Inclusion Labs respects your privacy and is committed to protecting your Personal Data (as defined below).

This Privacy Policy sets out how INCLUSION LABS LTD, company number 13961695, (“we”, “our”, “us”, “the Company”) will look after your Personal Data when you visit our website (regardless of where you visit it from) or participate in our surveys and tell you about your privacy rights and how the law protects you.

We are the controller and responsible for your Personal Data. This means that we are responsible for deciding how we collect, store and use personal information about you.

If you have any questions about this Privacy Policy, please contact us at: [email protected]

The data we collect about you

Personal Data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together as follows:

• Identity Data includes your first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes your address, email address and telephone numbers.
• Technical Data includes your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Profile Data includes your feedback and survey responses.
• Usage Data includes information about how you use our website.
• Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

Specific types of Personal Data we process includes:

• Name of the School, Institution or Business/Brand that you are representing.
• Website of the School, Institution or Business/Brand that you are representing.
• Your role at the School, Institution, Family or Business/Brand that you are representing.
• Whether or not you are over 18 years of age.
• Your sex.

As part of our surveys, we collect, store and use details about your racial or ethnic origin, sexual orientation, sex, gender identity, religion or belief, socio-economic status and disability to help with understanding the views of people from different backgrounds. These details are considered more sensitive or a “special category” of personal information.

How is your Personal Data collected?

We use different methods to collect data from and about you including through:

• Direct interactions (you may give us your Identity and Contact information by filling in forms or by corresponding with us by phone, email or otherwise).

This includes Personal Data you provide when you:

• request information from us about our services; or
• give us some feedback.

• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies, server logs and other similar technologies. 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 function properly. Further information about how we use cookies can be found in our cookie policy which can be found on our website.

• Third parties or publicly available sources. We may receive Personal Data about you from various third parties, such as Technical Data from analytics providers like Google based outside the EU.

When you take part in our surveys, we will collect your responses to the different questions in the survey. The questions in the survey will depend on the survey that you are participating in and we will only collect the personal information that is relevant to the type of survey we are carrying out for your school. We will also collect personal information to help us understand more about your background such as your gender and ethnicity. This is to help us understand the different views of people from different backgrounds.

We will not collect your name or contact details and will work directly with your school to provide you with a link to the survey.

How and why we use your Personal Data

We will use the information you have given in the survey to review your opinion on different topics; provide market research; provide feedback to your school on the views of its school community; create a report of responses to provide to your school; publish aggregated findings and statistics to raise awareness on the topic.

We will also use the information to measure our company’s impact on addressing issues raised.

Under data protection law, we must have a legal basis to use your personal information. We will collect, store and use the personal information that you give to us when you participate in our surveys on the legal basis that it is in our legitimate interests as a business to provide insights on the survey topics. We have considered our legitimate interests carefully and have balanced our legitimate interests against your rights under data protection law. We consider that this use is proportionate because it is relevant and appropriate to our relationship with you, it is in your reasonable expectations that we would use your responses in this way and any results are aggregated.

In summary, 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 we need to perform the contract, we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Our legal basis for this use is that it is necessary for reasons of substantial public interests. Our surveys are designed to assist your school to address any concerns in relation to equality and opportunity of treatment as well as addressing cultural diversity.

We do not use your personal information to make any decisions that will have a legal or significant impact on you based solely on automated decision making (i.e., without any human involvement).

All responses to questions are kept anonymous

When we provide the feedback and the report to your school all the responses will be combined together, and the information will be limited to make sure that you cannot be identified.

Disclosures of your Personal Data

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 will not share your personal information with a third party for them to market to you.

In order to process some of our data (e.g., to turn it into information to include in reports), we may have to share your Personal Data with a third party or parties (for example our data analysts or data specialists, system administration services, service providers who provide handling services), including:

• IT Suppliers. IT Suppliers that support our IT systems may access your personal information to the extent that they need to in order to provide their services and deal with any issues.

• Legal and/or Regulatory Institutions. We will share your personal information with entities, companies or individuals where this is necessary to comply with any law, rule, regulation, legal procedure.

• Professional Advisors. We may also share your personal information with our professional advisors (including lawyers, insurers and/or insurance brokers) to take advice e.g. in connection with any complaint or claim which you (or your school) make and to complete yours (or your school) purchase.

We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.

International transfers

We store your personal information in the United Kingdom or in countries within the EEA. European Economic Area (“EEA”) countries are all EU Member countries together with Iceland, Liechtenstein and Norway. We may transfer your Personal Data outside the European Economic Area (EEA) if you are based outside the EEA.

Data retention and security

We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We may keep details of aggregated findings and statistics to track changes over time.

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 requirements.

In some circumstances, you can ask us to delete your data.

In some circumstances, and as part of our surveys, 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 have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know.

Your rights

You also have a number of other rights over your personal information, which are:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. 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 to access your Personal Data is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, 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.

• 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.

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 and keep you updated.

Please contact us at [email protected] if you have any enquires about these rights or if you wish to exercise these rights in respect of the Personal Data we hold.

You 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 will keep our privacy notice under regular review. Any changes we make to our privacy notice in the future will be posted on our website page.