Privacy Policy

We are committed to protecting your personal information and being transparent about what we do with it, irrespective of how you interact with us.

This privacy notice describes how the Samera group companies collect, use, store and share personal information and what this means for you. The terms of this notice may change from time to time, so please check it periodically.

For the purposes of this notice, ‘us’, ‘we’ and ‘our’ refers to the relevant Samera entity that processes your personal information and interacts with you. The Samera entities covered by this notice are as follows:

Entity	Company Number
Samera Ltd	4563912 (England)
Samera AI Ltd	9868551 (England)
Samera International Ltd	10711620 (England)
Samera Growth Advisors Ltd	06917384 (England)
Samera Professional Services Private Limited	U69201DL2023FTC414269 (India)

Note: Samera Finance Ltd operates under a separate privacy notice in its capacity as an FCA-regulated commercial finance broker.

1. Our Legal Grounds for Processing Your Data

The UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 require us to have a lawful basis for processing your personal data. We rely on the following legal grounds:

• Performance of a contract: we need to use your personal data to provide the services you have requested or to take steps at your request prior to entering into a contract.
• Compliance with legal obligations: we process certain data to comply with legal requirements, including anti-money laundering and financial crime legislation.
• Legitimate interests: we process data for our business and commercial purposes, including improving our services, preventing fraud, and fulfilling our regulatory obligations. We balance these interests against your rights and freedoms.
• Consent: where we rely on your consent to process your data, you may withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing carried out before you withdrew consent.

2. What Information We Collect

We may collect the following categories of personal information:

• Identity data: name, job title, date of birth.
• Contact data: email address, telephone number, postal address and postcode.
• Financial data: where relevant to the services we provide, details of income, expenditure, financial status and assets.
• Technical data: IP address, browser type, and usage data collected via cookies when you visit our website.
• Communications data: records of correspondence and interactions with us.
• Other information you provide to us in the course of using our services.

We will only collect personal data that is necessary for the purpose for which it is being collected. We will not collect special category data (such as health, ethnicity or biometric data) without your explicit consent, unless we are required to do so by law.

3. How We Use Your Information

We use the information we collect for the following purposes:

• To provide and manage the services you have requested from us.
• Internal record keeping and administration.
• To improve our services and your experience of interacting with us.
• To comply with our legal and regulatory obligations.
• To send you information about our services that we believe may be of interest to you, where you have consented to receive such communications or where we have a legitimate interest in doing so.
• For statistical analysis and service improvement.

4. International Data Transfers

We work with our associated company, Samera Professional Services Private Limited, based in India, as part of our service delivery. This involves the transfer of personal data outside the United Kingdom.

We ensure that any such transfers are carried out in accordance with the UK GDPR and that appropriate safeguards are in place, including:

• Contractual protections, including data processing agreements incorporating the International Data Transfer Agreement (IDTA) or equivalent standard contractual clauses approved by the Information Commissioner’s Office.
• Security measures to protect your data during transfer and processing.
• GDPR training for all relevant staff at Samera Professional Services Private Limited.

We will not transfer your data to any other country outside the UK without ensuring equivalent protections are in place.

5. Sharing Your Information

We will not sell, rent or lease your personal information to third parties. We may share your data in the following circumstances:

• With third-party service providers who assist us in delivering our services, subject to appropriate data processing agreements.
• With our associated companies within the Samera group, where necessary to provide our services.
• Where required to do so by law or regulatory authority.
• Where you have given your consent.

We will not use your personal information to send you promotional information about third-party products or services without your consent.

6. How We Protect Your Information

We are committed to keeping your personal data secure. We have implemented appropriate technical and organisational measures to protect your information against unauthorised access, loss, destruction or alteration. These include:

• Secure, encrypted data storage on UK-based or EU-based servers.
• Access controls and staff training to limit who can access your data.
• Regular review of our security practices and data protection procedures.

In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify the Information Commissioner’s Office (ICO) within 72 hours and, where required, notify you directly.

7. Cookies

Our website uses cookies to improve your experience. A cookie is a small text file placed on your device when you visit our website. We use the following types of cookies:

• Strictly necessary cookies: required for the website to function and cannot be disabled.
• Analytics cookies: help us understand how visitors use our website so we can improve it. We only use this data in aggregate, anonymised form.
• Preference cookies: allow the website to remember your preferences.

You can control cookie settings through your browser. Disabling certain cookies may affect the functionality of our website. By continuing to use our website, you consent to our use of cookies as described in this notice.

8. Links to Other Websites

Our website may contain links to third-party websites. We are not responsible for the privacy practices of those websites and this notice does not apply to them. We recommend you review the privacy notice of any website you visit.

9. How Long We Keep Your Information

We will retain your personal data only for as long as is necessary to fulfil the purposes for which it was collected, including to satisfy any legal, accounting or reporting requirements.

As a general guide:

• Client and prospect data: retained for a minimum of 6 years from the end of our relationship, in line with standard legal and regulatory requirements.
• Marketing data: retained until you notify us that you no longer wish to be contacted, at which point we will retain only the minimum information necessary to suppress further contact.
• Website usage and analytics data: retained for no longer than 26 months.

When personal data is no longer required, we will securely delete or anonymise it. Where you have contributed user-generated content, we will retain it only for as long as is reasonably required for the purpose for which it was submitted.

10. Your Rights

Under UK data protection law, you have the following rights in relation to your personal data:

• Right to be informed: you have the right to be told how and why we use your data (which this notice fulfils).
• Right of access: you may request a copy of the personal data we hold about you (a Subject Access Request).
• Right to rectification: you may ask us to correct any inaccurate or incomplete data.
• Right to erasure: in certain circumstances, you may ask us to delete your personal data.
• Right to restrict processing: you may ask us to limit how we use your data in certain circumstances.
• Right to data portability: you may request that we provide your data in a structured, commonly used, machine-readable format.
• Right to object: you may object to processing based on our legitimate interests or for direct marketing purposes.
• Rights related to automated decision-making: you have rights in relation to any decisions made about you solely through automated means.

To exercise any of these rights, or if you have any questions about how we handle your data, please contact our Data Protection contact:

Karyn McElhinney

Email: karyn.mcelhinney@samera.co.uk

Samera Ltd, 136-138 High Street, Esher, Surrey, KT10 9QJ

We will respond to all requests within one calendar month. We may need to verify your identity before proceeding.

11. Right to Complain

If you are not satisfied with how we have handled your personal data, or you believe we are processing it unlawfully, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO):

Information Commissioner’s Office

Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Telephone: 0303 123 1113

Email: casework@ico.org.uk

Website: https://ico.org.uk

12. Marketing Preferences

From time to time we may wish to contact you with information about our services that we think may be of interest to you. We will only do this where you have consented, or where we have a legitimate interest.

You may indicate how you would like us to contact you:

☐	Post
☐	Email
☐	Telephone
☐	Text / SMS
☐	Automated Call

You may withdraw your consent to marketing communications at any time by contacting us at the address above.

13. Changes to This Notice

We may update this privacy notice from time to time to reflect changes in our practices, legal requirements or regulatory guidance. Any significant changes will be highlighted clearly on our website. The current version of this notice is always available at www.samera.co.uk.

This notice was last updated in June 2026.