Legal

Data Handling Statement

Last updated: 20 June 2026

Operated by Muloo (Pty) Ltd (South Africa). This is a plain-language description of how Muloo Signals actually handles data — it is not legal advice. Questions: legal@muloo.co.

This is the plain-English description of what Muloo Signals does with data. Everything in our Privacy Policy and DPA derives from this. The product is a HubSpot-connected tool that helps B2B teams identify prospects, research companies, draft personalised LinkedIn outreach, manage a human-approved task queue, and sync qualified leads into HubSpot. No risky LinkedIn automation, no auto-send, no spam workflows.

1. Data we process

Customer account data: user name, email, auth credentials, and workspace/portal config.

HubSpot data (via OAuth): contacts, companies, deals, tasks and notes — read, and with write scopes, written. Scoped per connected portal; portals are isolated.

Lead/prospect data: business-context data on prospects and their companies (name, role, company, public professional signals) used to research and draft outreach.

Generated content: AI-drafted outreach text and provenance/audit metadata.

2. How the data flows

1. You connect HubSpot via OAuth. Access and refresh tokens are encrypted at rest (AES via an application secret); the app fails closed if the secret is absent.

2. You bring leads in — CSV upload, paste, or a read-only HubSpot pull.

3. The app researches the company/prospect and drafts outreach using an AI sub-processor (Anthropic Claude). Drafts carry provenance and audit records.

4. Drafts enter a human-approved task queue. Nothing sends or syncs without a human action.

5. On approval, the app writes qualified leads, tasks and notes back into your HubSpot portal, recorded in a reversible sync log.

6. Compliance guardrails (send-guard, opt-out handling, a manual-send banner, and a /compliance audit page) gate outbound activity.

3. Sub-processors

All are hosted outside South Africa, so each is a cross-border transfer under POPIA s72, addressed via contractual data-protection terms and customer consent (see the DPA).

HubSpot, Inc. (USA) — the CRM the product integrates with: contacts, companies, deals, tasks, notes.

Anthropic, PBC (USA) — AI drafting of outreach: prospect/company context for the draft.

Railway (USA) — app and Postgres database hosting: all application data at rest.

Paystack — subscription billing: customer billing/contact data.

4. Security posture

HubSpot OAuth tokens encrypted at rest; per-portal tenant isolation; fail-closed on a missing auth secret; audit and reversible sync logs; least-scope OAuth. Disconnecting or uninstalling deletes the stored OAuth tokens and stops processing.

5. Retention

Data is retained for the life of the account and deleted on account closure or on request. See the Privacy Policy for details.

6. Lawful processing

Under POPIA s11 — performance of a contract and the legitimate interests of the parties for B2B prospecting, with opt-out honoured (POPIA s69 governs electronic direct marketing; our human-approved and opt-out design satisfies it). Where a customer or data subject is in the EU/UK, the equivalent GDPR/UK GDPR legal bases apply in parallel. Customers are the Responsible Party (controller); Muloo is the Operator (processor) for CRM/lead data they bring.