INICIO

Restoring Control, Confidence and Value.

INICIO PARTNERS LIMITED’S PRIVACY POLICY

Last updated: 30 December 2025

INICIO Partners Ltd (“INICIO”, “we”, “us”) is committed to handling personal data with transparency, discipline and care. This Privacy Policy explains what personal data we collect, why we collect it, how we use it, and the rights you have under UK data protection law.

This policy applies to information we collect via our website, when you contact us, and in the course of delivering our services.

1) Who we are (Data Controller)

INICIO is the data controller for personal data processed under this policy.

Contact (privacy enquiries): hello@inicio.partners
If you prefer, you can use the Contact page form and state that your message is a privacy enquiry.

2) The personal data we collect

We may collect and process the following categories of personal data:

A. Information you provide to us

  • Identity and contact details: name, email address, phone number, role/title, company name.

  • Enquiry information: the content of messages you submit, information about your business situation, and any documents you choose to share with us.

  • Commercial and engagement information: details needed to propose, contract for, and deliver services (e.g., billing contact details and project communications).

B. Information we collect automatically when you use our website

  • Usage data: pages visited, time spent on pages, navigation paths, referring pages.

  • Device and technical data: IP address, browser type/version, device type, operating system, approximate location derived from IP.

  • Cookie and similar technology data: depending on your cookie choices (see Cookies section below).

C. Information we receive from third parties (limited)

We may receive contact details from professional introductions (e.g., mutual contacts) or public sources (e.g., company websites, LinkedIn) where relevant to a business discussion.

Special category data: We do not intentionally collect special category data (e.g., health, religion, political opinions). Please avoid sending it unless strictly necessary; if you do, we will handle it with appropriate safeguards.

3) How we collect your data

We collect data when you:

  • submit a form on our website;

  • email or call us;

  • engage with us on professional platforms (e.g., LinkedIn);

  • become a client and we deliver services; and/or

  • browse our website (subject to cookie settings).

4) Why we use your data (purposes and lawful bases)

UK GDPR requires a “lawful basis” for processing. We use your personal data for the purposes below:

A. To respond to enquiries and discuss potential work

  • Purpose: respond to messages, arrange calls, understand your situation, provide information about our services.

  • Lawful basis: Legitimate Interests (running our business and responding to enquiries) and/or Steps to enter into a contract.

B. To deliver our services and manage client relationships

  • Purpose: contracting, onboarding, project delivery, communications, invoicing, maintaining records of work undertaken.

  • Lawful basis: Contract and Legal Obligation (where applicable, e.g., accounting/tax record keeping).

C. To improve our website and services

  • Purpose: maintain website performance, understand what content is useful, improve user experience, troubleshoot issues.

  • Lawful basis: Legitimate Interests and/or Consent (where analytics/marketing cookies require it).

D. Marketing communications (where applicable)

  • Purpose: send updates or insights relevant to your interests.

  • Lawful basis: Consent (where required) and/or Legitimate Interests (limited, B2B-appropriate communications).

  • Opt-out: you can unsubscribe at any time (see Your Rights).

E. Compliance and protection

  • Purpose: comply with legal requirements, prevent fraud/abuse, protect rights, resolve disputes.

  • Lawful basis: Legal Obligation and/or Legitimate Interests.

5) Marketing preferences

If we send you marketing communications:

  • We will keep it relevant and proportionate.

  • You can opt out at any time by using the unsubscribe link (where provided) or emailing hello@inicio.partners.

Opting out of marketing does not affect essential service communications (e.g., messages relating to a current engagement).

  • Employment and recruitment agencies, or current, past and prospective employers, where you require a reference from us
  • Our employees who work on our projects
  • Any person or organisation where we are required to because of a Court order, legal duty, or statutory obligation

6) Cookies and similar technologies

We use cookies and similar technologies for site functionality, security and (if you choose) analytics.

A. Managing cookie choices

Where our site displays a cookie banner or preference tool, you can manage your cookie settings there. You can also control cookies via your browser settings.

B. Types of cookies

  • Strictly necessary cookies: required for the site to function (cannot be switched off in our systems).

  • Performance/analytics cookies: help us understand site usage and improve content (used only where permitted by your settings).

  • Functionality cookies: remember preferences (where used).

  • Marketing cookies: used to measure campaign effectiveness or deliver targeted advertising (only where used and consented to).

7) Who we share personal data with

We do not sell personal data.

We may share personal data with trusted third parties where necessary to operate our website and business, such as:

  • website hosting and infrastructure providers;

  • website analytics providers (subject to your cookie preferences);

  • email and communications providers;

  • CRM and document management tools;

  • professional advisers (legal, accounting) where necessary; and

  • regulators, authorities, or courts where legally required.

Where third parties process personal data on our behalf, they act as processors and are required to keep data secure and use it only for specified purposes.

8) International transfers

Some service providers may process data outside the UK (for example, where cloud services are hosted internationally).

Where personal data is transferred outside the UK, we use appropriate safeguards such as:

  • the UK International Data Transfer Agreement (IDTA) or UK Addendum to EU SCCs; and/or

  • transfers to countries covered by UK adequacy regulations (where applicable).

You can ask us for further details of safeguards by emailing hello@inicio.partners.

9) How long we keep your data (retention)

We keep personal data only for as long as necessary for the purposes described in this policy, including legal, accounting, or reporting requirements.

Typical retention approach:

  • Enquiries (non-clients): retained for up to 12–24 months after last contact, unless there is a legitimate reason to keep it longer (e.g., ongoing discussions).

  • Clients: retained for the duration of the engagement and for a period afterwards to support contractual, professional and legal needs (often 6 years for certain business records, depending on the type of record).

  • Marketing lists: retained until you unsubscribe or we determine it is no longer appropriate to keep your details.

You can request deletion in certain circumstances (see Your Rights).

10) Security

We use appropriate technical and organisational measures designed to protect personal data against accidental or unlawful loss, unauthorised access, alteration, or disclosure. No method of transmission over the internet is completely secure, but we take security seriously and continuously improve controls.

11) Your rights under UK GDPR

You have rights in relation to your personal data, including:

  • Access: request a copy of the personal data we hold about you.

  • Rectification: request correction of inaccurate or incomplete data.

  • Erasure: request deletion in certain circumstances.

  • Restriction: request we limit how we use your data in certain circumstances.

  • Objection: object to processing based on legitimate interests, including direct marketing.

  • Data portability: request transfer of your data to you or another provider (where applicable).

  • Withdraw consent: where we rely on consent, you can withdraw it at any time (this will not affect past processing).

How to exercise your rights

Email hello@inicio.partners with:

  • your name and contact details,

  • the right you want to exercise, and

  • enough information for us to verify your identity and locate the relevant data.

We aim to respond within one month of receiving a valid request (and sooner where possible).

Complaints

If you are unhappy with how we handle your data, please contact us first so we can address it. You also have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection.

12) Automated decision-making

We do not use your personal data for automated decision-making that produces legal or similarly significant effects.

13) Links to other websites

Our website may contain links to third-party websites. We are not responsible for the privacy practices of those sites. Please review their privacy policies.

14) Changes to this Privacy Policy

We may update this policy from time to time. We will post the latest version on this page and update the “Last updated” date above.