Privacy Policy
Commodara Effective Date: March, 2026
1. Introduction
Commodara (“we,” “us,” “our,” or “Commodara”), operated by Becky Andrew, is committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, store, share, and protect your personal data when you visit commodara.com (the “Website”), use our assessment tools, subscribe to our newsletter, or engage with our Services.
This Privacy Policy is designed to meet the standards of internationally recognized data protection frameworks, including the EU General Data Protection Regulation (GDPR), and respects the data protection rights of individuals regardless of their location. Where local laws in your jurisdiction provide additional rights or impose additional requirements, those rights and requirements also apply.
By using our Services, you acknowledge that you have read and understood this Privacy Policy.
2. Data Controller
The data controller responsible for your personal data is:
Commodara Operated by: Becky Andrew Email: hello@commodara.com Website: commodara.com
3. Personal Data We Collect
We collect personal data in the following categories:
Information You Provide Directly. When you use our assessment tools (such as the Tokenization Readiness Tool), you provide your full name, work email address, and company name. When you subscribe to our newsletter, you provide your name and email address. When you book a consultation, you provide the information required by the booking platform, which may include your name, email, and scheduling preferences. When you contact us, you provide any information included in your correspondence.
Information Generated Through Assessment Tools. When you complete an assessment, we collect your responses to assessment questions, your overall readiness score and tier classification, your per-module scores across all assessment dimensions, and the date and time of submission. This data is linked to the personal information you provided at the start of the assessment.
Information Collected Automatically. When you visit the Website, we may automatically collect your IP address, browser type and version, device type and operating system, pages visited and time spent on the Website, referring website or source, and cookies and similar tracking technologies (see Section 9).
4. Legal Basis for Processing
We process your personal data on the following legal bases:
Consent. When you voluntarily submit your information through an assessment tool, newsletter signup, or contact form. You may withdraw consent at any time (see Section 8).
Legitimate Interest. For analytics, service improvement, and business operations, where our interests do not override your fundamental rights and freedoms.
Contractual Necessity. When processing is necessary to deliver a service you have requested, such as a paid consultation.
Legal Obligation. When we are required by law to process or retain your data.
5. How We Use Your Personal Data
We use your personal data for the following purposes:
Service Delivery. To provide assessment results, newsletter content, and consultation services you have requested.
Communication. To send you your assessment results, newsletter editions, and relevant updates about our Services. We will only send marketing communications where you have provided consent.
Personalization. To tailor recommendations in your assessment results based on your responses and to customize content relevant to your interests.
Analytics and Improvement. To understand how our Website and tools are used, identify trends, and improve our Services. Where possible, we use aggregated or anonymized data for analytics.
Business Operations. To manage our mailing list, track assessment completions, and maintain records for business purposes.
Legal Compliance. To comply with applicable laws, regulations, and legal obligations in any relevant jurisdiction.
We will not use your personal data for purposes incompatible with those described above without providing you notice and, where required, obtaining your consent.
6. How We Share Your Personal Data
We do not sell, rent, or trade your personal data. We may share your personal data with the following categories of recipients, and only to the extent necessary for the stated purposes:
Service Providers. We use third-party platforms to operate our Services, including customer relationship management and marketing automation platforms, booking platforms for consultation scheduling, our website hosting provider, and email delivery services. These providers process your data on our behalf and under our instructions. We take reasonable steps to ensure they provide adequate data protection safeguards.
Legal Requirements. We may disclose your personal data if required by law, regulation, legal process, or governmental request in any applicable jurisdiction, or if we believe in good faith that disclosure is necessary to protect the rights, property, or safety of Commodara, our users, or the public.
Business Transfers. In the event of a merger, acquisition, or sale of assets, your personal data may be transferred to the acquiring entity. We will notify you of any such transfer and any changes to this Privacy Policy.
We do not share your personal data with third parties for their own marketing purposes.
7. International Data Transfers
Commodara operates globally and your personal data may be transferred to and processed in countries other than your own. When we transfer personal data across borders, we take appropriate measures to ensure your data is protected, including using standard contractual clauses, relying on adequacy decisions where applicable, or implementing other legally recognized transfer mechanisms. By using our Services, you acknowledge that your data may be processed in jurisdictions with different data protection laws than your own.
8. Your Rights
Depending on your jurisdiction, you may have the following rights regarding your personal data:
Right of Access. You have the right to request a copy of the personal data we hold about you.
Right to Rectification. You have the right to request correction of inaccurate or incomplete personal data.
Right to Erasure. You have the right to request deletion of your personal data, subject to legal retention requirements.
Right to Restrict Processing. You have the right to request that we limit the processing of your personal data in certain circumstances.
Right to Data Portability. You have the right to receive your personal data in a structured, commonly used, machine-readable format.
Right to Object. You have the right to object to the processing of your personal data for direct marketing or where processing is based on legitimate interest.
Right to Withdraw Consent. Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.
Right to Lodge a Complaint. You have the right to lodge a complaint with the relevant data protection authority in your jurisdiction.
To exercise any of these rights, please contact us at hello@commodara.com. We will respond to your request within 30 days, or within the timeframe required by applicable law in your jurisdiction.
9. Cookies and Tracking Technologies
Our Website may use cookies and similar technologies to enhance your browsing experience, analyze Website traffic, and understand how our Services are used.
Essential Cookies. Required for the Website to function properly. These cannot be disabled.
Analytics Cookies. Help us understand how visitors interact with the Website by collecting information anonymously.
Marketing Cookies. Used to track visitors across websites to display relevant advertisements. We do not currently use marketing cookies, but will update this policy if that changes.
You can manage your cookie preferences through your browser settings. Most browsers allow you to refuse cookies or delete existing cookies. Please note that disabling cookies may affect the functionality of certain parts of the Website.
For more information on managing cookies, visit www.aboutcookies.org or www.allaboutcookies.org.
10. Data Retention
We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, including to satisfy any legal, accounting, or reporting requirements.
Assessment Data. Your assessment responses, scores, and contact information are retained for as long as necessary to provide follow-up services and maintain our relationship with you, or until you request deletion.
Newsletter Subscribers. Your name and email address are retained until you unsubscribe, at which point they will be removed from our active mailing list within 30 days.
Consultation Records. Information related to paid consultations is retained for as long as necessary for business and legal purposes.
Automatically Collected Data. Analytics and log data is retained in aggregated or anonymized form and is not subject to individual deletion requests.
11. Data Security
We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include encryption of data in transit (HTTPS), access controls limiting who can view personal data, and secure storage through reputable third-party service providers.
While we take reasonable precautions, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security of your data.
12. Children’s Privacy
Our Services are not directed to individuals under the age of 18. We do not knowingly collect personal data from children. If we become aware that we have collected personal data from a child under 18, we will take steps to delete that information promptly. If you believe we have inadvertently collected data from a child, please contact us at hello@commodara.com.
13. Third-Party Services
Our Website may contain links to third-party websites and services. This Privacy Policy does not apply to those third-party services. We encourage you to review the privacy policies of any third-party services you access through our Website.
Third-party platforms we use to deliver our Services have their own privacy policies governing how they handle your data. We recommend reviewing the privacy policies of the following types of services: customer relationship management platforms, booking and scheduling platforms, website hosting and analytics providers, and email delivery services.
14. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. Changes will be effective immediately upon posting the updated Privacy Policy on the Website with a revised “Last Updated” date.
For material changes, we will make reasonable efforts to notify you, such as through a notice on the Website or via email. Your continued use of the Services after any changes constitutes your acceptance of the updated Privacy Policy.
15. Do Not Track Signals
Some browsers transmit “Do Not Track” signals to websites. Due to the lack of a common industry standard for interpreting these signals, our Website does not currently respond to Do Not Track signals. We will update this policy if a standard is established.
16. California and Other Jurisdiction-Specific Rights
If you are a resident of California, the European Economic Area, the United Kingdom, or another jurisdiction that provides specific data protection rights, you may have additional rights under local law. These may include the right to know what personal data is being collected, the right to request deletion of your data, the right to opt out of the sale of your personal data (we do not sell personal data), and the right to non-discrimination for exercising your privacy rights.
We honour these rights regardless of your location to the extent they are consistent with our global privacy practices. To exercise any jurisdiction-specific rights, please contact us at hello@commodara.com.
17. Contact Information
If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:
Commodara Email: hello@commodara.com
Website: commodara.com
We aim to respond to all privacy-related inquiries within 30 days.