Privacy Policy

Last updated: May 2026

This privacy policy sets out how Zenith Meridian Ltd, trading as Incumbency.AI, uses and protects your personal data.

This privacy policy gives you information about how Incumbency.AI collects and uses your personal data as data controller through your use of this website, including any data you may provide when you register with us or purchase a product or service. At Incumbency.AI, we value your privacy as part of your autonomy. This Privacy Policy outlines how we collect, use, and safeguard your data as you journey through our website and services.

This policy also gives you information about how Incumbency.AI processes your data as data processor under the Incumbency.AI software. Incumbency.AI has entered into Data Processing Agreements with third party data controllers and Incumbency.AI will only process your data in accordance with that agreement.

This website is not intended for children and we do not knowingly collect data relating to children.

Controller

Incumbency.AI Ltd is the controller and responsible for your personal data as a user of this website (collectively referred to as "we", "us" or "our" in this privacy policy).

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the information set out in the contact details section below.

1. The types of personal data we collect

Personal data means any information about an individual from which that person can be identified. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data — first name, last name, any previous names, username or similar identifier, marital status, title, date of birth and gender.
Contact Data — billing address, delivery address, email address and telephone numbers.
Financial Data — bank account and payment card details.
Transaction Data — details about payments to and from you and other details of products and services you have purchased from us.
Technical Data — internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website.
Profile Data — your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Usage Data — information about how you interact with and use our website, products and services.
Marketing and Communications Data — your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity.

2. How is your personal data collected?

We use different methods to collect data from and about you including through:

Your interactions with us

You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

apply for our products or services;
create an account on our website;
subscribe to our services or publications;
request marketing to be sent to you; or
give us feedback or contact us.

Automated technologies or interactions

As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.

Third parties or publicly available sources

We may receive personal data about you from various third parties and public sources:

Technical Data from analytics providers, advertising networks, and search information providers.
Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK.

3. How we use your personal data

Legal basis

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

Performance of a contract with you — where we need to perform the contract we are about to enter into or have entered into with you.
Legitimate interests — where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience.
Legal obligation — where it is necessary for compliance with a legal obligation that we are subject to.
Consent — where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.

Purposes for which we will use your personal data

To register you as a new customer and to process and deliver your order, including managing payments, fees and charges and collecting and recovering money owed to us.
To manage our relationship with you, including notifying you about changes to our terms or privacy policy and dealing with your requests, complaints and queries.
To send you relevant marketing communications and make personalised suggestions and recommendations about goods or services that may be of interest to you.
To administer and protect our business and this website, including troubleshooting, data analysis, testing, system maintenance, support, security, reporting and hosting of data.
To deliver relevant website content and online advertisements to you and measure the effectiveness of the advertising we serve.
To use data analytics to improve our website, products and services, customer relationships and experiences.
To carry out market research through your voluntary participation in surveys.

Direct marketing

You may receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving marketing.

Third-party marketing

We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

Opting out of marketing

You can ask us to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us at customerservices@incumbency.ai.

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes, for example relating to order confirmations, appointment reminders, or updates to our Terms and Conditions.

Cookies

We use essential and analytical cookies to monitor usage and improve your experience. You can adjust your preferences in your browser settings.

4. Disclosures of your personal data

We may share your personal data where necessary with relevant third parties. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

5. International transfers

We do not transfer your personal data outside the UK.

6. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

7. Data retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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

In some circumstances we will anonymise your personal data for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

8. Your legal rights

You have a number of rights under data protection laws in relation to your personal data we hold as controller. You have the right to:

Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data corrected.
Request erasure of your personal data in certain circumstances.
Object to processing of your personal data where we are relying on a legitimate interest as the legal basis for that particular use of your data.
Object to direct marketing — you have the absolute right to object at any time to the processing of your personal data for direct marketing purposes.
Request the transfer of your personal data to you or to a third party.
Withdraw consent at any time where we are relying on consent to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent.
Request restriction of processing of your personal data in certain scenarios, for example where you want us to establish the data's accuracy or where you have objected to our use of your data.

No fee usually required

You will not have to pay a fee to access your personal data or to exercise any of the other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer if your request is particularly complex, in which case we will notify you and keep you updated.

9. Contact details

If you have any questions about this privacy policy, the use of your personal data, or you want to exercise your privacy rights, please contact us:

Email: customerservices@incumbency.ai

Post: 20 Wenlock Road, London, England, N1 7GU

10. Where Incumbency.AI acts as data processor

Incumbency.AI provides a case management platform for their customers, specifically for the Parliamentary environment, and processes data as data processor. Incumbency.AI only processes data under the instructions of the data controllers who purchase the software, and will only process data pursuant to a data processing agreement with the customer. The data processed under that agreement may include sensitive information such as:

political opinions;
health data;
criminal convictions;
immigration status; and
tax status.

The data controller is responsible for setting out the lawful basis for processing their constituents' data and Incumbency.AI will only process data in accordance with those instructions.

The Incumbency.AI software includes a mandatory Human-in-the-Loop and a compulsory "Draft Only" AI mode. No communication can be sent, and no casework can be finalised without proactive human review and authorisation. The automated decision-making rules in Articles 22A to 22D UK GDPR therefore do not apply to Incumbency.AI processing.

Incumbency.AI's configuration is "Closed-Loop" with Data Logging OFF. No constituent data is used for model training or retained by the AI provider.

The system has undergone full-spectrum CREST-accredited Penetration Testing, covering web application and infrastructure layers, with a clean post-remediation report.

Should you have any queries about the way in which your data is processed by Incumbency.AI, you should contact your relevant MP as data controller.

11. Complaints

You have the right to make a complaint to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). However, before doing so please make sure you have first made your complaint to us or asked us for clarification. The ICO will expect you to have done this before reviewing your complaint.

12. Changes to this policy

We keep our privacy policy under regular review. This version was last updated in May 2026.

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 your relationship with us, for example a new address or email address.

13. Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.