Privacy Policy

 Your privacy is important to us. This Privacy Policy is where we explain to you what personal information is collected when you visit our site, how it is collected, how we may use that information, where we store it, how long we store it for, and how we protect it. We will also explain your rights in relation to your personal information.

Please read the following carefully to understand our views and practices regarding your personal information and how we may collect it and treat it.

For convenience, we have divided our data protection policies into three separate pages:

  1. Our Privacy Policy
    You can find our privacy policy which explains generally how we collect, use, store, and protect your personal information.

  2. Our Cookie Policy
    This policy explains more about how we may collect personal information about you via cookies (it also explains what cookies are).

  3. Our Retention Policy
    You can find out how long we may hold onto your personal information.

If you have any questions please do not hesitate to contact us at mc@northstarim.com or, if you prefer to call or write to us, then you can find our contact details at the bottom of this page.

Who we are

We are registered in England and Wales. Our registered number is 10733388 and our registered office is at Triune Court, Monks Cross Drive, York, North Yorkshire, YO32 9GZ.

But, for the purposes of this Cookie Policy, it’s just easier if we refer to ourselves as “we”.

What this privacy policy governs

This Privacy Policy applies to our site, www.northstarim.com and any other services that we may provide to you through our site (we’ll just call these “our services” for short).

In the context of this Privacy Policy “personal information” means information which, on its own or in combination with other information, can be used to identify you, in particular by reference to an identifier such as your name, your address, or location data.

Provided that you consent to us collecting your personal information when you visit our site then this Privacy Policy will govern how we may use that personal information.

Because we are a business located in England, the personal information that you give us or that we collect from you will be held under UK data protection legislation (but we’ll just refer to this as “the legislation”). The legislation requires that we tell you that we are a data controller for your personal information or, in other words, we determine the purposes for which and the manner in which any of your personal information are, or are to be, processed by us.

How you consent to us collecting your personal information

When you visit our site you should see a pop-up at the bottom of your screen directing you to this Privacy Policy and our Cookie Policy.

By clicking or selecting the “I Agree” button that appears in the pop-up then you are demonstrating to us that you are freely giving us informed and specific consent for us to collect and process your personal information for the purposes specified in this Privacy Policy and you are accepting and consenting to the practices described.

If you do not click or select the “I Agree” button that appears in the pop-up at the bottom of your screen then we will endeavour to not collect your personal information – this is subject to the caveat below.

If you do not see a pop-up at the bottom of your screen then you may have already accepted our Privacy Policy and our Cookie Policy. You may also be using a pop-up blocker or similar tools that may prevent this policy from being brought to your attention. Please ensure that any pop-up blockers are disabled when you use our site. We cannot be held liable to you if you use pop-up blocks or similar tools that prevent us from complying with our obligations under the legislation.

Caveat: Even if you do not click or select the “I Agree” button there is still some information that we may automatically collect about you – this normally isn’t personal information but rather technical information sent by your device and used to connect your computer, tablet, or mobile device to the Internet, including your browser type and version, the time when you visit our site, your time zone setting, certain browser plug-in types and versions, operating system and platform. This type of information is sent by you to our site automatically and it isn’t something that we can prevent. We only use this information to administer our site including troubleshooting, load testing, traffic throughput, data analysis, performance testing, and for anonymised research and statistics purposes that we only use internally.

We will only hold your personal information as detailed in our Retention Policy.

Information we may collect

If you consent to us collecting your personal information then we may process the following data about you:

Information you give to us: 
You may give us personal information about you by filling in forms on our site or by corresponding with us by phone, e-mail or otherwise. This includes information you may provide to us when you register to use our site, subscribe to our services, search our site, participate in any discussion boards or other social media functions on our site, enter a competition, promotion or survey, and when you report a problem with our site.

The information you give us may include:

  • Your name;

  • Address;

  • E-mail address;

  • Phone number; and

  • IP address.

Information we collect about you:
When you visit our site we may collect information about you, including which pages you have visited (including date and time) which services and pages you viewed or searched for, page response times, download errors, files downloaded, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from a page and any phone number used to call our customer service number.

The purpose of this information is to allow us to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, improving our site to ensure that content is presented in the most effective manner for you and for your computer, and as part of our efforts to keep our site safe and secure.

Information you may pass to third-parties outside our control:
On many of the pages on our site you will see ‘social buttons’. These enable you to share or bookmark pages on our site. These may include buttons for: Twitter, Google+, Instagram, Facebook, Vimeo or other social features.

In order for us to implement these buttons on our site and connect them to the relevant social networks and external sites, there are scripts that are executed from domains owned by third-parties and outside of our control.

You should be aware that these sites are likely to be collecting information about what you are doing all around the Internet, including on our site. So if you click on any of these buttons, these sites will be registering that action and may use that information. In some cases these sites will be registering the fact that you are visiting our site, and the specific pages you are on, even if you don’t click on the button but are already or automatically logged into their services, like Google and Facebook.

We recommend that you check the respective policies of each of these sites to see how exactly they use your personal information and to find out how to opt out, or delete, such personal information.

How we may use your personal information

When you give us your personal information then we may use it to:

  1. Carry out our obligations from any contracts entered into between you and us and to provide you with information that you request from us.

  2. Provide you with information about our company or our services.

  3. Ensure that content from our site is presented in the most effective manner for you and for your computer.

If you provide us with your e-mail, telephone or mobile number then we may contact you by these electronic means (e-mail or SMS). However, we will not use your personal information for marketing purposes without your express consent.

If you do not wish to receive any information by electronic means then please get in touch with us.

Marketing

If you opt-in to receive information about us then, depending on what personal information we hold about you, we may decide to contact you via:

  • E-mail;

  • SMS;

  • Telephone or

  • Post.

You may opt-in to receive general information about Incredible or we may ask you to opt-in on a case by case basis.

We will do our best to let you know what method or methods of communication we will use. Don’t forget, you can always opt-out from receiving communications from us after you have opted-in or you can tell us that you only want to receive communications in a particular manner, or about a particular element of the company or the services that we offer. Depending on the type of campaign we might give you the ability to select how you would like to be contacted but this might not always be possible due to technical issues.

If you opt-in to receive communication then we may need to pass your personal information to select third parties who are responsible for facilitating communication with you on our behalf. For example, we may need to pass some of your personal details if you wish to be contacted via SMS because we need to partner with a third party business to provide us with this ability.

At present we do not use any third parties for any of our campaigns and if that were to change, we would update our Privacy Policy. If you hear from an organisation about Incredible, it may well be that we are using that service on a one-off basis – in which case, we will let you know. If you are unsure then please get in touch with us.

The purpose of opting into receiving communications from us is to help us better understand you, engage with you, share details about the services we can offer, and to assist us in providing the types of communications that you wish to receive from us. We will not knowingly sell your personal information for marketing purposes or pass your personal information to third parties.

If you are receiving communications from us in error or you have opted-out then please get in touch with us and we apologise for any inconvenience caused.

Disclosure of your information

Please remember that our Cookies Policy covers matters such as using your personal information for analytics purposes.

In some cases we may disclose information about you with select third-parties:

  • We may anonymise and aggregate your information with other users (for example, we may track that 500 men aged under 20 have clicked on a specific page on our site on any given day). We may use such aggregate and anonymised information to help reach a particular target audience or understand who uses our site.

  • Credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you or providing you with services.

  • Debt collection agencies where you have breached a condition of any contract entered between us and you.

  • If we or substantially all of our assets are acquired by a third party, in which case personal information held by us about you may be one of the transferred assets.

  • If we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce any agreements with you, or to protect our rights, property, or safety of our pupils, our employees, or others.

Where we store your personal information

The personal information that we collect from you will be stored within the United Kingdom. We will not knowingly transfer your personal information outside of the European Economic Area. Where it may be necessary for us to transfer your personal information outside of the European Economic Area we will get in touch with us and seek your consent.

All personal information you provide to us is stored on our secure servers. Any online payment transactions will be encrypted using Secure Socket Layer/Transport Layer technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted from our site and any transmission is at your own risk. Once we have received your personal information, we will use strict procedures and security features to try to prevent unauthorised access. We apply a ‘Privacy by Design’ approach to protecting your personal information in order to promote privacy and data protection compliance from the start.

Your rights

You have the right to ask us not to process your personal information or to restrict the purposes for which we may process your personal information. However, if you have an account with us on our site and you withdraw your consent then we reserve the right to suspend or terminate your access to certain parts of our site.

You can exercise your right to prevent processing of your personal information by not selecting or clicking on the “I Agree” button when you visit our site or when you login or create an account on our site.

You can also exercise your right at any time by contacting us. If you consented to us collecting and/or processing your personal information but you change your mind then you can get in touch with us about erasing the personal information we hold about you.

Please be aware that, even if we receive a request from you to delete your personal information, it may be that we cannot entirely remove all of your personal information. This is usually because we have a legitimate interest to hold onto some of that personal information, for example, if you have an ongoing contract with us, there are outstanding payments due by you to us, the personal information relates to a third-party, or we have a legal obligation to retain some or all of your personal information – but we’ll let you know.

Access to information

The legislation gives you the right to access a copy of the personal information that we hold about you.

In order to request a copy you need to submit a request – details on how to get in touch can be found at the bottom of this page. However, please remember that certain types of data cannot be disclosed to you as part of your request. For example, we cannot disclose information to you which identifies another individual or information that may be subject to legal professional privilege. In many cases we may be required to redact some of the documentation that you receive in order to comply with the legislation.

Additionally, we can’t just release your personal information to anyone. We can only release your personal information to you or an authorised third party who can demonstrate that you consented to have your personal information released – this is a legal requirement. Therefore, it is important for us to ensure that we confirm your identity before we can release any personal information.

If you send us a request to provide you with a copy of your personal information then we may ask you to provide some identification. We may ask you to provide a copy of your current and valid passport and/or driving license plus a utility bill (that is no more than 3 months old) and has your current address. We may also ask you to visit one of our offices or obtain a solicitors or notary publics’ confirmation of your identification.

All of this might sound very onerous but please understand that we have an obligation to protect your personal information and we need to be certain that it is being released to the right person.

What if I do not consent or withdraw consent?

If you do not consent to us collecting your personal information then we cannot guarantee the full functionality of our site and cannot be held responsible or liable to you for any reduction or restriction in access to our site or any of our other services.

Our site may, from time to time, contain links to and from the sites of our partners and affiliates. If you follow a link to any of these sites, please note that these sites have their own privacy and cookie policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to these sites.

How long will you hold onto my personal information?

Depending on how you engage with us it may be necessary for us to store your personal information for shorter or longer periods of time. Either way, we will only store your personal information for a legitimate and lawful reason. Please remember that this Privacy Policy only applies to how we may collect, store, use, and retain your personal information when you visit our site. If you become a client of Incredible, then you will be bound by the terms of additional policies that specifically relate to how we may use your personal information

You can find details on how long we may hold onto your personal information on our Retention Policy which can be found here.

Changes to our privacy policy

We may need to change this Privacy Policy if it’s necessary for legal reasons or to reflect changes to our site and services. In any case, the provisions of this Privacy Policy may be changed without prejudice to your rights. When we change our Privacy Policy we will make the updated Privacy Policy available on our site and we will also update the “Last Updated” date.

Once we change our Privacy Policy, it will become legally binding on you 30 days after we post it on our site. During that period you’re welcome to contact us if you have questions about the changes.

If you don’t agree with our changes to the Privacy Policy (regardless of whether you get in touch with us) then unfortunately we may need to restrict or limit your use of the parts of our site that require your personal information in order for us to deliver our services to you. We’re sorry we have to say that, but we hope you’ll appreciate that in order for certain parts of our site to work properly and in order for us to identify you in connection with our services we need to have everyone using our site and our services under the same rules instead of different people having different rules – that’s why we encourage you to get in touch with us if you have queries.

Contact us

This Privacy Policy was prepared with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of how cookies may be used to collect and/or process your personal information. However, we are happy to provide additional information or explanation needed.

If you have any questions, comments or requests regarding our Privacy Policy then please do not hesitate to get in touch with us. To make things easier for both of us we would appreciate it if your queries were addressed to:

Data Privacy Manager 
North Star Investment Management, Triune Court, Monks Cross Drive, York, North Yorkshire, YO32 9GZ