Privacy Policy

Last updated: 24 September 2026

Inclusive Hospitality Co and Inclusive Hospitality Company respect your privacy and are committed to protecting your personal information.

Inclusive Hospitality Co and Inclusive Hospitality Company are trading names of Elaine Hughes Consultancy Ltd, registered in England and Wales, Company No. 13411137, ICO Registration No. ZB675460.

In this Privacy Policy, “we”, “us” and “our” refer to Elaine Hughes Consultancy Ltd.

This Privacy Policy explains what personal information we collect, how we use it, who we may share it with, how long we keep it and the rights you have in relation to your information.

1. Information we may collect

We may collect personal information when you:

  • contact us through our website

  • complete an enquiry or contact form

  • book a call, consultation or meeting

  • complete the Venue Inclusion Score, questionnaire or another assessment

  • use one of our digital tools

  • work with us as a client

  • purchase or pay for a service

  • sign up to receive emails or other communications

  • attend a workshop, training session, Content Day or other event

  • contact us by email, LinkedIn or another business channel

This may include your:

  • name

  • email address

  • telephone number

  • job title

  • business or organisation name

  • website address

  • information about your venue, business or organisation

  • information you choose to provide in an enquiry, assessment or questionnaire

  • booking and appointment information

  • correspondence with us

  • invoice, payment and transaction information

  • marketing preferences

  • technical information relating to your use of our website or digital services

Please avoid providing health information or other sensitive personal information unless it is genuinely necessary for your enquiry or for us to deliver an agreed service.

Where special category information is required, such as information about health or disability, we will only process it where there is an appropriate lawful basis and an additional condition for processing under applicable data protection law. ICO guidance confirms that special category data requires both an Article 6 lawful basis and a separate Article 9 condition.

2. How we use your information

We may use your personal information to:

  • respond to enquiries

  • assess whether our services are suitable for your business

  • arrange calls, meetings, consultations and site visits

  • prepare proposals and quotations

  • provide consultancy, audits, training, Content Days or advisory services

  • manage bookings and client relationships

  • issue invoices and process payments

  • maintain accounting and business records

  • provide customer and billing support

  • administer assessments such as the Venue Inclusion Score

  • provide results, reports or personalised feedback from digital tools

  • improve our website, services and customer experience

  • send relevant business communications or marketing where permitted

  • understand how our website and services are being used

  • conduct research or produce aggregated insights where this has been explained

  • meet legal, tax, accounting and regulatory obligations

  • establish, exercise or defend legal claims where necessary

3. Our lawful basis for using your information

The lawful basis we rely on depends on why we are using your information.

Contract

We may process your information where this is necessary to take steps at your request before entering into a contract, or to provide services under an existing contract.

Legitimate interests

We may process information where this is reasonably necessary for the legitimate interests of operating and developing our business.

This may include:

  • responding to business enquiries

  • managing client relationships

  • maintaining business records

  • improving our services

  • communicating with relevant business contacts

  • protecting our business and legal interests

Where we rely on legitimate interests, we consider whether those interests are outweighed by your rights and interests.

Consent

We may rely on your consent where you have actively agreed to a particular use of your information.

This may include:

  • certain email marketing communications

  • research participation

  • optional follow-up contact

  • non-essential cookies

Where we rely on consent, you can withdraw it at any time.

Legal obligation

We may process or retain information where necessary to comply with legal, tax, accounting or regulatory requirements.

4. Email marketing and communications

Where you have subscribed to our mailing list or otherwise consented to receive marketing communications, we may send you information about our services, events, resources, research or other relevant updates.

In some business-to-business circumstances, we may communicate with professional contacts where permitted by law and where we believe the communication is relevant to their role or organisation.

You can unsubscribe from marketing communications at any time by using the unsubscribe link in an email or by contacting us.

You have an absolute right to object to the use of your personal information for direct marketing. If you object, we will stop using your information for that purpose.

We may retain limited information on a suppression list so that we can continue to respect your preference not to receive future marketing.

5. Who we may share information with

We may use trusted third-party service providers to help us operate the business and deliver our services.

These may include providers used for:

  • website hosting and website management

  • appointment booking

  • enquiry forms

  • questionnaires and assessments

  • digital tools

  • email marketing and communications

  • payment processing

  • accounting and invoicing

  • cloud storage

  • business administration

  • analytics and website performance

Platforms we currently use or may use include:

  • Squarespace for website services

  • Calendly for appointment booking

  • MailerLite for email marketing and communications

  • Stripe for payment processing

  • FreeAgent for accounting and invoicing

  • Base44 for digital tools, assessments and interactive services

  • ScoreApp for assessments, lead capture or related digital services

We may also use professional advisers, contractors or other service providers where reasonably necessary to operate the business or deliver agreed services.

We do not sell your personal information.

6. Payments

Payments may be processed through third-party payment providers such as Stripe.

When you make an online payment, payment-card information is generally provided directly to the payment provider.

We do not normally receive or store your full payment-card details.

We may receive transaction information including:

  • your name

  • payment amount

  • payment status

  • transaction reference

  • billing information where applicable

We may use this information to process payments, issue invoices or refunds, maintain financial records and resolve payment enquiries.

7. Assessments, questionnaires and digital tools

Where you complete an assessment, questionnaire, scorecard or interactive tool through Base44, ScoreApp or another platform, we may collect the answers and information you choose to provide.

This information may be used to:

  • provide your result or personalised feedback

  • generate a score, checklist or recommendation

  • respond to enquiries generated through the tool

  • improve our assessments and services

  • conduct research

  • produce aggregated or anonymised insights

  • contact you where you have requested further information or given appropriate permission

Where information is intended to contribute to research or a published report, we will explain this at the point of collection.

Unless explicitly stated otherwise, published research will not identify individual respondents.

8. Research and aggregated information

We may use information collected through questionnaires, assessments or research projects to understand trends in accessibility, hospitality, weddings, guest experience and related areas.

Where findings are published, we will normally use aggregated or anonymised data so that individual participants are not identifiable.

Where we wish to use an identifiable quotation, case study, testimonial, name or other identifying information, we will seek appropriate permission unless another lawful basis clearly applies.

9. International transfers

Some of the service providers we use may process or store personal information outside the UK.

Where this results in a restricted international transfer, we will take appropriate steps to ensure that the transfer is covered by an appropriate legal mechanism.

This may include:

  • UK adequacy regulations

  • appropriate safeguards

  • approved contractual mechanisms

  • another lawful exception where applicable

ICO guidance states that restricted transfers must be covered by adequacy regulations, appropriate safeguards or an applicable exception.

Where appropriate safeguards are used, additional transfer-risk or data-protection assessments may also be required.

10. How long we keep information

We keep personal information only for as long as reasonably necessary for the purpose for which it was collected.

The retention period will depend on factors including:

  • the nature of the information

  • why it was collected

  • whether we are currently working with you

  • whether an enquiry develops into a client relationship

  • legal, tax or accounting requirements

  • whether information may be needed to establish, exercise or defend legal claims

We may retain invoices, contracts and financial records for longer where required for tax, accounting or legal purposes.

Marketing information may be retained until you unsubscribe, object or otherwise ask us to stop using it, subject to limited suppression information being retained where necessary to respect your preference.

11. Your rights

Depending on the circumstances, you may have the right to:

  • request access to your personal information

  • ask us to correct inaccurate or incomplete information

  • ask us to erase your information

  • ask us to restrict how your information is used

  • object to certain uses of your information

  • request transfer of your information

  • withdraw consent where processing relies on consent

These rights do not apply in exactly the same way in every situation and some depend on the lawful basis being used.

12. Your right to object

You have the right to object to the use of your personal information in certain circumstances.

You have an absolute right to object to your personal information being used for direct marketing.

You may contact us verbally or in writing to make an objection.

Where an objection applies and we have no lawful basis to continue the relevant processing, we will stop using the information for that purpose.

13. Cookies

Our website uses cookies and similar technologies.

Some cookies are necessary for the website to operate.

Other cookies, such as analytics or marketing cookies, may require your consent.

For more information about the cookies used on this website and the choices available to you, please see our Cookie Policy.

14. Third-party websites

Our website may contain links to websites or services operated by other organisations.

We are not responsible for the privacy practices, content or security of third-party websites.

We recommend reviewing the privacy information provided by those organisations before providing personal information to them.

15. Automated decision-making

We do not currently use personal information to make solely automated decisions that produce legal or similarly significant effects about you.

Where an online assessment generates an automated score, category, recommendation or result, this is intended to provide information or guidance and does not itself produce a legal or similarly significant decision about you.

16. Security

We take reasonable organisational and technical measures to protect personal information from unauthorised access, disclosure, alteration, loss or misuse.

However, no online system, transmission method or electronic storage system can be guaranteed to be completely secure.

17. Intellectual property, ownership and trademarks

All intellectual property rights in our website, services, assessments, frameworks, methodologies, tools, written materials, training content, reports, templates, digital resources and original content are owned by, licensed to, or otherwise lawfully used by Elaine Hughes Consultancy Ltd, unless expressly stated otherwise.

This includes proprietary brands, frameworks, concepts and materials developed for Inclusive Hospitality Co and Inclusive Hospitality Company.

F’AIRE™ is a proprietary framework and trading identifier associated with Elaine Hughes Consultancy Ltd.

Other names, brands, marks, logos, product names or service names used by us may also be protected by copyright, trademark rights, passing-off rights or other intellectual-property protections, whether registered or unregistered.

Nothing in this Privacy Policy, use of our website, completion of an assessment, participation in research, purchase of a service or receipt of a report transfers ownership of our intellectual property to you.

You may not copy, reproduce, modify, distribute, publish, licence, resell, teach from, commercially exploit or create derivative works from our proprietary materials without prior written permission, except where expressly permitted by law or by a separate written agreement.

Where client-specific ownership or usage rights differ, those rights will be set out in the relevant proposal, contract, licence or other written agreement.

Our fuller contractual provisions relating to intellectual property and usage rights are contained in our Terms & Conditions.

18. Ownership of submitted information

You retain ownership of original information, materials and content that you provide to us, subject to any rights required for us to perform the services you have requested.

By submitting information through an enquiry form, assessment, questionnaire, research project or digital tool, you give us permission to process and use that information for the purposes explained at the point of collection and in this Privacy Policy.

Submission of information does not transfer ownership of your underlying intellectual property to us.

Where anonymised or aggregated research findings are created from multiple responses, the resulting analysis, report, presentation, methodology and associated original materials may constitute intellectual property belonging to Elaine Hughes Consultancy Ltd, subject always to applicable data-protection law and any specific agreement with research partners or participants.

19. Complaints

If you have concerns about how we use your personal information, please contact us first so that we have the opportunity to investigate and address the issue.

You also have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK’s independent data protection regulator.

20. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to our business, website, services, technology, suppliers or legal obligations.

The latest version will be published on this website with the date it was last updated.

21. Contact

Inclusive Hospitality Co / Inclusive Hospitality Company

Trading names of
Elaine Hughes Consultancy Ltd

Company No. 13411137

ICO Registration No. ZB675460

General and privacy enquiries
info@inclusivehospitalitycompany.com

Billing and payment enquiries
accounts@inclusivehospitalitycompany.com

Customer Support
www.inclusivehospitalitycompany.com/customer-support