Legal

Privacy policy

How we collect, use, and protect personal information — including the business contact data behind every campaign we run.

Last updated September 25, 2026

Draft — pending legal review

This document follows the structure and disclosure standard expected of a firm of this kind, but it has not been reviewed by counsel and it is not legal advice.

01

Who we are

Mogul is an appointment-setting, SDR, and closing firm, and issues this policy. Our registered company details are available on request at privacy@mogul.com.

For the purposes of the UK GDPR and the EU GDPR, we act as a controller of the information described in this policy, except where we run campaigns using data supplied by a client — in that case the client is the controller and we act as their processor under a written data processing agreement.

Our data protection contact is reachable at privacy@mogul.com.

02

What this policy covers

This policy applies to three groups of people:

  • Visitors to this website — anyone browsing our pages or submitting the intake form.
  • Prospects we contact — people at target companies we approach on our own behalf or on behalf of a client.
  • Clients and their teams — people at firms that engage us, including users of the client portal.

It does not cover third-party sites we link to. It does not cover data we process purely as a client’s processor, which is governed by that client’s own privacy notice and our data processing agreement with them.

03

Information we collect

From website visitors

  • Information you submit through the intake form: name, company, work email, phone number, and the answers you give about business type, offer, contract value, revenue range, sales capacity, market, constraint, and objective.
  • If you opt in to text messages on our contact form or fit-call request form: your mobile number and a record of that consent — see SMS / Text messaging below.
  • Server logs generated automatically when you request a page, including IP address, user agent, referring page, and timestamp.

From prospects we contact

  • Business contact details: name, job title, employer, business email address, business phone number, and public professional profile URLs.
  • Business context used to decide whether and why to make contact: company size, sector, location, publicly reported funding or leadership changes, and similar commercial signals.
  • A record of our correspondence with you, including messages sent, replies received, and any request you make to stop being contacted.

We do not seek or knowingly collect special category data, government identifiers, financial account details, or personal (non-business) contact details for prospecting.

From clients

  • Contact and billing details for the individuals who administer the engagement.
  • Account credentials and activity records for the client portal.
  • Any data a client supplies to us for a campaign, which we process under their instructions.
04

Where prospect information comes from

If we contacted you and you never gave us your details, this section is the one you want.

Your details were obtained from one or more of the following, and never from anywhere else:

  • Publicly accessible sources — your employer's website, public professional networking profiles, public company registers, published press coverage, conference and speaker listings, and public regulatory filings.
  • Licensed business-data providers who contract with us and warrant that they collected the data lawfully and permit its use for business-to-business contact.
  • Our own research, where a researcher located or verified your role and business email from the sources above.
  • A client, where they supplied a named target list. In that case the client is the controller and their privacy notice applies alongside this one.

We do not buy general-purpose mailing lists, scrape data from behind logins or paywalls, harvest personal email addresses, or use tools that guess at addresses in bulk and send to whatever does not bounce.

We contact you in your professional capacity, at your place of work, about a matter relevant to your role. We do not contact people at home.

05

Why we use it, and on what legal basis

Legitimate interests

Most of our prospecting relies on legitimate interests (UK/EU GDPR Article 6(1)(f)) — our interest, and our client’s, in offering a relevant commercial service to a business likely to want it. We have carried out a legitimate interests assessment weighing that against your rights, and we keep it on file. You can request a summary at any time.

Because we obtained your details indirectly, Article 14 requires that we tell you what we hold, where it came from, and how to object. This section and the one above are that notice, and every message we send links here.

Consent

Where the law of your jurisdiction requires opt-in consent before commercial electronic messages — including Canada under CASL, and any market where implied consent for B2B contact is not available — we obtain consent before sending, or we do not send.

Contract

We process client and portal-user data to perform our agreement with the client and to administer the engagement.

Legal obligation

We retain records where tax, accounting, or regulatory rules require it, and to evidence compliance with marketing law.

06

Who we share it with

We do not sell personal information. We share it only with:

  • The client on whose behalf a campaign is run, where you replied or agreed to a conversation. If you did not respond, your details are not passed on.
  • Service providers who process data on our instructions under written contract — email delivery, CRM and pipeline software, data enrichment and verification, calendar scheduling, cloud hosting, and telephony.
  • Professional advisers, including lawyers and accountants, where they need it to advise us.
  • A buyer or successor, if the business or part of it is sold, merged, or reorganized.
  • Authorities, where we are legally required to disclose it.

No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. All of the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties or affiliates under any circumstances.

A current list of our processors is available on request at privacy@mogul.com.

07

International transfers

We work with clients and prospects in more than one country, and some of our processors are located outside the UK and the EEA, including in the United States.

Where personal data is transferred outside the UK or the EEA, we rely on an adequacy decision where one applies, and otherwise on the UK International Data Transfer Addendum or the European Commission’s Standard Contractual Clauses, together with a transfer risk assessment. A copy of the safeguards applying to a given transfer is available on request.

08

How long we keep it

  • Prospect records — kept only while it remains relevant after the last meaningful contact, then deleted or anonymized.
  • Suppression records — kept indefinitely. If you ask us to stop contacting you we must keep a minimal record of that request, otherwise we cannot reliably honor it.
  • Intake submissions — kept only as long as needed to follow up where no engagement follows.
  • Client records — kept for the engagement and then for as long as contractual, tax, and accounting requirements oblige us to.
09

Your rights

Depending on where you live, you may have the right to ask us to:

  • Confirm what personal information we hold about you and give you a copy.
  • Correct information that is inaccurate or incomplete.
  • Delete information we no longer have grounds to keep.
  • Restrict how we use it while a dispute is resolved.
  • Provide it in a portable, machine-readable format.
  • Object to processing based on legitimate interests — including, at any time and for any reason, our use of your information for direct marketing. When you object to direct marketing we stop, without exception and without asking why.

If you are in California, the CCPA as amended by the CPRA gives you rights to know, delete, correct, and to opt out of sale or sharing. We do not sell or share personal information as those terms are defined, and we will not discriminate against you for exercising any right.

To exercise any right, email privacy@mogul.com. We respond within one month, and we do not require you to create an account to make a request.

You may also complain to a supervisory authority. In the UK that is the Information Commissioner’s Office; in the EU it is the authority where you live or work. We would rather you came to us first.

10

How to stop hearing from us

Any one of these works, and none of them requires a reason:

  • Reply to any message with the word stop, or anything else that makes the request clear. A person reads it.
  • Use the unsubscribe link at the foot of any email we send.
  • Email optout@mogul.com from any address, and tell us which address or company to suppress.

We action requests promptly, and in any case within 10 business days, which is the CAN-SPAM outer limit. Your details go onto a suppression list so no future campaign — ours or a client’s — reaches you again. Suppression can be applied to a whole domain if you ask.

11

SMS / Text messaging

Mogul runs one text messaging program: non-marketing service messages to people who have asked for them. We do not run a marketing text program. Consent to texts is never a condition of any purchase or of sending a form, and it is never inferred from a purchase, an inquiry, or a phone number given for another reason.

How you opt in

A visitor can opt in on either of two website forms: the contact form at https://www.sellwithmogul.com/contact, or the fit-call request form on our homepage (https://www.sellwithmogul.com/#intake). On each, they enter a phone number and tick a checkbox, unticked by default, next to the consent wording. The checkbox is separate from the rest of the form, is not bundled with any other agreement, and is not required to send the form. A number entered without ticking the box is never enrolled.

What we send

  • Replies to an inquiry you sent us
  • Scheduling, confirmations and reminders for fit calls and meetings
  • Client account updates, including onboarding steps, contract signing links, and invoice and payment notices
  • Customer support

What we never send

  • Marketing or promotional messages of any kind
  • Messages to numbers taken from purchased or third-party lead lists
  • Messages sent on behalf of our clients or any other third party
  • Unrelated advertising

What we record when you opt in

Your mobile number, the exact consent wording you were shown, the version of that wording, the time you agreed, the page you agreed on, and the IP address and browser the request came from. We keep this record as evidence of your consent for as long as we might text you and for four years after, which is the limitation period for claims about text messages in the United States.

Frequency and cost

Message frequency varies. Message and data rates may apply. Mogul does not charge for text messages, but your mobile carrier may.

How to stop

Reply STOP to any message to opt out. You will receive one confirmation and no further texts from us. Your number goes onto our do-not-text list, which every message we send is checked against. You can also ask us to stop by emailing hello@mogul.com.

How to get help

Reply HELP to any message, email hello@mogul.com, or call +1-208-500-2396.

Sharing

We share your mobile number with our SMS delivery provider solely to deliver the text messages you have requested.

No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. All of the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties or affiliates under any circumstances.

12

Cookies and site measurement

This site sets no advertising or analytics cookies, and we do not embed third-party trackers in it. Our outbound emails contain no tracking pixels.

Full detail, including the strictly necessary cookies used by the client portal, is in our cookie policy.

13

How we protect it

  • Access to prospect and client data is limited to the people on that engagement, on a least-privilege basis.
  • Data is encrypted in transit and at rest with our hosting and CRM providers.
  • Accounts require individual credentials and multi-factor authentication.
  • Processors are contracted with confidentiality and security obligations, and reviewed before engagement.
  • We maintain a documented procedure for handling suspected breaches, including notification to regulators and affected individuals where the law requires it.

No system is perfectly secure, and we do not claim otherwise. We would rather tell you what we actually do than promise unqualified safety.

14

Children

Our services are directed at businesses. We do not knowingly collect information from anyone under 16. If you believe we hold information about a child, contact us and we will delete it.

15

Changes to this policy

We update this policy when our practices change. The date at the top reflects the current version. Where a change materially affects how we use information we already hold, we will take reasonable steps to tell affected people directly rather than relying on this page alone.

16

How to contact us

Privacy questions, rights requests, and complaints: privacy@mogul.com.

To stop being contacted: optout@mogul.com.

By post: our postal address is available on request at legal@mogul.com.

Everything else is on our contact page.