Inclusion Score Privacy Statement
Effective Date: July 25, 2020
Inclusion Score, Inc. (collectively “Inclusion Score”, “we”, “us”, “our”) is committed to respecting your privacy and has developed this Privacy Statement to demonstrate its transparency and commitment to protecting your information. This statement is provided to explain our information practices and the choices you can make about the way your information is collected and used.
This statement applies to our websites, products, services, software, and applications (collectively “Inclusion Score Services” or “the Services”) on which we post a direct link to this statement or refer to this statement.
Capitalized terms not otherwise defined herein shall have the meaning ascribed to them in the Inclusion Score Bridge Terms of Service Agreement.
Please submit inquiries pertaining to this Statement by contacting Inclusion Score here.
This Privacy Statement explains how we collect, use and disclose information, including Personal Data, in connection with Inclusion Score Services. For these purposes, “Personal Data” means information related to an identified natural person or that could reasonably be used (by itself or in combination with other data reasonably available) to identify a natural person.
This Privacy Statement describes the choices available to you regarding our use of your Personal Data and how you can access and update this information. This statement also covers our treatment of any Personal Data that our business partners share with us or that we share with our business partners.
2. Information We Collect
When you visit our websites, register for the Service, or request more information about Inclusion Score Services, we may request that you provide Personal Data about yourself, and we also collect navigational information. In some cases, if you do not provide sufficient Personal Data, we may not be able to provide all of our available products and services.
Inclusion Score collects Personal Data such as name, title, phone number, email address, mailing address, and IP address. Additionally, when you sign up for a Inclusion Score paid service, we collect your billing information, including your credit card number, expiration date, and billing address. Inclusion Score may also receive Personal Data from its business partners based on your consent.
Inclusion Score also automatically collects navigational information such as your browser including your browser type, referrer page, domain name, access time, entry page, exit page, operating system type, and search engine keywords used.
COOKIES AND OTHER TRACKING TECHNOLOGIES
From time to time, Inclusion Score may invite you to participate in an online survey administered by Inclusion Score or a third-party agent. In addition to questions about your experience with Inclusion Score Services, these surveys include Personal Data such as name and email, and may request additional profile information. The results of these surveys help us better understand the needs of our customers in order to improve Inclusion Score Services, and may be shared in aggregate format with third parties.
We display personal testimonials of satisfied customers on our website in addition to other endorsements. With your consent, we may post your testimonial along with your name, company, title, logo, or profile photo. If you wish to update or delete your testimonial, contact us here.
Inclusion Score may invite you to participate in referral program to inform your colleagues and friends about Inclusion Score Services. If you choose to use our referral service to tell a friend about Inclusion Score Services, we will ask you for your friend’s name and email address, which we understand you are authorized to provide. To request removal of your Personal Data from our referral program, contact us here.
3. How We Use Your Information
Inclusion Score uses the information we collect through our websites and Services to measure our business success, to identify effective ways to communicate with or educate our customers and prospects, to meet requests for certain product features and services, and to communicate about product updates and service incidents.
Inclusion Score acts as an agent (the data processor) for each of our customers, in that Inclusion Score processes Personal Data only on the instructions from our customers (the data controller). As per our customer agreements, Inclusion Score does not access or make use of any data collected on the customer’s behalf except as necessary to provide our services to that customer. We do not aggregate, transfer, or otherwise disclose it to anyone but the customer, or pursuant to the customer’s instructions. We do, however, reserve a right to disclose data we collect if required by law or valid order of a court or other governmental authority.
Our legal basis for collecting and processing your Personal Data when you evaluate Inclusion Score Services, register for a Inclusion Score account, or purchase Inclusion Score Services is based on the necessity to perform a contract or take steps enter into a contract. Our legal basis for collecting and processing your Personal Data when you when you subscribe to receive Inclusion Score marketing emails is based on consent. There may be instances where processing Personal Data is in our legitimate interests (which is not overridden by your data protection interests), such as for research and development, to market and promote Inclusion Score Services, and to protect our legal obligations and interests.
4. Information We Share
Inclusion Score will not rent, sell, or share Personal Data about you with third parties except to provide services that you have requested, when we otherwise have your permission, or under the following circumstances:
When we need to disclose Personal Data to third-party agents that work on our behalf in order to provide Inclusion Score Services, but only to the extent needed to enable them to provide such services. For example, Inclusion Score uses third party agents for infrastructure hosting services and payment processing. All such third parties function as our agents performing services at our instruction and on our behalf pursuant to contracts which require they provide an equivalent level of privacy protection as is required by this Privacy Statement and any applicable data processing agreement in place.
When we need to transfer your Personal Data to provide you with a service or product you are requesting through a Inclusion Score business partner. For example, if you sign up for a Inclusion Score account through one of our authorized resellers.
When we conform to edicts of the law, to respond to subpoenas, court orders, or legal processes.
When you have violated our agreements for the Inclusion Score Services you are using or have used.
When we act under exigent circumstances to protect the personal safety of our customers or the public.
If we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Data could be one of the assets transferred to or acquired by a third party.
5. How to Access and Update Your Information
You have the ability to access, change and delete the Personal Data you submitted when you registered for the Service. If you are a registered Inclusion Score account user, you can access, change and delete your Personal Data at any time by signing into your account and editing your profile (under the Account option). If you are unable to sign into your account, reset your password or contact Inclusion Score Support. Inclusion Score takes steps to verify your identity before granting access to your account or Personal Data. If these options do not fully meet your needs, contact us here.
EUROPEAN PRIVACY RIGHTS
Inclusion Score acknowledges that you have the right to control your Personal Data, as provided by applicable data protection laws. Your rights include:
You can request access, correction, updates, portability and/or deletion of your Personal Data.
You have the right to object to Inclusion Score processing your Personal Data and request the processing be restricted.
If you have consented to the processing of your Personal Data, you have the right to change your mind at any time, but this will not affect any processing that has already taken place nor will it affect any processing that is required for legal obligations.
If we are unable to solve your request to your satisfaction, you have the right to complain to a data protection authority.
To exercise any of these rights, you can submit your request by contacting us here or by mail to Inclusion Score, Inc., 2550 Great America Way, Suite 325, Santa Clara, CA 95054 USA, Attention: Privacy. We will respond to your privacy requests within 30 days and notify you of the action(s) we have taken or required steps to fulfill the request.
Your requests to access, correct, or delete Personal Data may be restricted in certain situations, for example, if fulfilling the request would compromise Personal Data about another individual, or if you ask to delete information which Inclusion Score, Inclusion Score business partners, or Inclusion Score account owners are permitted by law or have compelling legitimate interests to keep.
If Personal Data pertaining to you as an individual has been submitted to us by a Inclusion Score customer and you wish to exercise any rights you may have to access, correct, or delete such data, please inquire with our customer directly and Inclusion Score will respond to the customer’s request within 30 days.
CALIFORNIA PRIVACY RIGHTS
California residents may request certain information regarding Inclusion Score’s disclosures in the prior calendar year, if any, of their Personal Data to third parties for their own direct marketing purposes. If you are a California resident, you can make such a request by contacting us here. You must clearly state the nature of your request and provide sufficient information for us to process your request; at a minimum your name, email address, and California postal address.
At any time, you can unsubscribe from our marketing emails by accessing our unsubscribe page, or by clicking on the “unsubscribe” link located at the bottom of our marketing emails.
We reserve the right to send you account-related communications, such as service announcements and administrative messages, that are considered part of your Inclusion Score Service, and we do not offer you the option to opt out of these messages.
6. International Data Transfers
Because Inclusion Score offices and Services are globally dispersed, we may process information in many countries, and therefore your Personal Data may be transferred to servers located in different geographical areas. Inclusion Score processes information as both a data controller and a data processor, and we take the necessary steps in these distinct capacities to ensure the protection for international transfers in compliance with applicable data protections laws and regulations.
Under the Privacy Shield Framework guidelines, Inclusion Score is responsible for the processing of the Personal Data it receives and subsequently transfers to a third party acting as an agent on its behalf. Inclusion Score adheres to the Privacy Shield Principles for onward transfers of Personal Data from the European Union and the United Kingdom, including the onward transfer liability provisions.
With respect to Personal Data received or transferred pursuant to the Privacy Shield Framework, Inclusion Score is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Inclusion Score may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Inclusion Score commits to resolve complaints about our collection or use of your Personal Data as follows. Individuals in the European Union and United Kingdom can direct any inquiries or complaints by contacting us here. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, you may contact our U.S.-based third party dispute resolution provider (free of charge) at https://www.jamsadr.com/eu-us-privacy-shield. Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
7. Data Security and Integrity
The security of your Personal Data is important to us. We use robust security measures to protect the Personal Data submitted to us, both during transmission and once it is received. All information transferred within the Inclusion Score Bridge Service, customers’ deployed applications, and the Inclusion Score website(s) is automatically served through a secure connection (HTTPS). However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. While Inclusion Score has implemented and will maintain appropriate security measures to protect your Personal Data, we cannot guarantee its absolute security. We use commercially acceptable means to maintain the integrity of your Personal Data and have implemented physical, technical, and administrative safeguards to protect your data from unauthorized access, use, disclosure, and destruction.
8. Data Retention
We retain Personal Data that you provide to us where we have an ongoing legitimate business need to do so (for example, as long as is required in order to contact you about Inclusion Score Services, or as needed to comply with our legal obligations, resolve disputes and enforce our agreements).
We regularly review collected data and set data retention policies in order to delete data in accordance with contractual agreements, legal obligations and applicable data protection laws.
9. Children and Privacy
Inclusion Score Services are intended for adults. We do not intentionally or knowingly collect Personal Data from children as defined by applicable law, and we request that children not submit any Personal Data to us. If you are aware that your child or any other child is using our Services, please contact us here.
10. Do Not Track Response
Certain web browsers may allow you to enable a “do not track” option that sends signals to the websites you visit indicating that you do not want your online activities tracked. However, some browsers with the “do not track” option selected may still accept cookies. Because there is no industry standard for how companies should respond to “do not track” signal, we do not respond to “do not track” signals at this time. If we do so in the future, we will modify this statement accordingly.
11. Material Changes
We reserve the right to make changes to this statement at any time to reflect changes to our data practices, so please review it frequently. Should we make material changes to the manner in which your Personal Data is processed, we will notify customers via email (sent to the email address specified in the user profile) and also post a notice on our website and Services.
12. Contact Inclusion Score
To comment or ask questions about this Privacy Statement and our data practices, or if you need to update, change or remove your information, contact us here or at the address below:
Inclusion Score, Inc.
2266 5th Ave, STE 1080
New York, NY 10037 USA