Privacy Policy
Introduction
The IMCC Limited (“we”, “us”, “our”) is committed to protecting your privacy. This policy explains how we collect, use, and safeguard your personal data when you visit our website (theimcc.net) or engage with us.
This policy applies to all visitors to our website, wherever you are located. We operate from the United Kingdom and serve clients across the UK, Europe, and the United States. Where applicable, we comply with the UK General Data Protection Regulation (UK GDPR), the EU General Data Protection Regulation (EU GDPR), and US state privacy laws including the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA).
We are the data controller for the personal data we process through this website. Our details are:
- The IMCC Limited
- Company number: 13214134
- Registered office:Units 1 & 2 Field View, Baynards Business Park, Baynards Green, Bicester, Oxfordshire, OX27 7SG
- Trading address: 25 Wilton Rd, Pimlico, London SW1V 1LW
- Email: hello@theimcc.net
We have assessed that the appointment of a Data Protection Officer (DPO) is not required under Article 37 of the GDPR, as our core activities do not involve large-scale systematic monitoring of individuals or large-scale processing of special category data. For any data protection enquiries, please contact us at hello@theimcc.net.
What data we collect
We may collect and process the following personal data:
Information you provide to us directly:
- Name, email address, and any other details you submit through our contact form.
- Any information included in correspondence you send to us by email or through the website.
Information we collect automatically:
- Technical data such as your IP address, browser type and version, operating system, time zone setting, and device information.
- Usage data including pages visited, time spent on pages, page interaction information, and navigation paths through the site.
- Data collected through cookies and similar technologies (see our Cookie Policy for details).
How we use your data
We use personal data for the following purposes. Where we refer to a “legal basis”, this applies to processing under UK GDPR and EU GDPR:
- To respond to your enquiries — when you contact us via our contact form or by email, we use the information you provide to respond to your request. Legal basis: legitimate interest in responding to communications (Article 6(1)(f)), or where applicable, your consent (Article 6(1)(a)).
- To administer and improve our website — we use technical and usage data to ensure our website functions properly, to diagnose problems, and to improve the user experience. Legal basis: legitimate interest in maintaining and improving our online presence (Article 6(1)(f)).
- To analyse website traffic — we use analytics tools to understand how visitors use our site so we can improve our content and services. Legal basis: your consent, given through our cookie consent mechanism (Article 6(1)(a)).
- To comply with legal obligations — we may process your data where required to do so by law. Legal basis: compliance with a legal obligation (Article 6(1)(c)).
Who we share your data with
We do not sell your personal data. We may share your data with:
- Hosting and infrastructure providers — our website is hosted on enterprise-grade infrastructure. These providers process data on our behalf and are bound by data processing agreements.
- Analytics providers — we use Google Analytics, provided by Google LLC, to understand website usage. Google processes analytics data on our behalf, which may involve the transfer of data to the United States. See our Cookie Policy for further details.
- CRM and email service providers — if applicable, contact form submissions may be processed through our customer relationship management system to ensure enquiries are handled efficiently.
- Professional advisers — including lawyers, accountants, and insurers where necessary.
- Law enforcement or regulatory authorities — where required by law or to protect our legal rights.
Data retention
We retain personal data only for as long as necessary to fulfil the purposes for which it was collected:
- Contact form enquiries: Retained for up to 24 months from your last interaction with us, unless an ongoing business relationship requires longer retention.
- Analytics data:Retained in accordance with our analytics provider's data retention settings, typically up to 14 months.
- Technical logs: Retained for up to 12 months for security and troubleshooting purposes.
International transfers
Our services operate across the UK, Europe, and the United States. Your data may be transferred to and processed in countries outside your country of residence.
Where personal data is transferred from the UK or EEA to a country that has not been deemed to provide an adequate level of data protection, we ensure appropriate safeguards are in place, such as the UK International Data Transfer Agreement (IDTA), EU Standard Contractual Clauses (SCCs), or reliance on an adequacy decision.
Where personal data is transferred from the UK or EEA to the United States, we rely on the EU-US Data Privacy Framework and its UK Extension where the recipient is certified, or EU Standard Contractual Clauses (2021) and the UK IDTA as appropriate. Our analytics provider, Google LLC, is a certified participant in the EU-US Data Privacy Framework.
Your rights — UK and EEA residents
If you are located in the United Kingdom or the European Economic Area, you have the following rights under UK GDPR and EU GDPR respectively:
- Right of access — to request a copy of the personal data we hold about you.
- Right to rectification — to request correction of inaccurate or incomplete data.
- Right to erasure — to request deletion of your personal data in certain circumstances.
- Right to restrict processing — to request that we limit how we use your data.
- Right to data portability — to request a copy of your data in a structured, commonly used format.
- Right to object — to object to processing based on legitimate interests, including the right to object to direct marketing.
- Right to withdraw consent — where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of processing carried out prior to withdrawal.
- Rights related to automated decision-making — we do not currently carry out automated decision-making or profiling that produces legal or similarly significant effects.
- Right to lodge a complaint — you have the right to lodge a complaint with a supervisory authority. See the Complaints section below for details.
To exercise any of these rights, please contact us at hello@theimcc.net. We will respond within one month of receiving your request (or within the timeframe required under the applicable regulation).
Your rights — US residents
If you are a resident of California or another US state with applicable consumer privacy legislation, this section provides additional disclosures required under the CCPA/CPRA.
Categories of personal information collected in the preceding 12 months:
| CCPA Category | Examples | Sources | Business Purpose | Shared With |
|---|---|---|---|---|
| Identifiers | Name, email address | Directly from you (contact form) | Responding to enquiries | CRM provider, hosting provider |
| Internet or electronic network activity | IP address, browser type, pages visited, navigation paths | Collected automatically via cookies and analytics | Website administration and improvement | Analytics provider (Google LLC) |
| Geolocation data | Approximate location derived from IP address | Collected automatically | Website analytics | Analytics provider (Google LLC) |
We have not sold or shared (for cross-context behavioural advertising) any personal information in the preceding 12 months.
Your rights: You may have additional rights, including:
- Right to know — you have the right to request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources from which it was collected, the business purpose for collecting it, and the categories of third parties with whom we share it.
- Right to delete — you have the right to request that we delete personal information we have collected from you, subject to certain exceptions.
- Right to correct — you have the right to request correction of inaccurate personal information.
- Right to opt out of sale or sharing — we do not sell your personal information and do not share it for cross-context behavioural advertising purposes.
- Right to non-discrimination — we will not discriminate against you for exercising any of your privacy rights.
We do not sell personal information as defined under the CCPA/CPRA. We do not use or disclose sensitive personal information for purposes other than those permitted under applicable law.
To exercise any of these rights, please contact us at hello@theimcc.net. You may also designate an authorised agent to submit a request on your behalf; we may require verification of both your identity and the agent's authority to act.
We will acknowledge your request within 10 business days and provide a substantive response within 45 days. If we require additional time, we will notify you and may extend this period by a further 45 days.
Complaints
If you are unhappy with how we have handled your personal data, you have the right to lodge a complaint with the relevant supervisory authority:
- UK residents:Information Commissioner's Office (ICO) — ico.org.uk, telephone 0303 123 1113
- EEA residents: Your local data protection authority. A full list is available at edpb.europa.eu.
- US residents:You may contact the California Attorney General's office at oag.ca.gov/privacy or the relevant state authority.
We would appreciate the opportunity to address your concerns before you contact a supervisory authority, so please reach out to us first at hello@theimcc.net.
Changes to this policy
We may update this privacy policy from time to time. Any changes will be posted on this page with an updated “last updated” date. We encourage you to review this policy periodically.
Contact
If you have any questions about this privacy policy or our data practices, please contact us at hello@theimcc.net.