agreed that it is required and how it should be shared securely.

3. How we use your information

We may use personal information to:

• respond to enquiries and communicate with you;
• review and manage Friction Finder applications;
• arrange meetings and appointments;
• understand potential client requirements;
• prepare proposals and Statements of Work;
• enter into and manage client engagements;
• provide our consulting services;
• maintain appropriate business and relationship records;
• manage invoicing, accounting and other business administration;
• protect our business, website and information systems;
• comply with legal, regulatory, tax and accounting obligations; and
• develop legitimate business relationships and opportunities.

Applying for a Friction Finder does not automatically subscribe you to marketing communications.

4. Our lawful bases for using personal information

Depending on the circumstances, we may rely on:

Legitimate interests where processing is reasonably necessary to operate and develop Nuela, respond to business enquiries, assess Friction Finder applications, manage prospective client relationships and undertake appropriate business-to-business relationship development.

Contract where processing is necessary to take steps towards entering into an engagement with you or your organisation, or to perform an agreed engagement.

Legal obligation where we need to process or retain information to comply with applicable laws or regulatory requirements.

Consent where we specifically ask for and receive your consent for a particular purpose. Where processing relies on consent, you may withdraw that consent at any time.

5. Friction Finder applications

If you apply for a Nuela Friction Finder, we use the information you provide to understand the business process you would like us to consider, assess whether and how Nuela may be able to help, communicate with you about your application and, where appropriate, provide the Friction Finder and discuss possible next steps.

Qualification decisions are made using professional judgement. We do not use solely automated decision-making to determine whether an application is accepted.

Detailed Friction Finder application information will normally be retained for up to 12 months from the last meaningful interaction, unless there is an ongoing business relationship or another legitimate or legal reason for retaining relevant information for longer.

We may retain a limited record of a completed Friction Finder for longer where reasonably necessary to administer the offer, maintain appropriate business records and understand previous interactions with an organisation.

6. Who we share information with

We may use trusted service providers to help operate Nuela. These may include providers of:

• website hosting and technology;
• secure online forms;
• appointment scheduling;
• email and business communications;
• cloud storage and productivity services;
• accounting, payment and financial services; and
• legal, accounting or other professional advice.

We only share information where reasonably necessary for the relevant purpose and expect service providers handling personal information on our behalf to protect it appropriately.

We may also disclose information where required by law or where reasonably necessary to establish, exercise or defend legal rights.

Nuela does not sell personal information.

7. International business and data transfers

Nuela is a UK company and operates internationally. We may work with clients, contacts, partners and service providers in the UK and other countries.

This may sometimes involve personal information being accessed, stored or processed outside the UK.

Where applicable data protection law requires safeguards for an international transfer of personal information, we will take appropriate steps to ensure those safeguards are in place.

Specific client engagements may include additional privacy, confidentiality or data-processing provisions where appropriate.

8. Client information

This Privacy Policy primarily describes personal information for which Nuela acts as a data controller in operating its own business.

During a client engagement, Nuela may sometimes process personal information on behalf of a client.

Where Nuela processes personal data on behalf of a client, the handling of that information will be governed by the relevant client agreement and, where required, appropriate data-processing terms.

9. How long we keep information

We keep personal information only for as long as reasonably necessary for the purpose for which it was collected, including legitimate business, contractual, legal, accounting and regulatory requirements.

Different types of information may therefore be retained for different periods.

Where information is no longer required, we will take reasonable steps to delete or anonymise it.

We review our retention arrangements periodically and may retain information for longer where there is an ongoing relationship, legal requirement, dispute or other legitimate reason to do so.

10. How we protect information

We take appropriate and proportionate technical and organisational measures to protect personal information against unauthorised access, loss, misuse, alteration or disclosure.

Access to personal information is limited to people and service providers who reasonably need it for the relevant purpose.

No internet-based service or method of electronic storage can be guaranteed to be completely secure, and we do not make such a guarantee.

11. Your rights

Depending on the circumstances and applicable law, you may have rights relating to your personal information, including the right to:

• request access to personal information we hold about you;
• ask us to correct inaccurate or incomplete information;
• request deletion of your information in certain circumstances;
• request restriction of processing in certain circumstances;
• object to certain uses of your information;
• request transfer of information where the right to data portability applies; and
• withdraw consent where we rely on consent.

You have the right to object to processing based on legitimate interests in certain circumstances.

These rights are not absolute and may depend on the circumstances and the lawful basis on which we process your information.

To exercise a privacy right or ask a question about your information, contact privacy@nuela.co.uk.

12. Website technologies and cookies

Our website may use cookies, local storage and similar technologies necessary to operate the website and remember choices you make.

Where we use optional analytics, marketing or other technologies that require permission under applicable law, we will provide appropriate information and choices before using them.

You can review or change available choices through the cookie settings on our website.

We periodically review the technologies used by our website and will update this Privacy Policy or associated cookie information where necessary.

13. Marketing communications

Where Nuela introduces email marketing or similar communications, we will manage those communications in accordance with applicable privacy and electronic marketing requirements.

Where consent is required, we will request it separately.

You can ask us to stop sending direct marketing communications at any time.

14. Complaints

If you have concerns about how Nuela uses your personal information, please contact us first at privacy@nuela.co.uk so that we can investigate.

You also have the right to make a complaint to the UK Information Commissioner’s Office (ICO) or, where applicable, another competent data protection authority.

15. Changes to this policy

We may update this Privacy Policy as Nuela develops, our services or technology change, or legal requirements change.

The latest version will be published on our website with the date it was last updated.