Privacy Policy

Effective November 13, 2019

The Sites (defined below) are owned by Liberty Mutual Insurance Company (“Liberty Mutual”) and operated by SunShower Learning (“SunShower”) (collectively “the Parties”). Liberty Mutual and SunShower understand that you care about how the information we receive from you or about you (“Personal Information”)is used and shared. We take your privacy seriously. This  the Parties Privacy Policy provides information on how the Parties collect, use, share and process Personal Information Personal Information in connection with your use of Inclusion in Action’s digital platforms including (the Site), Inclusion in Action’s mobile platform (the Mobile Site) (collectively the Sites), and the the Parties Application (the App). This Privacy Policy also provides information on your Personal Information Personal Information access rights where applicable. The Parties may update this Privacy Policy from time to time to comply with legal and regulatory requirements or to address changes to the Parties’ business operations.

Marketing & Communications Services
Information Collected as a Data Controller

The Parties may collect the following Personal Information, through Inclusion in Action’s Sites, for marketing and communications purposes. This Personal Information can be used to directly or indirectly identify you:

• Your name

• Your business email address

• Your IP address

• Your image

• Your photograph

• Video recording of you and your surroundings

• Audio recording of you and your surroundings

• Inferences drawn from your Personal Information

• Professional or employment related data

• The level of Personal Information collected by the Parties varies depending upon your request. the Parties may collect your business email address only or the Parties may collect both your name and business email address.

The Parties may also collect Personal Information that cannot be used to identify you including anonymous usage data and platform data for analytical purposes.

Your Personal Information will be maintained and stored by the Parties provided you consent to the Parties processing your Personal Information for business purposes, including where you request an the Parties demo, subscribe to the the Parties blog, and/or subscribe to marketing and communications emails (the Marketing and Communications Services). You may unsubscribe from the Marketing and Communications Services emails at any time. Where you have the right to request access to your Personal Information, in accordance with applicable data protection laws (Personal Information Protection Laws), and where you request deletion of your Personal Information, the Parties will delete your Personal Information unless otherwise prohibited by law or regulation.

Your Personal Information may be transferred outside your country of residence and if so, it will be transferred using a valid transfer mechanism; providing an adequate level of protection to any Personal Information transferred. Your Personal Information will be subject to the privacy and security rules and regulations of the Personal Information hosting country and which laws and regulations may not be as strict as your country of residence.

Inclusion in Action will implement appropriate systems’ security measures designed to help ensure the confidentiality and security of Personal Information and protect against anticipated threats and unauthorized access to Personal Information. For additional information on Inclusion in Action’s security practices please see the Personal Information Security section of this Privacy Policy.

User Access Rights
Under federal and state privacy regulations, you may have certain statutory rights in relation to your personal data. The parties do not discriminate against any persons because they choose to exercise such rights.

You may have the right to request access to your Personal Information where your Personal Information is controlled by the Parties as the Personal Information Controllers.

You may have the right to request that your Personal Information controlled by the Parties be corrected.

You may have the right to request that your Personal Information controlled by the Parties be deleted from Inclusion in Action’s systems. This process is also referred to as the ‘right to be forgotten’. the Parties will comply with this request except where the Parties is required by law or regulation to keep your Personal Information. In such circumstances the Parties will advise you as to this legal or regulatory obligation.

Where the Parties relies on your consent, to process your Personal Information controlled by the Parties, you may have the right to withdraw such consent to further use of your Personal Information.

In certain circumstances, you may have the right to object to the Parties processing your Personal Information. For example, you may unsubscribe from marketing messages or blogs to which you consented and subscribed.

In certain circumstances, you may have the right to request that the Parties transfer Personal Information that you have provided to us to a third party.

You may have the right to file a complaint with the local Personal Information Protection Regulator if you believe that the Parties has breached Personal Information Protection Laws when using your Personal Information.

You may request access to Personal Information collected and controlled by the Parties by sending an email to

Cookies and Web Beacons

Cookies are small text files that can be used by the Parties to make your experience more efficient. Cookies used on a the Parties digital platform are related to managing your identity and personalization; and can help the Parties remember information about your visit. Certain cookies can make your next visit more efficient and useful to you. The law provides that the Parties may store cookies on your device if such cookies are strictly necessary for the operation of Inclusion in Action’s Sites. For all other types of cookies the Parties needs your consent. the Parties obtains this consent when you access Inclusion in Action’s Sites and where the Parties provides you with an opportunity to opt-out of cookies. You may exercise your cookies preference by clicking on the appropriate opt-out links provided. The Parties uses cookies as outlined below.

Necessary Cookies

Necessary cookies help make Inclusion in Action’s Sites usable by enabling basic functions like page navigation and access to secure areas of the Sites. Inclusion in Action’s Sites cannot function properly without these necessary cookies.

Inclusion in Action uses the following necessary cookies on its Sites:

• Cookies to store the user’s cookie consent state for the current domain.

• Cookies used by the content network, Cloudflare, to identify trusted web traffic.

• Preference Cookies

Preference cookies enable a website to remember information that changes the way the website looks.

At this time, the Parties are not using any “preference” cookies on its Sites.

Statistic Cookies

Statistic cookies assist the Parties in understanding how users interact on digital platforms by collecting and reporting information anonymously.

Inclusion in Action uses Google Tag Manager and Google Analytics to:

• Collect data on the number of times a user has visited its Sites as well as dates for the first and most recent visit.

• Register a timestamp with the exact time of when the user leaves a Site.

• Calculate the duration of a Site visit.

• Throttle the speed of request to the server

• Collect data on where the user came from, what search engine was used, what link was clicked and what search term was used.

Marketing Cookies

Marketing cookies are used to track users across Inclusion in Action’s Sites. The intention is to display content or ads that are relevant and engaging for the user and thereby more valuable for publishers and third-party advertisers.

Inclusion in Action uses marketing cookies from the following sources:

• Google Tag Manager

• Google Analytics

• HubSpot

These marketing cookies are used to:

• Collect anonymous statistical data related to the user’s visits, such as the number of visits, average time spent visiting a website, and what pages have been loaded.

How to Remove Cookie Tracking

You have a choice whether to accept cookies, however, if you reject cookies or if cookies are disabled on your web browser, some parts of Inclusion in Action’s Sites may not be operable.

You can exercise your cookie preferences by clicking on the appropriate opt-out links provided. You can also manage cookie settings from within your browser. For your convenience information from the browsers on how to manage cookies from your desktop is provided below:

• Chrome

• Internet Explorer

• Firefox

• Safari

And if you want to manage cookies from your mobile device:

• Apple

• Android

• Blackberry

• Windows Phone

For additional information and/or specific questions related to Inclusion in Action’s cookies policy please contact:

Data Security

The Parties hold the confidentiality, integrity, and availability of your Personal Information in the highest regard and has implemented the following security measures as part of its program to protect Personal Information it controls. All Personal Information stored in the the Parties platform is encrypted at rest using Advanced Encryption Standard (“AES”) 256-bit encryption. the Parties uses Transport Layer Security (“TLS”) v1.2 to create secure connections for data in transit. the Parties utilizes a least privilege model, separation of duties, and unique IDs in provisioning access to systems and data. the Parties conducts background checks on employees, through its parent company Liberty Mutual Insurance Company. the Parties utilizes web application firewalls and DDoS protection services, employs secure coding practices based on industry best practice, and performs vulnerability scans and application penetration tests on its environment as part of its risk management process.

Notification of Changes

The Parties reserve the right to change this Privacy Policy from time to time, and such changes will be effective immediately upon posting to the Sites.  the Parties may also elect to notify you of changes or updates to the Privacy Policy, or to request your consent for such changes, by additional means, such as posting a notice on the front of Inclusion in Action’s Site, and/or by sending you an e-mail.

Contact Information

If you have questions regarding this Privacy Policy, you may contact:

Last modified on: November 13, 2019