Privacy Notice

Who is responsible for your information

PHM CLARITY LTD, trading as Commercial Clarity Advisory, is the data controller responsible for the personal information described in this notice.

PHM CLARITY LTD is registered in England and Wales under company number 17337435.

Registered office:
20 Wenlock Road
London
England
N1 7GU

In this notice, "I", "me" and "my" refer to Commercial Clarity Advisory, operated by Paul Meersman through PHM CLARITY LTD.

For questions about this notice or how your information is handled, please use the contact form on this website.

Information I may collect

When you contact me through this website or communicate with me directly, I may collect:

• your name
• your email address
• your telephone number, if you provide it
• your company name and role
• your website address
• the contents of your enquiry or correspondence
• information you provide during subsequent conversations
• proposal, contract, invoicing and payment information if you become a client

The website and its service providers may also collect limited technical information needed to operate and secure the site, such as:

• your IP address
• browser and device information
• pages visited
• dates and times of visits
• cookie and consent preferences

Further information about cookies is available in the Cookie Policy.

How I collect your information

I may receive personal information:

• directly from you through the contact form
• when you email, telephone or meet with me
• during discussions about potential or agreed work
• through a referral or professional introduction
• from publicly available professional sources, such as company websites or LinkedIn

Why I use your information

I may use personal information to:

• respond to enquiries
• understand whether my services may be relevant
• arrange meetings and continue conversations you have requested
• prepare proposals or take steps before entering into a contract
• deliver agreed services
• manage client and supplier relationships
• issue invoices and maintain financial records
• meet legal, regulatory and tax obligations
• maintain the security and proper operation of the website
• establish, exercise or defend legal claims
• send marketing communications where you have given permission

I will not add you to a mailing list without your permission. You may withdraw that permission at any time.

Lawful bases for using your information

Under UK data-protection law, I must have a lawful basis for using personal information.

Depending on the circumstances, I rely on:

• Steps before entering into a contract: where you ask about working with me or request a proposal
• Contract: where processing is necessary to provide agreed services
• Legitimate interests: to respond to business enquiries, manage professional relationships, operate and secure the website, and develop the business in a reasonable and proportionate way
• Legal obligation: where information must be retained or disclosed to comply with legal, accounting, tax or regulatory requirements
• Consent: where you have actively agreed to receive marketing communications or to the use of non-essential cookies

Where I rely on legitimate interests, I consider whether those interests are outweighed by your privacy rights.

Who your information may be shared with

I do not sell personal information.

Information may be shared only where reasonably necessary with:

• providers supporting website hosting and maintenance
• contact-form, email and communications providers
• secure document-storage and business-software providers
• accountants, insurers, lawyers or other professional advisers
• contractors supporting an agreed client engagement, where appropriate
• regulators, courts, law-enforcement bodies or public authorities where disclosure is legally required

Service providers may process information only for the relevant service and subject to appropriate contractual and security obligations.

International data transfers

Some technology or service providers may process information outside the United Kingdom.

Where this happens, I take reasonable steps to ensure that appropriate legal safeguards are in place. These may include UK adequacy regulations, approved contractual protections or other safeguards recognised under UK data-protection law.

How long information is kept

Personal information is kept only for as long as it is reasonably needed for the purpose for which it was collected.

As a general guide:

• enquiries that do not lead to work may be retained for up to 24 months after the last meaningful contact
• client, contractual and financial records may be retained for up to six years after the relationship ends where required for legal, accounting, tax or contractual purposes
• marketing information is retained until you withdraw your consent or object to receiving further communications
• technical and security records are retained only for as long as reasonably necessary to operate and protect the website

Information may be deleted sooner where it is no longer required. It may occasionally need to be kept longer where required by law or in connection with a legal claim.

How your information is protected

Reasonable technical and organisational measures are used to protect personal information against unauthorised access, loss, misuse, alteration or disclosure.

Access is limited to people and service providers who need the information for a legitimate business purpose.

No internet-based service can provide an absolute guarantee of security, but reasonable care is taken when selecting and using systems that process personal information.

Your rights

Depending on the circumstances, you may have the right to:

• ask for a copy of the personal information held about you
• ask for inaccurate or incomplete information to be corrected
• ask for your information to be deleted
• ask for the use of your information to be restricted
• object to processing based on legitimate interests
• object at any time to the use of your information for direct marketing
• ask for certain information to be transferred to you or another organisation
• withdraw consent where processing is based on consent

These rights are not absolute and may be subject to legal exceptions.

To exercise a right, use the contact form on this website. You may be asked for information needed to confirm your identity.

Automated decision-making

I do not use personal information collected through this website to make solely automated decisions that produce legal or similarly significant effects.

Complaints

Please contact me first if you have a concern about how your personal information has been handled. I will take the concern seriously and try to resolve it.

You also have the right to complain to the Information Commissioner's Office, the UK regulator for data protection.

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Further information is available on the Information Commissioner's Office website.

Changes to this notice

This privacy notice may be updated when the business, website, legal requirements or data-processing practices change.

The latest version will always be published on this page with its revision date.