Protection of personal data

Groupe GNG PRIVACY POLICY AND COOKIE POLICY

This privacy policy describes the personal data collected or generated (processed) when you use Mulebar’s websites (“Sites”). It also explains how your personal data is used, shared and protected, what choices you have relating to your personal data and how you can contact us.


WHO is Responsible for the Processing of Your Personal Data?

The Groupe GNG entity responsible for the processing of your personal data will depend on how you interact with Groupe GNG’s Sites where you are located in the world. The relevant Groupe GNG entity are referred to as “Mulebar”, “our”, “we” or “us” in this privacy policy.


WHAT Personal Data Do We Collect and WHEN?

We ask you for certain personal data to provide you with the products or services you request. For example, when you make purchases, contact our consumer services, request to receive communications, create an account, participate in our events or use our Sites.

This personal data includes your:

  • contact details including name, email, telephone number and shipping, billing address;
  • login and account information, including screen name, password and unique user ID;
  • personal details hometown and purchase history;
  • payment or credit card information;

When interacting with our Sites certain data is automatically collected from your device or web browser. More information about these practices is included in the “Cookies and Pixel Tags” section of this privacy policy below.  This data includes:

  • Device IDs, network access, storage information and battery information; and
  • Cookies, IP addresses, referrer headers, data identifying your web browser and version, and web beacons and tags.

WHY and HOW Do We Use Your Personal Data?

We use your personal data in the following ways:

To Provide the Features of the Sites you Request

When you use our Sites, we will use your personal data to provide the requested product or service.  For example, if you make a purchase on mulebar.com, we will use the contact information you give us to communicate with you about the purchase, event or promotion. If you contact our consumer services, we will use information about you, such as delivery or payment information, or the product you have purchased to help you resolve a problem or question.

To Communicate Information about our Products, Services, Events and for Other Promotional Purposes

When you consent, we will send you marketing communications and news concerning Mulebar’s products, services, events and other promotions.

If you are an existing customer of Mulebar (for example, if you have placed an order with us), we may use the contact details you provided to send you marketing communications about similar Mulebar products or services where permitted by applicable law (unless you have opted-out). In other cases, we ask for your consent to send you marketing information. We may use the information that you provide to us as well as information from other Mulebar products to personalize communications on products that may be interesting for you.

To Operate, Improve and Maintain our Business, Products and Services

We use the personal data you provide to us to operate our business.  For example, when you make a purchase, we use that information for accounting, audits and other internal functions.  We may use personal data about how you use our products and services to enhance your user experience and to help us diagnose technical and service problems and administer our Sites.

To Protect Our or Others’ Rights, Property or Safety

We may also use your personal data about how you use our Sites to prevent or detect fraud, abuse, illegal use, violations of our Terms of Use, and to comply with court orders, governmental requests or applicable law.

For General Research and Analysis Purposes

We use data about how our visitors use our Sites to understand customer behavior or preferences.  For example, we may use information about how visitors to mulebar.com search for and find products to better understand the best ways to organize and present product offerings in our storefront.

Legal Grounds

To process your personal data, we rely on certain legal grounds, depending on how you interact with our Sites.

  • When you purchase Mulebar products from our Sites, we need your personal data to fulfill our contract with you. For example, we need your payment and contact details to deliver your order.
  • We also rely on other legal grounds, such as our legitimate interests as a business, to comply with a legal obligation, or to protect your vital interests.

SHARING of Your Personal Data

Mulebar shares your personal data with:

  • Mulebar entities for the purposes and under the conditions outlined above.
  • Third party service providers processing personal data on Mulebar’s behalf, for example to process credit cards and payments, shipping and deliveries, host, manage and service our data, distribute emails, research and analysis, manage brand and product promotions as well as administering certain services and features.  When using third party service providers we enter into agreements that require them to implement appropriate technical and organizational measures to protect your personal data.
  • to any other third party where you have provided your consent.

PROTECTION and MANAGEMENT of Your Personal Data

Encryption & Security

We use a variety of technical and organizational security measures, including encryption and authentication tools, to maintain the safety of your personal data.

International Transfers of your Personal Data

We use a variety of measures to ensure that your personal data transferred to these countries receives adequate protection in accordance with data protection rules; this includes signing the EU Standard Contractual Clauses, verifying the recipient has adopted Binding Corporate Rules or adheres to the EU-US and Swiss-US Privacy Shield Framework.

Retention of your Personal Data

Your personal information will be retained for as long as is necessary to carry out the purposes set out in this privacy policy (unless a longer retention period is required by applicable law).


YOUR RIGHTS Relating to Your Personal Data

You have the right to request: (i) access to your personal data; (ii) an electronic copy of your personal data (portability); (iii) correction of your personal data if it is incomplete or inaccurate; or (iv) deletion or restriction of your personal data in certain circumstances provided by applicable law. These rights are not absolute. Where we have obtained your consent for the processing of your personal data, you have the right to withdraw your consent at any time.

Opting Out of Direct Marketing

If you have a Mulebar account, you can opt-out of receiving Mulebar’s marketing communications by clicking on the unsubscribe link in our mails.


COOKIES and Pixel Tags

Mulebar collects information, which may include personal data, from your browser when you use our Sites. We use a variety of methods, such as cookies and pixel tags to collect this information, which may include your (i) IP-address; (ii) unique cookie identifier, cookie information and information on whether your device has software to access certain features; (iii) unique device identifier and device type; (iv) domain, browser type and language, (v) operating system and system settings; (vi) country and time zone; (vii) previously visited websites; (viii) information about your interaction with our Sites such as click behavior, purchases and indicated preferences; and (ix) access times and referring URLs.

Third parties may also collect information via Sites through cookies, third party plug-ins and widgets. These third parties collect data directly from your web browser and the processing of this data is subject to their own privacy policies.

We use cookies and pixel tags to track our customers’ usage of the Sites and to understand our customers’ preferences (such as country and language choices). This enables us to provide services to our customers and improve their online experience. We also use cookies and pixel tags to obtain aggregate data about site traffic and site interaction, to identify trends and obtain statistics so that we can improve our Sites. There are generally three categories of cookies used on our Sites:

  • Functional:These cookies are required for basic site functionality and are therefore always enabled. These include cookies that allow you to be remembered as you explore our Sites within a single session or, if you request, from session to session. They help make the shopping cart and checkout process possible as well as assist in security issues and conforming to regulations.
  • Performance:These cookies allow us to improve our Sites’ functionality by tracking usage. In some cases, these cookies improve the speed with which we can process your request and allow us to remember site preferences you have selected. Refusing these cookies may result in poorly-tailored recommendations and slow site performance.
  • Social media and Advertising: Social media cookies offer the possibility to connect you to your social networks and share content from our Sites through social media.  Advertising cookies (of third parties) collect information to help better tailor advertising to your interests, both within and beyond our Sites. In some cases, these cookies involve the processing of your personal data. Refusing these cookies may result in seeing advertising that is not as relevant to you or you not being able to link effectively with Facebook, Twitter, or other social networks and/or not allowing you to share content on social media.

USING Mulebar Sites with Third-Party Products and Services

Our Sites allow you to interact with a wide variety of other digital products and services.  For example, our Sites can integrate with third-party devices for social networks and other digital services.

Our Sites may provide links to other (third-party) websites for your convenience or information. Linked sites have their own privacy notices or policies, which we strongly encourage you to review.


CHANGES to Our Privacy Policy

Applicable law and our practices change over time. If we decide to update our privacy policy, we will post the changes on our Sites. We strongly encourage you to read our privacy policy and keep yourself informed of our practices.  This privacy policy was last modified in May 2018.