Privacy Policy
Last updated: 26 September 2026
1. Who we are
This website is operated by Suraiya Comunello Advisory Ltd (company number 16935273, registered in England and Wales), registered office Francis Groves Close, Bedford, England, MK41 7DH ("we", "us", "our"). We are the data controller for the personal data described in this policy.
Contact for privacy matters: suraiya@comunelloadvisory.com
2. What personal data we collect
Depending on how you interact with the site, we may collect:
- Contact form submissions: name, email address, company name (if given), and the content of your message.
- Newsletter/email sign-up: name and email address.
- Booking/scheduling: name, email, and the date/time you select, if you book a call through a scheduling tool.
- Usage data: pages visited, time on site, referring site, device and browser type, and approximate location (via IP address), collected through analytics tools.
- Cookies and similar technologies: see our Cookie Policy for full details. Cookies are only set with your consent where required by law.
We do not knowingly collect any special category data (health, political opinions, religion, etc.) through this website.
3. Why we process your data and our legal basis
| Purpose | Legal basis (UK/EU GDPR) |
|---|---|
| Responding to enquiries submitted via the contact form | Legitimate interest in running our business / steps prior to entering a contract |
| Providing consultancy services to clients | Performance of a contract |
| Sending newsletters or marketing emails | Consent (you can withdraw this at any time) |
| Website analytics and improving the site | Consent (where cookies are used) or legitimate interest for aggregated, non-identifying analytics |
| Complying with legal and tax obligations | Legal obligation |
4. Tools and third parties we may use
We may use some or all of the following categories of third-party tools to run this website and our business. Only the tools actually in use on the site apply:
- Website hosting: Vercel Inc.: serves the website and keeps short-lived server logs, which include IP addresses.
- Analytics: Vercel Web Analytics: counts page views and referrers in aggregate. It sets no cookies and runs only if you accept the analytics category.
- Contact form delivery: Resend: delivers what you submit through the contact form to our inbox. It does not run in your browser.
- Web fonts: Fontshare (Indian Type Foundry): serves the typeface used across the site. Your browser requests the font file directly, so Fontshare receives your IP address. It sets no cookies.
Each of these providers processes data under its own privacy policy and acts as our data processor (or, for some advertising tools, an independent controller) under a data processing agreement.
5. International data transfers
Some of the tools above may store or process data outside the UK/EEA (for example, in the United States). Where this happens, we rely on one of: an adequacy decision (for example, the European Commission's adequacy decision for the UK, or similar decisions covering certain other countries), the provider's Standard Contractual Clauses, or another lawful transfer mechanism. You can ask us for details of the safeguards in place for any specific transfer.
6. How long we keep your data
- Contact form enquiries that don't turn into a client relationship: up to 12 months, then deleted.
- Client data (once you engage us): for the duration of the engagement plus any period required by UK/Spanish tax and accounting law (typically 5–6 years).
- Newsletter subscribers: until you unsubscribe.
- Analytics data: as set by the retention period of the analytics tool in use (commonly 14–26 months).
7. Your rights
Under UK GDPR and EU GDPR, you have the right to:
- Access the personal data we hold about you
- Correct inaccurate data
- Request erasure of your data
- Restrict or object to certain processing
- Request a portable copy of your data
- Withdraw consent at any time (for anything based on consent, e.g. newsletters or non-essential cookies)
To exercise any of these rights, contact us at suraiya@comunelloadvisory.com. You also have the right to complain to a supervisory authority. In the UK this is the Information Commissioner's Office (ico.org.uk). If you are based in Spain it is the Agencia Española de Protección de Datos (aepd.es).
8. EU representative
Our representative in the EU for data protection matters is Suraiya Comunello, based in Spain, contactable at suraiya@comunelloadvisory.com.
9. Children
This website and our services are directed at businesses and professionals, not children. We do not knowingly collect data from anyone under 16.
10. Automated decision-making
We do not use your personal data for any automated decision-making that produces legal or similarly significant effects on you.
11. Changes to this policy
We may update this policy from time to time. The "last updated" date at the top will reflect the most recent change. Material changes will be highlighted on the website.
12. Contact
Questions about this policy or how we handle your data: suraiya@comunelloadvisory.com / Francis Groves Close, Bedford, England, MK41 7DH.