The Incremental Pathway

Privacy notice

Last updated: 9 October 2026

About this notice

Incremental Pathway Limited respects your privacy and is committed to protecting your personal information.

This notice explains how we collect and use personal information when you:

• Visit our website

• Contact us

• Receive communications from us

• Work with us as a client, prospective client, supplier, partner or consultant

• Participate in a meeting, workshop or other engagement with us

Incremental Pathway Limited is the controller responsible for the personal information described in this notice.

Company number: 16016957

Registered office: 4a Hafer Road, London, England, SW11 1HF

Email: info@incrementalpathway.com

Our services are intended for businesses and professionals. They are not intended for children, and we do not knowingly collect personal information relating to children.

Information we collect

The information we collect depends on your relationship with us and how you interact with us. It may include:

Contact and professional information

Your name, job title, employer, business address, email address, telephone number and professional profile information.

Enquiry and communication information

Information contained in enquiries, emails, meeting notes, forms, survey responses and other communications with us.

Client and engagement information

Information needed to understand, plan and deliver our services. This may include information about your organisation, its products, operations, customers, employees, strategy and business challenges.

Some of this information may relate to other identifiable people within your organisation or connected with an engagement.

Commercial and transaction information

Information about proposals, contracts, services purchased or supplied, invoices, payments and our commercial relationship with you or your organisation.

Marketing information

Your communication preferences and information about your interaction with our business communications.

Website and technical information

Your IP address, browser and device information, approximate location, website usage information, referral source and information collected through cookies or similar technologies.

We do not normally seek special-category personal information, such as information about health, ethnicity, political opinions or religious beliefs. Please do not provide such information unless it is genuinely necessary for an engagement and has been agreed with us.

How we obtain information

We obtain personal information:

• Directly from you when you contact us, complete a form, communicate with us or participate in an engagement

• From your employer, colleagues, clients, advisers or other people involved in an engagement

• From publicly available professional sources, such as company websites, Companies House and LinkedIn

• From business partners, professional networks and referrals

• Automatically through our website and its supporting technologies

• From service providers that help us operate our website, communications and business systems

If we receive your information from another source, we will provide relevant privacy information when required by law.

How and why we use your information

Responding to enquiries and developing business relationships

We use contact, professional and communication information to respond to enquiries, understand potential requirements, prepare proposals and manage prospective business relationships.

Our lawful basis is our legitimate interest in developing and operating our business. Where you are entering into a contract with us personally, we may also use the information to take steps at your request before entering into that contract.

Providing and managing our services

We use contact, professional, engagement, commercial and communication information to plan, provide and manage our services.

Our lawful basis is performance of a contract where you are personally a party to that contract. Otherwise, we rely on our legitimate interests in delivering services to our clients and managing our business relationships.

Managing contracts, invoices and payments

We use contact, commercial and transaction information to administer contracts, issue and pay invoices, maintain financial records and recover amounts owed.

Our lawful bases are performance of a contract, compliance with our legal obligations and our legitimate interest in managing our finances.

Operating and protecting our business and website

We use contact, website and technical information to operate our systems, maintain security, troubleshoot problems, prevent misuse and protect our legal rights.

Our lawful bases are our legitimate interests in operating and protecting our business and compliance with applicable legal obligations.

Improving our services

We may use engagement, feedback and website-usage information to understand how our services and website are used and to improve them.

Our lawful basis is our legitimate interest in improving our services. Where non-essential cookies or similar technologies are involved, we obtain consent where required.

Business communications and marketing

We may use business contact information to send relevant information about our services, publications, events and other business activities.

Our lawful basis is normally our legitimate interest in communicating with clients, prospective clients and other business contacts. We obtain consent where it is required by electronic-marketing law.

You can opt out at any time by using the unsubscribe link in an email or contacting info@incrementalpathway.com.

Complying with legal obligations

We may use and disclose information where necessary to comply with tax, accounting, regulatory or other legal requirements.

When information is required

Some information is required so that we can respond to an enquiry, enter into a contract, provide services or comply with legal obligations.

If required information is not provided, we may be unable to provide the relevant service or continue the business relationship.

Sharing personal information

We may share personal information with:

• Employees and consultants involved in operating our business or delivering our services

• Clients, partners and other participants where necessary for an engagement

• Website hosting, cloud, communications, analytics, payment, accounting and IT service providers

• Technology and AI service providers where they are used to support our work

• Accountants, lawyers, insurers and other professional advisers

• Government bodies, regulators, courts or law-enforcement authorities where required

• A prospective purchaser, investor or successor in connection with a sale, investment or restructuring of our business

We only share information where there is a legitimate reason to do so. Service providers acting on our behalf are required to process information only for the agreed purposes and to protect it appropriately.

International transfers

Some of our service providers may process personal information outside the United Kingdom.

Where personal information is transferred to a country that is not recognised as providing an adequate level of protection, we use an approved transfer mechanism where required. This may include the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses, or another safeguard permitted by UK data-protection law.

You may contact us for more information about safeguards relevant to your personal information.

How long we keep information

We retain personal information only for as long as reasonably necessary for the relevant purpose.

Normally:

• General enquiries are retained for up to two years after the last substantive contact

• Client and engagement records are retained for up to seven years after the engagement ends

• Contracts, invoices and financial records are retained for the period required by tax, accounting and legal obligations

• Marketing information is retained until you opt out or we determine that it is no longer relevant

• Website logs and analytics information are retained according to the settings described in our Cookie Notice

We may retain information for longer where necessary to establish, exercise or defend legal claims. We may also retain limited information to record an opt-out and ensure that we do not send further marketing communications.

Security

We use appropriate organisational and technical measures to protect personal information against unauthorised access, loss, alteration or disclosure.

Access is limited to people and service providers that need the information for an authorised purpose.

Your rights

Depending on the circumstances, you may have the right to:

• Ask for access to your personal information

• Ask us to correct inaccurate or incomplete information

• Ask us to delete your information

• Ask us to restrict how your information is used

• Object to processing based on legitimate interests

• Receive certain information in a portable format

• Withdraw consent where we rely on consent

These rights are subject to legal conditions and exemptions. To exercise a right, contact info@incrementalpathway.com. We may need information from you to verify your identity.

You will not normally be charged for exercising your rights. We normally respond within one month, although the law permits additional time for certain complex requests.

Your right to object to direct marketing

You have an absolute right to object to the use of your personal information for direct marketing. If you object, we will stop using your information for that purpose.

You can object by using the unsubscribe link in a marketing email or contacting info@incrementalpathway.com.

Cookies

Our website uses cookies and similar technologies.

Essential cookies may be used where necessary for the website to operate. We request consent before using non-essential cookies where required by law.

Further information about the cookies we use, their purposes and how to change your preferences is available in our Cookie Notice.

Other websites

Our website may contain links to websites operated by other organisations. We are not responsible for how those organisations collect or use personal information.

You should review their privacy information before providing them with personal information.

Complaints

Please contact us first if you have questions or concerns about how we use your information:

info@incrementalpathway.com

You also have the right to complain to the Information Commissioner’s Office, the UK data-protection regulator.

Information Commissioner’s Office

Website: https://ico.org.uk/make-a-complaint/

Telephone: 0303 123 1113

Changes to this notice

We may update this notice when our services, systems or legal obligations change.

The current version and its revision date will be published on our website.