INCLUD3D Privacy Policy

Last updated: 8/10/2026

1. Who We Are

Included 3D Education Ltd (INCLUD3D) is a limited company registered in England & Wales with the company number 17242101. We deliver relationships, personal and health education for adults with learning disabilities through unique 3D learning tools, workshops and training for organisations.

For the purposes of UK data protection law, INCLUD3D is the data controller in respect of personal data processed about you as a client, prospect, member, or website visitor.

Contact: sarah@includ3d.com | includ3d.com

2. What Personal Data We Collect and Why

2.1 Client & Contact Information

We collect the following when you enquire about or use our services:

  • Name, email address, and telephone number

  • Business name and relevant business information including job title and location

  • Invoicing and payment details where applicable

  • Communications between us (emails, messages, meeting notes)

We collect this information to deliver our services, manage your account, issue invoices, and communicate with you. The lawful basis is performance of a contract and, where applicable, legitimate interests.

2.2 Mailing List & Newsletter Subscribers

When you subscribe to our mailing list or newsletter via Squarespace, we collect:

  • Name and email address

  • Email engagement data (opens, clicks) as tracked by Squarespace

We collect this information to send you marketing emails, updates, and newsletters. The lawful basis is consent. You can unsubscribe at any time via the link in any email, or by contacting us directly at sarah@includ3d.com

2.3 Website & Online Activity

When you visit includ3d.com we may collect:

  • IP address, browser type, operating system and device identifiers

  • Pages visited, time on site and referral sources

  • Form submissions and enquiry content

The tools we use are Squarespace (website and CRM) and Gmail (replies to website enquiry forms).

We collect this information to understand how our website is used and improve it and to respond to enquiries. The lawful basis is legitimate interests. Where cookies requiring consent are used, we will ask for your consent first.

2.4 Social Media

If you contact us via social media (Instagram, Facebook, LinkedIn), we will receive your public profile information and the content of your message. This data is also subject to the privacy policies of the relevant platforms.

2.4 Data We Do Not Collect

We do not collect or process:

  • Special category (sensitive) data such as racial or ethnic origin, religious beliefs, health information, sexual orientation, political opinions, biometric or genetic data

  • Criminal conviction or offence data

  • Personal data from anyone under the age of 18. If we become aware we have inadvertently collected data from a minor, it will be deleted immediately.

3. How We Use Your Data

We use your personal data only for the purposes for which it was collected, or for compatible purposes. These include:

  • Delivering and managing the services you have engaged us for

  • Sending invoices and managing payments

  • Communicating with you about your workshop, training, consultancy or product purchase

  • Sending marketing or newsletter communications where you have opted in (you can opt out at any time)

  • Improving our website and service offering

  • Complying with legal obligations, including supplying information to government agencies (e.g. HMRC, Police) when lawfully required

4. Our Lawful Bases for Processing

Under UK GDPR, we rely on the following lawful bases:

  • Contract: processing necessary to perform a contract with you or take steps at your request before entering into a contract

  • Legal obligation: processing necessary to comply with a legal obligation

  • Legitimate interests: processing necessary for our legitimate business interests, such as website analytics, responding to enquiries and keeping records, where these interests are not overridden by your rights

  • Consent: where we ask for, and you have given explicit consent, such as for email marketing. You can withdraw consent at any time by contacting us at sarah@includ3d.com

5. How We Store and Protect Your Data

We store your personal data using:

  • Secure, domain-specific emails (sarah@includ3d.com)

  • Google Workspace including Gmail and Google Drive (GDPR-compliant)

  • Squarespace – our website platform and CRM

We take appropriate technical and organisational measures to protect your data against unauthorised access, loss, or disclosure. Access to your data is limited to directors and employees of INCLUD3D only, and subcontractors who have signed a confidentiality and data protection agreement. We do not share your personal data with third parties for marketing purposes.

6. How Long We Keep Your Data

We retain personal data only for as long as necessary for the purpose it was collected, and in line with any legal retention requirements. As a guide:

  • Client contact and data required for service delivery: retained for the duration of the working relationship and up to 6 years afterwards (in line with HMRC requirements for financial records)

  • Invoicing and financial data: 6 years from the end of the relevant tax year

  • Marketing data (opted-in contacts): until you unsubscribe or ask us to delete your data

  • Website analytics: as set by the analytics provider (Squarespace and Google)

We regularly review the data we hold and securely delete anything that is no longer needed.

7. International Data Transfers

Some of the tools we use (such as Google and Squarespace) may transfer data outside of the UK. Where this occurs, we ensure that appropriate safeguards are in place in accordance with UK GDPR requirements, such as standard contractual clauses or transfers to countries with an adequacy decision.

8. Your Rights

Under UK GDPR, you have the following rights regarding your personal data:

  • Right of access: to request a copy of the personal data we hold about you (a Subject Access Request)

  • Right to rectification: to ask us to correct inaccurate or incomplete data

  • Right to erasure: to ask us to delete your data where it is no longer necessary, or where you withdraw consent

  • Right to restriction: to ask us to limit processing of your data in certain circumstances

  • Right to data portability: to receive your data in a structured, machine-readable format where processing is based on consent or contract

  • Right to object: to object to processing based on legitimate interests or for direct marketing purposes

  • Rights related to automated decision-making: to not be subject to solely automated decisions that significantly affect you, unless you have consented or it is necessary for a contract

To exercise any of these rights, please contact us using the details in Section 11 below.

9. Cookies

Our website (includ3d.com) uses cookies to improve your browsing experience and understand how visitors use the site. Under the updated rules introduced by the Data (Use and Access) Act 2025:

  • Strictly necessary cookies (files which are essential for a website to function or provide a service explicitly requested by the user) are used without requiring your consent

  • Analytics cookies that are used only for statistical purposes may be placed without consent, provided you are given a clear opt-out option

  • Any other non-essential cookies will require your prior consent

You can manage or disable cookies through your browser settings at any time. Please note that disabling some cookies may affect the functionality of the website.

10. How to Make a Data Protection Complaint

Under the Data (Use and Access) Act 2025, you have a legal right to raise a data protection complaint directly with us before escalating to the ICO. We take all complaints seriously and will handle them promptly and fairly.

10.1 How to Complain to Us

If you believe we have not handled your personal data in accordance with UK data protection law, please contact us:

You can raise a complaint by any means; we will accept it regardless of the channel. Please include:

  • Your name and contact details

  • A description of your concern and the data involved

  • What outcome you are seeking

10.2 Our Complaints Process

Once we receive your complaint, we will:

  • Acknowledge it within 30 calendar days of receipt (including weekends and bank holidays)

  • Investigate the matter thoroughly and fairly

  • Keep you updated on progress if the investigation takes longer than expected

  • Provide you with a written outcome and explain our decision

  • Tell you what steps we have taken (or will take) to address the issue

10.3 Escalating to the ICO

If you are not satisfied with our response, or if you prefer to go directly to the regulator, you have the right to complain to the Information Commissioner’s Office (ICO):

  • Website: ico.org.uk/make-a-complaint

  • Phone: 0303 123 1113

  • Post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in the law, our services, or the way we process data. When we make significant changes, we will post a notice on our website homepage and notify existing clients and subscribers by email. The date at the top of this policy shows when it was last updated.

12. Contact Us

For any questions about this Privacy Policy, to exercise your data rights, or to raise a complaint, please get in touch:

This policy complies with the UK General Data Protection Regulation, the Data Protection Act 2018, and the Data (Use and Access) Act 2025.