Privacy Policy

Last updated: 14 May 2026

Introduction

At Incredible Technologies Ltd ("Incredible"), we prioritize the protection and respect of your privacy. This policy outlines our practices regarding the collection, use, processing, storage, and disclosure of your information as you engage with our services. We aim to provide clarity on the types of personal data we gather and to inform you of your rights concerning how we handle your information.

Incredible Technologies Ltd, registered at 124 City Road, London, EC1A 2NX, serves as the data controller for the purposes of General Data Protection Regulation (GDPR).

For the most up-to-date version of this policy, please visit www.getincredible.com.

Key Policy Points

1. **Data Processing**: We process information from you, your linked accounts, and third parties to provide our services and meet regulatory requirements.

2. **Types of Data Used**:

  - Personal details (name, address, date of birth) for customer verification

  - Transaction data (excluding login or security details) to power Incredible's features

  - Payment information for processing transactions

  - Usage data to enhance our services

3. **Data Sharing**: We collaborate with several partners to deliver our services and comply with regulations:

  - Modulr (e-money provider)

  - TrueLayer (account aggregation)

  - Modulr (identity verification)

  - Other GDPR-compliant service providers

4. **Your Rights**: Under GDPR, you have the right to access, erase, or challenge the data we hold about you. Our support team is available to assist with such requests.

Data Collection

Information You Provide

When you sign up for our app, we collect necessary information to provide our services and comply with Know Your Customer (KYC) regulations:

- Full name

- Email address

- Residential address

- Date of birth

- Nationality

- Phone number

Additional details may be required for specific services within the app.

Automatically Collected Information

As you use our app or website, we automatically gather data including:

- Payment details (for transaction processing and fraud prevention)

- Device information (IP address, browser type, operating system)

- Product usage data

Third-Party Information

We receive information from trusted third-party providers:

- Credit card data (via account aggregation partners)

- KYC check results

- Public and commercial data sources (for regulatory compliance)

Data Usage

Service Improvement and Provision

We process collected information to:

- Facilitate access to Incredible's features

- Provide insights into your financial data

- Offer customer support

- Recommend relevant products and services

- Send important notifications and updates

- Conduct internal analysis and research

- Fraud Prevention and Regulatory Compliance

We use your data to:

- Detect fraudulent activities

- Verify your identity

- Maintain platform security

Lawful bases for processing (UK GDPR Article 6)

We process your personal data on the following bases:

- Contract (Art 6(1)(b)) - to provide the Incredible service you signed up for, including connecting to your credit card accounts and processing payments.
- Legitimate interests (Art 6(1)(f)) - for fraud prevention, service improvement, security monitoring, and call recordings (see Terms of Service 7.5).
- Legal obligation (Art 6(1)(c)) - to comply with FCA, HMRC, and anti-money-laundering requirements.
- Consent (Art 6(1)(a)) - for marketing communications, where applicable. You can withdraw consent at any time.

Automated decision-making and profiling

We use automated processing, including AI, to read, parse, and structure the account information from your connected credit cards. This is operational data structuring only.

We do not make solely automated decisions that produce legal or similarly significant effects on you. All decisions about your account, payments, and eligibility involve human review.

Under UK GDPR Article 22, you have the right to:
- Not be subject to a decision based solely on automated processing
- Request human intervention
- Express your point of view and contest the decision

Data Sharing

We share your data with:

1. **Service Providers**:

  - TrueLayer (account aggregation)

  - Modulr (e-wallet services and Direct Debit management)

  - Modulr (KYC and screening)

2. **Regulatory Bodies**: To comply with legal obligations, we may share information with relevant government entities.

Data Retention

We retain your information for as long as necessary to provide our services and meet regulatory requirements. You can request data deletion by contacting support@getincredible.com. Note that we must retain certain information for at least 5 years to comply with regulations.

Your GDPR Rights

Under GDPR, you have the following rights:

1. **Access**: Request a copy of your data

2. **Rectification**: Ask us to correct inaccurate information

3. **Erasure**: Request deletion of your data

4. **Withdraw Consent**: Opt-out of data processing

5. **Complain**: Lodge a complaint with the Information Commissioner's Office

6. **Restriction**: Ask us to limit how we use your data

7. **Portability**: Receive your data in a structured, machine-readable format

8. **Object**: Object to processing based on legitimate interests, including profiling

9. **Automated decisions**: Not be subject to solely automated decisions (see above)

To exercise these rights, please contact support@getincredible.com.

Policy Updates

Any future changes to this policy will be posted on our website. We will notify you via email or in-app notifications when appropriate.

Contact Information

For any questions or concerns regarding this privacy policy, please email support@getincredible.com.

© 2026 Incredible Technologies Ltd