TPM Privacy Notice
Last Updated: 24/10/2025
- Introduction
- Our Contact Details
- Personal Data We Collect
-
Account and Contact Information
- Name, email address, organisation, and login credentials.
- Information provided when creating or managing your account.
-
Client Screening Data
- Data relating to client movement assessments or performance results entered by physiotherapists using The Performance Matrix platform.
- This may include health-related data, classed as “special category data” under the UK GDPR.
-
Technical and Usage Data
- IP address, browser type, device details, and site usage statistics.
- Log-in sessions, cookies, and interactions with video or embedded content.
-
Marketing Preferences
- Your communication preferences and consent for receiving updates, newsletters, or promotional content.
- How We Collect Your Data
- When you register for or use The Performance Matrix platform.
- When you communicate with us by email, phone, or contact forms.
- When physiotherapists enter or upload client screening data to the platform.
- When you visit our website, which uses cookies and analytics tools (see Section 10).
- Why We Process Your Data (Legal Bases)
- How We Use Your Data
- Deliver, manage, and improve our movement-health tools and services.
- Store and display client screening results securely within The Performance Matrix system.
- Communicate with users and respond to enquiries.
- Maintain platform security, troubleshoot issues, and prevent fraud.
- Comply with legal obligations and maintain records.
- Send relevant updates and marketing information (if you have opted in).
- Create anonymised or aggregated datasets for research, product improvement, and insight purposes (see Section 6A).
- Use of Anonymised and Aggregated Data
- Research and statistical analysis into movement health and performance;
- Improving our technology, algorithms, and training methods; and
- Developing reports, insights, or commercial datasets that do not identify any individual.
- Sharing Your Information
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Service providers and processors that host, support, or maintain our systems, including:
- Krystal Hosting (UK hosting)
- Microsoft 365 / Zoho CRM (email and CRM)
- Google Analytics (website analytics)
- Vimeo (video content delivery)
- Stripe (payment processing)
- Regulators, awarding bodies, and associated companies, where necessary to deliver our services.
- Authorities or law enforcement where required by law or to protect our rights.
- International Data Transfers
- Request details of the personal information we hold about you;
- Request deletion of your data (subject to legal obligations); and
- Opt out of the sale or sharing of personal data (note: we do not sell personal data, only anonymised data that cannot identify you).
- Your Data Protection Rights
- Access – request copies of your personal data.
- Rectification – correct inaccurate or incomplete information.
- Erasure – request deletion of your data in certain circumstances.
- Restriction – limit how we process your data.
- Objection – object to processing based on legitimate interests.
- Data portability – receive a copy of your data in a structured, machine-readable format.
- Cookies and Tracking Technologies
- Essential cookie – required for secure login sessions and to maintain platform functionality.
- Functional cookies – enable features such as video playback via Vimeo.
- Analytics cookies – provided by Google Analytics to measure website traffic and user behaviour.
- Data Security
- Encryption and secure data storage.
- Access controls and user authentication.
- Staff confidentiality and data-protection training.
- Regular testing and monitoring of systems.
- Data Storage and Retention
- Client data (including screening results) retained for up to 6 years after account closure or final contact, unless required longer by law.
- Staff or business contact data retained for up to 6 years after the relationship ends.
- Anonymised or aggregated data may be retained indefinitely for research and analysis, as it no longer identifies any individual.
- Updates to This Privacy Notice
- Contact Us
Comera Movement Science Limited (“we”, “us”, “our”) provides education, consultancy, training, and technology to support movement professionals. Through our online platform — The Performance Matrix — we help physiotherapists and other professionals assess and track client movement health.
We are committed to protecting your privacy and handling personal data fairly, lawfully, and transparently. This Privacy Notice explains how we collect, use, and protect personal information when you visit our websites or use our services.
Comera Movement Science Limited is the Data Controller for personal information we collect and process.
Comera Movement Science Limited
Origin Workspace, 40 Berkeley Square, Bristol, BS8 1HP, United Kingdom
Tel: +44 (0)117 971 8128
Email: privacy@comeragroup.co.uk
Privacy Contact: Data Protection Lead
If you have any questions about this Privacy Notice or how we process your data, please contact us using the details above.
You also have the right to contact the Information Commissioner’s Office (ICO) — the UK’s data protection authority — at https://ico.org.uk.
| Purpose | Legal Basis |
|---|---|
| Provide and manage your account and services | Contract – necessary to perform our agreement with you |
| Process and store client screening results | Legitimate Interests or Explicit Consent (for health data) |
| Communicate about your account, support, or updates | Legitimate Interests |
| Send marketing communications | Consent (you can withdraw at any time) |
| Comply with legal or regulatory obligations | Legal Obligation |
| Improve our platform and website through analytics | Legitimate Interests |
| Generate anonymised or aggregated data for research and analysis | Legitimate Interests (outside GDPR scope once anonymised) |
Where we process health-related data, we rely on the physiotherapist’s responsibility to obtain the client’s explicit consent before entering data into the system.
We use personal data to:
We never sell personal data.
We may use data collected through The Performance Matrix in an anonymised or aggregated form for purposes such as:
Anonymised data means data that has been processed to remove all personal identifiers and cannot reasonably be used to identify you or any individual.
We may share or sell anonymised or aggregated data with third parties, including research institutions, universities, commercial partners, or industry bodies, for the purposes listed above. This data will never contain personally identifiable information, and we will not attempt to re-identify any individual from anonymised datasets.
We may share personal data with:
All third parties are bound by data-protection obligations and process data only under our instructions.
We may also share anonymised or aggregated data for research, statistical, or commercial purposes as described in Section 6A.
We currently store and process all personal data within the United Kingdom. If in the future data is transferred outside the UK or EEA, we will ensure adequate safeguards are in place, such as Standard Contractual Clauses or UK adequacy regulations.
For users based in the United States, we comply with the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA).
You have the right to:
Under the UK GDPR, you have the following rights:
To exercise these rights, contact us using the details in Section 2.
You also have the right to lodge a complaint with the ICO if you are not satisfied with our response.
Our website uses cookies to improve your browsing experience and platform functionality.
Types of Cookies Used
You can manage or disable cookies through your browser settings. Please note that disabling cookies may limit some website functions.
We do not use cookies for targeted advertising.
We use appropriate technical and organisational measures to protect personal data, including:
Access to personal data is limited to authorised personnel who require it to perform their duties.
We retain personal data only as long as necessary for the purposes for which it was collected, including for legal, regulatory, and audit reasons.
We may keep data longer where required by law, regulation, or to resolve disputes and enforce agreements.
We may update this Privacy Notice from time to time. The latest version will always be available on our website, with the revision date shown at the top.
If we make significant changes that affect how we process your data, we will notify you via email or within The Performance Matrix platform.
If you have any questions, concerns, or complaints about this Privacy Notice or how we process your data, please contact:
Comera Movement Science Limited
Origin Workspace, 40 Berkeley Square, Bristol, BS8 1HP, United Kingdom
Tel: +44 (0)117 971 8128
Email: privacy@comeragroup.co.uk
Privacy Contact: Data Protection Lead
You may also contact the Information Commissioner’s Office (ICO) at https://ico.org.uk or, for U.S. residents, your state privacy regulator.
