Policies

Privacy Policy

We respect your concerns about privacy and value the relationship we have with you. This Privacy Notice describes the types of personal information we may collect on our website, how we may use that information, with whom we may share it, and the measures we take to protect the security of the information. In addition, we describe the choices you can make about how we use the information you provide to us. We also provide you direction on how you can reach us to update certain information you’ve given us, ask us not to send you future communications, or answer any questions you may have about our privacy practices.

This Privacy Notice applies only to information we collect on our website and through your interaction with our website. This Privacy Notice does not apply to any other website, service, product, or application operated or provided by us or a third party.

 

Information We Collect and How We Use It

You may choose to provide personal information (such as your name, address, telephone number and e-mail address) on this website, and we may collect personal information about you when you visit or use this website. This privacy notice summarizes the ways you may provide the information, the types of information you may submit, and the information we may collect from you when you visit or use this website. We also tell you how we may use the information.

 

Contact Us

You may choose to contact us through our website. If you e-mail us via the “Contact Us” link on this site, we ask you for information such as name and e-mail address so we can respond to your questions and comments. You may choose to provide additional information and we use the information you provide to respond to your inquiries.

 

Use of Website

When you visit our website, we collect information from you through automated means. This includes, in particular, your internet protocol (IP) address, device information, browser information, and details on your usage of our website, so we can determine whether you are a repeat visitor to our website.

 

Information We Share

We do not sell, rent, trade or otherwise disclose personal information about our website visitors, except as described here. We share information about our website visitors with service providers we have retained to perform services on our behalf, such as website hosting, customer service, and information technology services. These service providers are not authorized by us to use or disclose the information, except as necessary to perform services on our behalf or to comply with legal requirements. We also may share information about you with other members of our corporate family. In addition, we may disclose information about you (i) if we are required to do so by law, (ii) in response to a request from law enforcement authorities or other government officials, (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity, or (iv) to exercise our legal rights or defend against legal claims.

We reserve the right to transfer any information we have about you in the event we sell or transfer all or a portion of our business or assets. Should such a sale or transfer occur, we will use reasonable efforts to try to direct the transferee to use personal information you have provided through this website in a manner that is consistent with this Privacy Notice.

 

Links to Other Sites

We may provide links to other websites for your convenience and information. These sites operate independently from our site and are not under our control. These sites may have their own privacy notices in place, which we strongly suggest you review if you visit any linked websites. We are not responsible for the content of these sites, any products or services that may be offered through these sites, or any other use of these sites.

 

Security

We maintain administrative, technical and physical safeguards designed to protect against unauthorized disclosure, use, alteration or destruction of the personal information we have about you. When you provide credit card information to make a purchase, we use the industry standard for Internet security — Secure Socket Layer (SSL) technology — to help protect the information you provide. This Internet encryption standard scrambles data as it travels from your computer to our server. Please note, however, that perfect security does not exist on the Internet. You’ll know that you’re in a secure area of our website when a “lock” icon appears on your screen and the “http” portion of our URL address changes to “https.” The “s” stands for “secure.”

 

Your Choices

If you would like to update your contact information or prefer not to receive certain communications from us (such as e-mail), please call us or write us using one of the options provided below.

 

Updates to this Privacy Notice

We may update or change this Privacy Notice from time to time and without prior notice to you. We will post a prominent notice on this site to notify you of any significant changes to our Privacy Notice and indicate below when it was most recently updated.

 

How to Contact Us

If you have any questions or comments about this Privacy Notice, or if you would like us to update certain information you have provided to us or your communication preferences, contact us by:

Calling us at 833-774-8223

Writing us at:
InComm Privacy
250 Williams Street
5th Floor
Atlanta, GA 30303

 

Last Update

This notice was last updated on December 16, 2021 (the “Last Update”).

 

HIPAA

To the extent that we process your personal information on behalf of a health insurance company, health care provider, or another entity covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) federal medical privacy law, we will safeguard your information in accordance with HIPAA and our agreements with customers. You can learn more about your rights under HIPAA by obtaining a copy of the HIPAA notice of privacy practices of the health insurance company or health care provider on whose behalf we have your information. To the extent that we maintain your information in accordance with HIPAA, this personal information may be excluded from other privacy laws and exempt from the privacy rights described in this Privacy Notice.

 

Additional Notice for California Consumers

This portion of our Privacy Notice applies to California consumers only. Most visitors to our website are representatives of businesses seeking to interact with us as part of their jobs. This Notice does not apply to information that we collect through these business-to-business interactions.

Personal Information Collected on California Consumers, Sources of Collection, and Business Purposes for Collection for the Last Twelve Months

We collect information from users of our website, as further described above in “Information we collect and how we use it,” when users visit and use our website. The personal information we have obtained on California residents includes the following:

Identifiers such as name, postal and email addresses, internet protocol (IP) address, and other contact information when you submit your name and email address to learn more about InComm products and services.
The following categories of personal information described in California Civil Code § 1798.80(e): (1) the personal information listed in the preceding bullet point as “identifiers,” (2) the other information that identifies, relates to, describes, or is capable of being associated with, a particular individual that we describe in “Information we collect and how we use it” above.
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site.
Geolocation data.
Disclosures of Personal Information on California Consumers for Business Purposes for the Last Twelve Months

We have disclosed the categories of personal information identified in this Additional Notice to service providers for various business purposes as specified below. For more information on the service providers with whom we share information, please see “Information we Share” above.

No Sales of Personal information for the Last Twelve Months

InComm has not sold any personal information described in this Privacy Notice to third parties within the previous twelve (12) months and will not sell personal information.

Business Purposes for Collecting Personal Information for the Last Twelve Months

We collected the personal information identified in this Additional Notice for the following business purposes:

Detecting and protecting against security incidents, and malicious, deceptive, fraudulent or illegal activity, and prosecuting the same;
Debugging to identify and repair errors in our systems; and
Undertaking activities to verify, maintain, and enhance the quality or safety of services we own, control, or provide.
Your California Privacy Rights

 

If you are a California resident, you have the following rights for purposes of the personal information covered by this Privacy Notice.

Right to Know About Personal Information Collected, Disclosed, or Sold and Right to Access. You have the right to request that we disclose the following information about your personal information we collect, use, and disclose: the categories of personal information we have collected about you; the categories of sources from which the personal information is collected; our business or commercial purpose for collecting or selling personal information; the categories of third parties with whom we share personal information; and the specific pieces of information we have collected about you. If any, the categories of personal information about you that we have sold, by category or categories of personal information for each third party to which we sold the personal information; and the categories of personal information about you that we disclosed for a business purpose. Right to Deletion of Personal Information. You have the right to request deletion of your personal information we collected from you. Right to Non-Discrimination for Exercise of a California Privacy Rights. We may not discriminate against you because of your exercise of any of the foregoing rights, or any other rights under the California Consumer Privacy Act, including by: Denying you goods or services; Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; Providing you a different level or quality of goods or services; or Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services. We may, however, charge different prices or rates, or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to InComm by your personal information.

 

How to Exercise Your California Rights; How We May Verify Your Request

You may request the rights listed above by:

calling us at 833-774-8223
using the webform available at this link
writing us at:

InComm Privacy
250 Williams Street
5th Floor
Atlanta, GA 30303

When you make a request, we may take steps to verify your identity before responding to your request. In order to verify your identity with respect to the non-sensitive data that is subject to this notice, we will ask you to confirm your email address by sending you an email, or if your request is made via telephone call or via letter, we will ask you to verify your identity by confirming your email, account or asking questions about the scope of your interaction with us. We reserve the right to take additional steps to verify your identity using other information we have about you.

You may designate an authorized agent to make a request on your behalf. You may make such a designation by providing the agent with written permission to act on your behalf. As permitted by law, we may take steps to verify your own identity in response to a request even if you choose to use an agent.

 

Accessibility

To access this Privacy Notice by an alternative method, please contact us at 833-774-8223.

Cookies & Web Beacons

When you visit our website, your browser automatically sends us certain Internet-related information (such as the Internet Protocol (IP) address of the computer you’re using). We also may use cookies and Web beacons to better understand how visitors use our site.

Cookies are small text files that websites often store on the computer hard drives of visitors to their sites. A cookie contains a unique code, which is used to recognize your computer when a user of your computer returns to a website that was visited previously. Web beacons are Internet tools that help us determine, for example, whether a website page has been viewed. We use cookies and Web beacons to enhance the online experience of our visitors and to better understand how our site is used. Cookies and Web beacons may tell us, for example, whether you have visited our site before or whether you are a new visitor.

The “help” portion of the toolbar on most browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, and how to disable existing cookies. Remember, though, without cookies, you may not be able to take full advantage of all our website features.

Terms of Use

This website is owned and operated by InComm. InComm offers this website, including all information, products and services available from this website, to you the user, conditioned upon your acceptance of all the terms, conditions, policies and notices stated here. Your continued use of the website constitutes your agreement to all such terms, conditions, policies and notices.

 

Your Use of this Site

This website is for your personal and noncommercial use. As a condition to your continued use of the website, you agree that you will not use the website for any purpose that is unlawful or prohibited by these Terms of Use.

If you use this site, you are responsible for maintaining the confidentiality of your account and password and for restricting access to your computer, and you agree to accept responsibility for all activities that occur under your account or password. You agree to (i) immediately notify InComm of any unauthorized use of your account or password or any other breach of security on the site of which you are aware, and (ii) exit from your account at the end of each session. InComm is not liable for any loss or damage arising from your failure to protect your account or password. If you are under 18, you may use the services provided via this site only with the permission of a parent or guardian. InComm and its affiliates reserve the right to refuse service, terminate accounts, remove or edit content, or cancel orders in their sole discretion.

 

Accuracy, Completeness and Timelines of Information on the Site

We are not responsible if information we make available on this site is not accurate, complete or current. The materials on this site are provided for general information only and should not be relied upon or used as the sole basis for making significant decisions without consulting primary or more accurate, more complete or more timely sources of information. Any reliance on the materials on this site will be at your own risk. This site may contain certain historical information. Historical information necessarily is not current and is provided for your reference only. We reserve the right to modify the contents of this site at any time, but we have no obligation to update any information on the site. You agree that it is your responsibility to monitor changes to the site.

 

International Users

InComm makes no claims that the content on this site is appropriate or may be downloaded outside of the United States. Access to the site may not be legal in certain countries or for certain persons. If you access the site from outside of the United States, you do so at your own risk and are responsible for compliance with the laws of your jurisdiction regarding online conduct and acceptable content.

 

Use of Materials from the Site

This site and all of its contents (including but not limited to software, files, graphics and data) are the property of and owned by InComm and/or its affiliates, suppliers or licensors and are protected by copyright, trademark and other laws of the United States and other countries. You may display and electronically copy, download and print hard copy versions of the materials contained on the site for your personal and noncommercial use, provided that you do not modify or delete any copyright, trademark or other proprietary notice that appears on the materials you copy, download or print. When you display, copy, download or print any materials on or from the site, they are provided to you by InComm and/or its affiliates, suppliers or licensors under a non-exclusive and limited license that is revocable. InComm and/or its affiliates, suppliers or licensors retain full and complete title to the materials and to any and all of the associated intellectual property rights. Any other use of the materials on the site, including but not limited to the modification, distribution, transmission, performance, broadcast, publication, licensing, reverse engineering, transfer or sale of, or the creation of derivative works from, any materials, information, software, products or services obtained from the site, without the prior written permission of InComm, is expressly prohibited. You may not frame or utilize framing techniques to enclose any trademark, logo or other proprietary information (including images, text, page layout or form) of InComm or its affiliates without express written consent. You may not use any meta tags or any other “hidden text” utilizing InComm’s or its affiliates’ name or trademarks without the express written consent of InComm. Any unauthorized use terminates the permission or license granted by InComm.

 

Requests for permission to undertake any of these activities should be mailed to:

InComm
250 Williams Street
Suite M-100
Atlanta, GA 30303
Attention: Legal Department

 

Disclaimers

YOUR USE OF THIS SITE IS AT YOUR OWN RISK. THE SITE IS PROVIDED ON AN “AS IS” AND “AS AVAILABLE” BASIS. WE RESERVE THE RIGHT TO RESTRICT OR TERMINATE YOUR ACCESS TO THE SITE OR ANY FEATURE OR ANY PART THEREOF AT ANY TIME. INCOMM EXPRESSLY DISCLAIMS ALL WARRANTIES OF ANY KIND, WHETHER EXPRESS OR IMPLIED, INCLUDING BUT NOT LIMITED TO THE IMPLIED WARRANTIES OF MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE AND ANY WARRANTIES THAT MATERIALS ON THE SITE ARE NONINFRINGING; THAT ACCESS TO THE SITE WILL BE UNINTERRUPTED OR ERROR-FREE; THAT THE SITE WILL BE SECURE; THAT THE SITE OR THE SERVER THAT MAKES THE SITE AVAILABLE WILL BE VIRUS-FREE; OR THAT INFORMATION ON THE SITE WILL BE COMPLETE, ACCURATE OR TIMELY. IF YOU DOWNLOAD ANY MATERIALS FROM THIS SITE, YOU DO SO AT YOUR OWN DISCRETION AND RISK. YOU WILL BE SOLELY RESPONSIBLE FOR ANY DAMAGE TO YOUR COMPUTER SYSTEM OR LOSS OF DATA THAT RESULTS FROM THE DOWNLOAD OF ANY SUCH MATERIALS. NO ADVICE OR INFORMATION, WHETHER ORAL OR WRITTEN, OBTAINED BY YOU FROM INCOMM OR THROUGH OR FROM THE SITE SHALL CREATE ANY WARRANTY OF ANY KIND. INCOMM DOES NOT MAKE ANY WARRANTIES OR REPRESENTATIONS REGARDING THE USE OF THE MATERIALS ON THIS SITE IN TERMS OF THEIR COMPLETENESS, CORRECTNESS, ACCURACY, ADEQUACY, USEFULNESS, TIMELINESS, RELIABILITY OR OTHERWISE.

IN CERTAIN STATES, THE LAW MAY NOT PERMIT THE DISCLAIMER OF WARRANTIES, SO THE ABOVE DISCLAIMER MAY NOT APPLY TO YOU.

 

Limitation of Liability

TO THE FULLEST EXTENT PERMITTED UNDER APPLICABLE LAW, YOU UNDERSTAND AND AGREE THAT NEITHER INCOMM NOR ANY OF ITS AFFILIATES, SUBSIDIARIES OR THIRD PARTY CONTENT PROVIDERS SHALL BE LIABLE FOR ANY DIRECT, INDIRECT, INCIDENTAL, SPECIAL, EXEMPLARY, CONSEQUENTIAL, PUNITIVE OR ANY OTHER DAMAGES RELATING TO OR RESULTING FROM YOUR USE OR INABILITY TO USE THIS SITE OR ANY OTHER SITE YOU ACCESS THROUGH A LINK FROM THIS SITE OR FROM ANY ACTIONS WE TAKE OR FAIL TO TAKE AS A RESULT OF ELECTRONIC MAIL MESSAGES YOU SEND US. THESE INCLUDE DAMAGES FOR ERRORS, OMISSIONS, INTERRUPTIONS, DEFECTS, DELAYS, COMPUTER VIRUSES, YOUR LOSS OF PROFITS, LOSS OF DATA, UNAUTHORIZED ACCESS TO OR ALTERATION OF YOUR TRANSMISSIONS OR DATA, AND OTHER TANGIBLE AND INTANGIBLE LOSSES. THIS LIMITATION APPLIES REGARDLESS OF WHETHER THE DAMAGES ARE CLAIMED UNDER THE TERMS OF A CONTRACT, AS THE RESULT OF NEGLIGENCE OR OTHERWISE ARISE OUT OF OR IN CONNECTION WITH THE USE, INABILITY TO USE, OR PERFORMANCE OF THE INFORMATION, USES, PRODUCTS OR MATERIALS AVAILABLE FROM THIS SITE, AND EVEN IF WE OR OUR REPRESENTATIVES HAVE BEEN NEGLIGENT OR HAVE BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. BECAUSE SOME JURISDICTIONS DO NOT ALLOW LIMITATIONS ON HOW LONG AN IMPLIED WARRANTY LASTS, OR THE EXCLUSION OR LIMITATION OF LIABILITY FOR CONSEQUENTIAL OR INCIDENTAL DAMAGES, THE ABOVE LIMITATION MAY NOT APPLY TO YOU.

 

Indemnification

You agree to indemnify, defend and hold harmless InComm and its affiliates and subsidiaries, and their officers, directors, employees, contractors, agents, licensors and suppliers, from and against all losses, liabilities, expenses, damages and costs, including reasonable attorneys’ fees and court costs, arising or resulting from any violation of these Terms of Use or any activity related to your account or password (including but not limited to negligent or wrongful conduct), by you or any other person accessing the site using your account or password. If you cause a technical disruption of the site or the systems transmitting the site to you or others, you agree to be responsible for any and all losses, liabilities, expenses, damages and costs, including reasonable attorneys’ fees and court costs, arising or resulting from that disruption.

 

Featured Links

This website may contain hyperlinks to other Internet sites. These hyperlinks are provided for your information and convenience only. InComm does not control these other websites and is not responsible for their content; nor does InComm’s inclusion of hyperlinks to such websites imply any endorsement or approval of the material on such websites or any association with their operators. Check the URL address provided in your browser to determine whether you are still in this InComm website or have moved to another site.

 

Trademarks

The trademarks, service marks, graphics and logos featured on this site are registered or unregistered trademarks, service marks or trade dress of InComm or its affiliates. InComm’s trademarks, service marks and trade dress may not be used in connection with any product or service that is not InComm’s, in any manner that is likely to cause confusion, mistake or deception among customers or in any manner that disparages or discredits InComm or its affiliates. Nothing contained on the site should be construed as granting by implication, estoppel or otherwise any license or right to use any trademark displayed on the site without the express written consent of InComm or such third party that may own the trademark. Misuse of any trademarks, or any other content, displayed on the site is prohibited. InComm aggressively enforces its intellectual property rights, including via civil and criminal proceedings.

 

Copyrights

All content included on this site, such as text, graphics, logos, button icons, images, audio clips, digital downloads, data compilations and software, is the property of InComm and its affiliates and is protected by U.S. and international copyright laws. You should assume that everything on the site is copyrighted unless otherwise noted and that it must not be used except with the express written consent of InComm or any third party InComm deems necessary. InComm neither warrants nor represents that your use of the material displayed on this site will not infringe rights of third parties.

Any product, service, program or technology described on the site may be the subject of intellectual property rights (including but not limited to copyright, trademark or patent rights) owned by InComm or a third party. Any such right that is not expressly licensed herein is reserved by InComm or the third party that owns such right. This site and all of its contents including, but not limited to, text, design, graphics, interfaces and code, and the selection and arrangement thereof, is protected as a compilation under the copyright laws of the United States and other countries.

 

Intellectual Property Rights of Others

We respect the intellectual property rights of others, and we request that our visitors do the same. If you think your work has been copied in a manner that constitutes copyright infringement, you may notify our copyright agent, who can be reached at:

InComm
250 Williams Street
Suite M-100
Atlanta, GA 30303
Attention: Legal Department

 

The notification must include ALL of the following:

A physical or electronic signature of the person authorized to act on behalf of the owner of an exclusive copyright that is allegedly infringed;
a description of the copyrighted work you claim has been infringed;
a description of where the material you claim is infringing is located on the site;
your address, telephone number, e-mail address and all other information reasonably sufficient to permit InComm to contact you;
a statement by you that you have a good faith belief that the disputed use is not authorized by the copyright owner, its agent or the law; and
a statement by you, made under penalty of perjury, that the above information in your notice is accurate and that you are the copyright owner or authorized to act on behalf of the owner of an exclusive right that is allegedly infringed.
Dealings with Advertisers
Your correspondence or business dealings with, or participation in promotions of, advertisers found on or through this site, including payment and delivery of related goods or services, and any other terms, conditions, warranties or representations associated with such dealings, are solely between you and such advertiser. You agree that InComm is not responsible or liable for any loss or damage of any sort incurred as the result of any such dealings or as the result of the presence of such advertisers on this site.

 

Termination of Privileges

InComm reserves the right to terminate your privilege of using all or any portion of this website at any time and without notice to you if, in its sole judgment, you breach any of these Terms of Use, including all of your privileges and your account in connection with the website.

 

Changes to these Terms of Use

InComm reserves the right to make changes to these Terms of Use at any time by posting the revised Terms of Use on the site. It is your responsibility to check periodically for any changes we may make to these Terms of Use. By continuing to use the website, you are agreeing to all changes made by InComm.

 

Jurisdiction

This website is controlled and operated by InComm from its principal offices in the State of Georgia in the United States. The laws of the State of Georgia and the United States govern these Terms of Use and your use of the site and purchase of products and services from this site, and you irrevocably consent to the exclusive jurisdiction of the courts located in Georgia for any action to enforce these Terms of Use. We recognize that it is possible for you to obtain access to this site from any jurisdiction in the world, but we have no practical ability to prevent such access. This site has been designed to comply with the laws of the State of Georgia and the United States. Those who choose to access the website from other locations do so on their own initiative and are responsible for compliance with local laws if and to the extent local laws are applicable. If any material on this site or your use of the site is contrary to the laws of the place where you are when you access it, then the site is not intended for you and we ask you not to use the site. You may not use or export materials on this site in violation of United States export laws or regulations. This website is not intended to subject InComm to the laws or jurisdiction of any state, country or territory other than the State of Georgia and the United States of America.

 

Miscellaneous

If any provision of this agreement is unlawful, void or unenforceable, the remaining provisions of the agreement will remain in place. These Terms of Use constitute the entire agreement and understanding between you and InComm with respect to use of the website, superseding all prior or contemporaneous communications. The failure of InComm to exercise or enforce any right or provision of these Terms of Use shall not constitute a waiver of such right or provision. A printed version of these Terms of Use shall be admissible in judicial or administrative proceedings based on or relating to use of the website to the same extent and subject to the same conditions as other business documents and records originally generated and maintained in printed form.

 

How to Contact Us

If you have any questions or comments about these Terms of Use or this site, you may contact us by calling us at:

(800) 486-8394

or writing us at:

InComm Customer Care
250 Williams Street
5th Floor
Atlanta, GA 30303

Transparency in Coverage Rule

This link leads to the machine readable files that are made available in response to the federal Transparency in Coverage Rule and includes negotiated service rates and out-of-network allowed amounts between health plans and healthcare providers. The machine-readable files are formatted to allow researchers, regulators, and application developers to more easily access and analyze data.

International Policies

InComm Payments UK Limited Privacy Statement

PURPOSE. We respect your concerns about privacy and value the relationship we have with you. This Privacy Statement (“Privacy Statement”) describes the types of Personal Information that InComm Payments UK (“we”) may collect to provide our unique alternative payment and settlement services to our customers, how we may use that information collected, and with whom we may share it. This Privacy Statement also describes the measures we take to protect the security of the information. In addition, this Privacy Statement describes the choices you can make about how we use the information that you provide to us and how to exercise your rights over your Personal Information. We also tell you how you can reach us to update certain information that you have given to us, ask us not to send you future communications, or answer any questions that you may have about our privacy practices.

 

INFORMATION WE COLLECT AND HOW WE USE IT. We may collect, either directly or indirectly through a third party, Personal Information1 of customers.

Personal Information that we collect may include the following:

  • first and last name; 
  • country of residence; 
  • date of birth; 
  • percentage of ownership in company; 
  • job title; 
  • address, 
  • email; 
  • PSP license # (if applicable); 
  • W9 taxpayer form; 
  • company name; 
  • company physical address; and 
  • company VAT number.

 

LAWFUL GROUNDS TO PROCESS. We typically process2 Personal Information only when it is necessary to comply with our legal obligations.

 

INFORMATION WE RETAIN. InComm has a formal Data Retention Standard which contains a comprehensive data retention schedule. Generally, we retain business-related information for 10 years unless no longer needed to serve the purpose for which the information was originally collected.

 

DISCLOSURE OF YOUR INFORMATION. We may share your Personal Information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.

We may share your information with selected third parties including business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you.

Additionally, we may share your information if we are under a duty to disclose or share your Personal Information in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of InComm Payments UK Ltd., our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

 

WHERE WE TRANSFER YOUR PERSONAL INFORMATION. Information that we collect may be transferred outside of the European Economic Area (“EEA”), including to countries, such as the United States, and to organizations, which have not been deemed as having “adequate” security measures by the European Commission. To facilitate adequate safeguards for information we transfer outside of the EEA, we have executed Model Clauses in our contracts, pursuant to European Commission Decision 2010/87/EC, to facilitate the legitimate, secure transfer of Personal Information outside the EEA as necessary. By submitting your Personal Information, you agree to this transfer, storing or processing. InComm will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Statement.

 

PROTECTING YOUR INFORMATION. We take protection of your Personal Information seriously and we deploy administrative, technical, and physical security measures to ensure a level of security appropriate to the risk including:

  • pseudonymization and encryption of Personal Information where appropriate based on the risk to the data; 
  • the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services; 
  • the ability to restore the availability and access to Personal Information in a timely manner in the event of a physical or technical incident; and 
  • regularly testing, assessing, and evaluating the effectiveness of our technical and organizational measures for ensuring the security of all processing activities. 

All Personal Information that we collect is stored on our secure servers.

 

YOUR RIGHTS. All individuals whose Personal Information is held by us have the right to:

  • ask what information we hold about them and why; 
  • ask for a copy of such information or access to such information; 
  • be informed how to correct or keep that information up to date; and 
  • be informed on how we are meeting our data protection obligations. Furthermore, for data collected in the EEA, data subjects have the right to: 
  • ask for a copy of such information to be sent to a third party; 
  • ask for data to be erased if possible and required under the GDPR; 
  • ask for processing of Personal Information to be restricted if possible and required under GDPR; 
  • object to processing of Personal Information if possible and required under GDPR; 
  • object to automated decision-making where applicable; and 
  • contact a supervisory authority in the EEA to lodge a complaint regarding InComm Payments UK Ltd.’s processing of your Personal Information. 
  • You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at InComm Payments UK Limited.

 

CHANGES TO THIS PRIVACY STATEMENT. Any changes we may make to this Privacy Statement in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check 3 back frequently to see any updates or changes to this Privacy Statement.

 

COMPLIANCE AND COOPERATION WITH REGULATORY AUTHORITIES. We regularly review our compliance with this Privacy Statement. When we receive a formal written complaint regarding the processing of Personal Information, we try to resolve it directly with the person who has made the complaint. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding our processing of Personal Information that we cannot resolve with a complainant directly.

 

CONTACT. All questions, comments and queries relating to our use of your information or regarding this Privacy Statement are welcomed and should be addressed to: Attn: Data Privacy Officer InComm Payments UK Limited 1600 Parkway Solent Business Park Whiteley Hampshire PO15 7AH Email: privacyofficer@incomm-europe.com Telephone: +44 (0) 1489 588200

 

 

Last updated: April 20, 2018
 

1 Under GDPR, Article 4(1), Personal Information or ‘personal data’ means any information relating to an identified or identifiable natural person. 2 Under GDPR, Article 4(2), ‘process’ or ‘processing’ means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

InComm Payments UK Limited CyberSource Privacy Notice

PURPOSE. We respect your concerns about privacy and value the relationship we have with you. This Privacy Notice describes the types of Personal Information that InComm Payments UK (“we”) may collect in order to provide our unique alternative payment and settlement services to our customers, how we may use that information collected, and with whom we may share it. This Privacy Notice also describes the measures that we take to protect the security of the information. In addition, we describe the choices you can make about how we use the information that you provide to us and how to exercise your rights over your Personal Information. We also tell you how you can reach us to update certain information that you have given us, ask us not to send you future communications, or answer any questions you may have about our privacy practices.

 

INFORMATION WE COLLECT AND HOW WE USE IT.

 

Settlement Services and Program Management Services

In the course of supporting alternative payment and settlement services in the European Territory, we may collect, either directly or indirectly through a third party, Personal Information1 from any Beneficial Owner2/Director/Officer of a Payment Service Provider (“PSP”) or Merchant who is party to a transaction in order to comply with Anti-Money Laundering/Know Your Customer (“AML/KYC”) legal and regulatory requirements. Under GDPR, Article 4(1), Personal Information or ‘Personal Data’ means any information relating to an identified or identifiable natural person.

Beneficial Owners includes individuals possessing a 10%+ equity in the PSP or Merchant that is party to the transaction.

Typically, we engage a third party with instructions to facilitate collection of Personal Information from Owners/Directors/Officers in order to complete the required due diligence application. Once we receive a completed due diligence application from the third party, we will conduct the AML/KYC investigation associated with the underlying payment transaction. In the event that the due diligence application is incomplete or requires further explanation, we will communicate requests for additional information through the third party. We do not receive any information related to payment transactions.

The information we may collect to carry out AML/KYC due diligence activities may include the following information:

  • first and last name 
  • address; 
  • country of residence; 
  • date of birth; 
  • percentage of ownership in company; 
  • job title; 
  • email; 
  • company information; 
  • company director name; 
  • VAT number; 
  • PSP license number; and 
  • W9 taxpayer form.

 

LAWFUL GROUNDS TO PROCESS. We process information related to Owners/Directors/Officers due 2 diligence as necessary to comply with our legal obligations to which we are subject under relevant AML/KYC laws and regulations.

 

INFORMATION WE RETAIN. InComm has a formal Data Retention Standard which contains a comprehensive data retention schedule. Generally, we retain business-related information for 10 years unless no longer needed to serve the purpose for which the information was originally collected.

 

DISCLOSURE OF YOUR INFORMATION. We may share your Personal Information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.

We may share your information with selected third parties including business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you.

In the event we go through a business transition, for example, a merger, acquisition by another company, or sale of part or all of our assets, we may disclose your Personal Information to third parties and your Personal Information held may be among one of the assets transferred.

Finally, we may share your information if we are under a duty to disclose or share your Personal Information to comply with any legal obligation, or to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of InComm Payments UK Ltd., our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

 

WHERE WE TRANSFER YOUR PERSONAL INFORMATION. Information that we collect may be transferred outside of the EEA, including to countries, such as the United States, which have not been deemed as having “adequate” security measures by the European Commission. To facilitate adequate safeguards for information we transfer outside of the EEA, we have executed Model Clauses in our contracts, pursuant to European Commission Decision 2010/87/EC, to facilitate the legitimate, secure transfer of Personal Information outside the EEA as necessary. By submitting your Personal Information, you agree to this transfer, storing or processing. InComm will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Notice.

 

PROTECTING YOUR INFORMATION. We take protection of your Personal Information seriously and we deploy administrative, technical, and physical security measures to ensure a level of security appropriate to the risk including:

  • pseudonymization and encryption of Personal Information where appropriate based on the risk to the data; 
  • the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services; 
  • the ability to restore the availability and access to Personal Information in a timely manner in the event of a physical or technical incident; and 
  • regularly testing, assessing, and evaluating the effectiveness of our technical and organizational measures for ensuring the security of all processing activities.

All Personal Information that we collect is stored on our secure servers.

YOUR RIGHTS. All individuals whose Personal Information is held by us have the right to:

  • ask what information we hold about them and why; 
  • ask for a copy of such information or access to such information; 
  • be informed how to correct or keep that information up to date; and 
  • be informed on how we are meeting our data protection obligations.

Furthermore, for data collected in the EEA, data subjects have the right to: 3

  • ask for a copy of such information to be sent to a third party; 
  • ask for data to be erased if possible and required under GDPR; 
  • ask for processing of Personal Information to be restricted if possible and required under GDPR; 
  • object to processing of Personal Information if possible and required under GDPR; 
  • object to automated decision-making where applicable; and 
  • contact a supervisory authority in the EEA to lodge a complaint regarding InComm Payments UK Ltd.’s processing of your Personal Information.

You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at InComm Payments UK Limited.

 

CHANGES TO OUR PRIVACY NOTICE. Any changes we may make to this Privacy Notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to this Privacy Notice.

 

COMPLIANCE AND COOPERATION WITH REGULATORY AUTHORITIES. We regularly review our compliance with this Privacy Notice. When we receive a formal written complaint regarding the processing of Personal Information, we try to resolve it directly with the person who has made the complaint. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding our processing of Personal Information that we cannot resolve with a complainant directly.

 

CONTACT. All questions, comments and queries relating to our use of your information or regarding this Privacy Notice are welcomed and should be addressed to:

 

Attn: Data Privacy Officer

InComm Payments UK Limited

1600 Parkway Solent Business Park

Whiteley

Hampshire PO15 7AH

Email: privacyofficer@incomm-europe.com

Telephone: +44 (0) 1489 588200

 

 

Last updated: April 20, 2018

InComm Payments UK Limited CyberSource Privacy Notice

PURPOSE. We respect your concerns about privacy and value the relationship we have with you. This Privacy Notice describes the types of Personal Information that InComm Payments UK (“we”) may collect in order to provide our unique alternative payment and settlement services to our customers, how we may use that information collected, and with whom we may share it. This Privacy Notice also describes the measures that we take to protect the security of the information. In addition, we describe the choices you can make about how we use the information that you provide to us and how to exercise your rights over your Personal Information. We also tell you how you can reach us to update certain information that you have given us, ask us not to send you future communications, or answer any questions you may have about our privacy practices.

 

INFORMATION WE COLLECT AND HOW WE USE IT.

 

Settlement Services and Program Management Services

In the course of supporting alternative payment and settlement services in the European Territory, we may collect, either directly or indirectly through a third party, Personal Information1 from any Beneficial Owner2/Director/Officer of a Payment Service Provider (“PSP”) or Merchant who is party to a transaction in order to comply with Anti-Money Laundering/Know Your Customer (“AML/KYC”) legal and regulatory requirements. Under GDPR, Article 4(1), Personal Information or ‘Personal Data’ means any information relating to an identified or identifiable natural person.

Beneficial Owners includes individuals possessing a 10%+ equity in the PSP or Merchant that is party to the transaction.

Typically, we engage a third party with instructions to facilitate collection of Personal Information from Owners/Directors/Officers in order to complete the required due diligence application. Once we receive a completed due diligence application from the third party, we will conduct the AML/KYC investigation associated with the underlying payment transaction. In the event that the due diligence application is incomplete or requires further explanation, we will communicate requests for additional information through the third party. We do not receive any information related to payment transactions.

The information we may collect to carry out AML/KYC due diligence activities may include the following information:

  • first and last name 
  • address; 
  • country of residence; 
  • date of birth; 
  • percentage of ownership in company; 
  • job title; 
  • email; 
  • company information; 
  • company director name; 
  • VAT number; 
  • PSP license number; and 
  • W9 taxpayer form.

 

LAWFUL GROUNDS TO PROCESS. We process information related to Owners/Directors/Officers due 2 diligence as necessary to comply with our legal obligations to which we are subject under relevant AML/KYC laws and regulations.

 

INFORMATION WE RETAIN. InComm has a formal Data Retention Standard which contains a comprehensive data retention schedule. Generally, we retain business-related information for 10 years unless no longer needed to serve the purpose for which the information was originally collected.

 

DISCLOSURE OF YOUR INFORMATION. We may share your Personal Information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.

We may share your information with selected third parties including business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you.

In the event we go through a business transition, for example, a merger, acquisition by another company, or sale of part or all of our assets, we may disclose your Personal Information to third parties and your Personal Information held may be among one of the assets transferred.

Finally, we may share your information if we are under a duty to disclose or share your Personal Information to comply with any legal obligation, or to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of InComm Payments UK Ltd., our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

 

WHERE WE TRANSFER YOUR PERSONAL INFORMATION. Information that we collect may be transferred outside of the EEA, including to countries, such as the United States, which have not been deemed as having “adequate” security measures by the European Commission. To facilitate adequate safeguards for information we transfer outside of the EEA, we have executed Model Clauses in our contracts, pursuant to European Commission Decision 2010/87/EC, to facilitate the legitimate, secure transfer of Personal Information outside the EEA as necessary. By submitting your Personal Information, you agree to this transfer, storing or processing. InComm will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Notice.

 

PROTECTING YOUR INFORMATION. We take protection of your Personal Information seriously and we deploy administrative, technical, and physical security measures to ensure a level of security appropriate to the risk including:

  • pseudonymization and encryption of Personal Information where appropriate based on the risk to the data; 
  • the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services; 
  • the ability to restore the availability and access to Personal Information in a timely manner in the event of a physical or technical incident; and 
  • regularly testing, assessing, and evaluating the effectiveness of our technical and organizational measures for ensuring the security of all processing activities.

All Personal Information that we collect is stored on our secure servers.

YOUR RIGHTS. All individuals whose Personal Information is held by us have the right to:

  • ask what information we hold about them and why; 
  • ask for a copy of such information or access to such information; 
  • be informed how to correct or keep that information up to date; and 
  • be informed on how we are meeting our data protection obligations.

Furthermore, for data collected in the EEA, data subjects have the right to: 3

  • ask for a copy of such information to be sent to a third party; 
  • ask for data to be erased if possible and required under GDPR; 
  • ask for processing of Personal Information to be restricted if possible and required under GDPR; 
  • object to processing of Personal Information if possible and required under GDPR; 
  • object to automated decision-making where applicable; and 
  • contact a supervisory authority in the EEA to lodge a complaint regarding InComm Payments UK Ltd.’s processing of your Personal Information.

You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at InComm Payments UK Limited.

 

CHANGES TO OUR PRIVACY NOTICE. Any changes we may make to this Privacy Notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to this Privacy Notice.

 

COMPLIANCE AND COOPERATION WITH REGULATORY AUTHORITIES. We regularly review our compliance with this Privacy Notice. When we receive a formal written complaint regarding the processing of Personal Information, we try to resolve it directly with the person who has made the complaint. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding our processing of Personal Information that we cannot resolve with a complainant directly.

 

CONTACT. All questions, comments and queries relating to our use of your information or regarding this Privacy Notice are welcomed and should be addressed to:

 

Attn: Data Privacy Officer

InComm Payments UK Limited

1600 Parkway Solent Business Park

Whiteley

Hampshire PO15 7AH

Email: privacyofficer@incomm-europe.com

Telephone: +44 (0) 1489 588200

 

 

Last updated: April 20, 2018

InComm Europe Limited Modern Slavery Act Statement

InComm Japan K.K Privacy Policy 個人情報保護方針

InComm Lottery Patent Pledge

InComm is committed to promoting innovation to further the overall growth and advancement of technology within the lottery industry and believes that opening up certain of its patents for use may foster innovation and promote technological advancement and cooperation while bringing lottery products to in-lane point-of-sale transactions. The Pledge will allow those within the Lottery Industry (as defined below) to freely and openly use the InComm Pledged Patents without fear of enforcement by e2Interactive, Inc. or InComm (collectively or individually, “InComm”).  InComm is therefore pledging the free use of certain of its patents in connection with on the following terms:

 

  1. InComm pledges that it will not initiate a lawsuit against any party in the Lottery Industry for infringing an InComm patent through activity related to the purchase, sale, activation, use, or redemption of printed or digital lottery tickets (“Use of Lottery Tickets”), for so long as such party is acting in good faith.   
  2. “InComm Pledged Patents” means the list of patents attached hereto as Schedule A, which may be amended from time-to-time. 
  3. The “Lottery Industry” means any party or entity, whether private, governmental, national, state, territory, semi-private, semi-governmental, or otherwise who participates in the preparation, processing, printing, sale, processing, drawing, or redemption of random, draw, or instant lottery tickets, whether printed or digital.   
  4. Defensive Termination. Because this Pledge is a promise not to assert certain InComm patents (the InComm Pledged Patents) without requiring any payment from a Pledge Recipient, we think it is only fair that we condition the Pledge upon the Pledge Recipient (and its affiliates) not asserting or profiting from the assertion of patents against InComm, its affiliates, or its products or services. Accordingly, InComm reserves the right to terminate the Pledge, to the extent InComm deems necessary to protect itself, its affiliates, or its products and services (“Defensive Termination”) with respect to any Pledge Recipient (or affiliate) who is not acting in good faith.

    A party is “acting in good faith” so long as such party and its related or affiliated companies have not:

    a. Asserted, helped other assert, or had a financial stake in any assertion of any patent or other intellectual property right against InComm or its affiliates; or

    b. Challenged, helped others challenge, or had a financial stake in any challenge to any InComm patent or application.

    Any party who has participated in (a) or (b) above shall be deemed an “Asserting Party.”  Defensive Termination by InComm with respect to an Asserting Party shall have the same effect as if this Pledge was never extended to such Asserting Party in the first instance. InComm, in its sole discretion, shall determine the manner and terms, if any, by which rights under Pledged Patents may be extended to an Asserting Party after that Asserting Party’s lawsuit or other legal proceeding is permanently dismissed, terminated or withdrawn in writing. 

  5. Mistaken Assertion. Should InComm ever initiate a lawsuit or other legal proceeding for patent infringement based on any product or service which is not the subject of a Defensive Termination, and then receive written notice from the party against whom such lawsuit or other legal proceeding has been filed providing sufficient information for InComm to reasonably determine that such product or service in fact satisfies the requirements of the Pledge, then InComm will use reasonable efforts to withdraw such lawsuit (or the applicable claims therein) or move to terminate such other legal proceeding (or the applicable portions thereof) within sixty (60) days after receiving such written notice. 
  6. No Waiver. This Pledge, while binding on InComm and its successors, is a forbearance of enforcement of InComm’s remedies against any party for claims of infringement for so long as such party is acting in good faith.  In order for InComm to preserve its ability to enforce the InComm Pledged Patents against any party not acting in good faith, this Pledge is not a waiver of any patent claims (including claims for damages for past acts of infringement) and is not a license, covenant not to sue, or authorization to engage in patented activities, or a limitation on remedies, damages, or claims.  Except as expressly stated herein, no rights shall be deemed granted, waived, or received by implication, exhaustion, estoppel, or otherwise.  This Pledge is not any indication of the value of an arms-length, negotiated license or a reasonable royalty. 
  7. No Assurances or Warranties. All parties acknowledge that this Pledge is not an assurance that the InComm Pledged Patents are enforceable, or that practicing InComm’s Pledged Patents does not infringe others’ patents or other intellectual property.  InComm is not liable to a party relying on this Pledge for related claims brought by another based on infringement of intellectual property rights or otherwise.  InComm makes no representations and disclaims any and all warranties as to the validity of the InComm Pledged Patents. In addition, InComm makes no representations and disclaims any and all warranties as to or their own non-infringement of third-party intellectual property rights arising from the use or distribution of technologies described and claimed in the InComm Pledged Patents. 
  8. Continuing Rights in Transfer or Modification.

    a.   Transfer.  It is InComm’s intent that this Pledge be legally binding, irrevocable (except as otherwise provided herein), and enforceable against InComm and entities controlled by InComm.  Should InComm ever transfer any of the InComm Pledged Patents to a third party, it will do so while protecting the continuing interests of any Pledge Recipient depending hereon (“Depending Party”).  InComm will endeavor to transfer only to a party that agrees to provide the same protection that InComm provided under this Pledge, and to place the same requirement on any subsequent transferee, this may not always be possible.  Notice of any such transfer shall be provided in accordance with the Notice provision set forth below.

    b.    Modifications.  InComm may modify this Pledge by publishing a new edition.  The prior edition (including its treatment of previously held patents and patent applications) will continue to apply to patents and patent applications that InComm holds and identifies as InComm Pledged Patents before the new edition is published.  Any new editions will apply to all patents granted and patent applications filed after the effective date of the new edition and set forth on Schedule A.  Notice of any such modification shall be provided in accordance with the Notice provision set forth below.

    c.    Continuing Rights.  Should the rights granted under this Pledge change in any way, either from (i) transfer of any of the InComm Pledged Patents to a party that does not agree to provide the same protection provided under this pledge or (ii) modification of this Pledge by InComm, any Pledge Recipient that is depending upon this Pledge or an older version of this pledge (“Depending Party”) before such transfer or  modification shall be entitled to continue its reliance on the terms of the previous Pledge subject to the terms below.  If InComm transfers any of the InComm Pledged Patents to a party that does not agree to provide the same protection provided under this pledge, before any such transfer InComm will offer to all Depending Parties a royalty-free, perpetual, non-exclusive, non-transferable, non-sublicensable license to the specific InComm Pledged Patents depended upon (“Protective License”).  

    In order to continue it continuing interests, any Depending Party shall provide written notice to InComm identifying the specific InComm Pledged Patents relied upon, no more than ninety (90) days from the notice of modification or transfer.  Notice of the date by which a Protective License must be obtained will be provided in accordance with the Notice provision set forth below. 

  9. Notice. The terms of this Pledge and information related thereto shall be published on a website associated InComm.  The specific address of this website shall be incomm.com/lottery-patent-pledge (“the Website”). InComm shall post notices of any modification, potential and/or pending Transfer, or other communications related to this Pledge on the Website.  While InComm may reach out to known Depending Parties to extend informal notice, publication of any such notices on the Website shall constitute official notice to any and all participants and/or Depending Parties.  If the address of the Website changes or is moved, notice of such change or move shall be published on the Website at least ninety (90) days prior to any such change or move.

  10. Licensing. While InComm intends for this pledge to be a binding statement, InComm may still enter into license agreements under individually negotiated terms for those who wish to use InComm technology but cannot or do not wish to rely on this pledge alone.

 

Schedule A
 

Patent No

Title

10089608

Processing of a User Device Game-Playing Transaction Based on Location

10127764

Processing of a User Device Game-Playing Transaction Based on Location

10217326

Processing of a User Device Game-Playing Transaction Based on Location

9227136

Systems and Methods for Integrated Game Play Through the Use of Barcodes on Smart Phones and Hand Held Devices

9672687

Processing of a Mobile Device Game-Playing Transaction Based on the Mobile Device Location

9672697

Processing of a Mobile Device Game-Playing Transaction Conducted between the Mobile Device and a Bluetooth Terminal

10115268

Systems and Methods for Integrated Game Play at Payment-Enabled Terminals

9824530

Processing of a User Device Game-Playing Transaction Based on Location

9824340

Processing of a User Device Game-Playing Transaction Based on Location

This Schedule is accurate as of 03 May 2019.

InComm Digital Solutions International Limited FY23 UK Tax Strategy

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