2. Important information and who we are
We do not knowingly collect data relating to children under the age of 13.
2. Who is the “Controller” of your personal data?
This version was last updated on 17/01/2023.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
4. Third-party links
3. The data we collect about you
1. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
2. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:“
Identity” data includes first name, last name, username and date of birth.
“Contact” data includes address, email address and telephone number/s.
“Transaction” data includes details about payments to and from you and other details of products and services you have purchased from us.
“Technical” data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
“Profile” data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
“Usage” data includes information about how you use our website including use of specific features, frequency of use, interactions with other members of the community, content consumption.
“Marketing and Communications” data includes your marketing preferences.
4. We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
5. If you fail to provide personal data. Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
4. How is your personal data collected? We use different methods to collect data from and about you including through:
1. Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, email or otherwise. This includes personal data you provide when you:
apply for our products or services;
create an account in our products;
subscribe to our service or publicationsrequest marketing to be sent to you;
enter a competition, promotion or survey;
give us some feedback or contact us.
2. Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
3. Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources.
4. Technical Data from the following parties:
analytics providers such as Google.
5. Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
5. How we use your personal data
1. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
2. Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
6. Marketing. We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
1. 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 products, services and offers may be relevant for you (we call this marketing).You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and, in each case, you have opted in to receiving that marketing.
2. Third-party marketing. We will get your express opt-in consent before we share your personal data with any company outside of MULA for marketing purposes.
3. Opting out. You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
5. Change of purpose. We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
7. Disclosures of your personal data
1. We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 7 above.
External Third Parties (full details of which are included in the Glossary at the end of this policy). External Third Parties may be inside or outside the European Economic Area (EEA).
2. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
8. International transfers
1. Some of our External Third Parties may be based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.
2. If 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:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
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.
9. Data security
1. 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.
2. 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.
10. 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, regulatory, tax, 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, regulatory, tax, accounting or other requirements.
11. Your legal rights
1. Under certain circumstances, you have rights under data protection laws in relation to your personal data. Full details of these rights can be found in the Glossary at the end of this policy and on the Information Commissioner's Office website. In summary, these rights are the right to:
Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.
2. 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
3. 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.
4. 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.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
External Third Parties
Service providers acting as processors (such as AWS in USA) who may be based inside and/ or outside the EEA who provide IT and system administration services including cookies/user experience/analytics.
Professional advisers acting as processors including lawyers, bankers, auditors and insurers based inside the EEA who provide consultancy, banking, legal, insurance and accounting services.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
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.
Welcome to mula.school (Website).
This Website is owned and operated by Storie S.R.L. (MULA), a company incorporated and registered in Italy with company number 10992450964 whose registered office is at 4 Via Filippo Turati Milano, Lombardia 20121.
In these Website Terms we/our/us means MULA®, and you/your means you as a user of the Website.
USE OF THE WEBSITE
By using the Website, you signify your agreement to be bound by these Website Terms. If you do not agree to accept these Website Terms, you should not use the Website.
We reserve the right to change these Website Terms at any time and you are advised to review the Website Terms regularly to ensure that you are aware of any changes. Your continued use of the Website after such changes are posted will be deemed your agreement to these Website Terms, as amended from time to time.
MULA® provides an online educational [and entertainment] media platform developed by or on behalf of us which connects you with digital content and live performances by experts, who are known as "Teachers of MULA" (the Service).
If you become a member of MULA® by registering to use the Service, the Service Terms, Community Guidelines shall also apply to your use of the Service. In the event of any conflict or inconsistency between these Website Terms, Community Guidelines and the Service Terms (as applicable), the Service Terms shall apply as appropriate.
ACCESSING OUR WEBSITE
Access to our Website and App is permitted on a temporary basis and we reserve the right to suspend, withdraw, discontinue or change all or any part of our Website or App without notice. We will not be liable to you if for any reason our Website or App is unavailable at any time or for any period.
We may update our Website and App from time to time, and may change the content at any time. The content on our Website and App is provided for general information only. It is not intended to amount to advice on which you should rely. You must obtain professional or specialist advice before taking, or refraining from, any action on the basis of the content on our Website or App.
Although we make reasonable efforts to update the information on our Website and App, we make no representations, warranties or guarantees, whether express or implied, that the content in our products is accurate, complete or up to date.
If we permit you to post or provide any information on or via Website or App, you must ensure that such information does not contravene any applicable laws or infringe any person's legal rights. We do not monitor or edit documents or files posted or provided to us by third parties and accordingly we do not accept any responsibility for any damage or loss you may suffer.
You agree that you will not:
make, transmit or store electronic copies of Material (defined below) protected by copyright without the permission of the owner.attempt to decompile, reverse engineer, disassemble, copy or adapt any software or otherwise derive source code from the Website or App;
tamper with, hinder the operation of, make unauthorised modifications to the Website or App including attempting to interfere with the access of any user, host or network;
use the Website or App for any activities which breach any laws, regulations, our Community Guidelines or policies, or infringe any third party rights;
remove, obscure, or alter any copyright notices, trade marks, or other proprietary rights notices of ours or any third party;
use the personal information of another person in order to access or use the Website or the Service;
andtransmit any bug, virus or other disabling feature to or through the Website.
If you inform us, or if we have reason to believe that, unauthorised use is being made of the Website or the Service (whether by you or through your account) then, without prejudice to our other rights and remedies, we may suspend or terminate your access to the Website or Service immediately (and without notice to you).
INTELLECTUAL PROPERTY RIGHTS
We are the owner or the licensee of all intellectual property rights in our Website and App, and in the Material published on it, other than any content that you post, upload or share to the Website (Your Content). The Website and the Materials (defined below) are protected by copyright and other intellectual property laws and treaties around the world. All our rights are reserved.
"Material" means any text, graphics, images, audio, video, software, data compilations, page layout, underlying code, software, information, data, content, recordings (including content and live performances provided by or on behalf of any Teacher of MULA) and any other form of information or data capable of being stored in electronic or other form that appears on or forms part of the Website, other than Your Content.
By using the Website or the Service you acknowledge that such Material is protected by copyright, trade marks, database rights, moral rights and other intellectual property rights. You may, for your own personal, non-commercial use only, retrieve, display and view the Website, Material and the Service on a computer screen or screen of any other device. Nothing on this Website or in these Website Terms shall be interpreted as granting, by implication, estoppel, or otherwise, any license or right to reproduce, modify, copy, distribute, screen or use for commercial purposes the Website, Material or Service without our prior written permission.
You must not collect, scrape, harvest, frame or deep-link to any Material on our Website or provided as part of the Service without our prior written consent.
You must not reverse-engineer any the software used on our Website in any way (except to the extent permitted by applicable laws). You must not create or use a modified or derivative version of the software used on our Website or distribute or sublicense the software used on our Website to third parties. You must take reasonable steps to ensure that the software used on our Website is not disclosed to any third party.
If you wish to reproduce or use information from this Website, you must contact us for express permission. You can do this by addressing your request to firstname.lastname@example.org.
We provide the Website on an "as is" and "as available" basis and to the fullest extent permissible by law we do not guarantee that our Website will meet particular requirements, or be available, accessible, uninterrupted, timely, secure or operate without error, or that it will be free from viruses, worms or other harmful elements. We recommend that you protect your equipment by having appropriate anti-virus software in place.
Where our Website contains links to other sites and resources provided by third parties, these links are provided for your information only. We have no control over the contents of those sites or resources so we assume no responsibility for the content of such sites. Such links should not be interpreted as endorsement by us of those linked websites. We will not be liable for any loss or damage that may arise from your use of them.
To the extent permitted by law, we exclude all conditions, warranties, representations or other terms which may apply to our Website or any content on it, whether express or implied.
We will not be liable to you for any loss or damage, whether in contract, tort (including negligence), breach of statutory duty, or otherwise, even if foreseeable, arising under or in connection with use of, or inability to use, our Website; or use of or reliance on any content displayed on our Website. In particular, we will not be liable for:
any injury or damage caused by your use of the Website or Service;
loss of profits, sales, business, or revenue;business interruption;
loss of anticipated savings;
loss of business opportunity, goodwill or reputation;
orany indirect or consequential loss or damage.
Nothing in these Website Terms is intended to exclude or limit for any liability that cannot be excluded or limited by law.
LINKING TO OUR WEBSITE AND APP
We reserve the right in our absolute discretion to prohibit any link from another site to materials or information on this Website without notice. Any link to material or information on this Website must be neither misleading nor deceptive and must fairly indicate this Website as the destination of the link. You must not establish a link to materials or information on this Website in such a way as to suggest any form of association with, approval of or endorsement by us where none exists.