PRIVACY POLICY

Includ Accessibility Pty Ltd (ABN 73 668 843 052)

Effective Date: 13th February 2026

Includ Accessibility Pty Ltd (“Includ”, “we”, “us”, “our”) respects your privacy and is committed to protecting personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

This Privacy Policy explains how we collect, use, disclose and protect personal information when you interact with us, use our services, or access our platform.

1. Who We Are

Includ Accessibility Pty Ltd

ABN 73 668 843 052

Website: includ.com.au

Email: nigel@includ.com.au

2. What Information We Collect

We may collect personal information that is reasonably necessary to provide our services, including:

Name and job title
Business contact details (email, phone number)
Organisation details
Billing and payment information
Communications with us (emails, support requests)
Platform usage data (for Monitor subscribers)

We do not intentionally collect sensitive information unless required and expressly provided.

3. Information Collected Through Accessibility Services

When delivering services such as Verify, Lived or Monitor, we may collect or process technical information relating to digital assets, including:

Website URLs and structural data
Accessibility testing outputs
Technical metadata required for reporting
Screenshots or issue references where relevant

These materials are collected solely for the purpose of providing accessibility services.

We do not intentionally collect unnecessary personal content from client websites.

4. How We Collect Information

We collect information when you:

Request a Quote or engage our services
Subscribe to Monitor
Contact us directly
Use our website or platform
Provide access for audit purposes

We may also collect limited technical data automatically via cookies and analytics tools.

5. How We Use Personal Information

We may use personal information to:

Provide and deliver services
Process invoices and payments
Manage subscriptions
Communicate about deliverables, support, or service updates
Improve our platform and service quality
Meet legal and regulatory obligations

We do not sell personal information.

6. Disclosure of Personal Information

We may disclose personal information to trusted third parties only where necessary, including:

Cloud hosting and storage providers
Payment processors
Professional advisers (legal, accounting)
Contractors engaged under confidentiality obligations

We require service providers to handle information securely and only for authorised purposes.

7. Overseas Storage and Transfers

Includ may use reputable cloud service providers that store or process data outside Australia.

Where this occurs, we take reasonable steps to ensure appropriate safeguards consistent with the Australian Privacy Principles.

8. Data Security

We take reasonable technical and organisational measures to protect personal information, including:

Secure hosting environments
Encryption in transit (SSL/TLS)
Access controls and authentication
Monitoring and security practices

However, no method of transmission or storage is completely secure.

9. Data Retention

We retain personal information only as long as reasonably necessary to:

Provide services
Meet contractual obligations
Comply with legal requirements
Resolve disputes

Information may be securely deleted or de-identified when no longer required.

10. Access and Correction

You may request access to, or correction of, personal information we hold about you by contacting:

nigel@includ.com.au

We will respond within a reasonable timeframe.

11. Complaints

If you believe we have breached the Australian Privacy Principles, you may contact us at privacy@includ.com.au.

If unresolved, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC).

12. Updates to This Policy

We may update this Privacy Policy from time to time. The latest version will always be published on our website.