Privacy Policy
Last updated: January 2026
1. Introduction
InCrementum, operated by Ray Costello ("we", "our", "us"), is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website or use our services. We comply with the General Data Protection Regulation (GDPR) and other applicable data protection laws.
2. Data Controller
Incrementum is the data controller for the personal data collected through this website.
Contact: Ray Costello
Email: privacy@incrementum.ie
Location: Ireland, EU
3. Information We Collect
Personal Information You Provide
- Name (first name)
- Email address
- Phone number (optional)
- Business information you share during consultations
Automatically Collected Information
- IP address (anonymized where possible)
- Browser type and version
- Device information
- Pages visited and time spent on site
- Cookie preferences
4. Legal Basis for Processing
We process your personal data based on the following legal grounds:
- Consent: When you opt-in to receive communications or accept cookies
- Contract: To provide the advisory and operations services you have requested
- Legitimate Interest: To improve our services and respond to inquiries
- Legal Obligation: To comply with applicable laws and regulations
5. How We Use Your Information
- To respond to your inquiries and schedule consultations
- To provide personalised business advisory and COO services
- To send relevant communications with your consent
- To improve our website and services
- To comply with legal obligations
6. Data Sharing
We do not sell your personal data. We may share data with:
- Service providers who assist in operating our website (hosting, analytics)
- Professional advisors (legal, accounting) when necessary
- Authorities when required by law
7. Your Rights Under GDPR
You have the following rights regarding your personal data:
Right of Access
Request a copy of your personal data
Right to Rectification
Request correction of inaccurate data
Right to Erasure
Request deletion of your data ("right to be forgotten")
Right to Data Portability
Receive your data in a machine-readable format
Right to Object
Object to processing based on legitimate interests
Right to Withdraw Consent
Withdraw consent at any time without affecting prior processing
8. Exercising Your Rights
To exercise any of your rights, please submit a request using the form below or contact us directly. We will respond within 30 days as required by GDPR.
9. Data Retention
We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by law. Lead data is retained for up to 3 years unless you request earlier deletion. Client business data is retained for 7 years for legal and professional purposes.
10. Security
We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. This includes encryption, secure hosting, and access controls.
11. International Transfers
Your data is processed within the EU/EEA. If we transfer data outside the EU/EEA, we ensure appropriate safeguards are in place (e.g., Standard Contractual Clauses, adequacy decisions).
12. Contact & Complaints
For any privacy-related questions or to lodge a complaint, contact us at:
You also have the right to lodge a complaint with the Irish Data Protection Commission (www.dataprotection.ie) or your local supervisory authority.