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OUR PRIVACY POLICY

This privacy policy has been compiled to better serve those concerned with how their ‘Personally Identifiable Information’ (PII) is being used online. PII, as described in US privacy law and information security, is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle your Personally Identifiable Information in accordance with our website.



WHAT PERSONAL INFORMATION DO WE COLLECT FROM THE PEOPLE WHO VISIT OUR BLOG, WEBSITE, OR APP?

When commenting or registering on our site, as appropriate, you may be asked to enter your name, email address, Website Address, or other details to help you with your experience.

WHEN DO WE COLLECT INFORMATION?

We collect information from you when you fill out a form or enter information on our site, including when you leave a comment.

HOW DO WE USE YOUR INFORMATION?

We may use the information we collect from you when you sign up for our newsletter, respond to a survey or marketing communication, surf the website, or use certain other site features in the following ways:

  • To send periodic emails regarding events, products, and services.

  • To follow up with you after correspondence (i.e. comments or email inquiries)

DO WE USE ‘COOKIES’?

Yes. Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your Web browser (if you allow) that enables the site’s or service provider’s systems to recognize your browser and capture and remember certain information. For instance, we use cookies to help us remember if you’ve already visited the site within a certain time period to prevent pop-up opt-in forms from showing too frequently. They are also used to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved user experience on our site. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.

WE USE COOKIES TO:

Compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. We may also use trusted third-party services, such as Google Analytics and Facebook, that track this information on our behalf.

You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. Since each browser is a little different, look at your browser’s Help Menu to learn the correct way to modify your cookies.

If you turn cookies off, It won’t affect the user’s experience.

THIRD-PARTY DISCLOSURE

We do not sell, trade, or otherwise transfer to outside parties your Personally Identifiable Information unless we provide users with advance notice. (See the cookie banner upon arrival to our site.) This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or serving our users, so long as those parties agree to keep this information confidential. We may also release information when its release is appropriate to comply with the law, enforce our site policies, or protect ours or others’ rights, property or safety.

However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.

THIRD-PARTY LINKS

Occasionally, at our discretion, we may include or offer third-party products or services on our website. These third-party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.

GOOGLE

Google’s advertising requirements can be summed up by Google’s Advertising Principles. They are put in place to provide a positive experience for users.

We use Google Google Analytics on our website.

Google, as a third-party vendor, may use cookies to serve ads on our site. Google’s use of the DART cookie enables it to serve ads to our users based on previous visits to our site and other sites on the Internet. Users may opt-out of the use of the DART cookie by visiting the Google Ad and Content Network privacy policy.

Note: This site does not use Google AdSense. We only use Google Analytics.

WE HAVE IMPLEMENTED THE FOLLOWING:

  • Demographics and Interests Reporting

We, along with third-party vendors such as Google use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our website.

OPTING OUT:

Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising Initiative Opt Out page or by using the Google Analytics Opt Out Browser add on.

CALIFORNIA ONLINE PRIVACY PROTECTION ACT

CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law’s reach stretches well beyond California to require any person or company in the United States (and conceivably the world) that operates websites collecting Personally Identifiable Information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals or companies with whom it is being shared. – See more at:

ACCORDING TO CALOPPA, WE AGREE TO THE FOLLOWING:

Users can visit our site anonymously.

Once this privacy policy is created, we will add a link to it on our home page or as a minimum, on the first significant page after entering our website. (This page is the Privacy Policy, located in the menu at the top of every page on this site.)

Our Privacy Policy link includes the word ‘Privacy’ and can easily be found on the page(s) specified above.

YOU WILL BE NOTIFIED OF ANY PRIVACY POLICY CHANGES:

  • On our Privacy Policy Page

CAN CHANGE YOUR PERSONAL INFORMATION:

By selecting the Update Preferences link at the bottom of any and all emails.

HOW DOES OUR SITE HANDLE DO NOT TRACK SIGNALS?

We honor Do Not Track signals and Do Not Track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.

DOES OUR SITE ALLOW THIRD-PARTY BEHAVIORAL TRACKING?

It’s also important to note that we allow third-party behavioral tracking, including but not limited to Google Analytics, MailerLite, and Facebook Pixel.

COPPA (CHILDREN ONLINE PRIVACY PROTECTION ACT)

When it comes to the collection of personal information from children under the age of 13 years old, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, United States’ consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online.

  • We do not specifically market to children under the age of 13 years old.

Third-parties, including ad networks or plug-ins may collect PII from children under 13.

Fair Information Practices

The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.

IN ORDER TO BE IN LINE WITH FAIR INFORMATION PRACTICES WE WILL TAKE THE FOLLOWING RESPONSIVE ACTION, SHOULD A DATA BREACH OCCUR:

We will notify the users via in-site notification:

  • Within 7 business days

We also agree to the Individual Redress Principle which requires that individuals have the right to legally pursue enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors.

CAN SPAM ACT

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.

We collect your email address in order to:

  • Send information, respond to inquiries, and/or other requests or questions

  • Market to our mailing list or continue to send emails to our clients after the original transaction has occurred.

Note: Your email address is only collected when you fill out a form or leave a comment on this website. Cookies are used by WordPress (this site’s web host), and plugins that run on this website, including but not limited to Google Analytics, Mailerlite (pop-up), and Facebook Pixel, to personalize your experience on this site as well as to help personalize ads you receive on other sites where ads are already being shown. You can disable cookies in your browser settings to prevent this type of tracking.

TO BE IN ACCORDANCE WITH CANSPAM, WE AGREE TO THE FOLLOWING:

  • Not use false or misleading subjects or email addresses.

  • Identify the message as an advertisement in some reasonable way.

  • Include the physical address of our business or site headquarters.

  • Monitor third-party email marketing services for compliance, if one is used.

  • Honor opt-out/unsubscribe requests quickly.

  • Allow users to unsubscribe by using the link at the bottom of each email.

PRIVACY NOTICE UNDER THE GDPR

Articles 12, 13 and 14 of the GDPR outline the requirements on giving privacy information to data subjects. These are more detailed and specific than in the UK Data Protection Act 1998 (DPA).

The GDPR says that the information we provide must be:

  • Concise, transparent, intelligible and easily accessible;

  • Written in clear and plain language, particularly if addressed to a child; and

  • Free of charge.


“Personal data” is defined in Article 4(1) of the GDPR:

“personal data”  means any information relating to an identified or identifiable

natural person (“data subject”); an identifiable natural person is one 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”.


YOUR RIGHTS UNDER GDPR

In this Section, we have summarized the rights that you have under data

protection law. Some of the rights are complex, and not all of the details have

been included in our summaries. Accordingly, you should read the relevant

laws and guidance from the regulatory authorities for a full explanation of

these rights.

1. Your principal rights under data protection law are:

(a) the right to access;

(b) the right to rectification;

(c) the right to erasure;

(d) the right to restrict processing;

(e) the right to object to processing;

(f) the right to data portability;

(g) the right to complain to a supervisory authority; and

(h) the right to withdraw consent.

2. You have the right to confirmation as to whether or not we process your

personal data and, where we do, access to the personal data, together with

certain additional information. That additional information includes details of

the purposes of the processing, the categories of personal data concerned

and the recipients of the personal data. Providing the rights and freedoms of

others are not affected, we will supply to you a copy of your personal data.

The first copy will be provided free of charge, but additional copies may be

subject to a reasonable fee.

3. You have the right to have any inaccurate personal data about you rectified

and, taking into account the purposes of the processing, to have any

incomplete personal data about you completed.

4. In some circumstances you have the right to the erasure of your personal

data without undue delay. Those circumstances include: [the personal data

are no longer necessary in relation to the purposes for which they were

collected or otherwise processed; you withdraw consent to consent-based

processing; you object to the processing under certain rules of applicable

data protection law; the processing is for direct marketing purposes; and the

personal data have been unlawfully processed]. However, there are

exclusions of the right to erasure. The general exclusions include where

processing is necessary: [for exercising the right of freedom of expression

and information; for compliance with a legal obligation; or for the

establishment, exercise or defence of legal claims].

5. In some circumstances you have the right to restrict the processing of your

personal data. Those circumstances are: you contest the accuracy of the

personal data; processing is unlawful but you oppose erasure; we no longer

need the personal data for the purposes of our processing, but you require

personal data for the establishment, exercise or defence of legal claims; and

you have objected to processing, pending the verification of that objection.

Where processing has been restricted on this basis, we may continue to store

your personal data. However, we will only otherwise process it: with your

consent; for the establishment, exercise or defence of legal claims; for the

protection of the rights of another natural or legal person; or for reasons of

important public interest.

6. You have the right to object to our processing of your personal data on

grounds relating to your particular situation, but only to the extent that the

legal basis for the processing is that the processing is necessary for: the

performance of a task carried out in the public interest or in the exercise of

any official authority vested in us; or the purposes of the legitimate interests

pursued by us or by a third party. If you make such an objection, we will

cease to process the personal information unless we can demonstrate

compelling legitimate grounds for the processing which override your

interests, rights and freedoms, or the processing is for the establishment,

exercise or defense of legal claims.

7. You have the right to object to our processing of your personal data for direct

marketing purposes (including profiling for direct marketing purposes). If you

make such an objection, we will cease to process your personal data for this

purpose.

8. You have the right to object to our processing of your personal data for

scientific or historical research purposes or statistical purposes on grounds

relating to your particular situation, unless the processing is necessary for the

performance of a task carried out for reasons of public interest.

9. To the extent that the legal basis for our processing of your personal data is:

(a) consent; or

(b) that the processing is necessary for the performance of a contract to

which you are party or in order to take steps at your request prior to

entering into a contract,

and such processing is carried out by automated means, you have the right

to receive your personal data from us in a structured, commonly used and

machine-readable format. However, this right does not apply where it would

adversely affect the rights and freedoms of others.

10. If you consider that our processing of your personal information infringes

data protection laws, you have a legal right to lodge a complaint with a

supervisory authority responsible for data protection. You may do so in the

EU member state of your habitual residence, your place of work or the place

of the alleged infringement.

11. To the extent that the legal basis for our processing of your personal

information is consent, you have the right to withdraw that consent at any

time. Withdrawal will not affect the lawfulness of processing before the

withdrawal.

12. You may exercise any of your rights in relation to your personal data by

written notice to us at the address below or strategy@inclusiondotlogic.com


IF AT ANY TIME YOU WOULD LIKE TO UNSUBSCRIBE FROM RECEIVING FUTURE EMAILS, YOU CAN:

Follow the instructions at the bottom of each email (Manage Preferences | Unsubscribe), and we will promptly remove you from ALL correspondence.

CONTACTING US

If there are any questions regarding this privacy policy, you may contact us using the information below.

INCLUSION.LOGIC

Attn: CLARISSA FUSELIER

strategy@inclusiondotlogic.com

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