Privacy Policy - Inclusioneering

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Last updated 15^th October 2023.

Inclusioneering Limited (registered number 13143525 ) (“us”, “our”, “we”, “Inclusioneering”) is the Data Controller of Personal Data collected through https://inclusioneering.com/ (the “Website”) or through workplace survey(s) (“Surveys” or a “Survey”) we are selected to carry out.

Inclusioneering Limited is Committed to Protecting and Respecting Your Privacy.

This Privacy Policy (the “Policy) sets out the types of Personal Data we may collect and Process when you access Website or participate in Survey(s).

By visiting or otherwise using the Website, or by participating in Survey(s), you agree to the terms of this Policy. If, for any reason, you do not agree to the terms of this Policy, please immediately stop using the Website or participating in Survey(s).

Definitions and Interpretation

The following definitions and rules of interpretation shall apply to this Policy:

“Child” means a person under the age of 18 and “Children” shall be interpreted accordingly;

“Data Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the Processing of personal data;

“Data Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;

“Data Subject” means an identified or identifiable natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

“Personal Data” means any information relating to a Data Subject; and

“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 and “Process” shall be interpreted accordingly.

Singular and plural. Unless the context otherwise requires, words in the singular shall include the plural and in the plural shall include the singular.

Writing. A reference to writing or written includes e-mail.

Including. Any words following the terms including, include, in particular, for example or any similar expression shall be construed as illustrative and shall not limit the sense of the words, description, definition, phrase or term preceding those terms.

Introduction

This Policy explains who we are, why and how we Process Personal Data collected through your use of the Website or participation in Survey(s). If you are the subject of Personal Data, we also explain what rights you have and how to get in touch with us to exercise those rights.

When you supply Personal Data to us, we have legal obligations towards you in the way we collect and use that data. For ease of reading, we have divided this Policy into several sections:

Introduction.
What information can we collect?
Special Category Data.
How is your personal information collected?
How and why do we use and share your personal information?
For how long do we keep your personal information?
Security.
International Data Transfers.
Your Rights.
Contact Details.

It is important that you read this Policy together with any other privacy notice or fair processing notices that we may provide on the Website or as part of any Survey(s) you may participate in at or around the time that we collect or Process Personal Data about you. For example, this may include fair processing notices that we may display to you at the time that you sign up to receive e-mail updates from us, so that you are fully aware of how and why we are using that data.

This Policy supplements other notices on the Website or in connection to Survey(s) you may have participated in — and is not intended to override or replace them.

By visiting or otherwise using the Website, or by participating in a Survey(s), you agree to its the terms (including as amended from time to time) and of this Privacy Policy. If, for any reason, you do not agree to the terms of this Policy, please immediately stop using this Website and or participating in Survey(s).

We reserve the right to revise or amend this Policy at any time to reflect changes to our business or changes in the law. Where these changes are significant, we will endeavour to let you know. However, it is your responsibility to check this Policy before each use of the Website or prior to participating in any Survey(s). For ease of reference, the top of this Policy indicates the date on which it was last updated.

It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us.

Please note that neither the Website, nor the Survey(s) are directed at Children and we do not knowingly collect Personal Data about Children. If you believe we have collected Personal Data about a Child of whom you are a parent or individual appointed to take parental responsibility for, please contact us immediately via email at privacy@inclusioneering.com.

What Information Can we Collect?

What is Personal Data?

Where this Policy refers to Personal Data it is referring to any data about you from which you could be identified. This may include your name, your date of birth, your contact details, or your IP address.

When Personal Data is provided, collected or submitted, Inclusioneering will endeavour to protect the anonymity of the person to whom it relates. Where a person can be indirectly identified from ‘anonymous’ data—perhaps because there is something unique about them—this data shall amount to Personal Data, and as such, this Policy shall apply.

By law, all organisations who Process Personal Data in the UK are obliged to Process Personal Data in certain ways and to ensure that Data Subjects are given an appropriate amount of information about how their data will be Processed. Data Subjects also have various rights to seek information from those organisations about how they are using their Personal Data, and to prevent the unlawful Processing of said data. For more information about these rights, please see the ‘Your Rights’ section of this Privacy Policy.

What Types of Data We May Collect From You When You Use the Website or Participate in a Survey?

The Personal Data we may collect from your use of the Website or participation in Survey(s) may include:

Identity Data which may include your name, date of birth or gender. Please note that
Contact Data which may include your e-mail address, billing address or delivery address.
Technical Data which may include your IP address, your login data or browser type and version.
Profile Data which may include your interests, preferences, feedback or Survey responses.
Usage Data which may include information about how you use the Website or Survey tool(s).
Marketing and Communications Data which may include your preferences in receiving marketing from us or our associated third parties.
Special Category Data which may include your ethnic identity, sexual orientation, disability status, gender identity, or other protected characteristics.

Special Category Data

When participating in a Survey, there may be certain Special Category Data that we collect, such as:

Ethnic Identity.
Sexual Orientation.
Disability Status.
Gender Identity.

When Processing special categories of Personal Data, we are obliged to have additional lawful bases for Processing this data. These are set out below.

How is Your Personal Information Collected?

Direct interactions

When you use the Website to contact us, or, take part in Survey(s), we may collect, store or use Personal Data associated with you.

Automated Technologies or Interactions

When you access the Website or participate in Survey(s), we may collect information about you through the use of technologies, such as cookies. The following are examples of Personal Data we may collect:

Information about your device, browser or operating system.
Your IP address.
Information about links that you click and pages you view on the Website.
Length of visits to certain pages.
Subjects you viewed or searched for.
Page response times.
Records of download errors and/or broken links.
Page interaction information (such as details of your scrolling, clicks, and mouse-overs).
Methods used to browse away from the page.
Or, the full Uniform Resource Locators (URL) clickstream to, through or from this Website (including date and time).

We use the data described above for several different reasons. First, we use it to ensure that the Website or Survey works properly and that you are able to receive their full benefit. Secondly, we use the data to monitor online traffic and audience participation across the Website or Survey(s). Thirdly, we use the data to gain insights about your preferences, interests, or other characteristics as defined in and for disclosed Survey purposes. We undertake these activities because we have a legitimate interest in doing so.

For more information on this kind of technology, please see our Cookies Policy

Third Parties or Publicly Available Sources

We also partner with third parties who may collect Personal Data including usage or statistical data through your use of the Website or participation in Survey(s). This may include business partners, sub-contractors in technical support and delivery of services, advertising networks, analytics providers or search information providers.

Updating Your Information

If you would like to update Personal Data you have previously given to us while using the Website or through your Survey participation, please contact us at privacy@inclusioneering.com.

As far as possible, survey results are anonymised during collection and analysis, so we are unable amend or erase Personal Data. This also applies to aggregated data compiled as part of Survey findings.

How and Why do we Use/Share Your Personal Data?

Lawful Basis for Processing Your Information

We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances:

Where you have asked us to do so, or consented to us doing so (although please be aware that consent is not necessarily required for us to Process your Personal Data, and we may rely on one of the other lawful basis where necessary).
Where we need to do so in order to perform a contract we have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your fundamental rights do not override those interests.
Where we need to comply with our legal or regulatory obligations.

Here are some examples about how we may use the information we collect about you and the lawful basis we rely on to do so.

Activity	Examples of the types of Personal Data we may collect	Lawful basis for Processing
To register you as a customer and deliver services to you	Identity, contact, financial, and transaction information	Performance of a contract with you
To manage our relationship with you including notifying you of any changes to the Website or Survey(s).	Identity, contact, profile and marketing communications information.	Performance of a contract with you
To administer and protect our business and this Website (including troubleshooting, data analysis and system testing.)	Identity, contact and technical information.	In accordance with our legitimate interest
To deliver relevant Website content and advertisements to you.	Identity, contact, profile, usage, marketing and communications and technical information.	In accordance with our legitimate interest (to understand how users use our services and to inform our marketing strategy)
To use data analytics to improve the Website, services, marketing, customer relationships and experiences	Technical and usage information.	In accordance with our legitimate interest (to improve our services)
To collect and analyse equity, diversity and inclusion workplace data.	Identity, contact, profile data Special category data	In accordance with our legitimate interest (to carry out research via Surveys and develop our services) Consent (special categories only)
To generate a report based on the outcome of research and surveys which will be shared with third parties.	Special category data.	In accordance with our legitimate interest (to carry out research via Surveys and develop our services) Consent (special categories only).

Marketing and Communications

We may use your Personal Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted-out of receiving that marketing. You will not receive marketing communications from us where we have only collected your Personal Data via a Survey.

We will get your express opt-in consent before we share your Personal Data with any third party for marketing purposes.

Opting Out of Marketing

To unsubscribe from marketing emails at any time, please click on the unsubscribe link at the bottom of any marketing email. You may also contact us or the third party directly if you do not wish to receive any marketing materials from us or them.

Sharing Your Personal Data

Depending on how and why you provide us with your Personal Data we may share it in the following ways:

With selected third parties to which we sub-contract to provide various services and/or aspects of the Website’s functionality, such as where third party plugins provide functionality such as survey services (see “Service Providers” below).
With analytics and search engine providers that assist us in the improvement and optimisation of this Website as described above.
With our clients who ask us to perform services for them, including the collection, analysis and benchmarking of diversity and inclusion data.

We may also disclose your Personal Data to third parties in events where we are obligated, such as:

If we were to sell or buy any business or assets, in which case we might disclose your Personal Data to the prospective seller or buyer of such business or assets as part of that transaction.
If our or substantially all of our assets are acquired by a third party, in which case Personal Data held by us will be one of the transferred assets.
If we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation, or if we are asked to provide your details to a lawful authority in order to aid in the investigation of crime or disorder.
In order to enforce or apply the Policy or notices previously described. This may include the Website’s Terms of Use or Terms and Conditions of Sale; or to protect the rights, property, or safety of our company, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection.

Service Providers (Data Processors)

Our service providers provide us with a variety of administrative, statistical, and technical services. We will only provide service providers with the minimum amount of Personal Data they need to fulfil the services we request, and we stipulate that they protect this data and do not use it for any other purpose. We take these relationships seriously and oblige all of our Data Processors to sign contracts with us that clearly set out their commitment to respecting individual rights, and their commitments to assisting us to help you exercise your rights as a Data Subject. We do not allow our third-party service providers to use your Personal Data for their own purposes. The following is a list of our major service providers:

Microsoft
Google
Qualtics

Links to Third Party Sites

Where we provide links to third party websites, plug-ins and applications that are not affiliated with Inclusioneering such sites are out of our control and are not covered by this Policy. If you access third party sites using the links provided, the operators of these sites may collect Personal Data from you that could be used by them, in accordance with their own privacy policies. Please check these policies before you access or submit any Personal Data to those websites.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the associated website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

Change of Purpose

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the Processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may Process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

For How Long Do We Keep Your Personal Data?

We will hold your personal information on our systems only for as long as required by the Relationship to provide you with the services you have requested, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation with respect to our relationship with you.

To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we Process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including contact, identity, financial and transaction Data) for six years after they cease being customers for compliance purposes. I n some circumstances you can ask us to delete your data: see ‘Your Rights’ below for further information, although this may not always be possible if we are obliged to retain the data for compliance purposes.

In some circumstances we may anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature.

Security

Inclusioneering Limited takes the protection of your information very seriously. We have put in place technologically and organisationally appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed, altered or disclosed in an unauthorised way,.

In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only Process your Personal Data on our instructions and they are subject to a duty of confidentiality.

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

International Data Transfers

Please note that some of our service providers may be based outside of the UK. These service providers may work for us or for one of our suppliers and may be engaged in, among other things, the fulfilment of your request for information and the provision of services or support services.

Where we transfer your data to a service provider that is outside of the UK we seek to ensure that appropriate safeguards are in place to make sure that your Personal Data is held securely and that your rights as a Data Subject are upheld. We will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data.

By submitting your personal information, you agree to this transfer, storing or Processing. If you would like more information about how the mechanism via which your Personal Data is transferred, please contact privacy@inclusioneering.com.

Your Rights

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance privacy@inclusioneering.com.

As a Data subject you have a number of rights in relation to your Personal Data. Below, we have described the various rights that you have, as well as how you can exercise them.

Right of Access

You may, at any time, request access to the Personal Data that we hold which relates to you (you may have heard of this right being described as a “subject access request”).

Please note that this right entitles you to receive a copy of the Personal Data that we hold about you in order to enable you to check that it is correct and to ensure that we are Processing that Personal Data lawfully. It is not a right that allows you to request Personal Data about other people, or a right to request specific documents from us that do not relate to your Personal Data.

You can exercise this right at any time by writing to us and telling us that you are making a subject access request. You do not have to fill in a specific form to make this kind of request.

Where you have submitted your data anonymously (e.g. via a Survey), your right of access shall only apply in the event that your data can be used to identify you.

Your Right to Rectification and Erasure

You may, at any time, request that we correct Personal Data that we hold about you which you believe is incorrect or inaccurate. You may also ask us to erase Personal Data if you do not believe that we need to continue Processing it including storing it (you may have heard of this right described as the “right to be forgotten”).

Please note that we may ask you to verify any new data that you provide to us and may take our own steps to check that the new data you have supplied us with is correct. Further, we are not always obliged to erase Personal Data when asked to do so; if for any reason we believe that we have a good legal reason to continue Processing Personal Data that you ask us to erase we will tell you what that reason is at the time we respond to your request.

You can exercise this right at any time by contacting us and telling us that you are making a request to have your Personal Data rectified or erased and on what basis you are making that request. If you want us to replace inaccurate data with new data, you should tell us what that new data is. You do not have to fill in a specific form to make this kind of request.

Where you have submitted your data anonymously (e.g. via a Survey), your right to rectification and erasure shall only apply in the event that your data can be used to indirectly identify you.

Your Right to Restrict Processing

Where we Process your Personal Data on the basis of a legitimate interest (see the sections of this Policy which explain how and why we use your information) you are entitled to ask us to stop Processing it in that way if you feel that our continuing to do so impacts on your fundamental rights and freedoms or if you feel that those legitimate interests are not valid.

You may also ask us to stop Processing your Personal Data (a) if you dispute the accuracy of that Personal Data and want us verify that data’s accuracy; (b) where it has been established that our use of the data is unlawful but you do not want us to erase it; (c) where we no longer need to Process your Personal Data (and would otherwise dispose of it) but you wish for us to continue storing it in order to enable you to establish, exercise or defend legal claims.

In some cases, we may demonstrate that we have compelling legitimate grounds to Process your information which override your rights and freedoms., We will tell you what that reason is, either at the time we first respond to your request or after we have had the opportunity to consider and investigate it.

You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a request to have us stop Processing the relevant aspect of your Personal Data and describing which of the above conditions you believe is relevant to that request. You do not have to fill in a specific form to make this kind of request.

Where you have submitted your data anonymously (e.g. via a Survey), your right to restrict Processing shall only apply in the event that your data can be used to indirectly identify you.

Your Right to Portability

Where you wish to transfer certain Personal Data that we hold about you, which is Processed by automated means, to a third party you may write to us and ask us to provide it to you in a commonly used machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Where you have submitted your data anonymously (e.g. via a Survey), your right to portability and erasure shall only apply in the event that your data can be used to indirectly identify you.

Your Right to Object to Processing

You may object to Processing of your Personal Data where we rely on legitimate interest for Processing that Personal Data. We will comply with your request unless we have a compelling overriding legitimate interest for Processing or we need to continue Processing your Personal Data to establish, exercise or defend a legal claim.

Your Right to stop Receiving Communications

Where we send you e-mail marketing communications (or other regulated electronic messages) you have the right to opt-out at any time. You can do this by using the ‘unsubscribe’ link that appears in the footer of each communication (or the equivalent mechanism in those communications).

Alternatively, if for any reason you cannot use those links, or if you would prefer to contact us directly – you can unsubscribe by writing to us at privacy@inclusioneering.com and telling us which communications you would like us to stop sending you.

Your Right to Object to Automated Decision Making and Profiling

You have the right to be informed about the existence of any automated decision making and profiling of your Personal Data, and where appropriate, be provided with meaningful information about the logic involved, as well as the significance and the envisaged consequences of such Processing that affects you.

Withdraw Consent, Where Consent is the Lawful Basis for Processing

You have the right to withdraw consent at any time where we are relying on consent to Process your Personal Data. However, this will not affect the lawfulness of any Processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Exercising Your Rights

When you write to us making a request to exercise your rights we are entitled to ask you to prove that you are who you say you are. We may ask you to provide copies of relevant ID documents to help us to verify your identity.

It will help us to Process your request if you clearly state which right you wish to exercise and, where relevant, why it is that you are exercising it. The clearer and more specific you can be, the faster and more efficiently we can deal with your request. If you do not provide us with sufficient information then we may delay actioning your request until you have provided us with additional information (and where this is the case we will tell you).

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Contact Details

If you have any queries regarding this Privacy Policy, if you wish to exercise any of your rights set out above or if you think that the Privacy Policy has not been followed, please contact us by emailing at privacy@inclusioneering.com.

You may also lodge a complaint to the supervisory authority about the way we Process your Personal Data. We would however, appreciate the chance to address your concerns before you approach the supervisory authority, so please contact us in the first instance.