top of page

Privacy Policy

INCPA Website Privacy Policy 

INCPA are committed to safeguarding the privacy of [our website  visitors, service users, individual customers, and customer  



This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where  we determine the purposes and means of the processing of that personal data. 

Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can  [specify whether you would like to receive direct marketing  communications and limit the collection, sharing and publication of  your personal data]. 


We use cookies on our website. In so far as those cookies are not  strictly necessary for the provision of [our website and services], we  will ask you to consent to our use of cookies when you first visit our  website. 


In this policy, "we", "us" and "our" refer to INCPA. [For more  information about us, see Section 14]. 


The personal data that we collect. 

In this Section 3 we have set out the general categories of personal  data that we process [ and, in the case of personal data that we did  

not obtain directly from you, information about the source and  specific categories of that data]. 


We may process data enabling us to get in touch with you ("contact  data").[The contact data may include [your name, email address,  telephone number, postal address and/or social media account  identifiers].[ The source of the contact data is [you and/or your   employer].[ If you log into our website using a social media account, we will obtain elements of the contact data from the relevant social media account provider.]


We may process [your website user account data] ("account  data").[ The account data may [include your account identifier,  name, email address, business name, account creation and modification dates, website settings and marketing preferences].  The primary source of the account data is [you and/or your employer, although some elements of the account data may be  generated by our website]. If you log into our website using a social  media account, we will obtain elements of the account data from the  relevant social media account provider. 


We may process [information relating to transactions, including  purchases of goods and/or services, that you enter into with us  and/or through our website] ("transaction data").[The transaction  data may include [your name, your contact details, your payment  card details (or other payment details) and the transaction  details]. [The source of the transaction data is [you and/or our  payment services provider].] 


We may process [information contained in or relating to any  communication that you send to us or that we send to you]  

("communication data"). The communication data may include [the  communication content and metadata associated with the  

communication]. [Our website will generate the metadata associated  with communications made using the website contact forms]. 


We may process [data about your use of our website and services]  ("usage data"). The usage data may include [your IP address,  geographical location, browser type and version, operating system,  referral source, length of visit, page views and website navigation  paths, as well as information about the timing, frequency, and  pattern of your service use]. The source of the usage data is [our  analytics tracking system]. 


Purposes of processing and legal bases 

In this Section 4, we have set out the purposes for which we may  process personal data and the legal bases of the processing. 

Operations - We may process [your personal data] for [the  purposes of operating our website, the processing and fulfilment of  orders, providing our services, supplying our goods, generating  invoices, bills and other payment-related documentation, monitoring  user’s information and analysis of our services, goods and/ or goods.  The legal basis for this processing is [our legitimate interests, namely  [the proper administration of our website, services, and business] OR  [the performance of a contract between you and us]. 


Publications - We may process [account data] for [the purposes of  publishing such data on our website and elsewhere through our  services in accordance with your express instructions]. The legal  basis for this processing is [consent] OR [our legitimate interests, 

namely [the publication of content in the ordinary course of our  operations] OR [the performance of a contract between you and us]. 


Relationships and communications - We may process [contact  data, account data, transaction data and/or communication data] for  [the purposes of managing our relationships, communicating with  you (excluding communicating for the purposes of direct marketing)  by email, SMS, post, fax and/or telephone, providing support services  and complaint handling]. The legal basis for this processing is [our  legitimate interests, namely [communications with our website  visitors, service users, individual customers and customer personnel,  the maintenance of relationships, and the

proper administration of  our website, services, and business]. 


Direct marketing - We may process [contact data, account data  and/or transaction data] for [the purposes of creating, targeting, and  sending direct marketing communications by email, SMS, post and/or  fax and making contact by telephone for marketing-related  purposes]. The legal basis for this processing is [consent] OR [our  legitimate interests, namely [promoting our business and  communicating marketing messages and offers to our website  visitors and service users]. 


Research and analysis - We may process [usage data and/or  transaction data] for [the purposes of researching and analysing the  use of our website and services, as well as researching and analysing  other interactions with our business]. The legal basis for this  processing is [consent] OR [our legitimate interests, namely  [monitoring, supporting, improving, and securing our website,  services, and business generally]. 


Record keeping - We may process [your personal data] for [the  purposes of creating and maintaining our databases, back-up copies  of our databases and our business records generally]. The legal basis  for this processing is our legitimate interests, namely [ensuring that  we have access to all the information we need to run our business  properly and efficiently in accordance with this policy]. 


Security - We may process [your personal data] for [the purposes of  security and the prevention of fraud and other criminal activity]. The  legal basis of this processing is our legitimate interests, namely [the  protection of our website, services and business, and the protection  of others]. 

Insurance and risk management - We may process [your  personal data] where necessary for [the purposes of obtaining or  maintaining insurance coverage, managing risks and/or obtaining  professional advice]. The legal basis for this processing is our  legitimate interests, namely [the proper protection of our business  against risks].


Legal claims - We may process [your personal data] where  necessary for [the establishment, exercise or defence of legal claims,  whether in court proceedings or in an administrative or out-of-court  procedure]. The legal basis for this processing is our legitimate  interests, namely [the protection and assertion of our legal rights,  your legal rights, and the legal rights of others]. 


Legal compliance and vital interests - We may also process your  personal data where such processing is necessary for compliance with  a legal obligation to which we are subject or to protect your vital  interests or the vital interests of another natural person. 

Providing your personal data to others 


We may disclose [your personal data] to [our insurers and/or  professional advisers] insofar as reasonably necessary for the  purposes of [obtaining or maintaining insurance coverage, managing  risks, obtaining professional advice]. 

[Your personal data held in our website database] OR [[Identify  personal data category or categories]] will be stored on the servers of  our hosting services providers. 


We may disclose personal data category or categories] to [our  suppliers, subcontractors, or Stakeholders] in so far as reasonably  necessary for [Monitoring purposes, funding applications and service  provision]. 


Financial transactions relating to [our website and services] [are] OR  [may be] handled by our payment services providers, we will share  transaction data with our payment services providers only to the  extent necessary for the purposes of [processing your payments,  refunding such payments, and dealing with complaints and queries  relating to such payments and refunds].  


In addition to the specific disclosures of personal data set out in this  Section 5, we may disclose your personal data where such disclosure  is necessary for compliance with a legal obligation to which we are  subject, or to protect your vital interests or the vital interests of  another natural person. We may also disclose your personal data  where such disclosure is necessary for the establishment, exercise, or  defence of legal claims, whether in court proceedings or in an  administrative or out-of-court procedure. 

International transfers of your personal data 

In this Section 6, we provide information about the circumstances in  which your personal data may be transferred to a third country under  [UK data protection law]. 


You acknowledge that [personal data that you submit for publication  through our website or services] may be available, via the internet, 

around the world. We cannot prevent the use (or misuse) of such  personal data by others. 


Retaining and deleting personal data 

This Section 7 sets out our data retention policies and procedures,  which are designed to help ensure that we comply with our legal  obligations in relation to the retention and deletion of personal data. 


Personal data that we process for any purpose or purposes shall not  be kept for longer than is necessary for that purpose or those  purposes. 


Notwithstanding the other provisions of this Section 7, we may retain  your personal data where such retention is necessary for compliance  with a legal obligation to which we are subject, or to protect your  vital interests or the vital interests of another natural person. 


Your rights 

In this Section 8, we have listed the rights that you have under data  protection law. 

Your principal rights under data protection law are: 

  • the right to access - you can ask for copies of your personal data. 

  • the right to rectification - you can ask us to rectify inaccurate  personal data and to complete incomplete personal data. 

  • the right to erasure - you can ask us to erase your personal data. 

  • the right to restrict processing - you can ask us to restrict the  processing of your personal data. 

  • the right to object to processing - you can object to the  processing of your personal data. 

  • the right to data portability - you can ask that we transfer your  personal data to another organisation or to you. 

  • the right to complain to a supervisory authority - you can  complain about our processing of your personal data; and 

  • the right to withdraw consent - to the extent that the legal basis  of our processing of your personal data is consent, you can withdraw  that consent. 

These rights are subject to certain limitations and exceptions.

You may exercise any of your rights in relation to your personal data  [by written notice to us, using the contact details on the website]. 

About cookies 

A cookie is a file containing an identifier (a string of letters and  numbers) that is sent by a web server to a web browser and is stored  by the browser. The identifier is then sent back to the server each  time the browser requests a page from the server. 


Cookies may be either "persistent" cookies or "session" cookies: a  persistent cookie will be stored by a web browser and will remain  valid until its set expiry date, unless deleted by the user before the  expiry date; a session cookie, on the other hand, will expire at the  end of the user session, when the web browser is closed. 


Cookies may not contain any information that personally identifies a  user, but personal data that we store about you may be linked to the  information stored in and obtained from cookies. 


Cookies that we use. 


We use cookies for the following purposes: 

[authentication and status - we use cookies [to identify you when  you visit our website and as you navigate our website, and to help us  determine if you are logged into our website]. 

[shopping cart - we use cookies to [maintain the state of your  shopping cart as you navigate our website. 

[personalisation - we use cookies [to store information about your  preferences and to personalise our website for you]. 

[security - we use cookies [as an element of the security measures  used to protect user accounts, including preventing fraudulent use of  login credentials, and to protect our website and services generally]. 

[advertising - we use cookies [to help us to display advertisements  that will be relevant to you]. 

[analysis - we use cookies [to help us to analyse the use and  performance of our website and services] 

[cookie consent - we use cookies [to store your preferences in  relation to the use of cookies more generally] 

Cookies used by our service providers. 

Our service providers use cookies, and those cookies may be stored  on your computer when you visit our website.

We use Google Analytics. Google Analytics gathers information about  the use of our website by means of cookies. The information gathered  is used to create reports about the use of our website. You can find  out more about Google's use of information by visiting and you can  review Google's privacy policy at 

• Managing cookies 

oMost browsers allow you to refuse to accept cookies and to delete  cookies. The methods for doing so vary from browser to browser, and  from version to version. You can however obtain up-to-date information  about blocking and deleting cookies via these links: 

o Blocking all cookies will have a negative impact upon the usability of  many websites. 

o If you block cookies, you will not be able to use all the features on our  website. 

• Amendments 

o We may update this policy from time to time by publishing a new version  on our website. 

o You should check this page occasionally to ensure you are happy with any  changes to this policy. 

o We [may] OR [will] notify you of [changes] OR [significant changes] to  this policy [by email]. 

Our details 

We are registered in [England and Wales] under registration number  08679002. 

bottom of page