Introduction

Incodia International Ltd (or we, or us, or the company) are committed to protecting and respecting your privacy. This policy sets out the basis on which any personal data we collect from you or that might be provided by you to us, will be processed by us. Please read carefully the following information to understand our views and practices regarding your personal data and how we will treat it. By visiting www.incodia.co.uk you are accepting and consenting to the practices described in this policy. For the purpose of the Data Protection Act 2018 (the Act), the data controller is Incodia International Ltd.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

How to contact us

If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:

Full name of legal entity: Incodia international Ltd
Email address: MHosty@incodia.co.uk
Postal address: 2 Seddon Place, Skelmersdale, WN8 8EB
Telephone number: 01695 50622

Links to other websites

Please note, this website may contain links to other websites, plug-ins and applications that are not controlled by Incodia international Ltd. Clicking on those links or enabling those connections may allow third parties to collect or share data about you.  These links are provided for your convenience. We are only responsible for our privacy practices and our security. We recommend that you check the privacy and security policies and procedures of each and every other website that you visit and each organisation that holds your personal data.

Information we may collect from you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, title, date and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

Sources

We obtain personal data:

• Directly from you such as when you file in forms through our website www.incodia.co.uk or register for any of our services, send us emails or otherwise. This includes personal data you provide when you:
  • contribute to our blogs and forums;
  • attend any our events;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us feedback or contact us.
• From various third parties and public sources as set out below:
  • another organisations, for example, where you receive information or services from one of our suppliers and have given permission to share your data;
  • social media sites or apps, such as Facebook and LinkedIn, if your settings and preferences allow;
  • publicly available sources such as Companies House.
• From automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy below for further details.

Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with the best possible experience when you browse our website and to also make improvements to our site.

Most browsers automatically accept cookies, but you can usually change your browser to prevent cookies being stored. With experience, you can usually choose to switch off all cookies or to allow only certain ‘trusted’ sites to place cookies.

For further information on cookies and Flash cookies and how to switch them off see the Information Commissioner’s website at www.ico.org.uk or visit  www.allaboutcookies.org or www.aboutcookies.org.

Please Note, turning cookies off may limit your user experience and limit the service we are able to provide.

Keeping Data Secure

We take the security of your data seriously, wherever possible we ensure data is encrypted in transit and at rest. Access to data is audited and limited to where it is required.

All personal data that we obtain about you will be recorded, used, and protected by us in accordance with current data protection law and this Privacy Policy.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

How we use your personal data

We will only use your personal data when the law allows us to.

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Data Retention

We will normally keep your personal data for 10 years after your last interaction with us, or our Website.  If we consider that you are no longer an active user of our Website or our services we may delete your personal data sooner than this.

We expect to contact you at least every two years to ensure you are still happy to hear from us according to the preferences you have provided to us.

Transfer of your personal data outside of Europe

To provide our services to you, we may transfer personal data to our trusted service provider(s).  We have taken proper steps to ensure that it is protected in accordance with this Privacy Policy and applicable privacy laws.

Some of our Suppliers and Partners are located in regions outside of Europe. If you agree to us providing your details to our Suppliers or Partners, your data may be transferred to the relevant one to satisfy your requirements.

Changes to this privacy policy

Privacy laws and practice are constantly developing and we aim to meet high standards.  Our policies and procedures are, therefore, under continual review. We may, from time to time, update our security and privacy policies.  If we want to make any significant changes in how we will use your personal data we will contact you directly and, if required, seek your consent.

We will ensure our Website has our most up to date policy and suggest that you check this page periodically to review our latest version.

Updating and correcting personal data

You may update or correct your personal data by contacting us in writing or by telephone and asking us to do it for you. Please include your name and/or email address when you contact us as this helps us to ensure that we accept amendments only from the correct person.

We encourage you to promptly update your personal data if it changes.  If you are providing updates or corrections about another person, we may require you to provide us with proof that you are authorised to provide that information to us.

Your Rights

You have a number of legal rights in respect of your personal data.  These include:

• The right to receive a copy of the personal data that we hold about you. We will require proof of identity and proof of authority if the request comes from someone other than the person whose data we are asked to provide.  This will ensure we only provide information to the correct person.  We normally expect to respond to requests within 28 days of receiving them.
• withdraw consent to direct marketing. You can exercise this right at any time and can update your preferences yourself or ask us to do it for you.  See section ‘Updating and correcting your personal data’ above for details.
• withdraw consent to other processing. Where the only legal basis for our processing your personal data is that we have your consent to do so, you may withdraw your consent to that processing at any time and we will have to stop processing your personal data.  Please note, this will only affect a new activity and does not mean that processing carried out before you withdrew your consent is unlawful.
• If you consider any of your personal data is inaccurate, you can correct it yourself or ask us to do it for you (see section ‘Updating and correcting your personal data’ above for details).
• In limited circumstances you may be able to require us to restrict our processing of your personal data.  For example, if you consider what we hold is inaccurate and we disagree, the processing may be restricted until the accuracy has been verified.
• Where we have no lawful basis for holding onto your personal data you may ask us to delete it.
• In limited circumstances you may be entitled to have the personal data you have provided to us sent electronically to you for you to provide to another organisation.
• to complain to the Information Commissioner’s Office. If you have a concern or complaint we would prefer you to contact us (see the section ‘How to contact us’ above) and we will try to resolve it for you.  If you want to make a complaint to the Information Commissioner’s Office, you can find information on how to do this at ico.org.uk.