Inclusio Limited (together with its affiliates, “Inclusio,” “we” or “us”) respects the privacy of the users (“User” or “you”) of its website located at www.inclusio.com (the “Website”), apps, and platforms (collectively, the “Services”). We are committed to protecting the information we collect and receive.
Collection of Information
Through your use of the Services, we collect both “Personal Information, ” which can be used to identify you, and “General Information,” which cannot be used to identify you. Together, Personal Information and General Information are referred to as “Information.” The Information we collect may include:
- Membership Information. When you use the Services or register for a membership, Inclusio will collect Personal Information about you, such as your name, email address, demographic information, date of birth, gender, and membership number.
- Information You Generate. Inclusio collects the content of the files and communications that you input, upload, receive, create, and control in using the Services (collectively, “Content”). Examples of Content include text, documents, audio, video, photos, images, software, and other media and files.
- Web beacons. “Web beacons” (also known as web bugs, pixel tags or clear GIFs) are tiny graphics with a unique identifier that may be included on our Services for several purposes, including to deliver or communicate with Cookies, to track and measure the performance of our Services, to monitor how many visitors view our Services, and to monitor the effectiveness of our advertising. Unlike Cookies, which are stored on the user’s hard drive, web beacons are typically embedded invisibly on web pages (or in an e-mail).
- Log Data and Device Information. We automatically collect Log Data and device information when you access and use the Services. That information includes, among other things: details about how you’ve used the Services (including if you clicked on links to third party applications), Internet Protocol (IP) address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, web browser, the pages you use on the Services, search terms, links clicked on the Services, the page from which you accessed the Services, and cookie data (collectively “Log Data”). This information is gathered for all users. We also may collect information about your online activity. Our goals in collecting this automatic information include helping customize and enhance your user experience and inhibiting fraud. We analyze (and may engage third parties to analyze) Log Data to improve, customize and enhance our Services by expanding their features and functionality and tailoring them to our User’s needs and preferences. We may use a person’s IP address to generate aggregate, non-identifying information about how our Services are used.
Usage of Information
We are committed to protecting your privacy and earning your trust. Your Information is an integral part of our operations, and we used it in a variety of ways in providing and improving the Services, administering your use of the Services, operating our business, and complying with our legal obligations. For example:
- To Operate and Provide Services. We collect and use Information to operate and provide you with our Services in accordance with our legitimate interests.
- For Informational, Promotional and Survey Purposes. We may use your Personal Information to inform you of our product and service offerings, subject to your ability to opt-out of receiving such information as described below. We may also contact you via surveys to conduct research about your opinion of current Services features or of potential new services. These activities are based on our legitimate interest in undertaking marketing activities to offer you products or services that may be of your interest.
- For Customized and Efficient Provision of Services. Inclusio keeps track of the websites and pages you visit within our platform and what features and algorithms you use and how frequently. We use this information to maintain and improve the content, design, usability and quality of the Services; to improve your user experience; to generate and provide statistics regarding use of the platform and the Services to deliver customized content and advertising to Users whose behavior indicated that they are interested in a particular subject area, and to develop new product and service offerings. These activities are based on our legitimate interest in improving the functionalities of the Services.
- Maintaining the Security of the Services and Complying with Applicable Law. We may use Information to prevent potentially prohibited or illegal activities, to detect and prevent fraud, spam, abuse, security incidents, and other harmful activity, to conduct security investigations and risk assessments, comply with our legal obligations, resolve any disputes with any of our Users and enforce our agreements with third parties, and to enforce our agreements and other policies.
Sharing Information with Third Parties
We will not share any Information that we have collected from or regarding you except as described below:
- With Your Consent. Where you have provided consent, we share your Information, including Personal Information, as described at the time of consent, such as when you authorize a third party application or website to access your membership or when you participate in promotional activities conducted by Inclusio partners or third parties.
- Services Providers. We may engage third-party services providers to work with us to administer and provide the Services. These third-party services providers have access to and may collect Information only for the purpose of performing services on our behalf and are not permitted to share or use the Information for any other purpose. They are also required to follow the same data security practices that we ourselves adhere to, and they may be located inside or outside of the European Economic Area (“EEA”).
- Aggregated and Anonymous Information. We may share aggregated and anonymous General Information with third parties for industry research and analysis, demographic profiling and other similar purposes. This Information does not contain any Personal Information.
- Business Transactions. Information that we collect from our Users, including Personal Information, is considered to be a business asset. Thus, if we are acquired by a third party as a result of a transaction such as a merger, acquisition or asset sale or if our assets are acquired by a third party in the event we go out of business or enter bankruptcy, some or all of our assets, including your Personal Information, may be disclosed or transferred to a third party acquirer in connection with the transaction.
- Disclosed for Our Protection and the Protection of Others. We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. We may disclose any Information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate: (i) to respond to claims, legal process (including subpoenas); (ii) to protect our property, rights and safety and the property, rights and safety of a third party or the public in general; and (iii) to stop any activity that we consider illegal, unethical or legally actionable activity.
We take great care in maintaining the security of our Services and your Information and endeavor to take all commercially reasonable measures to prevent unauthorized access to your Information by using standard technology and internal procedures. Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the security of any information you transmit to us or store on the Services and you do so at your own risk. We also cannot guarantee that such Information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. For more information, please refer to our Security Policy.
Privacy of Children
The Services are intended for a general audience and are not directed to children under the age of 16. We do not knowingly collect Information from anyone under the age of 16. If we learn that we have inadvertently collected Personal Information from a child under the age of 16, we will delete that information as quickly as possible. If you believe that we might have any information from a child under age 16, please contact us at email@example.com.
Under California law, users who are residents of California are permitted to request and obtain from us a list of what Personal Information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year (if any) and the names and addresses of those third parties. Requests may be made only once a year and are free of charge.
The length of time we retain Information depends on a number of factors relating to our business needs and legal requirements. In general, we will keep Information for such time as required by applicable law or to exercise our legal rights.
We offer you choices regarding the collection, use and sharing of your Personal Information and we’ll respect the choices you make. Please note that if you decide not to provide us with the Personal Information that we request, you may not be able to access all the features of the Services. You may exercise any of the rights described in this section below by sending an email to firstname.lastname@example.org. Please note that we may ask you to verify your identity before taking further action on your request.
- Accessing, Modifying and Deleting Your Information. You can access, update, modify or delete the Personal Information associated with your membership through your account settings or by sending us an email at email@example.com. If you want us to delete your Personal Information and your membership, please contact us with your request. We’ll take steps to delete your Personal Information as soon as we can, but some information may remain in archived/backup copies for our records or as otherwise required by law. You further have the right to ask us to correct inaccurate or incomplete Information concerning you (and which you cannot update yourself within your account).
- Data Portability. In some jurisdictions, applicable law may entitle you to request copies of your Personal Information held by us. You may also be entitled to request copies of Information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).
- Withdrawing Consent and Restriction of Processing. Where you have provided your consent to the processing of your Personal Information, you may withdraw your consent at any time by changing your membership settings or by sending us a communication specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your Personal Information, in particular where (i) you contest the accuracy of your Personal Information; (ii) the processing is unlawful and you oppose the erasure of your Personal Information; (iii) we no longer need your Personal Information for the purposes of the processing, but you require the Information for the establishment, exercise or defense of legal claims; or (iv) you have objected to the processing pursuant to your right to object to processing (below) and pending the verification whether the legitimate grounds of Inclusio override your own.
- Objection to Processing. In some jurisdictions, applicable law may entitle you to require us not to process your Personal Information for certain specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing, we will no longer process your Personal Information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defense of legal claims.
Links to Other Sites
Inclusio’s sites and applications are primary located and managed on servers within the EEA. In order to provide our products and services to you your Personal Information may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. We are committed to protecting the privacy and confidentiality of Personally Identifiable Information when it is transferred. If you reside or are located within the EEA and such transfers occur, we take appropriate steps to provide the same level of protection for the processing carried out in any such countries as you would have within the EEA to the extent feasible under applicable law.