Final - Privacy Statement

Attachment C Privacy Statement11.12.10.FINAL.docx

Generic Clearance to Conduct Formative Research/CNPP

Final - Privacy Statement

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Attachment C

Privacy Statement

Last updated: 10/05/2010

KnowledgePanel® Members have been invited to take part in a major national research effort. Members may complete surveys to provide feedback and opinions on a range of political, lifestyle, advertising and other questions, and may contribute other types of data along with other Panel Members. Active Panel Members receive certain benefits from Knowledge Networks in exchange for participating in surveys.

OUR PRIVACY COMMITMENTS

Knowledge Networks respects the privacy of every Panel Member. This Privacy Statement outlines the information Knowledge Networks will collect and how we will use that information. This Statement will also tell you how you can verify the accuracy of your Personal Information (defined below) submitted to Knowledge Networks and how you can request that we delete or update your Personal Information.

We've developed our privacy policy from industry guidelines and standards, and local, national, and international laws and requirements. All privacy practices and methods described in this policy apply only insofar as permitted by the applicable standards, laws and requirements. In addition, as a member of the Council of American Survey Research Organizations ("CASRO"), the professional trade association of survey research companies, Knowledge Networks adheres to the mandated CASRO Code of Standards and Ethics for Survey Research. You may visit CASRO, and view the CASRO Code, at www.casro.org.

Thanks again for placing your trust in Knowledge Networks.

Knowledge Networks has been awarded TRUSTe's Privacy Seal signifying that this privacy policy and practices have been reviewed by TRUSTe for compliance with TRUSTe's program requirements including transparency, accountability and choice regarding the collection and use of your personal information. TRUSTe's mission, as an independent third party, is to accelerate online trust among consumers and organizations globally through its leading privacy trustmark and innovative trust solutions. If you have questions or complaints regarding our privacy policy or practices, please contact us at [email protected]. If you are not satisfied with our response you can contact TRUSTe here.

The TRUSTe program covers only information that is collected through Knowledge Networks’ Web sites except as specifically provided for in this Privacy Statement, and does not cover information that may be collected through software downloaded from this site.

INFORMATION COLLECTED AND HOW WE USE IT

WHAT WE COLLECT:

A) PERSONAL AND DEMOGRAPHIC INFORMATION
During the KnowledgePanel® recruitment process, Knowledge Networks collects personal information such as your name, address, email address and the names and ages of members of your household ("Personal Information"). In addition, Knowledge Networks frequently asks Panel Members for characteristics (such as health problems or consumer habits), attributes, and demographic information (such as age, income, gender) (collectively, "Demographic Information") via online surveys.

You are in control of the Personal Information and Demographic Information that you provide to Knowledge Networks. We rely on you to provide updates to your Personal Information and Demographic Information. You can:

  • Ask for a copy of your Personal Information or Demographic Information.

  • Ask for your Personal Information or Demographic Information to be corrected or updated.

  • Ask us to remove your Personal Information or Demographic Information from your records.

  • To do this, please contact us using the links provided later in this statement. Knowledge Networks will use reasonable efforts to provide the requested information to you.

B) OPERATING INFORMATION
Knowledge Networks may, in the course of interacting with Panel Members, gather other types of information from Panel Members ("Operating Information"). For example, as a KnowledgePanel Member, you will receive surveys from Knowledge Networks on a regular basis. These surveys will ask questions about your interests, needs, and attitudes. We will receive your responses to these surveys. If we offer features, services, or programs in which you explicitly agree to participate, then Knowledge Networks will receive information from those features, services, or programs.

C) LOG FILES
As is true of most Web sites, we gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data.

We use this information, which does not identify individual users, to analyze trends, to administer the site, to track users' movements around the site and to gather demographic information about our user base as a whole.

We do not link this automatically-collected data to personally identifiable information.

D) COOKIES
A cookie is a small text file that is stored on a user's computer for record-keeping purposes. We use cookies on this site. We do not link the information we store in cookies to any personally identifiable information you submit while on our site.

We use persistent cookies. A persistent cookie remains on your hard drive for an extended period of time. You can remove persistent cookies by following directions provided in your Internet browser's "help" file. If you reject cookies, you may still use our site, but your ability to use some areas of our site, such as contests or surveys, will be limited.

HOW WE USE YOUR INFORMATION:

A) PERSONAL AND DEMOGRAPHIC INFORMATION
Personal Information is used to set up e-mail accounts for each household member who is 13 years of age or older (if you do not have Internet access at the time of recruitment), to communicate with you and your household members, and to assist you with questions that you may have about the KnowledgePanel procedures. It may also be used for panel recruitment, contest entry processing or delivery of free gifts to KnowledgePanelMembers, and delivery of our quarterly newsletter, which you are automatically enrolled to receive via email.

(To opt out of the newsletter, go to: http://members.knowledgenetworks.com/Profile.aspx.) Personal Information concerning location or address is also used to ensure that our panel accurately represents the country's population as a whole.

Panel Members are asked for Demographic Information in order to pre-qualify members or households for surveys that target specific groups. We also use this information to ensure that our panel accurately represents the country's population as a whole.

Knowledge Networks uses Personal Information and Demographic Information solely in the conduct of its research business. Personal Information or Demographic Information may be combined with information collected about you by Knowledge Networks or third parties with your express permission, with information that is collected about you from public records, or with information that Knowledge Networks may acquire from third parties that have a legal right to provide such information to Knowledge Networks.

B) OPERATING INFORMATION
Knowledge Networks uses Operating Information solely in the conduct of its research business. As is the case with Personal Information and Demographic Information, Operating Information may be combined with information collected about you by third parties with your express permission, with information that is collected about you from public records, or with information that Knowledge Networks may acquire from third parties that have a legal right to provide such information to Knowledge Networks.

DATA SHARING AND TRANSFER

A) HOW WE MAY SHARE INFORMATION:
Except as detailed in this section of the Privacy Statement, Personal Information regarding Panel Members will never be shared with any third parties without your express permission. We reserve the right, however, to disclose your personally identifiable information as required by law and when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, or legal process served on Knowledge Networks or its employees or agents.

In addition, occasionally Knowledge Networks will share contact information, such as name and mailing address, with third parties with whom we have partnered to provide specific services to Knowledge Networks, or services on behalf of Knowledge Networks, specifically for the purposes of panel recruitment, panel communications, contest entry processing or delivery of free gifts to KnowledgePanel Members. These partners have agreed not to share or resell this data and they are contractually obligated not to use any personally identifiable information except for the purpose of providing these services, unless you enter into a relationship with them that would directly allow them to do so.

Knowledge Networks collects and shares Demographic Information and Operating Information with its research clients in an anonymous form. Our research clients will never receive Personal Information of Panel Members, nor will they be able to identify Panel Members, without your express permission.

Knowledge Networks is an expanding business, and like other companies, we sometimes acquire or divest business units or ourselves be acquired. As part of such transfers or mergers, we may convey the business assets of the particular business unit, or the company as a whole, including Personal Information, Demographic Information, or Operating Information of Panel Members. In that eventuality, you would be notified via email.

B) DATA TRANSFERS:
Your Personal Information, Demographic Information, and Operating Information will generally be stored in our Knowledge Networks databases. For easier processing of e-mail communications, contests, sweepstakes, or other marketing purposes, or for panel recruitment or panel communications, however, your Personal Information, Demographic Information, or Operating Information may be sent to or accessed by Knowledge Networks’ service providers and contractors who are obligated to keep such information confidential in countries outside the United States or the European Union. Knowledge Networks data protection standards and those of its service providers and contractors are the same, regardless of where your information is stored.

Knowledge Networks adheres to United States/European Union Safe Harbor principles. If you feel that Safe Harbor privacy principles may have been violated by Knowledge Networks, you may contact Knowledge Networks or CASRO, 3 Upper Devon, Port Jefferson, NY 11777 (email: [email protected]) (telephone: 631-928-6954) with your complaint. Knowledge Networks is a member of CASRO.

CHILDREN'S PRIVACY

Knowledge Networks believes that it's especially important to protect children's privacy online and encourages parents and guardians to spend time online with their children to participate and monitor their Internet activity.

Knowledge Networks complies with all applicable national and international children's privacy regulations. We do not permit children who are under 13 years of age to become KnowledgePanel Members. We do not collect any Personal Information from children under 13 years of age. As part of the registration process for new Panel Members, we collect from the new Panel Member the names of each individual in the Panel Members' household, which may include the names of children who are under 13 years of age. Occasionally we may send a survey to a Panel Member who is a parent or guardian of a child under the age of 13 that asks that Panel Member to have his or her child who is under 13 answer the survey. We take reasonable steps to ensure parental consent to such procedure by sending the survey to the parent or guardian's password-protected email address. The information collected in response to such surveys is not combined with identifying information about the child. In every case such survey does not collect Personal Information about the child. We comply with the Children's Online Privacy Protection Act of 1998.

If a Panel Member has provided us with Personal Information about a child in the Panel Member's household who is under the age of 13, a parent or guardian of that child may contact us at the email address or mailing address listed at the bottom of this Privacy Statement if he or she would like this information deleted from our records. We will use reasonable efforts to delete the child's information from our databases.

If you would like to contact us about your or your child's Personal Information, or to find out how you can have your child's Personal Information removed from our database, please see the "Access To Your Information and Complaints" section later in this document.

DATA SECURITY AND RESPONSIBILITY

Knowledge Networks is committed to keeping the data you provide us secure and will take reasonable precautions to protect your Personal Information from loss, misuse or alteration. Vendors, contractors, or partners of Knowledge Networks who have access to your Personal Information in connection with providing services for Knowledge Networks are contractually required to keep the information confidential and are not permitted to use this information for any other purpose than to carry out the services they are performing for Knowledge Networks.

Knowledge Networks also safeguards Personal Information, Demographic Information, and Operating Information from unauthorized access. Most Operating Information is maintained in databases that are separate from those containing Personal Information and Demographic Information. Only authorized Knowledge Networks employees or agents carrying out permitted business functions are allowed to access these databases. In addition, each employee of Knowledge Networks is required to sign a confidentiality agreement requiring him or her to keep confidential all Personal Information of Panel Members. Employees who violate the confidentiality agreement are subject to disciplinary actions, including termination when appropriate.

While we strive to use industry-standard security technology, procedures and other measures to help protect your Personal or Demographic Information, we cannot guarantee the security of the information you transmit.

ACCESS TO YOUR INFORMATION AND COMPLAINTS

A) Accessing, Correcting, Updating and Preventing Use of Your Personal Information or Demographic Information
If you have submitted Personal or Demographic Information to Knowledge Networks through KnowledgePanel or otherwise, or if someone else has otherwise submitted your Personal or Demographic Information to Knowledge Networks, you can:

  1. Access, Correct, Update Your Personal or Demographic Information, by emailing your request to: [email protected], or by sending us a letter to the address listed below. Knowledge Networks will use reasonable efforts to supply you with the information you requested to access and to correct any factual inaccuracies in this information.

  2. Prevent Further Use of Your Personal or Demographic Information, by emailing your request to: [email protected]. Alternatively, you may call us at 1-800-782-6899 or send us a letter to the address listed below. In each case, we will then use reasonable efforts to prevent further use of your Personal Information or Demographic Information in our files.

B) Complaints
Knowledge Networks is committed to working with consumers to obtain a fair and rapid resolution of any complaints or disputes about privacy. Please send us your questions or comments regarding our privacy practices by emailing us at:
[email protected], or send us a letter to:

Privacy Compliance Coordinator
Knowledge Networks Inc.
P.O. Box 40
Cranford, NJ 07016 USA



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