inCharge Privacy Policy

Last modified 2nd April 2025

This privacy notice describes how we will collect, use, share and otherwise process your personal data in connection with your use of:

The inCharge mobile application software available on our site (App);
The inCharge website (Website);
Any of our services that are accessible through the App or the Website (Services), unless such Services state that a separate or additional privacy notice applies to a particular Service, in which case only that privacy notice applies.

Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

This notice is provided in a layered format so you can click through to the specific areas set out below.

IMPORTANT INFORMATION AND WHO WE ARE
THE DATA WE COLLECT ABOUT YOU
HOW IS YOUR PERSONAL DATA COLLECTED?
HOW WE USE YOUR PERSONAL DATA
DISCLOSURES OF YOUR PERSONAL DATA
INTERNATIONAL TRANSFERS
DATA SECURITY
DATA RETENTION
YOUR LEGAL RIGHTS
DESCRIPTION OF CATEGORIES OF PERSONAL DATA

1. Important information and who we are

inCharge HQ (Ireland) Limited is the controller and is responsible for a number of categories of your personal data (inCharge, we, us or our in this notice). inCharge HQ (Ireland) Limited may be the processor of Special Category data.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues, or the Data Protection Commission (DPC), the Irish regulator for data protection issues.

Changes to the privacy notice and your duty to inform us of changes

We keep our privacy notice under regular review.

This version was last updated on 2nd April 2025. It may change and, if it does, those changes will be posted on this page and notified to you when you next start the App or log onto your account. You may be required to read and acknowledge the changes to continue your use of the App or the Services.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you. Please visit the your Account to update your details.

Third party links and sites

Our App and Services may, from time to time, contain links to and from the websites of third parties. Please note that these websites (and any services accessible through them) are controlled by those third parties and are not covered by this privacy notice. You should review their own privacy notices to understand how they use your personal data before you submit any personal data to these websites or use these services.

2. The data we collect about you

We collect, use, store and transfer different kinds of personal data about you. To make it easier for you to use this privacy notice, we group these into the following categories. Each of these categories is described in more detail in the below section, 'Description of categories of personal data'.

Identity Data.
Contact Data.
Profile Data.
Transaction Data.
Device Data.
Content Data.
Usage Data.
Security Data.
Cookies Data.
Marketing and Communications Data.
Location Data.
Connected Data.
Feedback Data.
Personalisation Data.

We may be the processor of Special Category Data which is uploaded to the App by the Controller of that Special Category Data. When Special Category Data is uploaded to the app, the person uploading the information ('Uploader') who is the controller of that information, confirms that they have a lawful basis and condition for uploading that information to the app.

Further details can be found in the below section, 'special category data'.

3. How is your personal data collected?

We collect your personal data in the following way:

Registration. We collect your Identity Data, Contact Data and Special Category Data when you register your account with us.
Communications. When you communicate with us via email, telephone, one of our online forms or chat we collect your Contact Data. If you contact us through the App using the chat function, we also collect Device and Cookies Data to operate our chat function and respond to your messages. If the communication relates to an error or problem you are having with the App or one of our Services, we will also collect Usage Data for diagnosis and improvement.
Information you generate when using our App and Services. Each time you access and use our App and Services we collect Content, Device, Cookies, Personalisation, Special Category and Usage Data. We collect Content Data where you upload it to the App or interact with the content available on the App. We collect Device, Cookies, Personalisation and Usage Data by using cookies and other similar technologies. Please see our cookie notice for further details.
Information we collect through monitoring the use of our App, Sites and Services. Each time you access and use our App and Services we collect information about that access and use, being Device, Content, Cookies, and Usage Data.
Direct Marketing. We collect and record Direct Marketing Data when we add you to our marketing database, you request to change your direct marketing preferences, or you interact with our direct marketing communications, or we receive prospect information from our data broker partners.
Connected Data. We collect Connected Data when you choose to connect your connected device to your account.
Unique application numbers. When you want to install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.

Cookies

We use cookies (small files placed on your device) on the App and in our direct marketing emails to improve your experience and our development of the App and our Services. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie notice.

4. How we use your personal data

We will only use your personal data when we have a lawful basis to do so. Our lawful basis for each purpose for which we use your personal data is specified below. Most commonly we will use your personal data in the following circumstances:

Consent. Where you have freely consented before the processing in a specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by your Account or contacting us (see 'Your Legal Rights' below).
Performance of a contract. Where we need to process your personal data to perform a contract with you or where you ask us to take steps before we enter into a contract with you. Where we rely on performance of a contract and you do not provide the necessary information, we will be unable to perform your contract.
Legitimate interests. 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. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Legal obligation. Where we need to use your personal data to comply with a legal or regulatory obligation. Where we rely on legal obligation and you do not provide the necessary information, we may be unable to fulfil a right you have or comply with our obligations to you, or we may need to take additional steps, such as informing law enforcement or a public authority or applying for a court order.

Automated decision making and profiling

We do not make decisions based solely on automated processing or profiling that produce legal effects concerning you (or have similarly significant effects).

Criminal offence data and special category data

We may process data relating to criminal offences in monitoring the use of our App for security purposes, where we suspect you may have committed a crime, such as attempting to make a fraudulent purchase or claim or circumvent the security of the App or Services. In such circumstances we will provide that information to law enforcement and/or use it to establish, exercise or defend a legal claim. In those circumstances, according to the type of activity and purpose, we will rely on legitimate interests (protecting our business, employees and other users) and legal obligation (where required by legal, judicial or law enforcement to disclose or process that information). UK law and Irish Law authorises that processing under the Data Protection Act 2018 and although the appropriate authorisation will depend on a case-by-case basis, monitoring for criminal behaviour through the use of our App is in the Substantial public interest (preventing or detecting unlawful acts) and processing information related to suspected criminal activity for legal claims is permitted under the additional condition of legal claims.

Special categories of personal data

We may be the processor of Special Category Data when Special Category Data is uploaded to the App. When Special Category Data is uploaded to the app, the person uploading the information ('Uploader') who is the controller of that information, confirms that they have a lawful basis and condition for uploading that information to the App. If the Uploader provides information about another user of our App, then the Uploader, by uploading the information, confirms that they have a lawful basis and condition for uploading that information to the App.

5. Disclosures of your personal data

We may share your personal data with the following third parties:

External third parties.
- Your Appstore Provider and mobile network operator to allow you to install the App.
- Service providers acting as processors based in the UK and/or EU who provide IT and system administration services, hosting services for our App, delivery and logistics services, payment processing, fraud and identity verification providers, customer service support, email delivery and administration, and data storage and analysis.
- Our professional advisors acting as controllers based in the UK and EU including lawyers, auditors, insurers, and consultants who provide legal, accounting, insurance and other services.
- Your service providers that you have appointed, and we need to contact to fulfil your requests, such as your banking or payment card provider to process your transactions.
- Marketing and promotional partners and co-operatives acting as processors or controllers or joint controllers based in the UK and EU with whom we share data to enhance our offerings and identify prospective customers.
- Third party partners where you have expressly subscribed to receive marketing from or with them.
- Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
- HM Revenue and Customs, the Revenue Commissioners, regulators, law enforcement, public authorities or other third parties acting as controllers based in the UK and Ireland where necessary to exercise our rights or comply with a legal obligation.

6. International transfers

We do not transfer your personal data outside the UK or EEA.

7. Data security

All information you provide to us is stored on our secure servers and located in the UK or EEA. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our App or Services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use strict procedures and security features to protect your personal data from loss, unauthorised use or access.

We will collect and store personal data on your device using application data caches and browser web storage (including HTML5) Please see our cookies policy.

Certain Services include social networking, chat room or forum features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.

We have put in place procedures to detect and respond to personal data breaches and notify you and any applicable regulator when we are legally required to do so.

8. Data retention

By law we have to keep basic information about our customers (including Contact, Identity, Security and Transaction Data) for six years after they cease being customers.

In some circumstances you can ask us to delete your data: see 'Your Legal Rights' below for further information.

Once we no longer have a legal right to hold your personal data, we will delete or, in some circumstances, we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

If you do not use the App for a period of 6 years then we will treat the account as expired and will delete your personal data.

9. Your Legal Rights

You have the following rights under data protection laws in relation to your personal data.

Access. Request access to and/or a copy of the personal data we process about you (commonly known as a data subject access request). This enables you to check that we are lawfully processing it.
Correction. Request correction of any incomplete or inaccurate data we hold about you. (We may need to verify the accuracy of the new data you provide to us.)
Deletion. Request us to delete or remove personal data where there is no good reason for us continuing to process it. You also can ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we have processed your information unlawfully or where we need to erase your personal data to comply with law. (In some cases, we may need to continue to retain some of your personal data where required by law. If these apply, we will notify you at the time of our response.)
Objection. Object to us processing your personal data where (a) we are relying on legitimate interests as the lawful basis and you feel the processing impacts on your fundamental rights and freedoms, or (b) the processing is for direct marketing purposes. In some cases, we may refuse your objection if we can demonstrate that we have compelling legitimate grounds to continue processing your information which override your rights and freedoms.
Restriction. Request that we restrict or suspend our processing of your personal data:
- if you want us to establish the data's accuracy;
- where our use of the data is unlawful, but you do not want us to erase it;
- where we no longer require it, but you need us to hold onto it to establish, exercise or defend legal claims; or
- you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
Data portability. Request we transfer certain types of your personal data to you or your chosen third party in a structured, commonly used, machine-readable format. This right only applies to information processed by automated means that we process on the lawful bases of consent or performance of a contract.
Withdraw consent. Withdraw your consent at any time where we are relying on consent to process your personal data. Please know that this does not affect the lawfulness of any processing carried out before you withdraw your consent, and after withdrawal, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Complain to the UK or Irish data protection regulator. If you are unhappy with how we process your personal data, we ask that you contact us first using the details below so that we have the chance to put it right. However, you also have the right to make a complaint to the at any time.

You can exercise any of these rights at any time by contacting us at karen@inchargehq.com.

10. Description of categories of personal data

Identity Data: first name, last name, title, date of birth and Profile Data.
Contact Data: first name, last name, contact address, email address and telephone numbers, your communication preferences and copies of the communications between you and us.
Profile Data: your email address, username and password.
Transaction Data: billing and delivery addresses, payment card details, history of your payments, purchases, deliveries, returns and refunds and the applicable terms and conditions of your purchases.
Device Data: the type of device you use, your unique device identifier, mobile network information, your mobile operating system, the type of mobile browser you use, IP address and time zone setting.
Content Data: information that you store or generate in the App, being photos, videos and associated metadata, check-ins, posts and messages.
Usage Data: logs and detail of your use of our Apps and Services, being the dates and times on which you download, access and update the App and our Services, any error or debugging information, and the resources that you access and the actions we and you take in relation to them and Cookies Data.
Security Data: information we collect about your use of the App, our Services and our Sites in order to ensure your and our other users' safety and security, being Usage Data, Cookies Data and the information provided to us by our payment processing provider.
Cookies Data: the information collected through the cookies and similar technologies listed in our Cookies Notice.
Direct Marketing Data: your direct marketing preferences, consents for receiving direct marketing from us and/or our third parties and the history of the direct marketing communications we have sent to you.
Location Data: your current location as disclosed by GPS technology WiFi connections and your IP address for the time period where you have permitted us to collect it.
Connected Data: information stored on your Device that you permit the App to connect to.
Feedback Data: your feedback and survey responses.
Personalisation Data: Cookies Data, Device Data, Content Data, Transaction Data, Connected Data, Social Media Data, Usage Data, Location Data, and the preferences we have inferred you have and use to personalise the App and Services.