1. Purpose of This Policy

This Privacy Policy explains how personal data is collected, used, stored and protected when individuals visit https://mbinternational.info, contact MB International or make an enquiry about its professional services.

MB International is committed to processing personal data with clarity, proportionality, confidentiality and respect for the individuals concerned.

2.  Data Controller

Data controller: Matthew Bleakley, operating under the commercial name MB International

NIF/NIE: Y2347255G

Professional address: Calle Pirra 13, 2ºA Madrid 28022 Spain Contact email for privacy matters: contact@mbinternational.info Website: https://mbinternational.info

References in this policy to “MB International”, “MBI”, “we”, “us” or “our” refer to the data controller unless otherwise stated.

A Data Protection Officer has not been appointed because MB International is not presently required to appoint one under the nature and scale of its ordinary website activity.

3.  Applicable Law

Personal data is processed in accordance with applicable data-protection legislation, including:

• Regulation (EU) 2016/679, the General Data Protection Regulation (“GDPR”).
  • Spanish Organic Law 3/2018 on the Protection of Personal Data and Guarantee of Digital Rights (“LOPDGDD”).
  • Spanish Law 34/2002 on Information Society Services and Electronic Commerce (“LSSI-CE”), where applicable.

  • Other applicable Spanish and European data-protection requirements.

4.  Personal Data We May Collect

Depending on how a person interacts with MB International, we may collect:

Contact and identification data

• Name.
  • Professional email address.
  • Organisation.
  • Professional role.
  • Telephone number, where voluntarily provided outside the website form.

  • Other contact details voluntarily supplied.

Enquiry information

• The situation, decision or professional requirement the individual wishes to discuss.
  • The outcome the individual or organisation wishes to achieve.
  • Messages, correspondence and follow-up communications.

  • Information voluntarily included in an enquiry.

Professional engagement information

Where an enquiry develops into a professional relationship, additional information may be collected through a separate engagement process. This may include organisational context, professional objectives, contractual information, billing details, session records or diagnostic information.

Such processing may be governed by additional contractual and confidentiality provisions.

Technical and usage data

Depending on the website configuration and the user’s cookie choices, we may collect:

• IP address.
  • Browser and device information.
  • Operating system.
  • Pages visited.
  • Referral source.
  • Approximate geographic region.
  • Website interaction and performance information.
  • Cookie preferences.

  • Security and server-log information.

Optional analytics or tracking data will only be collected where permitted by law and, where required, after the user has provided valid consent.

Data received from third parties

We may receive personal data from:

• An individual’s employer or organisation.
  • A professional referrer or mutual contact.
  • Event, collaboration or partnership contacts.
  • Publicly available professional sources.

  • Service providers supporting website enquiries or professional administration.

Where data is not obtained directly from the individual, the relevant privacy information will be provided where required by law.

5.  Special Categories of Data

The initial contact form is not designed to collect health information, political opinions, religious beliefs, trade-union membership, biometric data, sexual-orientation information or other special categories of personal data.

Users should not include highly sensitive personal information in an initial website enquiry.

Where special-category data is exceptionally relevant to a subsequent professional engagement, it will only be processed where an appropriate legal basis exists and proportionate safeguards are in place.

6.  Why We Process Personal Data Responding to enquiries

Purpose: To review, understand and respond to enquiries submitted through the website or by email.

Legal basis: Taking steps at the request of the individual before entering into a possible contract and, where relevant, MB International’s legitimate interest in managing genuine professional enquiries.

Assessing engagement suitability

Purpose: To determine whether MB International’s services are appropriate for the situation, objectives and professional environment described.

Legal basis: Pre-contractual steps requested by the individual and MB International’s legitimate interest in accepting only appropriate and aligned engagements.

Delivering contracted services

Purpose: To administer and provide agreed professional services, interventions, strategic partnerships, reports or related work.

Legal basis: Performance of a contract.

Business administration and legal compliance

Purpose: To manage proposals, contracts, invoicing, accounting, taxation, records, legal obligations and professional administration.

Legal basis: Performance of a contract, compliance with legal obligations and legitimate interests in properly administering the business.

Website operation and security

Purpose: To maintain the website, prevent misuse, protect systems, diagnose technical problems and maintain appropriate security.

Legal basis: MB International’s legitimate interest in operating a secure and reliable website and, where applicable, compliance with legal obligations.

Analytics and website improvement

Purpose: To understand how the website is used and improve its structure, accessibility, content and performance.

Legal basis: User consent where analytics involve non-essential cookies or comparable tracking technologies.

Professional updates or communications

Purpose: To send Leadership Signals, publications, professional updates or event information where the recipient has requested them.

Legal basis: Consent or another lawful basis expressly permitted under the LSSI-CE.

Submitting a general enquiry does not automatically subscribe an individual to promotional communications or professional updates. Where marketing consent is required, it is requested separately. Any commercial electronic communications are subject to applicable consent requirements and the exceptions permitted under Spanish Law 34/2002.

Establishing or defending legal claims

Purpose: To preserve evidence and establish, exercise or defend legal rights.

Legal basis: Legitimate interests and applicable legal provisions.

7.  Whether Providing Data Is Required

Fields marked as required on the website form must be completed so that MB International can understand and respond to the enquiry.

If required information is not provided, MB International may be unable to review or respond meaningfully.

Individuals are responsible for ensuring that the information they provide is accurate, relevant and reasonably up to date.

8. Contact-Form Privacy Information

When individuals submit an enquiry through MB International’s website, they are provided with concise information about the processing of their personal data and access to this Privacy Policy before submission.

The information collected through the contact form is used to review and respond to the enquiry, understand relevant professional requirements and assess whether an initial conversation or prospective engagement may be appropriate.

Depending on the circumstances, processing is based on steps requested by the individual before entering into a potential contract (Article 6(1)(b) GDPR), or MB International’s legitimate interest in managing genuine professional enquiries (Article 6(1)(f) GDPR), where applicable and appropriately assessed.

Submission of the contact form does not automatically enrol an individual in a mailing list or authorise unrelated promotional communications.

Where MB International separately offers newsletters, publications or promotional updates that require consent, the individual will be provided with a separate, optional means of giving that consent.

Individuals are encouraged not to submit sensitive personal information or confidential information relating to third parties through the initial contact form.

Further information about processing purposes, recipients, retention, international transfers and individual rights is provided in this Privacy Policy.

9.  Data Retention

Personal data will be retained only for as long as reasonably necessary for the purpose for which it was collected and for any applicable legal or professional obligations.

Indicative retention criteria are:

• Unsuccessful or non-progressing enquiries: ordinarily up to 12 months after the last substantive communication, unless a shorter or longer period is justified.
  • Active pre-contractual discussions: for the duration of the discussion and a reasonable follow-up period.
  • Client and contractual records: for the duration of the professional relationship and the legally required limitation, tax and accounting periods.
  • Invoices and tax documentation: for the periods required by Spanish tax, accounting and commercial law.
  • Consent records: for as long as necessary to demonstrate valid consent and manage withdrawal.
  • Website security logs: for a proportionate security and troubleshooting period.
  • Newsletter data: until the individual unsubscribes or consent is otherwise withdrawn, subject to retaining a minimal suppression record where necessary.

  • Potential legal claims: for the applicable limitation period.

Data may be securely blocked or restricted rather than immediately deleted where retention is required to meet a legal obligation or defend legal rights.

10. Recipients and Service Providers

MB International does not sell personal data.

Personal data may be disclosed to, or accessed by, recipients and service providers where necessary for legitimate professional operations, the performance of agreed services or compliance with applicable legal obligations.

Depending on the relevant activity, these may include:

• Website hosting, maintenance and technical-support providers.

• Email, communications and business-productivity providers.

• Contact-form delivery and website-security providers.

• Cloud storage and document-management providers.

• Customer relationship management, scheduling and business-administration providers.

• Professional collaborators and delivery partners where their involvement is necessary and appropriately authorised.

• Accounting, tax, legal and other professional advisers.

• Public authorities where disclosure is required by law.

Access is limited according to the purpose of processing and the recipient’s responsibilities.

Where a service provider acts as a processor on behalf of MB International, the relationship is governed by the contractual and data-protection requirements applicable under Article 28 GDPR.

Where another organisation acts as an independent controller, the relevant sharing is assessed according to the applicable legal basis and transparency requirements.

Further information about relevant recipients or categories of recipients may be requested at contact@mbinternational.info.

11. International Data Transfers

MB International operates internationally and uses digital services that may involve the storage of, access to or processing of personal data outside the European Economic Area (EEA).

Where personal data is transferred to a country outside the EEA, MB International will assess the applicable requirements under Chapter V of the GDPR.

Depending on the circumstances, an international transfer may be supported by:

• An adequacy decision adopted by the European Commission.

• Appropriate safeguards, such as the European Commission’s Standard Contractual Clauses, together with any supplementary measures required.

• The EU–US Data Privacy Framework, where the relevant US recipient is appropriately certified and the framework applies.

• Another transfer mechanism or narrowly applicable derogation permitted by the GDPR.

International transfers are assessed with regard to the country, recipient, type of personal data and applicable safeguards.

Individuals may request further information about relevant international transfer arrangements, including how to obtain or access applicable safeguards, by contacting contact@mbinternational.info.

12.  Automated Decisions and Profiling

MB International does not use website-enquiry data to make solely automated decisions producing legal or similarly significant effects.

Website analytics may generate aggregated or pseudonymous usage profiles where the user has consented, but these are not used to make significant automated decisions about individuals.

13.  Data Security

MB International applies proportionate technical and organisational measures intended to protect personal data against unauthorised access, alteration, disclosure, loss or destruction.

Measures may include:

• Access controls.
  
  

  • Strong authentication.

• Secure hosting and encrypted connections.
  • Restricted administrative permissions.
  • Software and plugin maintenance.
  • Secure backups.
  • Confidentiality obligations.
  • Provider due diligence.
  • Data minimisation.

  • Appropriate incident-response procedures.

No internet transmission or storage system can guarantee absolute security. Users should avoid transmitting unnecessary sensitive information through the initial website form.

14.  Individual Rights

Subject to the conditions established by law, individuals may exercise the following rights:

• Access: To ask whether their personal data is being processed and receive a copy.
  • Rectification: To correct inaccurate or incomplete data.
  • Erasure: To request deletion where there is no lawful reason to continue processing.
  • Restriction: To request that processing be limited in certain circumstances.
  • Objection: To object to processing based on legitimate interests or to direct marketing.
  • Portability: To receive certain data in a structured, commonly used and machine-readable format and, where technically feasible, transmit it to another controller.
  • Withdrawal of consent: To withdraw consent at any time, without affecting processing already carried out lawfully before withdrawal.

  • Human intervention: Where applicable, not to be subject to qualifying solely automated decisions and to request human review.

Requests may be sent to:

Email: contact@mbinternational.info

Postal address: Calle Pirra 13, 2ºA Madrid 28022 Spain

The request should identify the individual and clearly state the right being exercised. Additional information may be requested where reasonably necessary to verify identity and protect personal data.

Requests will ordinarily be addressed within one month, subject to extensions permitted by the GDPR for complex or numerous requests.

15.  Complaints to the Supervisory Authority

Individuals who believe that their data-protection rights have been infringed may lodge a complaint with the Spanish Data Protection Agency:

Supervisory authority: Agencia Española de Protección de Datos (AEPD)

Website: https://www.aepd.es

Individuals have the right to lodge a complaint with the AEPD where they consider that the processing of their personal data infringes applicable data-protection law.

Individuals are encouraged, although not required, to contact MB International first so that the concern can be examined and addressed directly.

16.  Data Concerning Other People

A user who provides personal data concerning another person must ensure that they are legally entitled to do so and that the other person has received the necessary privacy information where required.

Users should not submit confidential information about colleagues, employees, clients or third parties unless it is necessary, proportionate and lawful.

17.  Children

The website and MB International’s professional services are directed primarily toward adult professionals and organisations.

The website is not designed to knowingly collect personal data directly from children. Individuals under 14 should not submit personal information through the website without the involvement and authorisation required under Spanish law.

18. Cookies and Similar Technologies

The MB International website uses cookies and similar technologies to support website functionality, maintain security, remember applicable preferences and, where enabled and authorised, analyse website use or provide additional functionality.

Cookies and similar technologies that are strictly necessary for the operation of the website or for services explicitly requested by the visitor may be used without consent where permitted by applicable law.

Other cookies and comparable tracking technologies requiring consent will only be activated after the visitor has provided valid consent.

Visitors may accept, reject or configure optional cookies using the website’s consent-management system. They may also withdraw or change their choices through the available cookie-preference controls.

For information about the cookies used, their purposes, providers, retention periods and consent settings, please consult our Cookie Policy.

19.  Links to Other Websites

The website may link to external services. This Privacy Policy does not govern third-party websites.

Users should review the privacy information of each external service before providing personal information.

20.  Changes to This Policy

MB International may update this Privacy Policy to reflect changes in law, technology, website functionality or professional operations.

Material changes will be communicated through the website where appropriate.

Effective date: 30/07/2026

Last updated: 21/10/2026