Privacy Policy

INCLUDE® PRIVACY POLICY

Effective Date: March 29, 2021

Include® Software Corporation (“Include”) collects information about you when you use our mobile applications, web applications, desktop applications, team services, and all other products and services (collectively, the “Services”) and through all other interactions and communications you have with us.

Scope and Application

This Privacy Statement (“Statement") applies to persons who use the Services.

Collection of Information

Information You Provide to Us

We collect information you provide directly to us via any application or communication, or in any other manner. This information may include name, email, phone number, postal address, profile picture, payment method, items requested, notes, and all other information that is provided.

Information We Collect Through Your Use of the services

When you use the Services, we may collect information about you in the following general categories:

• Location: When you use the Services that are location enabled, we collect precise location data. If you permit our apps to access location services through the permission system used by your mobile operating system (“platform”), we may also collect the precise location of your device when the app is running in the foreground or background. We may also derive your approximate location from your IP address.

• Contacts: If you permit the Services to access the address book on any device by any means, we may access and store names and contact information from any available address book to facilitate social interactions through the Services and for other purposes described in this Statement or at the time of consent or collection.

• Transactions: We collect transaction details related to your use of the Services, including date and time, service type, and other transaction details.

• Usage and Preferences: We collect information about how you and site visitors interact with the Services, preferences expressed, and settings chosen. In some cases we do this through the use of cookies, pixel tags, and similar technologies that create and maintain unique identifiers.

• Devices: We may collect information about your mobile device, including, for example, the hardware model, operating system and version, software and file names and versions, preferred language, unique device identifier, serial number, device motion information, and mobile network information.

• Call and SMS Data: The services may facilitate communications between Users and other parties. In connection with facilitating this capability, we receive call data, including the date and time of the call or SMS message, phone numbers, and the content of the SMS message.

• Logs: When you interact with the Services, we may collect log data, which may include information like device IP address, access dates and times, app features or pages viewed, app crashes and other system activity, type of browser, and the third-party site or service you were using before interacting with the Services.

Important Information About Platform Permissions

Most mobile platforms (iOS, Android, etc.) have defined certain types of device data that apps cannot access without your consent. These platforms have different permission systems for obtaining your consent. We work within the privacy guidelines required by these platforms, respectively.

Information We Collect From Other Sources

We may also receive information from other sources and combine that with information we collect through the Services. For example:

• If you choose to link, create, or log in to any of the Services with any 3rd party provider, e.g. Google, Facebook, etc., or if you engage with a separate app or website that uses our API (or whose API we use), we may receive information about you or your connections from that site or app.

• If your employer uses the Services, we may receive information about you from your employer.

• We retain rating and performance information you provide to us or about us with 3rd party services we partner with or monitor.

Use of Information

We may use the information we collect about you to:

• Provide, maintain, and improve the Services, including, for example, to facilitate payments, send receipts, provide products and services you request (and send related information), develop new features, and send product updates and administrative messages.

• Perform internal operations, including, for example, to prevent fraud and abuse of the Services, to troubleshoot software bugs and operational problems, to conduct data analysis, testing, and research, and to monitor and analyze usage and activity trends.

• Send you communications we think will be of interest to you, including information about products, services, promotions, news, and events of Include and other companies, where permissible and according to local applicable laws.

• Personalize and improve the Services, including to provide or recommend features, content, social connections, referrals, and advertisements.

We may transfer the information described in this Statement to, and process and store it in, the United States and other countries, some of which may have less protective data protection laws than the region in which you reside. Where this is the case, we will take appropriate measures to protect your personal information in accordance with this Statement.

Sharing of Information

We may share the information we collect about you as described in this Statement or as described at the time of collection or sharing, including as follows:

Through the services

We may share your information:

• With third parties to provide you a service you requested through a partnership or promotional offering made by a third party or us.

• With the general public if you submit content in a public forum, such as blog comments, social media posts, or other features of the services that are viewable by the general public.

• With third parties with whom you choose to let us share information, for example other apps or websites that integrate with our API or Services, or those with an API or Service with which we integrate.

• With your employer (or similar entity) and any necessary third parties engaged by us or your employer (e.g., an expense management service provider), if you or your employer uses any of the Services.

Other Important Sharing

We may share your information:

• With Include subsidiaries, partners, and affiliated entities that provide services or conduct data processing on our behalf, or for data centralization and/or logistics purposes.

• With vendors, consultants, marketing partners, and other service providers who need access to such information to carry out work on our behalf.

• In response to a request for information by a competent authority if we believe disclosure is in accordance with, or is otherwise required by, any applicable law, regulation, or legal process.

• With law enforcement officials, government authorities, or other third parties if we believe your actions are inconsistent with our User agreements, Terms of Service, or policies, or to protect the rights, property, or safety of Include or others.

• In connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company.

• If we otherwise notify you and you consent to the sharing.

• In an aggregated and/or anonymized form which cannot reasonably be used to identify you.

Social Sharing Features

The Services may integrate with social sharing features and other related tools which let you share actions you take on the services with other apps, sites, or media, and vice versa. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the social sharing service. Please refer to the privacy policies of those social sharing services for more information about how they handle the data you provide to or share through them.

Analytics and Advertising Services Provided by Others

We may allow others to provide audience measurement and analytics services for us, to serve advertisements on our behalf across the Internet, and to track and report on the performance of those advertisements. These entities may use cookies, web beacons, SDKs, and other technologies to identify your device when you visit our site and use the Services, as well as when you visit other online sites and services.

Your Choices

Account Information

When we keep account information, you or your employer may correct account information at any time by either logging into your online or in-app account, or by contacting us at team@include.com with account change information. Please note that in some cases we may retain certain information about you as required by law, or for legitimate business purposes to the extent permitted by law. For instance, if you have a standing credit or debt on your account, or if we believe you have committed fraud or violated our Terms, we may seek to resolve the issue before deleting your information.

Access Rights

Include will comply with an individual’s requests regarding access, correction, and/or deletion of the personal data it stores in accordance with applicable law.

Location Information

We request permission for our app’s collection of precise location from your device per the permission system used by your mobile operating system. If you initially permit the collection of this information, you can later disable it by changing the location settings on your mobile device. However, this will limit your ability to use certain features of the Services.

Contact Information

We may also seek permission for our app’s collection and syncing of contact information from your device per the permission system used by your mobile operating system. If you initially permit the collection of this information, iOS users can later disable it by changing the contacts settings on your mobile device. The Android platform does not provide such a setting.

Promotional Communications

You may opt out of receiving promotional messages from us by following the instructions in those messages. If you opt out, we may still send you non-promotional communications, such as those about your account, about Services you have requested, or our ongoing business relations.

Your California Privacy Rights

California law permits residents of California to request certain details about how their information is shared with third parties for direct marketing purposes. Include does not share your personally identifiable information with third parties for the third parties’ direct marketing purposes unless you provide us with consent to do so.

Changes to the Statement

We may change this Statement from time to time. We encourage you to periodically review the Statement for the latest information on our privacy practices.

Contact Us

If you have any questions about this Privacy Statement, please send your questions by email to team@include.com, or by US Postal Mail to Include Software Corporation, Attn: Legal,1906 Towne Centre Blvd Ste 280, Annapolis, MD 21401.