INCLUDIFI PRIVACY POLICY

This Privacy Policy (“Privacy Policy”) describes how Diversity Abroad, LLC and our subsidiaries and affiliates (collectively, “Diversity Abroad,” “us,” “we,” or “our”) collect, use and share your personal information in connection with our website at includifi.com (the “Site”), the Includifi mobile application (the “App”), the Includifi platform, features, and services, our email communications, and your engagement with our social media platforms (collectively, the “Platform”).

We reserve the right, at any time, to modify this Privacy Policy. If we make revisions that change the way we collect, use, or share personal information, we will post those changes in this Privacy Policy. You should review this Privacy Policy periodically so that you keep up to date on our most current policies and practices. We will note the effective date of the latest version of our Privacy Policy at the end of this Privacy Policy. Your continued use of the Platform following posting of changes constitutes your acceptance of such changes.

COLLECTION OF PERSONAL INFORMATION

• Personal Information You Provide to Us.

  Personal information you may provide to us through the Platform or otherwise includes:
  • Contact details, such as your first and last name, email and mailing addresses, residence, postal code, and phone number.
  • Education information, such as your university, area of study, affiliations, and status (i.e., student, mentor, department lead, etc.).
  • Profile information, such as your username and password that you set to establish an online account with us, any videos, pictures, or other media you upload to your account, demographic information (such as your age, gender, and biographical details), appointments, groups you have joined, your interests and preferences, and information that may be related to a service, account, course, or an event you register for.
  • Your resume/CV and related information that you may provide or submit.
  • Communications, such as messages that you send or receive via the Platform and communications that we exchange, including when you contact us with questions, feedback, or otherwise.
  • Payment and transactional data, such as the information needed to complete your orders and registrations on or through the Platform (including name, credit card information, bank account number, billing and shipping information), and information about services you have purchased from us.
  • Marketing data, such as your preferences for receiving communications about our products, services, activities, events, and publications, and details about how you engage with our communications.
  • Other information that we may collect which is not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

• Personal Information from Other Sources.

  We may obtain personal information from other sources, such as:
  • Universities, institutions, companies, organizations and other entities that sponsor your membership or that you engage with via the Platform.
  • Public sources, such as social media sites.
  • Business partners, such as joint marketing partners and event co-sponsors.

• Personal Information from Third Party Platforms.

  If you connect or otherwise sign into the Platform through a social media or other third party platform, such as Google or Facebook, we may collect information from that platform. You may also have the opportunity to provide us with additional information via the third party platform, such as a list of your friends or connections and your email address. You can read more about your choices in connection with linked third party platforms in the “Your Choices” section, below.

• Personal Information Collected Automatically.

  We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your activity over time on our Platform and other sites and online services, such as:
  • Device data, such as your computer or mobile device operating system type and version number, manufacturer and model, browser type, screen resolution, IP address, unique identifiers, the website you visited before browsing to our website, and general location information such as city, state or geographic area.
  • Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.
  • Geolocation data, which we will collect if you are provided with the opportunity to consent to location tracking in our App.

• Cookies and Similar Technologies.

  Like many online services, we use the following technologies:
  • Cookies, which are text files that websites store on a visitor‘s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising.
  • Flash cookies, or locally-stored objects, which are used on websites for purposes similar to cookies but allow storage of a larger amount of data.
  • Web beacons, also known as pixel tags or clear GIFs, which are typically used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked, typically to compile statistics about usage of websites and the success of marketing campaigns.
  • Software development kits, or SDKs, which are third-party computer codes used in connection with the App for a variety purposes, including to provide analytics regarding the use of the App, integrate with social media, add features or functionality to the App, or facilitate online advertising. SDKs may enable third parties to collect information directly via the App.

• Personal Information About Others

  Users of the Platform may have the opportunity to refer friends or other contacts to us and share their contact information with us. Please do not refer someone to us or share their contact information with us unless you have their permission to do so.

USE OF PERSONAL INFORMATION

Our primary purpose in collecting personal information is to provide the products and services that you request on the Platform. We may use your personal information for various purposes, including the following:

• To Provide Our Products and Platforms.

  For example, we may use your personal information to:
  • provide you with the content, features, products, and services that you request;
  • connect you with other users on the Platform;
  • process your transactions;
  • communicate with you about the Platform (including by sending announcements, updates, security alerts, and support and administrative messages);
  • display your content or share your information on the Platform, including with organizations or other users;
  • understand your interests, personalize your experience on the Platform, and deliver information about products and services relevant to your interests; and
  • respond to your inquiries and requests for customer support, including to investigate and address your concerns and monitor and improve our responses.

• For Research and Development.

  We use personal information to understand and analyze the usage trends and preferences of our users to make our Platform and other offerings better, diagnose technical issues, prevent fraud, and develop new features and functionality. As part of these activities, we may create aggregated, de-identified or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Platform and promote our business.

• To Determine Your Eligibility and Set Up Your Account.

  We use your personal information to determine your eligibility for some of our products, services, and promotions. For example, this may include verifying your name, student email address and university affiliation to confirm that you are eligible for a certain service. If you set up an account on the Platform, we will use the registration information you provide in relation to that account creation to create, maintain, customize, and secure your account.

• For Marketing and Advertising.

  We, our business partners, and our third party advertising partners may collect and use your personal information for direct marketing and interest-based advertising purposes.
  • We may send you Includifi-related or other direct marketing communications as permitted by law. You may opt-out of our marketing communications as described in the “Opt-out of Marketing Communications” section below.
  • We also contract with third-party advertising companies and social media companies to display ads on our Platform and other sites. These companies may use cookies and similar technologies to collect information about you (including the device data and online activity data described above) over time across our Platform and other sites and services or your interaction with our emails, and use that information to serve ads that they think will interest you and/or use hashed customer lists that we share with them to deliver ads to you and to similar users on their platforms. You can learn more about your choices for limiting interest-based advertising, in the “Advertising Choices” section below.

• For Compliance and Protection.

  We may use your personal information to:
  • comply with applicable laws, lawful requests, and legal process (such as to respond to requests from government authorities);
  • maintain the safety, security, and integrity of our Platform, products and services, business, databases and other technology assets;
  • protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
  • audit our internal processes for compliance with legal and contractual requirements and internal policies;
  • enforce the terms and conditions that govern the Platform; and
  • prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

SHARING OF PERSONAL INFORMATION

In addition to the specific situations discussed elsewhere in this Privacy Policy or as otherwise described at the time of collection, we may share your personal information in the following circumstances:

• Related Companies and M&A Transactions. We may share your personal information with companies that are affiliated with us (that is, that control, are controlled by, or are under common control with us). In addition, if we sell all or part of its business or make a sale or transfer of assets or are otherwise involved in a corporate divestiture, merger, consolidation, acquisition, reorganization, sale, spin-off, or other disposition of all or any portion of the business or assets of, or equity interests in, us or our affiliates (including, in connection with a bankruptcy or similar proceedings), we may transfer your personal information to a third party as part of that transaction, including at the negotiation stage.
• Consent. We may ask if you would like us to share your personal information with other unaffiliated third parties who are not described elsewhere in this Privacy Policy, and we may do so with your consent.
• Legal Compliance. We may disclose your personal information to law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate to comply with law or for the compliance, fraud prevention and safety purposes described above.
• Platform Providers. We may share your personal information with third parties who perform services on our behalf that are necessary for the orderly operation of the Platform. Among other things service providers may help us perform website hosting, maintenance services, database management, web analytics, online course hosting, billing, payment processing, fraud protection, marketing, or any other use set out in this Privacy Policy.
• Advertising Partners. We may disclose your personal information to third party advertising companies that collect information about your activity on the Site and other online services to help us advertise our services, and/or use hashed customer lists that we share with them to deliver ads to them and similar users on their platforms.
• Clients and Sponsoring Organizations. We may share limited personal information with the relevant university, institution, company, organization or entity that is a client of Company or that otherwise sponsors your membership on the Platform.
• Includifi Partners. We may share your personal information with third party partners, such as those that have joined our programs, participate in our events, or jointly offer content, promotions and other service offerings with us. If you decide to request, enter into, or participate in an event, promotion, or other product or service offering that is offered by us and identified as a joint effort with a third-party partner or client, the information that you provide may be shared with us and with that identified third party.
• Third Party Platforms. The Platform may offer you the ability to post or share your personal information through a social media platform using such site’s integrated tools (e.g., Facebook “Like” button, or Twitter “Tweet” button). If you register for the Platform using a third party platform like Facebook or Google, we will share your personal information to facilitate the connection. Please note, we do not control the third party’s use of your personal information and you should review the privacy policy of the entities that provide these platforms.
• Other Users and the Public. The Platform may provide you with the opportunity to post or make available content, messages, and other information to other users of the Platform or the public. For example, you may be able to post your content in a newsfeed or public forum on the Platform or choose to be featured in a newsletter or other communication. We do not control how other users or third parties use any personal information that you make available to them. Please be aware that any information you post publicly can be cached, copied, screen captured or stored elsewhere by others (e.g., search engines) before you have a chance to edit or remove it.
• Professional Advisors. We may disclose your personal information to our professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.

SECURITY OF PERSONAL INFORMATION

No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from the risks presented by unauthorized access or acquisition, we cannot guarantee the security of your personal information.

YOUR CHOICES

You can make the following choices with respect to your personal information.

• Access or Update Your Personal Information. If you have registered for an account with us, you may review and update certain account information by logging into your account.
• Opt-out of Marketing Communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us at [email protected]. You may continue to receive service-related and other non-marketing emails.
• Third Party Platforms. If you choose to connect to the Platform through your account on a third party platform (like Google or Facebook), you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third party platform, that choice will not apply to information that we have already received from that third party.
• Cookies. Most browsers let you remove and/or stop accepting cookies from the websites you visit. To do this, follow the instructions in your browser’s settings. Many browsers accept cookies by default until you change your settings. If you do not accept cookies, however, you may not be able to use all functionality of the Platform and our Sites may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org.
  We use Google Analytics to help us understand user activity and patterns on the Site. You can learn more about these cookies at https://developers.google.com/analytics/resources/concepts/gaConceptsCookies how Google protects your data at http://www.google.com/analytics/learn/privacy.html. You can prevent the use of Google Analytics relating to your use of our Site by downloading and installing a browser plugin available at https://tools.google.com/dlpage/gaoptout?hl=en.
• Advertising Choices. Some of our advertising partners are members of the Network Advertising Initiative (NAI) and are subject to the Self-Regulatory Principles for Online Behavioral Advertising published by the Digital Advertising Alliance (DAA). You can obtain more information about these companies’ information collection practices and opt-out of receiving interest-based advertising from participating NAI and DAA members at http://www.networkadvertising.org/managing/opt_out.asp and/or the DAA’s website at optout.aboutads.info. You can also limit collection of your information for interest-based ads by blocking third party cookies in your browser settings or using privacy plug-ins or ad blocking software that help you block third party cookies. In addition, your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for targeted online advertising purposes. If you opt-out of interest-based advertisements, you will still see advertisements online but they may be less relevant to you.
  Some of the third party advertising companies we may work with offer their own opt-out options that you can use to limit their use of your information for interest-based advertising, such as Google (https://adssettings.google.com/authenticated), Facebook (https://www.facebook.com/about/ads), and LinkedIn ( https://www.linkedin.com/help/linkedin/answer/62931/manage-advertising-preferences ). Please note that we also may work with companies that offer their own opt-out mechanisms or do not participate in the opt-out mechanisms described above. Even after using these opt-out mechanisms, you may receive interest-based advertising from other companies.
• Do Not Track Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
• Declining to Provide Information We need to collect personal information to provide certain services. If you do not provide the information requested, we may not be able to provide those services.

INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

We are headquartered in the United States of America. If you are from a country outside of the United States of America with laws governing data collection, use, and disclosure that may differ from U.S. law and you provide personal information to us, please note that any personal information that you provide to us may be transferred to the United States of America. By providing your personal information, where applicable law permits, you hereby specifically and expressly consent to such transfer and processing and the collection, use, and disclosure set forth herein or in any applicable terms of service.

NOTICE FOR CALIFORNIA RESIDENTS

Under California Civil Code sections 1798.83-1798.84, California residents who have an established business relationship with us are entitled to ask us once a year for information regarding the personal information we have shared, if any, with third parties for their direct marketing purposes. If you are a California resident and would like to submit such a request, please submit your request in writing to the email address listed in the section titled “CONTACTING US” below with “Shine the Light” in the subject line. The request must include your name, street address, city, state, and ZIP code and an attestation that you are a California resident. We are not responsible for requests that are not labeled or sent properly, or that do not have complete information.

CONTACTING US

You can contact us via email at [email protected] or by writing to us at the address below: