INCLUDE® PRIVACY POLICY
Effective Date: October 8, 2026
Introduction
This Privacy Policy replaces the Include Software Privacy Policy dated March 29, 2021. Include keeps earlier versions and sends a copy on request to legal@include.com.This Privacy Policy explains how Include Software Corporation ("Include," "we," "us," or "our") collects, uses, discloses, and protects personal information when Include decides why and how that information is processed. It also explains Include's different role when it processes information for a business that subscribes to GO, Include Asset, or another Include service.
Scope and Our Two Roles
This Privacy Policy applies to personal information Include handles for its own business purposes, including information about:  
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* visitors to Include's websites;  
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* contacts at prospective and current subscribers;  
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* people who create or use Include accounts;  
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* people who deal directly with Include for sales, support, implementation, billing, events, or other business purposes; and  
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* job applicants, vendors, and other people who deal directly with Include.

A different rule applies to information that a subscribing business, its Users, or its Clients place in the Services ("Subscriber Data," which the Include Software Terms of Service call "Your Data"). For Subscriber Data, the subscriber decides why the information is processed, and Include processes it on the subscriber's behalf as a service provider or processor. The Terms of Service, including their data processing terms in Section 5.11, govern that processing. If your information is in a subscriber's GO account and you want to exercise a privacy right about it, contact that subscriber, such as your employer or the business you dealt with. Include will help the subscriber as the law and our agreement with the subscriber require.

This Privacy Policy does not cover third-party services that a subscriber or User chooses to connect to Include. The provider's own privacy policy applies to the information it receives.
Personal Information We Collect Include's Own Purposes
Depending on how you deal with Include, we may collect these categories of personal information:  

Identifiers and contact information: Name, business email address, telephone number, mailing address, account identifier, username, and profile information.  

Professional and business information: Employer, company, title, role, business unit, industry, account relationship, and communications about your organization's needs.  

Account and authentication information: Sign-in identifiers, authentication events, device registrations, permissions, and security-related account information. Include staff will never ask you for your password.  

Commercial and billing information: Services purchased, subscription details, invoices, payment status, and limited payment-method information. Full payment card numbers are handled through the payment processor's payment fields, not ordinary GO records.  * Internet, device, and usage information: IP address, browser and device type, operating system, app version, pages and features used, timestamps, referring pages, and crash and diagnostic information.  

Communications and support information: Emails, support requests, chat messages (including messages sent through the chat on our website), call notes, implementation communications, survey responses, and feedback you send to Include.  

Website information: Pages viewed, form submissions, and the technical information our website and chat providers need to deliver them.  

Location information: Approximate location derived from IP address. Precise location that a subscriber's mobile app records for its workforce, such as at clock in and clock out, is Subscriber Data processed for that subscriber.  

Audio, visual, and similar information: Photos, screenshots, recordings, or other media you choose to send Include for support or implementation.  

Sensitive personal information: In limited cases, sign-in credentials, financial-account information, or government identifiers needed for billing or account security. Sensitive information in a subscriber's payroll, workforce, or accounting records is Subscriber Data processed for that subscriber.  

Inferences: Limited inferences about account needs, feature interests, or likely support needs drawn from business dealings. Include does not use Subscriber Data to infer personal characteristics for advertising.

We may also create aggregated or de-identified information that cannot reasonably be associated with an identifiable person. We may use and keep that information for lawful business purposes and will not try to re-identify it, except to test our de-identification process or as the law permits.
Where The Inforamtion Comes From
We collect personal information from:  

* you, when you contact Include, create or use an account, request a demonstration, buy Services, submit a support request, use the chat on our website, attend an event, or otherwise deal with us;  

* the business that gives you access to the Services, such as your employer or another subscriber;  

* your device, browser, and use of Include's websites and applications;  

* third-party services that you or your organization connect or authorize;  

* payment, communications, analytics, monitoring, security, and other service providers that support our operations;  

* referral sources, business partners, and publicly available business sources; and  

* other lawful sources reasonably related to a business relationship with Include.
How We Use Personal Information
Include may use personal information to:  

* provide, administer, secure, support, and troubleshoot accounts and Services;  

* authenticate Users, manage permissions, detect misuse, prevent fraud, and protect Include, its subscribers, and others;  

* perform implementation, data conversion, training, and support work a subscriber requests;  

* process subscriptions, invoices, payments to Include, renewals, and account administration;  

* communicate about security, service changes, billing, support, and other operational matters;  

* answer inquiries and provide demonstrations, proposals, product information, training, and account services;  

* understand how our websites and Services are used, diagnose problems, measure performance, and improve product design and usability;  

* develop and test new features using information we are permitted to use for that purpose;  

* send marketing communications, subject to your choices and the law;  

* comply with law, legal process, contractual obligations, and regulatory requirements;  

* establish, exercise, or defend legal claims; and  

* carry out a merger, financing, acquisition, reorganization, sale of assets, or similar corporate transaction.

We do not sell Subscriber Data, use Subscriber Data for targeted or cross-context behavioral advertising, or use Subscriber Data to train or fine-tune artificial
AI Features
GO includes AI features, including Van, and features that read records or documents, summarize information, draft content, answer questions, and carry out permitted actions at a User's request.

When a User uses an AI feature, Include sends the parts of Subscriber Data reasonably needed for the request to the AI model provider for that feature. Include currently uses commercial AI services from OpenAI and Anthropic. Under their commercial or business terms, inputs and outputs sent through their business interfaces are not used for general model training by default. Those providers may keep request data for limited periods for safety, abuse monitoring, legal compliance, or features that require storage, as their business terms allow.

Include does not use Subscriber Data to train or fine-tune its own or another company's artificial intelligence models unless the subscriber agrees in writing. AI output is returned to the subscriber's account and handled as Subscriber Data under the Terms of Service.

If a User connects an outside AI assistant or another outside tool to GO, information sent to that tool is governed by the subscriber's agreement with that provider, not by this Privacy Policy.
How We Disclose Personal Information
We may disclose personal information to the following kinds of recipients when reasonably necessary for the purposes above:  

* Service providers and Subprocessors. Hosting, database, file storage, mobile sync, communications, mapping, monitoring, product analytics, website, chat, AI, and other providers that perform services for Include. The current Subprocessors for Subscriber Data are listed in Section 24 of the Terms of Service.  

* Your organization. If you use the Services through your employer or another subscriber, its account administrators and authorized Users may see information about your account, role, activity, and Subscriber Data, according to the permissions that organization controls.  

* Third-party services a subscriber selects. If you or your organization connect a payment processor, bank connection, payroll provider, accounting system, outside AI tool, or another integration, Include sends the information that connection needs to the provider at your organization's direction.  

* Professional advisers and business counterparties. Lawyers, accountants, auditors, insurers, financing sources, and potential or actual parties to a corporate transaction, under appropriate confidentiality obligations.  

* Government, legal, and safety recipients. Courts, regulators, law enforcement, or others when we reasonably believe the law or legal process requires it, or it is necessary to protect rights, safety, or security, or to prevent fraud or abuse.  

* With your direction or consent. Other recipients when you or the relevant subscriber directs or authorizes it.

Include does not disclose Subscriber Data to third parties for their own advertising.
Our Websites and The GO Apps
Include's public websites are hosted by our website provider and load fonts from Google; when you visit, those providers receive technical information such as your IP address and browser details so they can deliver the pages. The chat on our website is provided by a chat service provider, which receives the messages you type and the technical information needed to deliver them.

Our website and chat providers may use cookies needed to deliver the site and keep a chat session going; you can block them in your browser. Include does not use advertising, retargeting, or cross-site tracking technologies on its websites, and does not sell personal information or share it for targeted or cross-context behavioral advertising. If that ever changes, we will update this Privacy Policy and provide any choices the law requires before using such technologies.

In the GO web application, Include uses product analytics and monitoring providers, as part of providing the Services to the subscriber, to understand how features are used and to find and fix errors; that information is Subscriber Data. GO's mobile apps use the device's location when a User clocks in or out or takes a photo or capture, and voice dictation may be processed by the device's operating system provider, such as Apple or Google, to turn speech into text. Information the mobile apps collect for a subscriber's workforce is Subscriber Data.
Subscriber Data and Workforce Information
A subscriber may use GO to process information about its employees, applicants, contractors, Clients, vendors, and other people. Depending on the subscriber's use, this can include names, contact information, work records, time and attendance, compensation, payroll and tax information, government identifiers, bank information, precise location, photos, documents, messages, accounting records, signed agreements, and other information the subscriber chooses to place in the Services.

For this information, Include acts on the subscriber's instructions. The subscriber is responsible for deciding whether and how to collect it, for giving the notices the law requires, and for obtaining the permissions the law requires. The Terms of Service impose purpose limits, confidentiality and security obligations, Subprocessor requirements, privacy-rights assistance, deletion requirements, and other service-provider protections on this processing.

If you contact Include directly about Subscriber Data, we may refer you to the subscriber that controls the account so it can verify and act on your request.
Data Retention
Include keeps personal information only as long as reasonably necessary for the purposes it was collected for, to provide the Services, to comply with law, and to establish or defend legal rights. The criteria vary by category:  

Subscriber Data: Governed by Section 6 of the Terms of Service: kept while the subscription is active and for 60 days after it ends, then deleted from live systems, ordinarily within the following 90 days, with backup copies expiring on Include's backup schedule and limited legal exceptions.  

Account, subscription, invoice, and business relationship records: For the relationship and afterward for as long as reasonably needed for tax, accounting, audit, contract enforcement, dispute resolution, and other legal or legitimate business requirements.  

Security, authentication, diagnostic, and technical logs: As long as reasonably needed to operate and secure the Services, investigate incidents, prevent abuse, fix problems, and meet legal requirements.  

Support and implementation communications: As long as reasonably useful to support the account, document work performed, improve support, resolve disputes, and meet legal requirements.  

Marketing information: Until you opt out, the information becomes outdated, or Include no longer needs it for the marketing purpose it was collected for, keeping only the suppression records needed to honor an opt-out.  

Website and chat information: As long as reasonably needed to answer your inquiry, run the website, and keep records of our communications with you.

When information is subject to a legal hold, a regulatory requirement, a security investigation, or an active dispute, Include may keep it longer than usual and will limit its use to that purpose.
Security
Include maintains administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, use, alteration, and disclosure. No security program can eliminate all risk. Subscribers and Users also control important security factors, including account permissions, credentials, devices, exported data, and the third-party services they choose to connect.

Include's obligations for security incidents affecting Subscriber Data are described in Section 5.8 of the Terms of Service.
Your Choices
You can:  

* update certain account information through the Services or through your account administrator;  

* turn device permissions such as location, camera, photos, notifications, or microphone on or off in your device settings, knowing that some features will not work without the permission they need; and  

* unsubscribe from marketing email using the link in the message.

Operational, security, billing, and other service messages may still be sent when needed to administer an account or provide the Services.
United States State Privacy Rights
Depending on where you live and whether a particular state privacy law applies to Include, you may have rights about personal information Include controls, including rights to:  

* confirm whether Include is processing your personal information and get access to it;
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* correct inaccurate personal information;  

* delete personal information, subject to legal exceptions;  

* get a portable copy of certain personal information;  

* opt out of the sale of personal information, sharing for cross-context behavioral advertising, or processing for targeted advertising (Include does none of these);  

* opt out of certain profiling or automated decision-making where the law provides that right;  * limit certain uses of sensitive personal information where the law provides that right; and  

* receive equal service and pricing without unlawful discrimination for exercising a privacy right.

To make a request about information Include controls, email legal@include.com with "Privacy Request" in the subject line. Describe the right you want to exercise and give enough information for us to find the relevant records.

Include may verify a request by asking for information reasonably necessary to match you to the relevant records or account, and will use that information only for verification, security, fraud prevention, and legal compliance.

An authorized agent may make a request where the law allows; we may ask for proof of the agent's authority and, where permitted, verify your identity directly.

If the law gives you a right to appeal our decision on a request, email legal@include.com with "Privacy Appeal" in the subject line and explain the decision you want reviewed.

If your request is about Subscriber Data that Include processes for a subscriber, Include will normally direct it to that subscriber and help the subscriber as the law and our agreement require.
California Disclosures
This section applies to the extent the California Consumer Privacy Act, as amended ("CCPA"), applies to Include's processing of a California resident's personal information.

In the preceding 12 months, Include may have collected the categories of personal information in Section 2 from the sources in Section 3, for the purposes in Section 4, and may have disclosed those categories to the recipients in Section 6 for business purposes.

Include does not sell personal information and does not share it for cross-context behavioral advertising. Include does not knowingly sell or share the personal information of people under 16.

Include uses sensitive personal information only for purposes reasonably necessary to provide requested Services, secure accounts and systems, carry out authorized business functions, comply with law, or other purposes the CCPA allows without a right to limit.

Include does not offer financial incentives, or price or service differences, in exchange for personal information.California residents may exercise the rights in Section 12. If the CCPA requires Include to offer another way to make requests, Include will provide it.
Children
Include's services are not intended for children under 13, and we do not knowingly collect personal information from them. If a subscriber includes information about minors in Subscriber Data, they are responsible for compliance with applicable laws regarding notice and consent.

A subscriber may, where lawful, place information about young workers, dependents, Clients, or other minors in Subscriber Data. Include then processes that information for the subscriber, and the subscriber is responsible for any notice, consent, or other legal requirement that applies to collecting and using it.
Processing In The United States and Other Countries
Include hosts the Services in the United States. Include and its service providers may process personal information in the United States and in other countries where they operate. Privacy laws differ between countries. Where the law requires a particular mechanism or safeguard for an international transfer, Include will use it or cooperate in putting it in place.
Changes To This Privacy Policy
Include may update this Privacy Policy as its Services, practices, service providers, or legal obligations change. We will post the updated version with a new version number and effective date. If a change materially affects how Include uses personal information it has already collected for its own purposes, we will give any additional notice or choice the law requires.

Changes to how Include processes Subscriber Data are also governed by the Terms of Service, including their provisions on changes to the Terms and on Subprocessors.
Contact Include
For privacy questions or requests, email legal@include.com or write to Include Software Corporation, Attention: Legal, 390 NE 191st Street, Suite 8978, Miami, Florida 33179.

Courier deliveries that need a street address go to Include Software Corporation, 300 SW 1st Avenue, Suite 155, Fort Lauderdale, Florida 33301.

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