PRIVACY POLICY

1. Definitions and Interpretation

   In this Policy the following terms shall have the following meanings:

   “Account”	means an account required to access and/or use certain areas and features of Our Site;
   “Cookie”	means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14, below; and
   “Cookie Law”	means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;

2. Information About Us

   Our Site is owned and operated by Comera Group Limited, a limited company registered in England under company number 6340829.

   Registered address: Origin Workspace, 40 Berkley Square, Bristol, BS8 1HP, United Kingdom

   Comera Financial Consultants are regulated by the Financial Conduct Authority, No 488266.

3. What Does This Policy Cover?

   This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

4. What Is Personal Data?

   Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

   Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

5. What Are My Rights?

   Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

   1. The right to be informed about Our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 15.
   2. The right to access the personal data we hold about you. Part 13 will tell you how to do this.
   3. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
   4. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 15 to find out more.
   5. The right to restrict (i.e. prevent) the processing of your personal data.
   6. The right to object to us using your personal data for a particular purpose or purposes.
   7. The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
   8. The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
   9. Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

   For more information about Our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.

   It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.

   Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

   If you have any cause for complaint about Our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

   We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 15.

6. What Data Do You Collect and How?

   Depending upon your use of Our Site, we may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table. Please also see Part 14 for more information about Our use of Cookies and similar technologies. We do not collect any ‘special category’ or ‘sensitive’ personal data, personal data relating to children or data relating to criminal convictions and/or offences.

   Data Collected	How We Collect the Data
   Identity Information including name, title, photo.	This data may be collected as part of account registration or managment.
   Contact information including address, email address, telephone number.	This information will be collected as part of the checkout process for shipping and billing purposes.
   Business information including business name, industry, job title, profession.	This information will be collected as part of the checkout process for shipping and billing purposes.
   Payment information including card details.	Collected at checkout for processing payments
   Profile information including preferences, interests, login details, purchase history.	This information may be organically collected as you interact with our store.
   Technical information including IP address, browser type and version, operating system.	May be be collected by analytics plugins

7. How Do You Use My Personal Data?

   Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data, and Our lawful bases for doing so:

   What We Do	What Data We Use	Our Lawful Basis
   Providing and managing your Account.	Identity Information, Contact Information, Business Information, Profile Information	Necessary is order to verify and process orders
   Providing and managing your access to Our Site.	Profile Information, Technical Information	Consent
   Administering Our Site.	Identity Information, Contact Information, Business Information, Profile Information	To ensure our site continues operating and to resolve technical issues
   Administering Our business.	Identity Information, Contact Information, Business Information, Profile Information	To ensure orders are processed and delivered.
   Supplying Our products and services to you.	Identity Information, Contact Information, Business Information	Contract
   Managing payments for Our products and services.	Identity Information, Payment Information	Contract
   Communicating with you.	Identity Information, Contact Information, Business Information	Keeping you informed on order progress
   Supplying you with information by email that you have opted-in-to (you may opt-out at any time by clicking the unsubscribe link at the bottom of any marketing emails	Identity Information, Profile Information, Contact Information	Consent

   With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email with information, news, and offers on Our products and services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with Our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.

   We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 15.

   If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.

   In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

8. How Long Will You Keep My Personal Data?

   We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

   Type of Data	How Long We Keep It
   Identity Information including name, title, photo	As long as an account is active and for a 3 year period after last activity
   Contact information including address, email address, telephone number.	As long as an account is active and for a 3 year period after last activity
   Business information including business name, job title, profession.	As long as an account is active and for a 3 year period after last activity
   Payment information including card details	We do not keep this information
   Profile information including insert data collected, e.g. preferences and interests, username and password, purchase history.	As long as an account is active and for a 3 year period after last activity. Purchase records may be kept longer if required by HMRC or regulatory bodies.
   Technical information including IP address, browser type and version, operating system.	6 months

9. How and Where Do You Store or Transfer My Personal Data?

   We will only store your personal data in the UK. This means that it will be fully protected under the Data Protection Legislation.

   The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:

   • limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
   • procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so;

10. Do You Share My Personal Data?

    We may share your personal data with other companies in Our group for the purpose of service delivery and business administration. This includes subsidiaries

    If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, Our obligations, and the third party’s obligations under the law, as described above in Part 9.

    If we sell, transfer, or merge parts of Our business or assets, your personal data may be transferred to a third party. Any new owner of Our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.

    In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

11. How Can I Control My Personal Data?

    In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via Our Site, you may be given options to restrict Our use of your personal data. In particular, we aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details).

    You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

12. Can I Withhold Information?

    You may access certain areas of Our Site without providing any personal data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.

    You may restrict Our use of Cookies. For more information, see Part 14.

13. How Can I Access My Personal Data?

    If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

    All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15.

    There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover Our administrative costs in responding.

    We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of Our progress.

14. How Do You Use Cookies?

    Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our products and services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

    All Cookies used by and on Our Site are used in accordance with current Cookie Law.

    Before Cookies are placed on your computer or device, you will be shown a pop-up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended. You will be given the opportunity to allow only necessary Cookies.

    Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown in the table below. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.

    Our Site uses analytics services provided by Google and Zoho. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how Our Site is used. This, in turn, enables us to improve Our Site and the products and services offered through it.

    The analytics service(s) used by Our Site use(s) Cookies to gather the required information. You do not have to allow us to use these Cookies, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable us to continually improve Our Site, making it a better and more useful experience for you.

    The following Cookies are used on our site:

    Cookie	Duration	Description
    b3e783bb62		This cookie is set by the provider Zoho. This cookie is used for collecting information on user interaction with the web-campaign content. This cookie helps the website owners to promote products and events on the CRM-campaign-platform.
    cookielawinfo-checkbox-advertisement	1 year	The cookie is set by GDPR cookie consent to record the user consent for the cookies in the category "Advertisement".
    cookielawinfo-checkbox-analytics	11 months	This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Analytics".
    cookielawinfo-checkbox-functional	11 months	The cookie is set by GDPR cookie consent to record the user consent for the cookies in the category "Functional".
    cookielawinfo-checkbox-necessary	11 months	This cookie is set by GDPR Cookie Consent plugin. The cookies is used to store the user consent for the cookies in the category "Necessary".
    cookielawinfo-checkbox-others	11 months	This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Other.
    cookielawinfo-checkbox-performance	11 months	This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Performance".
    LS_CSRF_TOKEN	session	This cookie is set by the provider Cloudflare. This cookie is used for the purpose of website security that is Cross-Site-Request forgery prevention. It is used to identify the trusted web traffic.
    mailchimp_landing_site	1 month	The cookie is set by the email marketing service MailChimp.
    PHPSESSID	session	This cookie is native to PHP applications. The cookie is used to store and identify a users' unique session ID for the purpose of managing user session on the website. The cookie is a session cookies and is deleted when all the browser windows are closed.
    sales1.comeragroup-_zldp	2 years	This cookie is set by the provider Zoho. This cookie identifies unique visits for a visitor in the website.
    sales1.comeragroup-_zldt	1 day	This cookie is set by the provider Zoho. This cookie identifies unique visits for a visitor in the website.
    viewed_cookie_policy	11 months	The cookie is set by the GDPR Cookie Consent plugin and is used to store whether or not user has consented to the use of cookies. It does not store any personal data.
    _ga	2 years	This cookie is installed by Google Analytics. The cookie is used to calculate visitor, session, campaign data and keep track of site usage for the site's analytics report. The cookies store information anonymously and assign a randomly generated number to identify unique visitors.
    _gat_gtag_UA_130405147_6	1 minute	This cookie is set by Google and is used to distinguish users.
    _gid	1 day	This cookie is installed by Google Analytics. The cookie is used to store information of how visitors use a website and helps in creating an analytics report of how the website is doing. The data collected including the number visitors, the source where they have come from, and the pages visted in an anonymous form.
    _zcsr_tmp		This cookie is set by the provider Zoho. This cookie is used for the chat window to contact us.

    In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

    You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.

    It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

15. How Do I Contact You?

    To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:

    Email address:	compliance@comeragroup.co.uk
    Postal address:	Origin Workspace, 40 Berkley Square, Bristol, BS8 1HP, United Kingdom

16. Changes to this Privacy Policy

    We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change Our business in a way that affects personal data protection.

    Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date. This Privacy Policy was last updated on 07 June 2021.