InQubee respects your privacy and is committed to protecting your personal information.

This Privacy Policy explains how InQubee collects, uses and protects personal information when you visit this website, contact me, enquire about my services, or when I process business contact information as part of the business development and lead generation services I provide.

1. Who I am

InQubee is a freelance business development and lead generation service operated by Ilse Bernthal, a sole trader based in the UK.

For the purposes of applicable UK data protection legislation, including the UK General Data Protection Regulation (UK GDPR) and Data Protection Act 2018, I am responsible for determining how and why personal information is processed where I act as the data controller.

Email: ilse@inqubee.co.uk

2. What personal information I collect

The information I collect depends on how you interact with InQubee and the services I provide.

This may include:
 

• name;

• job title or position;

• company or organisation name;

• business email address;

• business telephone number;

• business postal address;

• LinkedIn or other professional profile;

• information about your organisation or role;

• correspondence and information you provide when contacting me; and

• business contact information obtained from public sources or third-party business data providers.

I do not intentionally collect sensitive or special category personal information as part of my normal business development and lead generation activities.

3. Information provided directly to InQubee

If you use the contact form on this website, I will collect the information you choose to provide, such as your name, company, email address, telephone number and the content of your enquiry.

I use this information to:
 

• respond to your enquiry;

• communicate with you about InQubee's services;

• provide information or quotations you have requested; and

• develop and manage a potential or existing business relationship.

4. Information obtained from other sources

As part of prospecting for InQubee and providing business development and lead generation services for clients, I may research and compile business contact information from sources other than the individual concerned.

These sources may include:
 

• company and organisation websites;

• LinkedIn and other professional networking platforms;

• publicly available business directories and registers;

• press articles and other publications;

• exhibition websites, exhibitor catalogues and attendee or delegate information where lawfully available;

• other publicly available online or offline business information;

• business contact lists purchased or licensed from third-party data providers; and

• information supplied by clients from their own business records or data providers.

The information obtained will generally relate to an individual's professional or business capacity rather than their private life.

Where I obtain personal information from sources other than the individual, I will consider whether its collection and intended use is fair and lawful, taking into account the source of the information, the context in which it was obtained and the individual's reasonable expectations.

Where required by data protection legislation, appropriate privacy information will be provided to individuals whose personal information I obtain from third-party or publicly available sources.

5. How I use personal information

I may use personal information to:
 

• respond to enquiries and provide my services;

• identify and contact relevant business prospects for InQubee or my clients;

• carry out lead generation, business development and appointment-setting activities;

• communicate with existing and prospective clients or business contacts;

• arrange meetings or other business conversations;

• manage quotations, proposals, contracts, invoices and payments;

• maintain appropriate business records;

• operate and improve this website and my services;

• comply with legal and regulatory obligations; and

• establish, exercise or defend my legal rights.

6. Lawful basis for processing

I will only process personal information where there is an appropriate lawful basis under UK data protection legislation.

Depending on the circumstances, this may include:

Legitimate interests

I may rely on legitimate interests where processing is necessary for legitimate business development, networking, prospecting or marketing activities, provided that these interests are not overridden by the rights and freedoms of the individual.

When relying on legitimate interests, I will consider the nature and source of the information, the context in which it was obtained, the individual's reasonable expectations and the potential impact of the processing.

Contract

I may process personal information where necessary to enter into or perform a job, contract or agreement.

Legal obligation

I may process information where necessary to comply with a legal or regulatory obligation.

Consent

Where consent is required, I will obtain it before carrying out the relevant processing. Where processing is based on consent, consent can be withdrawn at any time.

7. Direct marketing and communications

InQubee's services may involve contacting people in a professional or business capacity by telephone, email, LinkedIn or other appropriate business communication channels.

I will comply with applicable data protection and electronic marketing legislation, including the UK GDPR, Data Protection Act 2018 and Privacy and Electronic Communications Regulations (PECR).

The rules for electronic marketing can differ depending on the type of organisation or individual being contacted. Different rules may apply, for example, to limited companies and to sole traders or individuals.

The fact that business contact information is publicly available does not, by itself, mean that an individual has consented to receive marketing communications. I will take this into account when determining whether and how contact information may be used.

You have the right to object to direct marketing at any time. If you ask me not to contact you for marketing purposes, I will respect your request and retain only the information necessary to ensure that your preference is respected.

8. Client data and third-party data

Where I process personal information on behalf of a client, the client may be the data controller and InQubee may act as its data processor, depending on the nature of the engagement and the arrangements between us.

Client prospect data may be researched by InQubee, purchased or licensed from third-party business data providers, or supplied by the client from its own records or data providers.

Where a client provides personal information to InQubee for processing on its behalf, the client is responsible for ensuring that it has an appropriate lawful basis for providing the information and instructing its use.

Where I use third-party business data providers, I will take reasonable steps to assess whether the data is suitable for the intended purpose and has been obtained in accordance with applicable data protection requirements.

Where InQubee determines the purposes and means of processing personal information itself, InQubee may act as the data controller for that processing.

9. Sharing personal information

I do not sell or rent personal information.

I may share personal information where necessary:
 

• with clients where this forms part of the service I am providing;

• with technology and service providers supporting my business, such as website hosting, CRM, email, telephone and accounting providers;

• with professional advisers where necessary;

• with HM Revenue & Customs, regulators, law enforcement agencies or other authorities where legally required; or

• where necessary to establish, exercise or defend my legal rights.

Where appropriate, I will ensure that suitable contractual and data protection arrangements are in place with service providers processing personal information on my behalf.

10. Website, cookies and analytics

The InQubee website is hosted using Wix.

Wix may process information relating to website visitors and use cookies and similar technologies for purposes including website functionality, security and performance.

The website may also use Google Analytics, subject to the required consent, to understand how visitors use the website and improve its content and performance.

Further information about cookies and how they are used is provided in the Cookies Policy.

11. How long I keep personal information

I retain personal information only for as long as reasonably necessary for the purpose for which it was collected, taking into account legal, accounting, contractual and legitimate business requirements.

Information relating to prospective business contacts may be retained for a reasonable period where there is an ongoing or potential legitimate business purpose for doing so.

Where you object to direct marketing, I may retain limited information, such as your name and contact details, on a suppression or do-not-contact list so that I can respect your preference in the future.

When information is no longer required, it will be securely deleted or otherwise disposed of.

12. Keeping information secure

I take reasonable technical and organisational measures to protect personal information against accidental loss, unauthorised access, alteration, disclosure or destruction.

However, no electronic transmission or storage system can be guaranteed to be completely secure.

13. Your data protection rights

Depending on the circumstances, you may have rights under UK data protection law including:
 

• the right to be informed about how your personal information is used;

• the right to request access to personal information I hold about you;

• the right to request correction of inaccurate or incomplete information;

• the right to request deletion of your personal information in certain circumstances;

• the right to request restriction of processing in certain circumstances;

• the right to object to certain processing; and

• the right to withdraw consent where processing is based on consent.

You have an absolute right to object to direct marketing.

If you wish to exercise any of these rights, please contact me using the details below.

14. Third-party websites

The InQubee website may contain links to other websites or online services.

I am not responsible for the privacy practices, content or security of third-party websites. I recommend reviewing the privacy policy of any external website you visit.

15. Changes to this Privacy Policy

I may update this Privacy Policy from time to time to reflect changes to my business, website, services, technology or legal requirements.

The latest version will be published on this website and the date of the most recent update will be shown at the top of the policy.

16. Contact

If you have any questions about this Privacy Policy, how your personal information is handled, or wish to exercise your data protection rights, please contact:

InQubee
Ilse Bernthal
Email: ilse@inqubee.co.uk

17. Complaints

If you have concerns about how I have handled your personal information, please contact me first so that I can try to resolve your concern.

You also have the right to complain to the Information Commissioner's Office (ICO), the UK's supervisory authority for data protection.

Further information is available from the Information Commissioner's Office.

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