Privacy Policy.

Purpose of this Notice

This notice describes how we collect and use personal data about you, in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time (together, the "Data Protection Legislation").

Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

McNulty Business Advisory ("McNulty", "we", "us", "our" and "ours") is a business advisory firm based in Belfast, Northern Ireland.

For the purpose of the Data Protection Legislation and this notice, we are the "data controller". This means we are responsible for deciding how we hold and use personal data about you. We are required under the Data Protection Legislation to notify you of the information contained in this privacy notice.

We have appointed a Data Protection Point of Contact who is responsible for assisting with enquiries in relation to this privacy notice or our treatment of your personal data. Should you wish to contact our Data Protection Point of Contact, you can do so using the details in Section 12.

How We Collect Personal Data

We may collect personal data about you in a number of ways:

• Directly from you — when you contact us, book a discovery call, email us, or engage our services.
• From your accountant or professional advisor — when they engage us on your behalf.
• Automatically — via cookies and similar technologies when you visit our website (see our Cookie Policy).
• From third parties — such as Companies House, credit reference agencies, or public registers, where relevant to the services we provide.

We may process your personal data for purposes necessary for the performance of our contract with our clients and to comply with our legal obligations.

We may also process your personal data where you are an employee, subcontractor, supplier, or customer of our client, in the context of delivering our services to them.

Please note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.

Categories of Data We Collect

Depending on your relationship with us, we may collect and process the following categories of personal data:

• Identity data — name, title, job title, professional qualifications.
• Contact data — postal address, email address, telephone numbers.
• Financial data — bank account details, payment information, and financial information relevant to the advisory services we provide.
• Transaction data — details of services provided, invoices, and payment history.
• Technical data — IP address, browser type and version, time zone, device information.
• Marketing and communications data — your preferences in receiving communications from us.

We do not knowingly collect special categories of personal data (such as data revealing racial or ethnic origin, political opinions, religious beliefs, health data, or biometric data) unless expressly required to do so for the purposes of a specific engagement.

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:

• To carry out our obligations arising from any agreements entered into between our clients and us — which will most usually be for the provision of our advisory services — where you may be a subcontractor, supplier, or customer of our client.
• To provide you with information related to our services, events, and activities you request from us or which we feel may interest you, provided you have consented to be contacted for such purposes.
• To seek your thoughts and opinions on the services we provide.
• To notify you about any changes to our services.
• To comply with our legal and regulatory obligations.
• Where necessary for our legitimate interests (such as business development, marketing, and internal administration) — provided those interests do not override your own interests, rights and freedoms.

In some circumstances we may anonymise or pseudonymise the personal data so that it can no longer be associated with you, in which case we may use it without further notice to you.

If you refuse to provide us with certain information when requested, we may be unable to perform the contract we have entered into with you, or we may be unable to comply with our legal or regulatory obligations.

We may also process your personal data without your knowledge or consent, in accordance with this notice, where we are legally required or permitted to do so.

Data Retention

We will only retain your personal data for as long as is necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements.

When assessing what retention period is appropriate, we take into consideration:

• The requirements of our business and the services provided.
• Any statutory or legal obligations — for example, HMRC requires retention of certain financial records for a minimum of six years.
• The purposes for which we originally collected the personal data.
• The lawful grounds on which we based our processing.
• The types of personal data we have collected.
• The amount and categories of personal data involved.
• Whether the purpose of the processing could reasonably be fulfilled by other means.

In some circumstances, you can ask us to delete your data: see Section 8 (Your Rights) below.

Change of Purpose

Where we need to use your personal data for another reason, other than for the purpose for which we collected it, we will only use your personal data where that reason is compatible with the original purpose.

Should it be necessary to use your personal data for a new, unrelated purpose, we will notify you and communicate the legal basis which allows us to do so before starting any new processing.

Data Sharing

Why might we share your personal data with third parties?

We will share your personal data with third parties where we are required by law, where it is necessary to administer the relationship between us, or where we have another legitimate interest in doing so.

Which third-party service providers process your data?

Third parties include third-party service providers and the members of our professional network. The following activities are carried out on our behalf by third-party service providers:

• IT and cloud hosting services
• Professional advisory services (including external accountants, lawyers, and specialist consultants)
• Administrative and back-office services
• Marketing and communications services
• Banking and payment services
• Online appointment booking — Calendly, which receives the details you enter when you book a meeting
• Card payments for booking deposits — Stripe; we do not see or store your card details

All of our third-party service providers are required to take commercially reasonable and appropriate security measures to protect your personal data. We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions.

Other third parties

We may share your personal data with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal data with a regulator or to otherwise comply with the law.

International transfers

Where personal data is transferred outside the United Kingdom or the European Economic Area, we ensure appropriate safeguards are in place — including UK International Data Transfer Agreements, adequacy decisions, or Standard Contractual Clauses — to protect your data.

Your Rights

Your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Should your personal information change, please notify us of any changes of which we need to be made aware by contacting us using the details below.

Your rights in connection with personal data

Under certain circumstances, by law you have the right to:

• Request access to your personal data. This enables you to receive details of the personal data we hold about you and to check we are processing it lawfully.
• Request correction of the personal data we hold about you.
• 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 exercised your right to object to processing.
• 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data, for example if you want us to establish its accuracy or the reason for processing it.
• Request transfer of your personal data to you or another data controller if the processing is based on consent, carried out by automated means, and this is technically feasible.

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 or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is an appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Withdrawing Consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose (for example, in relation to direct marketing), you have the right to withdraw your consent for that specific processing at any time.

To withdraw your consent, please email us at kevin@mcnultybusinessadvisory.com.

Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) you originally agreed to, unless we have another legitimate basis for doing so in law.

Security

We have put in place appropriate technical and organisational 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, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and 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.

Changes to this Notice

Any changes we may make to our privacy notice in the future will be updated on this page.

Where the changes are material, we will notify you directly using the contact details you have provided to us. We encourage you to review this notice periodically so you are aware of how we collect and use your personal data.

This privacy notice was last updated on 18 September 2026.

Contact Us

If you have any questions regarding this notice, or if you would like to speak to us about the manner in which we process your personal data, please contact our Data Protection Point of Contact:

Information Commissioner's Office

You also have the right to make a complaint to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues, at any time. The ICO's contact details are:

• Address: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
• Telephone: 0303 123 1113 (local rate) or 01625 545 745
• Website: https://ico.org.uk/concerns

We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.