PRIVACY POLICY

1. INTRODUCTION

This privacy notice provides you with details of how we collect and process your personal data through your use of our site,

inclusioninprogress.com.

By providing us with your data, you warrant to us that you are over 13 years of age.

Inclusion in Progress, LLC, is the data controller and we are responsible for your personal data (referred to as “we”, “us” or

“our” in this privacy notice).

Contact Details

Our full details are:

Full name of legal entity: Inclusion in Progress, LLC

Email address: inclusioninprogress.com

Postal address: 30 N. Gould Street, Suite R, Sheridan, WY 82801, USA

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your

personal information changes by emailing us at info@inclusioninprogress.com.

2. WHAT DATA DO WE COLLECT ABOUT YOU, FOR WHAT PURPOSE AND ON WHAT GROUND WE PROCESS IT

Personal data means any information capable of identifying an individual. It does not include anonymised data.

We may process the following categories of personal data about you:

● Communication Data that includes any communication that you send to us whether that be through the contact

form on our website, through email, text, social media messaging, social media posting or any other communication

that you send us. We process this data for the purposes of communicating with you, for record keeping and for the

establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests

which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal

claims.

● Customer Data that includes data relating to any purchases of goods and/or services such as your name, title, billing

address, delivery address email address, phone number, contact details, purchase details and your card details. We

process this data to supply the goods and/or services you have purchased and to keep records of such transactions.

Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at

your request to enter into such a contract.

● User Data that includes data about how you use our website and any online services together with any data that you

post for publication on our website or through other online services. We process this data to operate our website

and ensure relevant content is provided to you, to ensure the security of our website, to maintain back- ups of our

website and/or databases and to enable publication and administration of our website, other online services and

business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to

properly administer our website and our business.

● Technical Data that includes data about your use of our website and online services such as your IP address, your

details about the number of times you use our website, time zone settings and other technology on the devices you

use to access our website. The source of this data is from our analytics tracking system. We process this data to

analyse your use of our website and other online services, to administer and protect our business and website, to

deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising.

Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly

administer our website and our business and to grow our business and to decide our marketing strategy.

● Marketing Data that includes data about your preferences in receiving marketing from us and our third parties and

your communication preferences. We process this data to enable you to partake in our promotions such as

competitions, prize draws and free give-aways, to deliver relevant website content and advertisements to you and

measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate

interests which in this case are to study how customers use our products/services, to develop them, to grow our

business and to decide our marketing strategy.

● We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and

advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand

the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which

is to grow our business. We may also use such data to send other marketing communications to you. Our lawful

ground for this processing is either consent or legitimate interests (namely to grow our business).

Sensitive Data

We do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or

ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership,

information about your health and genetic and biometric data. We do not collect any information about criminal convictions

and offences.

3. HOW WE COLLECT YOUR PERSONAL DATA

We may collect data about you by providing the data directly to us (for example by filling in forms on our site or by sending us

emails). We may automatically collect certain data from you as you use our website by using cookies and similar technologies.

Please see our cookie policy for more details about this.

We may receive data from third parties such as analytics providers such as Google based outside the EU, advertising

networks such as Facebook based outside the such as search information providers such as Google based outside the EU,

providers of technical, payment and delivery services, such as data brokers or aggregators.

We may also receive data from publicly available sources such as Companies House and the Electoral Register based inside

or outside of the EU.

4. MARKETING COMMUNICATIONS

Our lawful ground of processing your personal data to send you marketing communications is either your consent or our

legitimate interests (namely to grow our business).

Before we share your personal data with any third party for their own marketing purposes we will get your express consent.

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking

or unchecking relevant boxes to adjust your marketing preferences OR by following the opt-out links on any marketing

message sent to you or] OR by emailing us at info@inclusioninprogress.com at any time.

If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of

other transactions, such as purchases, warranty registrations etc.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below:

● Service providers who provide IT and system administration services.

● Professional advisers including lawyers, bankers, auditors and insurers

● Government bodies that require us to report processing activities.

● Third parties to whom we sell, transfer, or merge parts of our business or our assets.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in

accordance with the law. We only allow such third parties to process your personal data for specified purposes and in

accordance with our instructions.

6. INTERNATIONAL TRANSFERS

We are subject to the provisions of the General Data Protection Regulations that protect your personal data. Where we

transfer your data to third parties outside of the EEA, we will ensure that certain safeguards are in place to ensure a similar

degree of security for your personal data. As such:

● We may transfer your personal data to countries that the European Commission have approved as providing an

adequate level of protection for personal data by; or

● If we use US-based providers that are part of a privacy framework (such as the successor to the EU-US Privacy

Shield), we may transfer data to them, as they have equivalent safeguards in place; or

● Where we use certain service providers who are established outside of the EEA, we may use specific contracts or

codes of conduct or certification mechanisms approved by the European Commission which give personal data the

same protection it has in Europe.

● If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will

have the right to withdraw this consent at any time.

7. DATA SECURITY

We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed,

or accessed without authorisation. We also allow access to your personal data only to those employees and partners who

have a business need to know such data. They will only process your personal data on our instructions and they must keep it

confidential.

8. DATA RETENTION

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the

purposes of satisfying any legal, accounting, or reporting requirements.

When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of

harm from unauthorized use or disclosure, the processing purposes, if these can be achieved by other means and legal

requirements.

For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial

and Transaction Data) for six years after they stop being customers.

In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use

this information indefinitely without further notice to you.

9. YOUR LEGAL RIGHTS

Under data protection laws you have rights in relation to your personal data that include the right to request access,

correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of

processing is consent) to withdraw consent.

If you wish to exercise any of the rights set out above, please email us at info@inclusioninprogress.com.

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 or refuse to comply with your request in these

circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your

personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed

to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your

request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may 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.

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the data

protection authority of the country in which you are based. We would be grateful if you would contact us first if you do have a

complaint so that we can try to resolve it for you.

10. THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those

connections may allow third parties to collect or share data about you. We do not control these third-party websites and are

not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of

every website you visit.

11. 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 this website may become inaccessible or not function properly. For

more information about the cookies we use, please see:

COOKIE POLICY

What’s a cookie?

● A “cookie” is a piece of information that is stored on your computer’s hard drive if you agree to this and which

records how you move your way around a website so that, when you revisit that website, it can present tailored

options based on the information stored about your last visit. Cookies can also be used to analyze traffic and for

advertising and marketing purposes.

● Cookies are used by nearly all websites and do not harm your system.

We are required to obtain your consent for all non-essential cookies used on our website. You can block cookies (including

essential cookies) at any time by activating the setting on your browser that allows you to refuse the setting of all or some

cookies. However, if you use your browser settings to block essential cookies you may not be able to access all or parts of our

site.

How do we use cookies?

● We use cookies to track your use of our website. This enables us to understand how you use the site and track any

patterns with regards to how you are using our website. This helps us to develop and improve our website as well as

products and / or services in response to what you might need or want.

● Cookies are either:

– Session cookies: these are only stored on your computer during your web session and are automatically deleted

when you close your browser – they usually store an anonymous session ID allowing you to browse a website

without having to log in to each page but they do not collect any personal data from your computer; or

– Persistent cookies: a persistent cookie is stored as a file on your computer and it remains there when you close your

web browser. The cookie can be read by the website that created it when you visit that website again. We use

persistent cookies for Google Analytics.

● Cookies can also be categorised as follows:

– Strictly necessary cookies: These cookies are essential to enable you to use the website effectively, such as when

buying a product and / or service. Without these cookies, the services available to you on our website cannot be

provided. These cookies do not gather information about you that could be used for marketing or remembering

where you have been on the internet.

– Performance cookies: These cookies enable us to monitor and improve the performance of our website. For

example, they allow us to count visits, identify traffic sources and see which parts of the site are most popular.

– Functionality cookies: These cookies allow our website to remember choices you make and provide enhanced

features. For instance, we may be able to provide you with news or updates relevant to the services you use. They

may also be used to provide services you have requested such as viewing a video or commenting on a blog. The

information these cookies collect is usually anonymised.

– Targeting cookies: These cookies record your visit to our website, the pages you have visited and the links you have

followed. We will use this information to make our website and the advertising displayed on it more relevant to your

interests.

– First and third party cookies: First party cookies are cookies set by our website. Third party cookies are cookies on

our website that are set by a website other than our website, such as where we have adverts on our website or use

Facebook pixels so that we can show you relevant content from us when you are on Facebook.

We use only first party cookies on this website.

You can alter your cookie preferences at any time by [INSERT YOUR MECHANISM FOR DOING THIS EG BY CLICKING ON

THE COOKIE ICON AND ADJUSTING THE SLIDERS TO ‘OFF’ ]. Please refresh your page to ensure that the new settings

have taken effect.

You can also control your cookie settings through your web browser.

You can opt out of being tracked by Google Analytics across all websites, by going to

http://tools.google.com/dlpage/gaoptout.

Except for essential cookies, all cookies will expire after 90 days.