Privacy Policy

IncludeAs respects the privacy of all of its users and is committed to protecting such privacy in accordance with this Privacy Policy (“Privacy Policy”). Please note that this Privacy Policy does not apply to the practices of companies or websites which are not owned or controlled by IncludeAs.

1. About:

We are Include As Inc. (“IncludeAs”, “us”, “we” or “our”), a corporation formed pursuant to the Canada Business Corporations Act (R.S.C., 1985, c. C-44) in Canada. IncludeAs is a registered name pursuant to the Business Names Act, R.S.O. 1990, c. B.17.

2. About the Services:

We provide users (“you”, “your” or “User(s)”) with online event services, including but not limited to, invitation creation, event location, management and promotion services delivered via the IncludeAs website (currently located at, the IncludeAs mobile applications (“IncludeAs App”) and/or any other platform or media through which we make such services available from time to time (collectively, the “Services”).

A User may be a “Member” (meaning a User that has registered and created an account with IncludeAs or through one of the connected social networking services (“Social Networking Services”). As a Member, you are enabled to utilize a host of services for your private and public events which are made available to Members through the website and/or IncludeAs App.

A User may be a “Visitor” (meaning a User that is browsing the website and/or viewing content from or affiliated with IncludeAs).

3. About this Privacy Policy:

This Privacy Policy informs you of the policies and practices regarding the collection and use of information you submit to us or which we collect about you through our Services. IncludeAs reserves the right to change this Privacy Policy from time to time. We will inform you of any changes by posting the updated Privacy Policy on the IncludeAs website and/or the IncludeAs App. If you object to any changes, do not continue using the Services. Your continued use of the Services after the changes are communicated as set forth in this section will indicate your consent to our use of your information consistent with this Privacy Policy, including those changes.

4. What Information Does IncludeAs Collect?

In the course of operating the Services, we may collect two types of information: Personal Information and Non-Personal Information:

 (a) “Personal Information” is:

  • information about you that can be used to contact or identify you - such as your first and last name, e-mail address and password;
  • information about your specific and/or general location;
  • any information that you submit on the Services, including information you decide to supply about yourself, your events, photographs and/or videos, guest name(s), attending/not attending events, and your reply to events;
  • any information you submit on the Services regarding any company and its associated information;
  • information about the number of replies you make to public and private events;
  • information you provide when you submit a reply to an event without using your IncludeAs account;
  • any information regarding your distance and/or event preferences;
  • any information relating to your account, and use of the Services;
  • Any information we obtain from Social Networking Services (such as Facebook and Google), although the information we receive may depend on the privacy settings you have with the Social Networking Services;
  • any information relating to your correspondence with us.

 (b) “Non-Personal Information” is is information of an anonymous nature, such as an Internet Protocol Address (“IP Address”), the type and version of browser or operating system being used, your mobile device identifier, the geographic location of the IP address you are using to access the Internet, browser type, operating system (including identifying whether you are connecting via a mobile device), the time of day of your access, your general physical location or your more specific location if you are connecting through your mobile device. Aggregate information, such as demographic statistics of our users (e.g., average age or geographical allocation of our users), number of visitors and average time spent on the Services, is also considered Non-Personal Information.

5. Why We Collect and Use your Information?

Collecting Personal and Non-Personal Information about you is essential to our being able to provide the Services we offer to our Users. Our primary goals in collecting information are to administer and improve your use of the Services, and to deliver content that may be of interest to you. We also collect your Personal Information to establish and maintain responsible commercial relations with you and to meet legal and regulatory requirements.

6. Your Consent to Process Information about You to Others.

By providing Personal and Non-Personal Information to us, you are expressly and voluntarily accepting and agreeing to our collection, processing, sharing, and disclosure of your Personal Information and Non-Personal Information in the ways set out in this Privacy Policy.

You agree and understand that we are not responsible for the actions of Users and third parties who receive your information. It is important that you review the applicable policies of any third parties who receive your information before replying to an event.

7. How Does IncludeAs Use Information?

Your information may be used by us for the following purposes:

(a) Registration.

In order to create an IncludeAs account, you will need to download the IncludeAs App on the App Store or Google Play Store. You will also need to provide us with Personal Information (including your name, email address, and password) and agree to the Terms and Conditions, Contest Rules, and Privacy Policy.

You may also connect to the Services through Social Networking Services. You must also agree to the Terms and Conditions, Contest Rules, and Privacy Policy if you connect to our Services through this method. When you connect through Social Networking Services, we may also obtain certain Personal Information you have provided to the Social Networking Services (such as your name, profile picture, e-mail address). The information we obtain may depend on the privacy settings you have with the Social Networking Services.

(b) To confirm eligibility and enforce compliance with any Terms and Conditions and applicable law.  We may use your Personal Information to verify your contact information and confirm eligibility to access and use the Services. We may also use your Personal Information to enforce our Terms and Conditions, Privacy Policy, and Contest Rules. As such, we may use your Personal Information to pursue available legal remedies to us and to prosecute or defend a court, arbitration or similar proceeding.

(c) Process and administer your Account. When you create an IncludeAs account or connect through Social Networking Services, we will collect Personal Information and Non-Personal Information to process your account in order to provide Services to you, including your use of the IncludeAs website and/or IncludeAs App.

(d) Facilitate the ordinary operation of the Services, including providing your personal, business and geo-location information to other users, third-party service providers and contractors.

(e) Display, share and transfer information - Event Creation.   After you create an IncludeAs account or connect through Social Networking Services, you may choose to provide additional information (including Personal Information) about your event(s). Providing information regarding your event(s) allows you to send and share your event pages with others.

When you enter and/or submit any Personal Information regarding a private event, we will collect and store this information on a URL address, which will be made available to anyone with the URL address associated with your private event page. If your private event contains a gift registry with items selected from Amazon, we will link and/or display the gift registry and any items reported as purchased on your event page.

When you enter and/or submit any Personal Information regarding a public event, we will collect and store this information, which will be made available to some, a subgroup of, or all Users of the Services. In addition, any information regarding your public event will be publicly available to non-Users of the Services. For example, other Users of the Services may share your event on their Social Networking Services, including Twitter, Facebook, Google, and LinkedIn. Anyone with the URL address associated with your event page will have access to the information displayed on your event page.

(f) Display, share, and transfer information - Event Reply.   When you reply to an event, we collect your Personal Information (including first name, last name, e-mail address, and the photograph associated with your Social Networking Service), Going and/or Not Going entry, any guest name(s) you provide, and any information you provide regarding the purchase of gift registry item(s). When you reply to an event, we will share and transfer the following information to the User who created the event:

  • first and last name;
  • profile photograph associated with any Social Networking Services;
  • going and/or not going entry;
  • any additional guest name(s) you provide; and
  • information you enter and/or submit regarding the purchase of gift registry items.

The Services may contain information licensed under the Open Government Licence – Toronto (“Open Government Licence”). Events containing information gathered from the Open Government License will be stored and collected by IncludeAs. IncludeAs will not share Personal Information relating to these events with the City of Toronto. You understand and acknowledge that we DO NOT guarantee and/or verify the accuracy of the information obtained under the Open Government License - Toronto. You also understand and acknowledge that we cannot guarantee that an event purporting to be a City of Toronto event was created by IncludeAs using information from the Open Government Licence.


(g) Share and transfer Information - Social Networking Services.   You may share information about your own public events, and/or public events created by other Users, on your Social Networking Services. You allow us to transfer information you wish to share onto your Social Networking Services.

(h) Display information based on event preferences.   You may enter information in your Settings regarding your event preferences. IncludeAs will collect and use this information to display events that match your preferences in order to enhance your experience with the Services.

(i) Provide and display personalized content.   In some cases, we may use your Personal Information in conjunction with your Non-Personal Information to recommend and deliver personalized content from across the web, including from advertisers. We also combine your Personal Information with Non-Personal Information and Log Data and aggregate it with information collected from other Users to provide you with better recommendations, to improve the quality and performance of our Services and to analyze and understand how our Services are used.

(j) Communicate with you about your account or the Services we offer.   We may from time to time contact you about new features, changes, and enhancements available through the Services.

(k) Provide user support and customer service communication.   We may also use and collect your Personal and Non-Personal Information to respond to your inquiries, comments, concerns and any requests for information, including your use of the Services. We may also retain this information for legal and internal audit purposes.

(l) Use of IP Addresses.  An Internet Protocol (IP) address is a set of numbers that is automatically assigned to your computer whenever you log on to your Internet Service provider, company’s local area network (LAN) or wide area network (WAN). Web servers – the powerful computers that provide Web pages for viewing – automatically identify your computer by the IP address assigned to it during your session online. IncludeAs may collect IP addresses for purposes of system administration, to report anonymous user information to our advertisers (as explained below), and to audit the use of our Services. We can and will use IP addresses to identify users of our Services when we feel it is necessary to enforce compliance with our Terms and Conditions, Privacy Policy, and Contest Rules, or to protect our Service, and/or other Users.

(m) Information collected by advertisers.  We may allow third parties, including our authorized service providers, advertising companies, and ad networks, to display advertisements on the Services. These companies may use tracking technologies, such as cookies or web beacons, to collect information about Users of the Services. This information allows them to deliver targeted advertisements and personalized online experiences and gauge their effectiveness. Some of these third-party advertising companies may be interest-based advertising companies that may use cookies to collect non-personally identifiable information during your use of the Services in order to show advertisements likely to be more interesting to you. To learn more about interest-based advertising or to opt-out of this use of your anonymous information, you can visit the Network Advertising Initiative's opt-out link at

(n) Analyze, Support and/or improve the Services we offer.   Log data is used to monitor and analyze use of the Services, to determine the composition of and engage our user base, to analyze usage patterns, to optimize your access to our Services, and to control the load on our servers so that we can serve you better.

(o) Cookies.  A “cookie” is a small piece of data that is sent to your browser from a web server and stored on your computer’s hard drive. We may use cookies to help us provide customizable services, to allow you to sign-in to our Services, and to track advertising and how our Services are being used. The cookies we pass to you are anonymous. They do not reveal your personal identity nor can they capture private data. Rather, these cookies establish a user session and allow our server to correctly provide Users with the appropriate frames and content. We track the usage in order to modify the Services according to our Users’ needs. We pay attention to what information is requested and attempt to make it easier to find in the future.

(p) provide information to representatives, marketing partners and advisors.  . On occasion, IncludeAs will make available to potential advertisers and research firms aggregated results from research it has conducted on its Services. IncludeAs will only provide such information on an aggregated basis and does not disclose personally identifiable information.

(q) Send or display informational and promotional materials from us, our partners, advertisers or third parties.  . We may use your information to display advertisements on your screen that closely match your interests and preferences.

(r) Google advertising.  We use Google AdSense Advertising on our Services. Google, as a third-party vendor, uses cookies to serve ads on our Services. Google's use of cookies enables it to serve ads on the Services based on previous visits to sites on the Internet. Users may opt-out of the use of cookies by visiting the Google Ad and Content Network privacy policy.

We, along with third-party vendors such as Google, use first-party cookies (such as the Google Analytics cookies) and third-party cookies or other third-party identifiers together to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our Services.

(s) Contests.   We may run contests in which we ask participants for Personal Information, such as their name and e-mail address. If you reply to an event, your contact information will be used to reach you in connection with the contest.

(t) Surveys.   - IncludeAs may from time to time conduct voluntary surveys of its Users to obtain User opinions regarding its Services. Such information may be compiled and shared in the aggregate with other third parties, but no personal details will be traceable or associated with specific individuals.

(u) Service providers.   We may employ third party companies and individuals to facilitate our Services, to provide the Services on our behalf, to perform application and/or site-related services (e.g., without limitation, maintenance services, database management, web analytics and improvement of the Services) or to assist us in analyzing how our Services are used. These third parties have access to your Personal Information to perform these tasks on our behalf. You understand and agree that these third party companies may include companies outside of Canada, United States, and European Union.

(v) Business transfers.   We may disclose and transfer your Personal and Non- Personal Information in connection with a corporate reorganization, merger, amalgamation with another entity, or a sale of all or a substantial portion of the assets of IncludeAs.

(w) Internal, external and regulatory audit purposes.   We may conduct our own internal audits in order to ensure compliance with our own practices and procedures. This may involve the usage and disclosure of your Personal and Non-Personal Information. We may also be required to disclose your Personal and Non-Personal Information where we are subject to external and regulatory audits.

(x) Compliance with law and law enforcement.   . In certain special cases, we may disclose your Personal Information when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against you, someone who may be causing injury to you, or otherwise injuring or interfering with IncludeAs’ rights, property or operations, other Users, or anyone else who could be harmed by such activities. We may also disclose your Personal Information when we believe the law requires it, or in response to any demand by law enforcement authorities in connection with a criminal investigation, or civil or administrative authorities in connection with a pending civil case or administrative investigation.

8. Does Third-Party Content, Links to Third-Party Websites, and/or Third-Party Apps appear on the Services?

When you are on the Services, you may be directed to other websites and applications that are operated and controlled by third parties. We are not responsible for the data collection and privacy practices employed by any of these third parties or their websites or apps. These third parties may have their own terms of service, privacy policies or other policies. For example, if you “click” on a link, the “click” may take you off the Services onto a different location. These other online services may independently collect information about you, including Personal Information, and may or may not have their own published privacy policies. We are not responsible for these third-party privacy policies. Be sure to review any available policies before submitting any Personally Information to a third-party application or otherwise interacting with it and exercise caution in connection with these applications.

9. How Long Will IncludeAs Retain Information?

Unless there is a specific legal or regulatory requirement for us to keep information, we will retain it for no longer than is reasonably necessary for the purposes for which the data was collected or for which it is to be further processed.

10. Where Will Information Be Collected And Stored?

(a) Information we collect may be transferred to, and stored in, servers located in Canada or those of third parties that act on our behalf (such as hosting providers) in Canada, United States, European Union, or other countries. You agree to the collection, transfer, and storage of information outside of Canada, United States, the European Union, or other countries. You understand and agree that, in some circumstances, Personal Information collected by IncludeAs may be subject to disclosure in accordance with the laws applicable in the jurisdiction in which the information is processed or stored. These laws may not provide the same level of protection for such information as will Canadian laws.

(b) Information we collect that is in paper form will be stored and kept at our corporate location.

11. How Secure Is The Information?

You should be aware that while we take reasonable measures to maintain the security of your Personal and Non-Personal Information, we are not able to fully eliminate all security risks or potential breaches. We do not ensure or warrant the security of any data or information you transmit to us, and you do so at your own risk.

12. Questions, Comments or Suggestions

If you have questions, comments or suggestions about this Privacy Policy, please contact us by email or postal mail as follows:

  • Include As Inc.
  • 11 Rogers Road
  • Toronto, Ontario
  • M6E 1N5

Attention: Privacy Officer