INTRODUCTION
Sula Expeditions Ltd, a company registered in Scotland with company no. SC857556 Our registered office address is 3 Regent Street, Keith, AB55 5DW, operating under the Trade Name Mull Wildlife Breaks. Mull Wildlife Breaks respects your privacy and is committed to protecting your personal data.
This Privacy Policy will inform you as to how we look after your personal data when you provide personal data to us during the process of your bookings through email communication or by other means (such as over the telephone) and tell you about your privacy rights and how the law protects you.
PURPOSE OF THIS PRIVACY POLICY
This Privacy Policy aims to give you information on how we collect and process your personal data, including any data you may provide to us through our email communications or over telephonic communication.
It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other notices and is not intended to override them.
If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us using our info@mullwildlifebreaks.co.uk address.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
Changes to the Privacy Policy and your duty to inform us of changes
We keep our Privacy Policy under regular review. This policy has been created in October 2025 and historic versions will be collected and kept for consultations on requests if any changes to it occur. It is important that the personal data we hold about you is accurate and current. Please keep us informed if any of the details you provide to us should change, during the course of your relationship with us.
THIRD-PARTY LINKS
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
THE DATA WE COLLECT ABOUT YOU
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). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data
This includes data relating specifically to your identity, such as your first name, maiden name, last name, marital status, and title.
Contact Data
This includes data relating to how you may be contacted, such as your billing address, delivery address, email address and telephone numbers.
Financial Data
This includes data relating to your means and methods of payment, such as your bank account details.
Transaction Data
This includes data relating to the transactions you have carried out with us, such as details about payments to and from you.
Marketing and Communications Data
This includes your preferences in relation to whether or not you want to receive marketing from us and your communication preferences.
Special Categories of Personal Data
We collect the following special categories of personal data about you. Details about your dietary requirements which may disclose your religious or philosophical beliefs as well as your health.
We collect and process the above data only where it is strictly necessary to do so in order to deliver the Break that you have purchased. Furthermore, we will only collect and process the above special categories of sensitive personal data where you have provided us with your explicit consent to do so.
You are not under any obligation to consent to us processing your sensitive personal data. However, without your consent, we won’t be able to make the necessary arrangements to provide the Break that you have booked or are attempting to book. As a result, if you do not provide your consent, we will be unable to proceed with your booking.
If you are happy to consent to our use of your sensitive personal data, you will also be able to withdraw your consent at any time. However, as this will prevent us from providing the Break you have booked, we will be required to treat any withdrawal of consent as a cancellation of your booking and the cancellation charges referred to in clause 7 in our applicable Terms and Conditions will become payable.
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.
In other words, where we require details from you in order to provide you with your chosen Break, if you do not provide us with the necessary details then we will not be able to provide the services you have booked or are attempting to book.
In this case, depending upon when you fail to provide the necessary data, we may either not be able to process your booking or we may have to cancel your booking, in which case we will treat this as a ‘cancellation by you’ in accordance with clause 7 of our applicable Booking Terms and Conditions.
HOW YOUR PERSONAL DATA IS COLLECTED
We use different methods to collect data from and about you including through:
Direct interactions
You may give us your Identity, Contact, Financial Data, Transaction, Technical, Profile, Usage and Marketing and Communications by filling in forms or by corresponding with us by post, phone, email or otherwise.
Third parties
We may receive personal data about you from various third parties as set out below:
Technical Data from the following parties:
- analytics providers such as Google Analytics based outside the UK;
 - advertising networks such as Google Ads and Facebook Ads based outside the UK.
 
Please note that when using our social networks like Facebook, Instagram and LinkedIn, you may be able to share information through them. For example, when you ‘like’, ‘share’ or review our services. When doing this, your personal information may be visible to the providers of those social networks and/or their other users. Please remember it is your responsibility to set appropriate privacy settings on your social network accounts so you are comfortable with how your information is used and shared on them. This will not be the responsibility of Sula Expeditions Ltd.
HOW WE USE YOUR PERSONAL DATA
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.
Purposes for which we will use your personal data
We have set out below, in a table format, 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.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest | 
| To allow the completion of a booking, communication between company and customer regarding their booking, highlight special requests, marketing, reporting/analysis. | (a) Lead Name (b) Email Address (c) Telephone number (d) Country (e) All passenger names (f) Customer supplied accommodation details  | Performance of a contract with you; Article 6(1)(b) – contract. | 
| To allow the completion of a booking, communication between company and customer regarding their booking, highlight special requests, marketing, reporting/analysis. | (a) Special Requirements | Performance of a contract with you; Article 6(1)(b) – contract. Article 9 condition for processing special category data; Article 9(2)(a) – explicit consent.  | 
| To allow the completion of payment for a booking. | (a) Name (b) Billing address  | Performance of a contract with you; Article 6(1)(b) – contract. | 
| To allow the completion of a booking, communication between company and customer regarding their booking, highlight special requests, marketing, reporting/analysis. | (a) Passenger count (b) Assistance information  | Performance of a contract with you; Article 6(1)(b) – contract. | 
| To monitor our communications with you in order to check any instructions given to us, for training purposes, for crime prevention, to improve the quality of our customer service and to defend legal claims. | (a) Identity (b) Contact (c) Technical  | (a) Necessary for our legitimate interests (to assist us in training our employees and defend our business in the event of a claim). (b) Necessary to comply with a legal obligation.  | 
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.
DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table above.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change 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 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.
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.
DATA RETENTION
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
Details of retention periods for different aspects of your personal data can be requested by contacting us.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
- 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.
 
If you wish to exercise any of the rights set out above, please email us at info@mullwildlifebreaks.com
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.
