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https://sago.com/en/legal/privacy/
PRIVACY POLICY
Updated 11 December 2023
1.1. Purpose
Privacy policy of SS Holdings Group, LLC D/B/A Sago, branded as “Sago”, for
people who are engaging with us or our digital platforms as research or
prospective clients, as research partners or participants (e.g., consumers,
healthcare professionals, patients, or business individuals).
1.2. Policy
Your privacy is important to us.
It is Sago’s policy to respect your privacy and comply with any applicable law and
regulation regarding any personal information we may collect about you,
including across our website, and other sites we own and operate.
In the event our site contains links to third-party sites and services, please be
aware that we have no control over the content and policies of those sites and
cannot accept responsibility or liability for their respective privacy practices.
Our privacy policy aims to bring you all the necessary transparency for a positive
and confident experience with our services. Additional information may be
provided to you as necessary when you sign up for a particular product or
service.
Our privacy policy complies with global research industry Codes and Standards,
as well as all pertinent laws governing privacy.
1.2.1 What Information Do We Collect
Information we collect falls into one of two categories: “voluntarily provided”
information and “automatically collected” information.
“Voluntarily provided” information refers to any information you knowingly and
actively provide us when using or participating in any of our services and
promotions.
“Automatically collected” information refers to any information automatically
sent by your devices while accessing our products and services.
We only collect and use your personal information lawfully, fairly, and in a
transparent manner. We systematically respect the principle of minimization,
which implies collecting and processing only what is strictly necessary to
achieve our legitimate objective. We do not aim any of our products or services
directly at children under the national child age consent, and we do not
knowingly collect personal information about children under the national child
age consent.
We process personal data that we need in order to carry out our business. We
only process personal information in a way that is compatible with the purposes
for which we collected it or subsequently authorized by the data subject. We
take reasonable steps to ensure that personal data is reliable for its intended
use, accurate, complete, and current.
The information notice that is sent to you before any collection or processing
details the applicable legal basis, which depends on the services you use and
how you use them. This means we only collect and use your information on the
following grounds:
In order to respect your choice when we request consent from you:
“Personal information” only includes information relating to natural persons who
can be identified or who are identifiable, directly from the information in
question. Or who can be indirectly identified from that information in
combination with other information. For example, name, contact details,
location, consumer options/preferences, video/audio recordings… We may ask
your consent for processing such information — for example, when you register
an account or when you contact us via email, social media, or any similar
technologies — which may include your name, your email, your phone/mobile
number… When you contact us, you shall consent to your name and email
address being used so we can respond to your inquiry.
Participation in all market research projects is voluntary and based on consent.
Respondents may opt out of any market research project, at any time.
Personal information may also include “Sensitive information” or “Special
categories of data” which is a subset of personal information that is given a
higher level of protection. The types of sensitive information that we may collect
about you include:
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Racial or ethnic origin
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Political opinions
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Religious or Philosophical beliefs
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Sexual orientation
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Sexual practices or sex life
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Medical or Health conditions
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Trade union membership
We will obtain your affirmative express consent (opt-in) if such information is to
be (i) disclosed to a third party or (ii) used for a purpose other than those for
which it was originally collected or subsequently authorized by the individuals
through the exercise of your opt-in choice. We will also treat as sensitive any
personal information received from a third party where the third party identifies
and treats it as sensitive.
In addition, we ensure that strengthened security measures are applied to these
data, in order to avoid any breach of confidentiality, integrity, and availability.
A “Cookie” is a small piece of data that our website stores on your computer and
accesses each time you visit. We use cookies to collect information about you
and your activity across our site to understand how you use our site and to
enable you to access and use our website. At all times, you may decline cookies
from our site.
Please refer to our Cookie Policy for more information.
You may withdraw your consent at any time using the facilities we provide;
however, this will not affect any use of your information that has already taken
place.
While you may request that we delete your contact details at any time, we
cannot recall any email we have already sent. If you have any further inquiries
about how to withdraw your consent, please feel free to enquire using the
details provided in the Contact Us section of this privacy policy.
In order to allow the performance of a contract or transaction at your request:
For example, if you purchase a product, service, or subscription from us, we may
need to use your personal and payment information in order to process and
deliver your order.
In order to follow our legitimate interests:
Where we assess whether it is necessary for our legitimate interests, such as
for us to provide, operate, improve, and communicate our services, we consider
our legitimate interests to include:
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research and development, understanding our audience, marketing and
promoting our services, measures taken to operate our services
efficiently, marketing analysis, and measures taken to protect our legal
rights and interests,
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business development, including operating and improving our website,
associated applications, and associated social media platforms,
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security and fraud prevention, and to ensure that our sites and apps are
safe, secure, and used in line with our terms of use.
When you visit our website, our servers may automatically log the standard data
provided by your web browser. It may include your device’s Internet Protocol (IP)
address, your browser type and version, the pages you visit, the time and date of
your visit, the time spent on each page, and other details about your visit. The
data we collect can depend on the individual settings of your device and
software. We recommend checking the policies of your device manufacturer or
software provider to learn what information they make available to us.
Additionally, if you encounter certain errors while using the site, we may
automatically collect data about the error and the circumstances surrounding
its occurrence. This data may include technical details about your device, what
you were trying to do when the error happened, and other technical information
relating to the problem. You may or may not receive notice of such errors, even
at the moment they occur, that they have occurred, or what the nature of the
error is.
Please be aware that while this information may not be personally identifying by
itself, it may be possible to combine it with other data to personally identify
individual persons.
“Transaction data” refers to data that accumulates over the normal course of
operation on our platform. This may include transaction records, stored files,
user profiles, analytics data, and other metrics, as well as other types of
information, created or generated, as users interact with our services.
We consider “User-generated content” to be materials (text, image and/or video
content) voluntarily supplied to us by our users for the purpose of publication,
processing, or usage on our platform. All user-generated content is associated
with the account or email address used to submit the materials.
Please be aware that any content you submit for the purpose of publication will
be property of the client after posting (and subsequent review or vetting
process). User-generated content cannot be used for purposes beyond market
research (i.e., advertisements and customer testimonials) without express
written permission. Once published, it may be accessible to third parties not
covered under this privacy policy.
In order to comply with the law:
In some cases, we may have a legal obligation to use or keep your personal
information. Such cases may include (but are not limited to) court orders,
criminal investigations, government requests, and regulatory obligations. If you
have any further inquiries about how we retain personal information in order to
comply with the law, please feel free to enquire using the details provided in the
Contact Us section of this privacy policy.
1.2.2 How Do We Ensure the Security of Your Personal Information
Because we are ISO 27001 certified, we comply with high international standards
for computer security and the protection of personal information.
When we collect and process personal information, and while we retain this
information, we will protect it within commercially acceptable means to prevent
loss and theft, as well as unauthorized access, disclosure, copying, use, or
modification.
You are responsible for selecting any password and its overall security strength,
ensuring the security of your own information within the bounds of our services.
For example, ensuring any passwords associated with accessing your personal
information and accounts are secure and confidential.
We comply with laws applicable to us in respect of any data breach.
1.2.3 How Long Do We Keep Your Personal Information
We keep your personal information only for as long as we need to. This time
period may depend on what we are using your information for, in accordance
with this privacy policy.
For example, if you have provided us with personal information as part of
creating an account with us, we may retain this information for the duration your
account exists on our system. If your personal information is no longer required
for this purpose, we will delete it or make it anonymous by removing all details
that identify you.
However, if necessary, we may retain your personal information for our
compliance with a legal, accounting, or reporting obligation (i) such as reporting
of Incentive payments on a yearly basis to federal and/or state regulatory
authorities pursuant to legal requirements or (ii) for archiving purposes in the
public interest, scientific, or historical research purposes or statistical
purposes.
Except as otherwise permitted by law, regulation, or EU-U.S. Data Privacy
Framework Principles, we destroy or anonymize personal data after it no longer
serves a purpose of processing as contemplated above and/or once a lawful
basis for processing it ceases to exist.
1.2.4 Who Are the Recipients of Your Personal Information and Where Are
They Located
We may disclose personal information to:
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a parent, subsidiary, or affiliate of our company in order to provide
product support
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third-party service providers for the purpose of enabling them to provide
their services, including (without limitation) IT service providers, data
storage, hosting and server providers, analytics, error loggers, debt
collectors, maintenance or problem-solving providers, professional
advisors, and payment systems operators
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our employees, contractors, and/or related entities in order to support the
product
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our existing or potential agents or business partners in order to support
the product
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credit reporting agencies, courts, tribunals, and regulatory authorities, in
the event you fail to pay for goods or services we have provided to you
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courts, tribunals, regulatory authorities, and law enforcement officers, as
required by law, in connection with any actual or prospective legal
proceedings, or in order to establish, exercise, or defend our legal rights
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third parties, including agents or sub-contractors, who assist us in
providing information, products, services, or direct marketing to you
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an entity that buys, or to which we transfer all or substantially all of our
assets and business
Third parties we currently use include:
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Google Analytics for product usage metrics (unless prohibited by national
data protection authorities)
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Google Ads and LinkedIn Insights Tag to measure our marketing
campaigns
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Google Cloud Natural Language for text sentiment and for image analytics
(brand/logo recognition)
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Azure Application Insights for logging and troubleshooting user issues
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Azure Cognitive Services for image analytics and machine text translation
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Amazon web services for data storage, compute, and image processing
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Help Scout for managing and responding to customer support requests
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Twilio for video interview capabilities
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Rev for video transcription services
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Hotjar for product usage metrics
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Drift Chatbot to help site visitors to navigate and make decisions
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Marketo (our Automation tool) to record and process user-submitted
information
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Sense to get account insights
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Research Defender, Imperium, IPQualityScore, RelevantID, and MaxMind to
identify suspicious respondents, eliminate fraudsters and bad actors, and
ensure accurate and high-value datasets
If we or our assets are acquired, or in the unlikely event that we go out of
business or enter bankruptcy, we would include data, including your personal
information, among the assets transferred to any parties who acquire us. You
acknowledge that such transfers may occur and that any parties who acquire us
may, to the extent permitted by applicable law, continue to use your personal
information according to this policy, which they will be required to assume as it
is the basis for any ownership or use rights we have over such information.
The personal information we collect is stored and/or processed in the United
States, or where we or our partners, affiliates, and third-party providers
maintain facilities.
The countries to which we store, process, or transfer your personal information
may not have the same data protection laws as the country in which you initially
provided the information. If we transfer your personal information to third
parties in other countries: (i) we will perform those transfers in accordance with
the requirements of applicable law; and (ii) we will protect the transferred
personal information in accordance with this privacy policy.
1.2.5 Which Are the Security Measures in Place?
Access to private, sensitive, and confidential information, including your
personal information, is restricted to authorized employees with legitimate
business reasons.
All employees are expected to always maintain the confidentiality of personal
information, and failure to do so will result in appropriate disciplinary measures.
We follow reasonable technical and management practices to help protect the
confidentiality, security, and integrity of data stored on our system. While no
computer system is completely secure, the measures implemented by our
website reduce the likelihood of security problems to a level appropriate to the
type of data involved. We employ physical, electronic, and procedural
safeguards in connection with the collection, storage, and disclosure of any
personal contact information. We encrypt the transmission of sensitive
information using secure socket layer technology (SSL).
1.2.6 What Are Your Rights
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Access: You may request details of the personal information that we hold
about you. We reserve the right to limit such access where the burden or
expense of providing access would be disproportionate to the risks to
your privacy in the case in question, or where the rights of persons other
than you would be violated.
Your choice: By providing personal information to us, you understand we
will collect, hold, use, and disclose your personal information in
accordance with this privacy policy. You do not have to provide personal
information to us, however, if you do not, it may affect your use of our
website or the products and/or services offered on or through it.
Information from third parties: If we receive personal information about
you from a third party, we will protect it as set out in this privacy policy. If
you are a third party providing personal information about somebody else,
you represent and warrant that you have such a person’s consent to
provide the personal information to us.
Marketing permission: If you have previously agreed to us using your
personal information for direct marketing purposes, you may change your
mind at any time by contacting us using the details below.
Correction: If you believe that any information, we hold about you is
inaccurate, out of date, incomplete, irrelevant, or misleading, please
contact us using the details provided in this privacy policy. We will take
reasonable steps to correct any information found to be inaccurate,
incomplete, misleading, or out of date.
Non-discrimination: We will not discriminate against you for exercising
any of your rights over your personal information. Unless your personal
information is required to provide you with a particular service or offer (for
example processing transaction data), we will not deny you goods or
services and/or charge you different prices or rates for goods or services,
including through granting discounts or other benefits, or imposing
penalties, or provide you with a different level or quality of goods or
services. Respondents are not discriminated against for their answers.
Selection for participating in a study relies on research project objectives.
Participation in studies is not related to any fees, and membership in our
panel will also have no costs.
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Complaints: If you believe that we have breached a relevant data
protection law and wish to make a complaint, please contact us using the
details below and provide us with full details of the alleged breach. We will
promptly investigate your complaint and respond to you, in writing,
setting out the outcome of our investigation and the steps we will take to
deal with your complaint. You also have the right to contact a regulatory
body or data protection authority in relation to your complaint.
You have the right to choose (opt-out) whether your personal data is (i) to be
disclosed to a third party or (ii) to be used for a purpose that is materially
different from the purpose(s) for which it was originally collected or
subsequently authorized by you. If you wish to opt out, all you need to do is
contact us at [email protected]. If you contact us to opt out, we will explain
the options available and comply with your request as required by the Principles
and the applicable law. Please note that applicable laws allow certain exceptions
to your ability to opt-out, such as where we are parties to a contract that is still
being performed, where the law requires us to maintain information tow claims
or tax reports, or otherwise. In such cases, we will retain and continue to use
your information only to the extent permitted or required by law. The above optout right doesn’t apply where the sharing of your personal data is with a third
party who is acting as our agent (such as our service providers who perform
services that help us to run our business). We won’t provide your personal data
to a third party under these circumstances unless we have a contract in place
with that third party that requires the third party to comply with the DPF
Principles.
Under European, Australian, and Canadian data protection laws, you also have
the following rights:
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Downloading of Personal Information: We provide a means for you to be
provided with the personal information you have shared through our site.
Please contact us for more information.
Restrict: You have the right to request that we restrict the processing of
your personal information if (i) you are concerned about the accuracy of
•
•
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your personal information; (ii) you believe your personal information has
been unlawfully processed; (iii) you need us to maintain the personal
information solely for the purpose of a legal claim; or (iv) we are in the
process of considering your objection in relation to processing on the
basis of legitimate interests.
Objecting to processing: You have the right to object to the processing of
your personal information that is based on our legitimate interests or
public interest. If this is done, we must provide compelling legitimate
grounds for the processing which overrides your interests, rights, and
freedoms, in order to proceed with the processing of your personal
information.
Data portability: You may have the right to request a copy of the personal
information we hold about you. Where possible, we will provide this
information in CSV format or another easily readable machine format. You
may also have the right to request that we transfer this personal
information to a third party.
Deletion: The data controller of a project may have a right to request that
we delete the personal information we hold at any time, and we will take
reasonable steps to delete personal information from our current records.
If you ask us to delete your personal information, we will let you know how
the deletion affects your use of our website or products and services.
There may be exceptions to this right for specific legal reasons which, if
applicable, we will set out for you in response to your request. If you
terminate or delete your account, we will delete your personal information
without undue delay. Please be aware that search engines and similar
third parties may still retain copies of your personal information that has
been made public at least once, like certain profile information and public
comments, even after you have deleted the information from our services
or deactivated your account.
We would respond to your requests without undue delay and at the latest within
one month of receipt of your request. That period may be extended by two
further months where necessary, taking into account the complexity and
number of the requests.
1.3. United States Considerations
The purpose of this privacy policy is to inform you about the processing of your
personal data by Sago and its entities in accordance with research industry
Codes and Standards relating to the USA and additionally the country in which
each Sago company is based.
Sago companies comply with all pertinent Federal and State laws governing
privacy, including but not limited to the enacted California Consumer Privacy Act
(CCPA) and recently amended California Privacy Rights Act (CPRA).
For questions or concerns relating to privacy, you may contact us by email
at [email protected].
All requests to exercise your rights must be accompanied by the details
necessary to process your request. A copy of proof of identity may be requested
if necessary.
1.4. European Considerations
The purpose of this privacy policy is to inform you about the processing of your
personal data by Sago and its entities in accordance with the European Data
Protection Regulation (the GDPR) and the UK GDPR, the amended French Data
Protection Act, the new Spanish Fundamental Law on Data Protection (the
NLOPD), the new German Federal Data Protection Act (the BDSG), and the UK
Data Protection Act (the DPA).
Sago has signed internal EU Commission Standard Contractual Clauses and UK
Addendum to safeguard its international transfers of personal data.
You have the right to lodge a complaint with your national data protection
authority. You can find more information about your data protection rights on
your authority’s website.
Sago has appointed a Data Privacy Officer in each European country to be your
privileged interlocutor regarding the processing of your personal data. If you
wish to contact a DPO, you can write to them at the following addresses:
•
•
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DE: [email protected]
FR: fr@ sago.com
SP: es@ sago.com
UK: uk@ sago.com
All requests to exercise your rights must be accompanied by the details
necessary to process your request. A copy of proof of identity may be requested
if necessary.
1.5. Canadian Considerations
The purpose of this privacy policy is to inform you about the processing of your
personal data by the Sago and its entities in accordance with the laws of Ontario
and the applicable federal laws of Canada.
If you have any questions or comments about this Privacy Policy, you may
contact us at [email protected] or via postal mail at:
370 King St. West, 5th Floor, Box 4
Toronto, ON, Canada, M5V1J9
1.6. Australian Considerations
The purpose of this privacy policy is to inform you about the processing of your
personal data by Sago and its entities in accordance with the federal Privacy
Act, the Australian Privacy Principles, and States and Territories’ legislations.
The Central Server is located in an Australian data centre with a fully redundant
network with No Single Point of Failure, contains Multiple Layers of Network
Security and is also secured with Windows Firewall and IPsec Policy.
You can change your information at any time, through the profile tab in your
member portal. We are obliged by law to ensure that your information is
accurate and up to date at all times.
If you have any queries or complaints in relation to your personal information,
please don’t hesitate to get in touch: [email protected]
You will need to outline what information you would like access to or identify
your concerns. We will endeavour to respond to you within 3 business days.
1.7. Data Privacy Framework (DPF) Specificities
We comply with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK
Extension to the EU-U.S. DPF as set forth by the U.S. Department of Commerce.
We have certified to the U.S. Department of Commerce that we adhere to the
EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard
to the processing of personal data received from the European Union in reliance
on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. If there is any
conflict between the terms in this privacy policy and the EU-U.S. DPF Principles,
the Principles shall govern. To learn more about the DPF Program, and to view
our certification, please visit https://www.dataprivacyframework.gov/. We
commit to subject to the DPF Principles all the personal data received from the
EU in reliance on the EU-U.S. for as long as we retain the personal data.
Sago receives personal data from EU and UK employees, respondents, panel
members, clients, and website visitors. Sago will process their personal data for
the following purposes:
Categories of Data Subjects
Purposes of the Processing of
Categories of Third Parties
their Data
Involved
· Bug tracking, incident
· Support
requests
EU and UK employees
management and project
management
management system
· HR management
· Human resources
· Data storage
management services
· Vouchers management
· Data host
· Market Research services
EU and UK respondents
· Project management
providers
· Requests management
· Ticketing services
· Panel Management
EU and UK panel members
EU and UK clients
· Requests management
· Data host
Data storage
· Ticketing services
· Relationship management
· Customer relationship
· Business development
management solutions.
· To enable websites core
features (like user logins)
· To configure settings on the
website visited (like language)
· To provide with customized,
enhanced, or optimized content
and services
· To measure the website
EU and UK websites’ visitors
performance and marketing
· Cookies management
campaign success
platform
For complaints concerning Human Resources (HR) Personal Data and Personal
Data other than HR, at no cost, you may file a complaint concerning how we
process your Personal Data. We will take steps to remedy issues arising out of
our alleged failure to comply with the DPF Principles. All you need to do is
contact us at [email protected]. If your complaint cannot be resolved
through our internal processes, we cooperate with the panel established by the
Data Protection Authorities (DPAs).
Under certain circumstances and following the procedures and subject to
conditions set forth in the DPF Annex I, you may also be able to invoke binding
arbitration to address complaints about Sago’s compliance with the DPF
Principles.
We are subject to the investigatory and enforcement powers of the FTC, the
DOT or any other U.S. authorized statutory body.
We will disclose personal data in response to lawful requests by public
authorities, including to meet national security or law enforcement
requirements.
When we transfer personal data to a third party acting as a controller, we comply
with the DPF Principles. We also enter into a contract with the third-party
controller that provides that such data may only be processed for limited and
specified purposes consistent with your consent and that the recipient will
provide the same level of protection as the DPF Principles and will notify us if it
makes a determination that it can no longer meet this obligation. Those
contracts provide that, when such a determination is made, the third-party
controller ceases processing or takes other reasonable and appropriate steps to
remediate.
When we transfer personal data to a third party acting as an agent, (i) we
transfer such data only for limited and specified purposes; (ii) we require (usually
by contract) at least the same level of privacy protection as is required by the
DPF Principles; (iii) we take reasonable and appropriate steps to ensure that the
agent effectively processes the personal data transferred in a manner
consistent with the organization’s obligations under the Principles; (iv) we
require the agent to notify us if it makes a determination that it can no longer
meet its obligation to provide the same level of protection as is required by the
Principles; (v) upon notice, including under (iv), we take reasonable and
appropriate steps to stop and remediate unauthorized processing; and (vi) we
will provide a summary or a representative copy of the relevant privacy
provisions of our contract with that agent to the Department of Commerce upon
request.
If we transfer personal data to a third party acting as an agent on our behalf who
processes such data in a manner inconsistent with the DPF Principles, we
remain liable under the DPF Principles, unless we prove that we are not
responsible for the event giving rise to the damage.
In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF,
we commit to cooperate and comply respectively with the advice of the panel
established by the EU data protection authorities (DPAs) and the UK Information
Commissioner’s Office (ICO) with regard to unresolved complaints concerning
our handling of personal data received in reliance on the EU-U.S. DPF and the UK
Extension to the EU-U.S. DPF.
When we become subject to a court order that is based on non-compliance or an
order from a U.S. statutory body (e.g., FTC or DOT) listed in the DPF Principles or
in a future annex to the Principles that is based on non-compliance, we will make
public any relevant EU-U.S. DPF-related sections of any compliance or
assessment report submitted to the court or U.S. statutory body to the extent
consistent with confidentiality requirements.
1.8. How Can You Find Out About Changes to This Policy
At our discretion, we may change our privacy policy to reflect updates to our
business processes, current acceptable practices, or legislative or regulatory
changes. If we decide to change this privacy policy, we will post the changes
here at the same link by which you are accessing this privacy policy.
If the changes are significant, or if required by applicable law, we will contact
you (based on your selected preferences for communications from us) and all
our registered users with the new details and links to the updated or changed
policy.
If required by law, we will get your permission or give you the opportunity to opt
in to or opt out of, as applicable, any new uses of your personal information.
1.9. Contact Us
For any general questions or concerns regarding your privacy, you may contact
us using the following details:
US
•
[email protected]
EU
•
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DE: [email protected]
FR: dpo.fr@ sago.com
SP: dpo.es@ sago.com
UK: dpo.uk@ sago.com
Canada
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[email protected]
Australia
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[email protected]
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5/30/24, 6:37 PM
Privacy - Influence Your World | Toluna
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Toluna Influencers Panel Privacy Notice
Last updated: January 2022
Who are we?
We are Toluna Group Limited, part of the Toluna Holdings Limited worldwide group ("We" "Our" "Us" or "Toluna”). You can see
who our group members are by clicking on the link below:
https://tolunacorporate.com/locations/
Toluna are an online data collection group focused on providing high-quality market research data to its clients who are in vario
business sectors, including other market research agencies and other global and corporate clients of all sizes. We also build an
maintain large online consumer panels, providing real-time digital consumer insights to our clients via our market research
surveys and analytics platforms.
The Toluna company with whom you registered as a Member is the controller and responsible for your personal data.
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice
you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO
at [Contact Us].
This privacy notice does not apply where you have agreed to participate in surveys administered by third parties. In these
situations, Toluna is not the sponsor of the survey and the technologies/media of those surveys and the survey results or survey
data are and will be controlled by the sponsor of those surveys. Please refer to the relevant sponsor’s privacy policy to learn
more about those sponsor’s privacy practices.
What is our Privacy Commitment to you?
We respect your privacy and are committed to protecting your personal data. This privacy notice describes how we collect, use
share and secure personal data you provide on http://www.influencers.toluna.com (our "site”) and/or via our Mobile app when
you become a member of our influencers panel and participate in surveys and/or research studies ("surveys”) that we conduct
for, and on behalf of our clients. It also explains your privacy rights and how laws that are applicable to you may protect you and
is intended to supplement other notices and privacy policies and not to override them.
The registration, use of and access to your Membership and use of our systems and media ("Services”) is subject to this privac
notice.
This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use
the Glossary to understand the meaning of some of the terms used in this privacy notice.
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Frequently asked questions:
Who are we?
What is our Privacy Commitment to you?
What personal data do we collect about you?
How do we use your personal data?
Who do we share your personal data with?
Do we transfer your personal data to other countries?
What other ways can you become a member of our influencers panel? – Our mobile app
What cookies do we use on our site?
What other tracking technologies do we use for surveys you participate in and for other purposes?
What is our winner’s policy and privacy guarantee?
What security measures do we undertake to protect your personal data?
What are our data retention and destruction policies?
Business Transfers
Links
Children’s privacy
Your rights
How do you access your information; use the member services area and/or update, correct or delete your information?
How do you terminate your influencers' panel membership?
Data Retention
How do you ask a question or make a complaint?
Your other rights
Your rights in California
Changes to the privacy notice and your duty to inform us of changes
Privacy contact details
What personal data do we collect about you?
Personal data means any information about an individual from which that person can be identified. It does not include data
where the identity has been removed (i.e. anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
(A) Identity data – name (includes first, last, maiden and married names), date of birth, marital status, gender, panelist id, an
username.
(B) Contact data – postal address, email address, and telephone number.
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(C) Special categories of personal data – ethnic/racial origin, health, genetics, political opinion, religion, sexual orientation
and sex life.
(D) Demographic/Profile data – interests, preferences, feedback and survey responses and including, but not limited to;
age, marital status, gender, birthday, household size, income, education, and employment status.
(E) Technical data includes internet protocol (IP) addresses, login data, browser type, and version, time zone setting and
location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to
access this website.
(F) Pseudonymized data are identifiable data as unique identifiers e.g. panelist ID’s or Technical data are used, however
direct identifiers, such as; name and Contact data are removed.
Influencers Panel Members
When you agree to become a member of our influencers panel ("Member"), you are able to participate in our surveys. We will
ask you to complete the registration form via https://influencers.toluna.com (our "site") or via links displayed on our partners’
websites and you may also register to be a Member via our mobile app.
Non-members of our Influencers Panel
If you are not a Member of our influencers panel ("non-member"), but take a survey with us and provide us with your personal
data, the only personal data we may preserve about you is your email address, gender, age information, full or partial zip/posta
code, machine ID and IP address. We do this so we may:
contact you if you have won a prize or are entitled to an incentive, in which case, we will collect and maintain such personal
data, to the extent required by any applicable law or regulation (e.g. for tax reasons, if applicable);
to match you against the survey you are taking; and
improve the user experience.
We will not contact you for any other reason.
Public forums and blogs
Our website offers publicly accessible blogs or community forums. You should be aware that any information you provide in the
areas may be read, collected, and used by others who access them.
We display personal testimonials of satisfied customers on our site in addition to other endorsements. With your consent, we
may post your testimonial along with your username. If you wish to update or delete your testimonial, you can contact us
at [Contact Us].
You should be aware that any personal data you choose to make public on the site, in the Community area (under a public
message on your wall, as an opinion, topic, battle, thumb it, or any other public area or forum) can be read, collected, stored
and/or used by other users and could be used to send you unsolicited messages.
We strongly discourage you from disclosing any of your personal data in any public forum or community area that you may find on the site
and in particular, we would never ask you to provide your Contact data or Identity data on a public community area, even if it was part of a
survey. We cannot guarantee that third parties with whom you share your personal data via those public forums or community areas will
keep them secure or confidential. Please be aware that we are not responsible for the personal data you choose to submit or make public. In
addition, we are not responsible for the content you publicly post on the site that can be found via web-based search engines.
How do we use your personal data?
In the table below, we have set out a more detailed explanation of the ways in which we use your personal data. Where we use
any third parties for modelling, analytical or data matching purposes, please be assured that such parties are not allowed to use
your personal data for any reason, other than the reasons we state in the table and we enter into contracts with those third
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parties to ensure your data is kept secure, confidential and erased in accordance with our data retention and destruction policie
as set out in our Panelist Privacy Notice.
In many countries, we are required by law to explain the legal bases we rely on when we process your personal data. These
legal bases are listed as follows and we may use more than one lawful basis when processing your personal data.
Consent – In certain cases, we collect and process your personal data with your consent e.g. when you participate in surveys,
we will ask you if you wish to participate.
Contractual obligations – In some circumstances, we need to process your personal data to comply with a contractual
obligation e.g. when we use your personal data to send you your rewards.
Legal compliance – If the law requires us to, we may need to collect and process your personal data in response to lawful
requests by public authorities or if e.g. we believe in good faith that disclosure is necessary to protect our rights, to protect your
safety or the safety of others, to investigate fraud or breaches of our site terms, or to respond to a government request.
Legitimate interest – means the interest of our business in conducting and managing our business to enable us to give you th
best service/product and the best and most secure experience. We make sure we consider and balance any potential impact o
you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not us
your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are
otherwise required or permitted to by law).
Your Membership
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Your Membership (2)
Market research surveys
Scientific research/Safety monitoring (Pharmacovigilance Adverse Events Reporting)
Mobile Device surveys and usage
Profiling
Data matching and enrichment
Ad-Effectiveness campaigns & look-a-likes
Ad exposure and measurement
Legal/public authority disclosure
Fraudulent and quality checking
Who do we share your personal data with?
Any of our group members found at https://tolunacorporate.com/locations may access or use your personal data for the purpos
set out in table above and/or to carry out our regular business activities, such as to provide, maintain and personalize our sites
and services, to communicate with you, and to accomplish our legitimate business purposes, pursuant to contractual safeguard
In general, responses we collect from you via our surveys are provided to our clients either in anonymized and aggregated form
or in pseudonymized form. If we provide the results in anonymized and aggregated form, the results include information about
groups of individuals and not on an individual level. If we provide the results in pseudonymized form, the results will be on an
individual basis, using unique identifiers, such as your assigned panelist ID, but will not include your Identity data or Contact dat
Identity data or Contact data about you would only be provided to our clients in specific surveys for the purposes of research an
we would never provide such data to our clients unless we have first received your consent and confirmed with them that their
use is in accordance with applicable law and market research codes of practice.
From time to time we may engage third parties to issue you with cheques or processing the delivery of your rewards and /or
other third parties for the purposes of those parties providing us or our clients with services such as; data processing or analytic
services or to append data they previously collected about you. Such third parties are not allowed to use your personal data for
any other reason and we enter into contracts with those third parties to ensure your personal data is kept secure and erased in
accordance with our data retention and destruction policies.
From time to time, Toluna may use third-party software for email list management and email distribution or may use third-party l
management providers to match our Members to members of other lists or panels or to validate the accuracy of personal data
you provide. These companies are authorized to use your personal data only as necessary to provide these services to us,
pursuant to written instructions. In such cases, these companies must abide by our data privacy and security requirements and
are not allowed to use personal data they receive from us for any other purpose.
Though we make every effort to preserve your privacy, we may be required to disclose your personal data in response to lawfu
requests by public authorities, including to meet national security or law enforcement requirements. We may also disclose your
personal information as required by law, such as to comply with a subpoena or other legal process, when we believe in good fa
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that disclosure is necessary to protect our rights, to protect your safety or the safety of others, to investigate fraud or breaches o
our site terms, or to respond to a government request.
Please see the table above for more on these uses.
Do we transfer your personal data to other
countries?
Toluna is a global company and your personal data is transferred to other members of the Toluna group of companies and our
trusted service providers, who are located in countries other than where you live. Please be aware that laws in other countries
may differ from the laws applicable in your own country of residence. See in the attached list of all the Toluna
companies: https://tolunacorporate.com/about.
Toluna USA Inc., - The EU-U.S. Privacy Shield Framework
Our global back up and hosting service centre is located in the USA. Toluna USA Inc., (“Toluna USA”) is a member of the Tolun
group of companies and all data we use are transferred to Toluna USA for those purposes. Toluna USA recognises that the EEA
have established strict protections regarding the handling of personal data from the EEA, including requirements to provide
adequate protection for such personal data transferred outside of the EEA. Toluna ensures that it provides adequate protection
for the processing of certain EEA personal data about all individuals (including about you).
Toluna USA participates in and has certified its compliance with the EU-US Privacy Shield Framework Toluna is committed to
subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framewor
to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of
Commerce’s Privacy Shield List. [https://www.privacyshield.gov/list].
Toluna USA is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and
subsequently transfers to a third party acting as an agent on its behalf (Iron Mountain). Toluna USA complies with the Privacy
Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability
provisions. If there is any conflict between the terms of this privacy notice and the Privacy Shield Principles, the Privacy Shield
Principles shall govern.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Toluna is subject to the
regulatory enforcement powers of the US Federal Trade Commission. For more information about the Privacy Shield, see the U
Department of Commerce's Privacy Shield website located at https://www.privacyshield.gov. In certain circumstances, we may
be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or
law enforcement requirements.
In compliance with the Privacy Shield Principles, Toluna USA commits to resolve complaints about its collection or use of your
personal data. EEA individuals with enquiries or complaints regarding our Privacy Shield policy should first contact the Data
Protection Officer at [Contact Us].
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based
third party dispute resolution provider (free of charge) at feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described on the Privacy Shield website https://www.privacyshield.gov/article?id=How-toSubmit-a-Complaint, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been
exhausted.
You may have the option to select binding arbitration for the resolution of your complaint under certain circumstances, provided
you have taken the following steps: (1) raised your complaint directly with Toluna and provided us the opportunity to resolve the
issue; (2) made use of the independent dispute resolution mechanism identified under the How do you ask a question or make
complaint? paragraph below; and (3) raised the issue through the relevant data protection authority and allowed the US
Department of Commerce an opportunity to resolve the complaint at no cost to you. For more information on binding arbitration
see the US Department of Commerce Privacy Shield Framework: Annex 1 (Binding Arbitration)
at https://www.privacyshield.gov/EU-US-Framework.
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What other ways can you become a member of
our influencers panel? – Our mobile app
Mobile Applications
You may choose to become a Member by using our mobile application (app). When you download and use our mobile app, we
automatically collect system and performance information on the type of device you use, operating system version, device
identifier and hardware usage statistics such as CPU, RAM, storage, and app version. We will use the information we collect via
our mobile app in accordance with the terms of this privacy notice and the provisions set out below.
We send you push notifications from time-to-time in order to notify you about surveys and ask you if you would like to participate
in certain marketing research studies in accordance with this privacy notice. If you no longer wish to receive these types of
communications, you may turn them off at the device level. To ensure you receive proper notifications, we will need to collect
certain information about your device such as operating system and user identification information.
SMS
We may make available a service either directly or through third parties by which you can receive messages on your wireless
device via short message service ("SMS Service")
Your provider's standard data and messaging rates apply to all SMS correspondence. All charges are billed by and payable to
your mobile service provider. You represent that you are the owner or authorised user of the wireless device on which message
will be received and that you are authorised to approve the applicable charges. Personal data obtained from you in connection
with this SMS Service may include your Identity data and Contact data, your provider's name, and the date, time, and content o
your messages. The use of this information will be in accordance with this privacy notice. If fees are charged to your wireless
account invoice, we may be required to provide your carrier with your Identity data and Contact data in connection therewith.
Your wireless carrier and other service providers may also collect data about your wireless device usage, and their practices are
governed by their own policies. You acknowledge and agree that the SMS Service is provided via wireless systems which use
radios (and other means) to transmit communications over complex networks. We will not be liable for any delays in the receipt
of any SMS messages, as delivery is subject to effective transmission from your network operator. SMS message services are
provided on an as-is basis. We do not guarantee that your use of the SMS Service will be private or secure, and we are not liab
to you for any lack of privacy or security you may experience. You are fully responsible for taking precautions and providing
security measures best suited for your situation and intended use of the SMS Service. You can opt out from this service at any
time by going to your account page and unticking the option “I agree to receive invitations to surveys by SMS” in the Personal
Details tab. If available in your country, you may also be able opt out by text by following the instructions given to you in the SM
we send you.
Single Sign-ON
You can log in to our site using sign-in services such as Facebook Connect or an Open ID provider. These services will
authenticate your identity and provide you with the option of becoming a Member. Services like Facebook Connect give you the
option to post information about your activities on this site to your profile page to share with others within your network.
Referral
If you choose to use our referral service to tell a friend about our site, you may pass your unique referral link to your friend and i
your friend becomes a Member, we will provide you with Toluna points as a reward.
What cookies do we use on our site?
Our site uses cookies to distinguish you from other users of our site, and estimateS visits and click throughs for specific
campaigns. This helps us to provide you with a good experience when you browse our site and also allows us to improve our
site. These cookies expire when your browsing session ends. By continuing to browse the site, you are agreeing to our use of
cookies.
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A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree.
Cookies contain information that is transferred to your computer's hard drive.
For detailed information on the cookies we use and the purposes for which we use them, see our cookie policy
at: https://www.influencers.toluna.com/cookie-policy.
What other Tracking Technologies do we use for
surveys you participate in and for other
purposes?
Surveys - client cookie tracking, including for Ad effectiveness campaigns
We may share your unique panellist ID (UID) with our clients, who may write, set or read cookies or use other Technical data
about you from multiple locations, including our own servers or systems. If you participate, your UID will be stored or associated
with those Technical data to allow us and/or our clients to conduct online ad-effectiveness campaigns, track your visits to
websites, use your Demographic/Profile data to create look-a-like segments and/or gain other online insights about you. If you
have interacted with the online ad or promotion, our client will send your UID and the specific survey to us and we may provide
you with the opportunity to complete the survey.
Other Technologies
Automated technologies or interactions.
As you interact with the site, we will automatically collect Technical data about your equipment, browsing actions and patterns.
We collect this Technical data by using cookies, server logs, digital finger printing technologies and other similar technologies.
We may also receive Technical data about you if you visit other websites employing our cookies. Please see our cookie policy f
further details.
Server log files:
We may collect Internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating
system, date/time stamp, and/or clickstream data. This Technical data may be combined with other information collected about
you for the purposes of improving our services, site functionality and collecting analytical data.
Fingerprinting technologies:
In general, digital Fingerprinting technologies assign a unique identifier or "Machine-ID" to a user's computer to identify and trac
your device (“Technology"). The Technology will analyse publicly available information and data obtained from your computer's
web browser and from other publicly available data points, including the technical settings of your computer, the characteristics
your computer, and its IP Address, to create a unique identifier, which will be assigned to your device. We use the Technology fo
quality control, validation, and fraud detection and prevention purposes, including assisting us in ensuring the integrity of survey
results. Appropriate technical and operational processes and procedures will be put in place to ensure that the Technology is
safe, secure and does not cause undue privacy or data security risks and the Technology will be used and distributed in a
professional and ethical manner and in accordance with (a) this privacy notice, (b) any other statements and/or disclosures mad
to you as a member of the community and (c) applicable laws and market research codes of practice. In the event any unethica
conduct is discovered in connection with the use of the Technology, or that the Technology is being used in a manner that is
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inconsistent with privacy notice, immediate action will be taken to prohibit such unethical conduct and to ensure the proper
administration of the Technology.
Advertising
We partner with third parties to either display advertising on our site or to manage our advertising on other sites. Our third-party
partners may use technologies such as cookies to gather information about your activities on their site and other sites in order t
provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the
purpose of serving you interest-based ads, you may opt-out by clicking here. Please note this does not opt you out of being
served ads. You will continue to receive generic ads.
Digital Fingerprinting
In general, digital Fingerprinting technologies assign a unique identifier or "Machine-ID" to a user's computer to identify and trac
your computer. We will not use digital fingerprinting technology (the “Technology") to collect your Identity or Contact data, or trac
your online activities; and will not disrupt or interfere with the use or control of your computer or alter, modify or change its
settings or functionality. Occasionally, in specific market research programs, we will use the Technology to assist our clients in
ensuring the integrity of survey results. The Technology will analyse publicly available information and data obtained from your
computer's web browser and from other publicly available data points, including the technical settings of your computer, the
characteristics of your computer, and its IP Address, to create a unique identifier, which will be assigned to your computer. The
unique identifier will be an alpha-numeric ID In order to assist our clients in protecting and ensuring the integrity of survey result
we may; (a) link or associate your unique identifier to you and any of your personal data; (b) share your unique identifier with ou
clients and with other sample or panel providers; and (c) receive or obtain a unique identifier linked to you from a third party,
including without limitation a sample or panel provider or our client, however we will only provide such information to any third
parties (including our clients) on an aggregated and anonymised or pseudonymised basis. In addition, any unique identifier(s)
received or obtained by us and linked to you will be protected in accordance with this privacy notice and if required by law, we w
ask for your consent in advance.
We shall do everything we can to ensure that the Technology is safe, secure and does not cause undue privacy or data security
risks and we shall use and distribute the Technology in a professional and ethical manner and in accordance with (a) this privac
notice, (b) any other statements and/or disclosures made by us to you and (c) applicable laws and market research codes of
practice. In the event that we discover or learn of any unethical conduct in connection with the use of the Technology, or that the
Technology is being used in a manner that is inconsistent with the statements and/or disclosures made by us to you or is in
breach of applicable laws and the market research codes of conduct, we will take immediate action to prohibit such unethical
conduct and to ensure the proper administration of the Technology.
Social Media Widgets
Our site includes Social Media Features, such as the Facebook Like button (and Widgets, such as the Share This Button or
interactive mini-programs that run on our site). These Features may collect your IP address; which page you are visiting on our
site; and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a
third party or hosted directly on our site. Your interactions with these Features are governed by the privacy notice of the compan
providing it.
What is our winner’s policy and privacy
guarantee?
Members and others who take our surveys are randomly selected to win prizes for participation in surveys, content, games and
other promotions. All winners are notified by email or via our site of their winnings. Toluna shall post the usernames of winners o
our site and on our own blogs and newsletters. For more information, please visit our Terms and Conditions page. Cash and
other prizes awarded to non-members will be awarded directly.
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What security measures do we undertake to
protect your personal data?
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or access
in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents,
contractors and other third parties who have a business need to know. They will only process your personal data on our
instructions, and they are subject to a duty of confidentiality.
Although we do everything we can to keep your data safe, unfortunately no systems can guarantee they are 100% secure. If yo
have questions about the security of your personal data, or if you have reason to believe that the personal data that we hold
about you is no longer secure, please contact us immediately as described in this Privacy Notice.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable
regulator or supervisory authority of a breach where we are legally required to do so.
What are our data retention and destruction
policies?
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purpose
of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal
data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process
your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
As the results of the surveys and other aggregated or Pseudonymised data are used for research, scientific, historical and/or
statistical purposes (whether publicly or privately funded), we and our clients or other third parties may use this information for
such purposes in accordance with the terms indefinitely without further notice to you.
Business Transfers
As we continue to develop our business, we might sell or buy additional assets. In such transactions, Toluna's right to contact yo
as a Member and the information you have voluntarily provided in your user profile would generally be one of the transferred
business assets. Any merger, sale or transfer of Toluna of substantially or all of its business assets (which included our influence
panel), or other fundamental corporate transaction would be to an entity that agreed to comply with all of the material terms of o
privacy notice. You will be notified via email and/or a prominent notice will be posted on our site if any transaction may result in
any new proposed uses of your personal data which are incompatible with the uses set out in this Privacy Notice and of the
choices you may have regarding your personal data.
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Links
From time to time we may offer visitors the ability to voluntarily link to other sites. Toluna does not review, and is not responsible
for, the content or effect of the privacy policies of these sites.
Children’s privacy
Toluna will not knowingly collect any information from any child under the age of 16 without permission from his/her parents, leg
guardian or an adult responsible for the care of the child. Eligible ‘young people’ (individuals aged between 16 and 17) may be
invited to participate in our Teens panel from time to time. We comply with COPPA, the EU “Safer Internet programme”, the
General Data Protection Regulations and the ESOMAR guidelines in relation to surveys concerning children and young people
you are a parent or guardian of a child under 16 and become aware that your child has provided personal data to us and you a
not aware of such processing, please contact us as described in this Privacy Notice and we will take reasonable steps
immediately to remove any such information.
Your rights
How do you access your information; use the member services area and/or update, correct or delete your information?
Upon request, Toluna will provide you with information about whether we hold any of your personal data. You may access,
correct, or request deletion of your personal data, or terminate your membership by logging into your Member Account. By
following the appropriate directions, your information should be automatically updated in our database. For these purposes, and
if you are unable to correct your personal data yourself via the Account, you may write to us at the postal address found at the
end of this privacy notice, or contact us here. We will respond to all requests within a reasonable timeframe.
How do you terminate your panel membership?
If you choose to end your membership with Toluna or to require us to cease processing your personal data, you may discontinu
your membership by going to “Account” and selecting the "Unsubscribe" tab or by going directly to the page "Unsubscribe page
By following the appropriate directions, your record will be marked as "do not contact", and you will no longer receive
communications from Toluna. In addition, you will forfeit any incentive balance that has not been requested as of the time you o
out. As an alternative, you may send an email directly using the Contact us form requesting to be removed. Email links are
provided on the site so that you may contact us directly with any questions or concerns you may have. Each email we receive is
read and responded to individually. In most cases it will take 2 to 3 days to process this change, but please allow up to two full
weeks for your status to be finalised. Please note that you may continue to receive communications during this short period afte
changing your preferences while our systems are fully updated.
Data Retention
If you terminate your membership, we will no longer use your personal data to contact you, but in accordance with our backup
procedures, we will retain your personal data until your personal data are eventually destroyed in accordance with our data
retention and destruction policies and we will continue to employ the security procedures and technologies to keep your person
data safe.
How do you ask a question or make a complaint?
You can direct any questions or complaints about the use or disclosure of your personal data to our Privacy Contact. We will
investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your personal data within 30
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days of receiving your complaint.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based
third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request. Under certain
conditions, more fully described on the Privacy Shield website https://www.privacyshield.gov/article?id=How-to-Submit-aComplaint, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
Your other rights
You may:
request access to your personal data and we may conduct ID checks before we can respond to your request.
have your personal data erased, corrected or restricted if it is inaccurate or requires updating. You may also have the rig
under certain circumstances to request deletion of your personal data; however, this is not always possible due to legal
requirements and other obligations and factors. You can update your account information via your Account or by contacting
at the address given below.
object to the processing your personal data if we are not using your personal data for the purposes set out in this privacy
policy.
Your rights in California
You have certain rights under the California Consumer Privacy Act 2018 (CCPA) if you are citizen of California. You can exercis
the above rights by:
Calling us on our toll-free number [877-438-4224].
Email us at [Contact US].
Writing to us at the address given under the Privacy Contact Details; or
Following the process under the paragraph How do we terminate your influencer panel membership? above
If you wish to opt out of our Membership program, you may do so in accordance with the process under the paragraph How do
you terminate your influencers panel membership? above. Once you make an opt-out request, we will remove you from ou
Influencer panel and we will not contact you again unless you decide to re-register with us.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not exclude
you from participating in any Surveys you may be eligible for on the basis of you exercising your CCPA rights.
Please note that you do not have the right to the erasure of the results of any surveys you participated in and we have provided
to our clients in accordance with uses set out in the table under [How do we use your personal data?]. Those results may includ
your Demographic and Profile data and/or Technical data but will not include any of your Identity data or Contact data allowing
you to be directly identified. We don’t erase the results of the Surveys you participated in because we provide you with certain
financial incentives as permitted by the CCPA. When you became a Member, you opted in to participate in Surveys from time to
time and by way of a contract between you and us, we have provided you with certain rewards, such as; Toluna points and/or
participation in our sweepstakes in return for; your time; your participation in surveys; and giving us your opinions. The rules on
those rewards are found here: https://www.toluna.com/Terms
Changes to the privacy notice and your duty to
inform us of changes
This version was last updated on the date at the top of this privacy policy.
We reserve the right to modify this privacy statement at any time, so please review it frequently. If we do decide to change our
privacy notice, we will post those changes to this privacy statement on the homepage, or other places we deem appropriate so
that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If we
https://www.toluna.com/privacy
12/15
5/30/24, 6:37 PM
Privacy - Influence Your World | Toluna
make material changes to this policy, we will notify you here, by email, or by means of a notice on our home page prior to the
change becoming effective.
It is important that the personal data we hold about you is accurate and current. Please keep your Account details updated if yo
personal data changes during your relationship with us.
Privacy contact details
You may contact us by writing to:
The Data Protection Officer
Toluna
85 Uxbridge Road
W5 5TH
London
https://www.toluna.com/privacy
13/15
Privacy Policy | Prodege : Prodege
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Privacy Policy
United States and Canada
Play Video
NEW PRIVACY POLICY
1. Introduction
2. Information We Collect Directly
3. Information We Receive from Third Parties
4. Use and Sharing of Information
5. Friend Referrals
6. Community Features and User Content
7. Third Party Services
8. Advertising Networks
9. Session Replay and Analytics Companies
10. Cookies and Tracking Technologies
11. Card Linked Offers Programs
12. Social Features
13. Disclosure of Data
14. Business Transactions
15. Updating Your Information, Choice and Opt-Out
16. Notification of Privacy Policy Updates
17. Children's Privacy
18. Security
19. Location of Processing and Applicable Law
20. Contact Us
U.S. STATE PRIVACY NOTICE
A. Notice of Data Practices
B. Your Consumer Rights and How to Exercise Them
C. How We Process Your Consumer Privacy Requests
D. Non-Discrimination/Non-Retaliation
E. Notice of Financial Incentive Programs
F. Our Rights and the Rights of Others
G. Additional Notices for California Residents
Looking for Customer Support?
Find the Help Centers Below:
SwagbucksInboxDollarsMyPointsUpromiseTadaySense
NEW PRIVACY POLICY
This Privacy Policy was last updated on: August 1, 2023
1. Introduction
This "Privacy Policy" is for residents and persons located within the United States and
Canada. For all other visitors, please visit the international version of our Privacy
Policy here. We want you to be familiar with how we collect, use, and share your
Personally Identifiable Information (defined below). This Privacy Policy outlines the type
of information that we collect and receive from and about you via the Prodege Sites
and Features and our Services (both as defined below), and our data practices related
thereto, with additional disclosures for California, Colorado, Connecticut, Nevada, Utah
and Virginia residents in the U.S. State Privacy Notice section below. To the extent that
there is a conflict between this Privacy Policy and the U.S. State Privacy Notice section,
the U.S. State Privacy Notice section will control as to residents of those states. Please
review this Privacy Policy carefully, especially before providing any Personally
Identifiable Information through the Prodege Sites and Features or our Services. The
Prodege Sites and Features and our Services are generally operated in and controlled
from the United States of America unless otherwise stated.
Prodege Sites and Features and our Services may collect and use location-aware and
cross-device data for advertising and other purposes.
IF YOU DO NOT WISH TO HAVE US COLLECT, USE, AND SHARE INFORMATION AS
DESCRIBED IN THIS PRIVACY POLICY, PLEASE DO NOT USE ANY OF THE PRODEGE
SITES AND FEATURES OR OUR SERVICES.
Notice of Terms of Use, Including Arbitration: Your use of the Prodege Sites and
Features and our Services is subject to our Terms of Use, which includes binding
individual arbitration of any disputes which may arise in connection with such
use. Please note that your use of the Prodege Sites and Features or our Services
constitutes your express agreement to our Terms of Use, including its arbitration
provisions and class action waiver. Please read the Terms of Use—including the
arbitration provisions—carefully, and do not use any of the Prodege Sites and
Features or our Services if you do not agree.
Prodege, LLC and its Affiliates (defined below) (collectively, “Prodege,” “we,”
“our” or “us”) own and operate a number of different services, including, without
limitation, Swagbucks, MyPoints, InboxDollars, Upromise, CouponCause, Swagbucks
Live, MyGiftCardsPlus, ySense, Tada, DailyRewards, Pollfish, BitBurst, Easy Bucks,
AdGate Media, Prodege.com, and others that may be added from time to time
(collectively, the “Prodege Sites”). This Privacy Policy applies to the Prodege Sites and
to all of the features, websites, mobile applications, Internet browser extensions,
emails, online services and other functionalities (collectively, the “Features”) available
via or related to the Prodege Sites, whether accessed via a computer, mobile device, or
other devices you use (each a "Device" and collectively, “Devices”), or otherwise
(collectively, the “Prodege Sites and Features”), the services available on or through
the Prodege Sites and Features, including our emails and other electronic
communications (collectively, “our Services”). Unless specifically stated, such as in
the U.S. State Privacy Notice section, this Privacy Policy only covers information we
collect through Prodege Sites and Features and our Services and does not cover any
information we receive or collect offline or that is collected by any unrelated websites
or companies to which we may provide links. Please contact us with any questions
regarding this Privacy Policy and our privacy practices as instructed in Section 20
(Contact Us) of this Privacy Policy below.
2. Information We Collect Directly
When you visit any Prodege Sites and Features or use any of our Services, you may
share and/or we may automatically collect information that identifies you personally. In
this Privacy Policy, “Personally Identifiable Information” (or “PII”) refers to any
information that can reasonably be used to identify, contact or locate you; provided,
however, that the U.S. State Privacy Notice section applies a definition of personal
information under applicable state law that may be broader than PII. Examples of PII
may include, without limitation, your name, your precise geo-location, your credit card
number, your email address, your mailing address, and your phone number. We also
collect, and may create from PII, information about you that is not PII (“Non-PII”). If we
combine PII collected via Prodege Sites and Features or our Services with other of your
PII or with Non-PII, that combined data will be treated as PII subject to this Privacy
Policy.
PII and Non-PII may be collected on, through, or in connection with any of the Prodege
Sites and Features or our Services. For example, we may collect PII and/or Non-PII
when you create or register for an account with us, fill out surveys, join a mailing list,
upload receipts, correspond with us, enter one of our sweepstakes or contests, choose
to submit testimonials, stories, photos or the like, or otherwise volunteer or provide
information about yourself. You may also choose to install and use optional Internet
browser extensions, add-ons, or similar plug-in software and technologies (each an
"Extension" and collectively, “Extensions”) which may collect and use your information
in a variety of ways. For example, the Swagbucks SwagButton, MyPoints Score!, Tada,
InboxDollars Billy Button, Upromise Extension, ySense Addon, and similar software or
technologies we may offer from time to time are Extensions that allow you to shop
directly with our merchant partners and qualify for rewards. The Extensions also
provide other features and access to Offers (defined below), and allow you to monitor
your earnings, customize your account information or experience, and other activities.
If you install an Extension, we will automatically track certain websites you visit to allow
us to provide the aforementioned features and to correlate your browser history,
merchant visits, and Prodege Sites and Features engagements to provide better
Services and Offers to you. In addition, Tracking Technologies (defined below) may be
placed on your Devices when you install and use Extensions or when you click on an
affiliate or Ad Network (defined below) link within a shopping-rewards feature. Your
browsing activity on our merchant partners’ websites and other websites you visit may
be tracked by cookies, Extensions, or other Prodege Sites and Features having such
tracking capabilities. We may also use GPS or similar geo-location technology to
determine the geo-coordinates of where you or your Device are located. In addition,
our mobile applications may collect, among other things, certain information
automatically, including, but not limited to the type of mobile Device you use, your
mobile Device’s unique device identifier (“UDID”), the IP address of your mobile Device,
your mobile operating system, the type of mobile Internet browsers you use, and
information about the way you use the mobile application.
If you don’t provide us with or allow us to collect your PII, we generally will be unable to
provide you with our Services and you may be unable to use the Prodege Sites and
Features.
You may be able to limit data collection by changing the settings on your Device (but
our services and features may lose functionality as a result), or as otherwise explained
in the sections below.
3. Information We Receive from Third Parties
We may also receive and supplement the information we directly collect from or about
you with information from third parties, including Trusted Third Parties (defined
below), and to the extent it is combined with PII collected via Prodege Sites and
Features or our Services, it will be governed by this Privacy Policy. If you are on a third
party website or service and you opt-in to receive information from us, the third party
may forward to us your email address and other information about you so that we may
contact you as requested. In addition, we may receive information from Third Party
Services to ensure that you properly receive any qualified Offers and for our other Data
Purposes (defined below). We may also supplement and combine the PII we collect
about you with outside records from third parties in order to enhance our ability to
provide you with Offers and for our other Data Purposes, and to the extent it is
combined with PII collected via Prodege Sites and Features or our Services, it will be
governed by this Privacy Policy.
4. Use and Sharing of Information
We use your PII and non-PII we collect about you in order to: (i) provide you with our
Services; (ii) operate and improve the Prodege Sites and Features; (iii) provide
advertising, content, surveys, location-based deals, special offers, promotions, and
other rewards opportunities (collectively, “Offers”); and (iv) for other marketing,
administrative, operational, business, and commercial purposes subject to applicable
law and not inconsistent with this Privacy Policy or other notice by us at collection
(collectively, our “Data Purposes”). We may use and disclose Non-PII for any purpose
subject to applicable law and not inconsistent with this Privacy Policy or other notice by
us at collection. Without limitation, your PII and non-PII may be used by itself,
aggregated, or combined with unique identifiers (such as Prodege-assigned identifiers,
UDIDs, etc.), and shared with (a) our parent companies, subsidiaries, sister companies,
trusted agents and affiliated Services that we own and/or operate (“Affiliates”); and (b)
our service providers, vendors, advertisers, merchants, survey partners, joint business
ventures, and other trusted third parties (collectively, “Trusted Third Parties”) (some
of whom may offer Third Party Services (defined below)), for purposes related to our
business, including, without limitation, advertising, attribution, measurement of
campaigns, analytics and research, and our other Data Purposes as permitted by
applicable law. Notwithstanding the foregoing, no phone number you provide to us or
one of our mobile service providers (currently Airship, Twilio, Telesign, and Button) for
purposes of sending you a link for downloading a mobile app, special offer, a security
verification, text (SMS) marketing, or otherwise, will be used or shared with any third
party to be used for any other purpose, except as may be permitted or required by law
or legal process or with your consent or at your direction.
5. Friend Referrals
We may provide you with an opportunity to invite your friends, family, and
acquaintances (“Friends”) to use our Services. If you elect to use our referral service for
informing a Friend about any of our Services, you may provide us with your Friend’s
name and email address. Through our referral service, you may have the ability to
direct us to automatically send the Friend one or more emails or other
communications, on your behalf, inviting them to visit or register for our Services
(which invite may include additional subsequent reminders and communications). You
must have your Friend’s consent to provide us with his or her information for this
purpose and should not knowingly give us referral information for any person not
permitted to use the Prodege Sites and Features, including, without limitation, a child
under the age of 13, a person whose account has previously been suspended or
deactivated, or a person who resides or is located in a territory where use of the
Prodege Sites and Features is not authorized.
6. Community Features and User Content
The Prodege Sites and Features may provide you the opportunity to participate in,
make available, and/or post text (e.g., questions, comments, and suggestions), images,
audio, videos, or other content (collectively, “User Content”) publicly through our
blogs, chat rooms, forums, interactive features, public-facing member profile, thirdparty social networking services or other communication functionality (“Community
Features”). Please note that certain information, such as your username, Service start
date, earning preferences, qualified rewards, profile picture and other profile
information we believe will help motivate you and others to participate in our program
may be publicly displayed on the Prodege Sites and Features along with User Content.
User Content may also contain metadata, which may contain information about or
relating to you, that we may also collect, share and use. Anything posted through
Community Features is publicly available. This means that others will have access to
that User Content and may use it or share it with third parties; this is beyond our
control. If you choose to voluntarily disclose PII in the User Content and/or on the
Community Features, that information will be considered publicly available information
as well. The protections of this Privacy Policy will not apply to publicly available
information. In addition, by posting through our Community Features, you are agreeing
that we may use your User Content (and excerpts from your User Content) in
connection with our Data Purposes.
7. Third Party Services
The Prodege Sites and Features contain links to, or otherwise enable the opportunity to
interact with (e.g., Facebook button), other websites, and other services provided by
Trusted Third Parties (such as when you link to their site to take a survey or transact
with them to qualify for rewards) that we do not own, operate nor control (“Third Party
Services”). In addition, because aspects of the Prodege Sites and Features include
third-party Offers, Third Party Services may collect your information based on your
interaction with those Offers, including via Tracking Technologies (defined and
discussed below). In addition, by interacting with Offers via Prodege Sites and Features
or our Services, you authorize and direct us to share your PII and non-PII with Third
Party Services making Offers, and for them to share Offer-related activity data and
other information with us. This helps us and them make and fulfill Offers, including
making it easier for you to sign up for Offers, facilitating your communications or
transactions with them, authenticating and/or validating your identification, crediting
you with any qualified rewards, and for our other Data Purposes. Except as legally
required for our service providers, the privacy and other practices of Third Party
Services are not covered by this Privacy Policy, and we are not responsible for their
privacy or other practices. We encourage our users to be aware of and to read the
privacy statements, terms of service and similar disclosures and conditions of Third
Party Services that collect PII or other data before visiting or otherwise interacting with
those services.
For more information on Third Party Services, see sections 8, 9, 11 and 12 of this
Privacy Policy (Advertising Networks, Session Replay and Analytics Companies, Card
Linked Offers Programs and Social Features).
8. Advertising Networks
Companies that host networks connecting advertisers with delivery platforms for
digital advertising (collectively, “Ad Networks”), which are Third Party Services, may
provide advertising based on your interests, as reflected in your use of Prodege Sites
and Features and our Services, as well as your use of other websites and services.
Some of these Ad Networks may place persistent cookies or other Tracking
Technologies (defined below) on your Devices, allowing them to recognize you and/or
your Device each time they send you an online advertisement. Ads themselves may
also include Tracking Technologies. In this way, Ad Networks may compile information
about where you see advertisements online and determine which ads you click on, so,
for instance, that we and they may provide you with Offers or advertisements believed
to be of most interest to you. We are not the data controller for the cookies or other
Tracking Technologies that may be placed by these third parties on your Devices, nor
do we have responsibility for these third parties’ privacy policies or information
collection practices. You may limit or remove such cookies and Tracking Technologies
through your Device settings; for more information, visit section 10(ii) (What Are My
Cookie Choices?) below.
9. Session Replay and Analytics Companies
We use certain third-party analytics and/or other technology providers to help us
understand how you use Prodege Sites and Features or our Services, and these
companies may set their own cookies and other Tracking Technologies on your
Devices. For example, we may use third-party services to record and review your
interactions with the Prodege Sites and Features and our Services, including mouse
movements, clicks, page visits, keystrokes/key touches, and other details, including any
PII that you provide. These “session replay” services help us organize and analyze your
interaction data for our Data Purposes, including to improve and prevent fraud related
to Prodege Sites and Features and our Services. By using any of the Prodege Sites and
Features or our Services, you expressly consent to the recording and sharing of your PII
and other data with third-party “session replay” services and other analytics providers.
We may also use Google Analytics and similar third-party analytics providers to track
visitors’ activity on our website. Google Analytics and similar third-party analytics
providers may also use web browsing data and other data analysis to improve their
own products. For more information on how to limit this activity, including to learn
about the opt-out mechanism Google offers, visit section 10(ii) (What Are My Cookie
Choices?) below. These and other Trusted Third Parties may collect information about
you, including but not limited to your online activities over time and across different
websites and services, when you use the Prodege Sites and Features or our Services, or
other online websites and services.
10. Cookies and Tracking Technologies
i.
Use of Cookies and Tracking Technologies
We set and access, and third parties (including Trusted Third Parties) may set and
access, cookies, web beacons, embedded scripts, pixels, tags, software development
kits (“SDKs”), session replay tools, and other tracking technologies (collectively,
“Tracking Technologies”) on your Devices in connection with your use of Prodege Sites
and Features or our Services. Such third parties (“Cookie Operators”) may collect
information across various channels using Tracking Technologies for purposes of
delivering more relevant Offers to you or other Business Purposes. We may use a
variety of Tracking Technologies in connection with our Data Purposes. Tracking
Technologies may automatically capture PII and other information, including, without
limitation, your IP Address, UDID, and browser or operating system type and version,
and may detect whether your Device or software has certain capabilities such as a
microphone or webcam access. We and Third Party Services generally use Tracking
Technologies and the information they generate to support the Prodege Sites and
Features and our Services or Third Party Services, including, for instance: (i) by offering
you surveys, shopping, and other targeted Offers; (ii) for identity verification; (iii) for
analytics; (iv) to ensure compliance with our programs; and (v) to identify and honor
your choices (such as opt-outs). Tracking Technologies may also be used as follows: (a)
to provide you with convenience when you access the Prodege Sites and Features or
our Services by remembering that you have visited us before and by remembering
your username, password and other user information, and your preferences to help
you avoid future re-entry of certain information; (b) to allow us and Third Party
Services to understand or predict your interests so we and they can personalize your
experience on Prodege Sites and Features or our Services and elsewhere online, across
Devices, web browsers, email, mobile and other applications. In doing so, we and
Third Party Services may link the information collected from Tracking Technologies,
and from other sources, with other of your PII and non-PII, and we and they may track
your web-browsing and other activity in order to provide you with Offers and for our or
their other Data Purposes); (c) for analytical and statistical purposes, quality control,
validation and verification purposes, and to improve the services we and Third Party
Services offer; and (d) Third Party Services may link the information we share with them
(or that they collect) to cookies stored on your browser or Devices, and they may collect
information such as your IP address, UDID, browser or operating system type and
version, and demographic or inferred-interest information. Third Party Services may
use this information to recognize you across different channels and platforms,
including but not limited to, computers, mobile devices, and Smart TVs, over time for
advertising, analytics, attribution, and reporting purposes. For example, Third Party
Services may deliver an advertisement to you in your web browser based on a
purchase you made in a physical retail store, or they may send a personalized
marketing email to you because you visited a particular website. Our mobile
applications may include Tracking Technologies that share your Device’s precise geolocation and other details about your Device (like hardware characteristics, a variety of
sensor data, and a list and history of installed third-party applications) with Third Party
Services who may use this information to generate Offers for you, for advertising,
attribution, measurement of campaigns, analytics, and research, and their or our other
Data Purposes. See instructions to limit or disable such tracking in section 10(ii) below;
but be aware that limiting such tracking will affect some Device or mobile application
functionality and may limit your ability to use our Services, complete Offers and earn
rewards.
ii.
What Are My Cookie Choices?
Cookies may include a small data file which is stored on your systems. We use both
session cookies and persistent cookies. For the session cookies, once you close your
browser, the cookie terminates. A persistent cookie is a small text file stored on your
hard drive for an extended period of time. Persistent cookies can be removed or
disabled by following your web browser help-file directions.
You can exercise control over browser-based cookies by adjusting the settings on your
browser, and mobile Devices may offer ad and data limitation choices. Please note that
when you use cookie control tools, you will have to change your settings for each
browser and Device you use, and your limitation on cookies can limit the functionality
of online services you use, including Prodege Sites and Features and our Services. Use
the help function on your browser or click on the applicable links below to learn more:
Google Chrome
Firefox
Internet Explorer
Edge
Safari
If you block cookies in this manner, Prodege Sites and Features and our Services
(including the ability to complete Offers and earn rewards), may not operate as
intended.
One use of cookies is interest-based advertising, which uses your activity information
to help provide you with more relevant Offers. To learn more about internet-based
advertising in general, and exercise certain opt-outs that some Ad Networks provide,
which may include use of geo-location, cross-device data-directed, and/or “audience
matched advertising” ads, please visit the following ad industry self-regulatory
resources:
Digital Advertising
US: http://www.aboutads.info/choices
Alliance
Canada: https://youradchoices.ca/en/tools
(Web Browser Opt-Out)
Digital Advertising
Alliance
(Mobile App Opt-Out)
US: http://www.aboutads.info/appchoices
Canada: https://youradchoices.ca/en/tools
Network Advertising
Initiative
(Opt-Outs)
http://www.networkadvertising.org/managing/opt_out.asp
We support these self-regulatory programs and expect the Ad Networks we work with
to do so as well. If you’d like to opt-out of being tracked by Google Analytics, simply
install this add-on to your browser: https://tools.google.com/dlpage/gaoptout.
We are not responsible for the completeness, accuracy or effectiveness of any thirdparty cookie-choice programs or tools. If you exercise these choice controls they may
need to be compiled on each browser and Device you use, and if they use a cookie to
signal your opt-out, your choice may no longer be recognizable if you later clear or
block cookies. Not accepting cookies (or opting out of cookies), installing ad blocking
technologies, and/or disabling analytics providers may make certain features of the
Prodege Sites and Features and our Services unavailable to you and may affect our
ability to validate whether or not you qualified for a reward by successfully completing
an Offer.
Note that your browser settings may allow you to automatically transmit a “Do Not
Track” signal to websites and online services you visit. At present, we do not believe
that there is a consensus among industry participants as to what “Do Not Track” means
in this context. Like many websites and online services, we currently do not alter our
practices when we receive a “Do Not Track” signal from a user’s browser. To find out
more about “Do Not Track,” you may wish to visit http://www.allaboutdnt.com.
11. Card Linked Offers Programs
We may offer a service enabling you to enroll a qualifying payment card in order to
earn rewards or benefits when you make qualifying transactions with participating
merchants (a “CLO Program”). Your participation in a CLO Program is further governed
by our Card Linked Offer Service Terms. If you participate in a CLO Program and
provide your payment information for that purpose, we and Third Party Services
(including, without limitation, Braintree Payments (a division of PayPal, Inc.), Visa, Inc.,
Rewards Network, and Figg, Inc.) will have the right to use and share the transaction
information generated in such CLO Program (“CLO Transaction Data”) for the
purposes of operating and improving the CLO Program, including, without limitation:
(a) to confirm whether you qualify for an Offer; (b) to confirm whether a specific
transaction occurred or rewards were earned (for example, the date and amount of
your purchase and the last 4 digits of your card number so the merchant can verify
your purchase if there is a missing or disputed transaction); (c) to allow participating
merchants and others to assess the results of their campaign and analyze ways to
improve or optimize a CLO Program and its Offers; (d) to create a record of the CLO
Transaction Data and thereafter maintain and use such CLO Transaction Data in
connection with operating the CLO Program; and (e) to provide information in
response to a request from a government authority or a payment organization
involved in a transaction with you, a merchant, another relevant Trusted Third Party, or
others. By participating in a CLO Program, you authorize and direct the sharing,
exchange, and use of CLO Transaction Data described above and herein by and
among us and Third Party Services, applicable payment card networks, and
participating merchants. Please visit the Card Linked Offer Service Terms to learn
more about the data collection, use, and sharing practices related to the CLO Program.
If you would like to opt out of card linking and CLO Transaction Data collection in
connection with a CLO Program, please visit the card linking section of the applicable
Service and remove any payment cards that you no longer wish to be associated with
the CLO Program.
12. Social Features
Certain functionality on Prodege Sites and Features or our Services may permit
interactions that you initiate between our Services and third-party social media services
(“Social Media Services”) such as Google, Apple, Facebook, Pinterest, Instagram and
Twitter (“Social Features”). Examples of Social Features include enabling you to “like”
or “share” content from our Services with Social Media Services; to log-in to our
Services using your username and password for Social Media Services; to transmit
content to or from our Services to or from your account on Social Media Services; and
to otherwise connect our Services to Social Media Services. Enabling or interacting with
Social Features may also set one or more cookies or other Tracking Technologies on
your Devices. Please refer to the terms of use and privacy policies of such Social Media
Services offering such Social Features. If you choose to use Social Features, information
you post or provide access to may be shared with and publicly displayed on our
Services or on such Social Media Services. Similarly, if you post information on a Social
Media Service that references any of our Services (e.g., by using a hashtag associated
with any of our Services in a tweet or status update), your post may be published on
the Prodege Sites and Features in accordance with the terms of the Social Media
Services and our Terms of Use. In addition, we may receive information about you if
other users of a Social Media Service give us access to their profiles and you are one of
their “connections,” or information about you is otherwise accessible through your
connections’ web pages, profile pages, groups you or they belong to, or similar pages
on such Social Media Service.
The information we collect in connection with Social Features is subject to this Privacy
Policy. The information collected by any Social Media Service via Social Features
remains subject to their privacy practices, including whether they continue to share
information with us, the types of information shared, and your choices with regard to
what is visible to others on such Social Media Service.
13. Disclosure of Data
In addition to the types of disclosure and sharing of data described throughout this
Privacy Policy, we may disclose your PII and non-PII as described in this section. We
may disclose your PII and non-PII when required by law, or where we have a good-faith
belief that such action is necessary to comply with a judicial or administrative
proceeding, a criminal investigation, a court order, or legal process served on us. We
may also share your PII and non-PII at the request of governmental authorities
conducting an investigation, or if we in our sole discretion believe there to be a credible
situation that requires us to investigate, prevent, or take action regarding illegal
activities, suspected fraud or abuse, situations involving potential threats to the
physical safety of any person, or violations of our Terms of Use or Privacy Policy for any
of the Prodege Sites and Features or our Services. We may also use IP addresses, UDID
or other Device, activity or session identifiers to identify users, and we reserve the right
(in our sole discretion) to do so in cooperation with Third Party Services, as well as
copyright owners, Internet service providers, wireless service providers, or law
enforcement agencies, without notice to you. We may also share your PII with Third
Party Services in connection with their performance of services to, or on behalf of, the
Prodege Sites and Features or our Services (and vice versa) and for our Data Purposes.
In addition, if you use our mobile applications, we may share your current geo-location
with Third Party Services so that we or they may provide you with Offers based on your
location, for our Data Purposes, and for advertising, attribution, measurement of
campaigns, analytics and research. Please see section 15 (Updating Your Information,
Choice and Opt-Out) below for information about how you can opt out of such
sharing.
We may share or sell aggregate or individualized information about you that may
include, without limitation: (1) your PII and related information; (2) your use of the
Prodege Sites and Features and our Services; (3) Third Party Services and other
websites you visit; and (4) your geo-location and information derived therefrom. We
share this information with Trusted Third Parties for the purpose of providing you with
Offers and for our Data Purposes.
14. Business Transactions
In the event Prodege or any of its Affiliates is involved with a business transition, such
as a financing, merger, consolidation, restructuring, acquisition by another company,
sale or assignment of rights or assets (or a portion thereof), or other company change,
we may transfer your and other users’ information, including PII and non-PII, and other
business data in connection with that business transaction (e.g., to a subsequent owner
or operator of Prodege or any of our Services, or any affiliates, agents, service
providers, or partners of the foregoing), including during the course of any due
diligence process (collectively, “Business Transactions”).
15. Updating Your Information, Choice and Opt-Out
You are responsible for maintaining the accuracy of any information you submit to us,
such as your contact information. If you have any questions about updating your
information, privacy choices and/or opting out of certain programs, services, and data
activities, please visit section 20 (Contact Us) below for more information and
instructions to contact us. You may opt out of receiving marketing emails by: (i)
following the opt-out instructions provided to you in those emails; (ii) visiting your
account settings or similar features on the relevant Prodege Sites and Features; or (iii)
contacting us as provided in section 20 (Contact Us) below. Please note that as long as
you remain registered with or a user of any of the Prodege Sites and Features or our
Services, even if you opt out of marketing emails, you may still receive administrative
and transactional emails, such as notices about service and status updates and
changes to our Terms of Use or Privacy Policy. If you sign up to receive text (SMS)
messages from the Prodege Sites and Features, you may unsubscribe from any text
SMS messages received by replying “STOP”. If you do not wish to receive
advertisements, content, surveys, promotions, Offers, or rewards from us by virtue of
your installation of our Extensions, you should not install or should uninstall such
Extensions. You may remove or disable cookies and/or opt out of interest-based
advertising as described above in section 10(ii) (What Are My Cookie Choices?) and you
may clear your browser history in accordance with the system settings of your web
browser. You may also opt out of providing your geo-location information to us by
turning off the location services for your Device located in your account settings (if
available) or in your Device settings. If you do not want our mobile applications to
collect any PII or non-PII about you, you should uninstall the application using the
standard uninstall procedures that may be available as part of your mobile Device or
via the mobile application marketplace or network where you obtained the mobile
application.
16. Notification of Privacy Policy Updates
We reserve the right to make changes to this Privacy Policy from time to time via
updates. If we decide to make an update with material changes to this Privacy Policy,
we will provide notice of the update by sending you an administrative email and/or
posting links to the updated Privacy Policy in places on the Prodege Sites and Features
deemed appropriate by us so our users are always aware of what PII and other
information we collect, how we use it, and under what circumstances it may be shared
with others. Your continued use of any of the Prodege Sites and Features and our
Services after delivery of the administrative email to you, or after the update links are
posted, constitutes your acceptance of the updated Privacy Policy as to any continued
use of the Prodege Sites and Features and our Services, including our future use of PII
or other information previously or thereafter collected in accordance with the updated
Privacy Policy. If you do not accept the changes, please immediately discontinue your
use of any Prodege Sites and Features and our Services and close your account with
us.
17. Children's Privacy
The Prodege Sites and Features and our Services are for general audiences, and we do
not knowingly collect any personal information (as defined by the federal Children’s
Online Privacy Protection Act (“COPPA”)) from children younger than the age of 13. If
you are under the age of majority (18 in most states and provinces), you should use the
Prodege Sites and Features and our Services only with the permission and guidance of
your parent or guardian. If you are under 13, you should not use our Service. If we
learn that we have inadvertently collected personal information from a child younger
than 13, we will take actions as required by COPPA.
If a California resident is known to us to be under 16 years of age, we will obtain any
required expressed opt-in consent to any sale of their personal information collected
by the Prodege Sites and Features or our Services, in accordance with the CCPA and
applicable regulations thereunder. California minors also have certain rights to remove
their own public posts on the Prodege Sites and Features. More information is
included in section G (Additional Notices for California Residents) of the U.S. State
Privacy Notice below.
18. Security
We maintain security measures in place to help protect against the loss, misuse and
alteration of the PII and other information under our control. Please be advised,
however, that the Internet and other technologies and communication channels are, by
their nature, not entirely secure, and your PII and non-PII may therefore be subject to
interception or loss which is beyond our reasonable control. While we strive to protect
your PII and non-PII, we cannot ensure or warrant the security of any PII or non-PII you
transmit to us or that we otherwise collect, and any transmission is done at your own
risk. Accordingly, as permitted by applicable law, we assume no responsibility or
liability for disclosure of your PII or non-PII due to errors in transmission, unauthorized
third-party access, or other causes beyond our reasonable control.
19. Location of Processing and Applicable Law
Although we generally maintain our user data in the United States, it is possible that
some of the data processing may occur outside of the United States, carried out by
companies or individuals under contract with us. While the data protection laws of
these countries may vary, we will make every reasonable effort to protect your PII in
accordance with this Privacy Policy. By using the Prodege Sites and Features and our
Services, you consent to this transfer of your PII and non-PII to any server used by
Prodege or its service providers from time to time.
If you are not a resident of the United States or Canada, please consult the
international version of our Privacy Policy here and be aware that data protection laws
in the United States and Canada (as well as the legal procedures for courts,
governmental authorities, and parties in civil litigation to obtain access to our user
data) may differ substantially from the laws and procedures in your country of
residence. In addition, if you submit your PII to us, you are consenting to the
processing, storage, use and transfer of that PII within the United States as provided in
this Privacy Policy.
The interpretation and application of this Privacy Policy shall be governed by the laws
of the United States and the State of California without regard to its conflict of law
provisions. Except as otherwise expressly provided in our Terms of Use, your use of the
Prodege Sites and Features or our Services are not intended to subject us to the laws
or jurisdiction of any state, country or territory other than that of the United States and
the State of California.
20. Contact Us
If you have any questions or concerns regarding this Privacy Policy or your use of any
Prodege Sites and Features or our Services, please visit our Help Center or contact
options (located or accessed from the applicable Prodege Sites and Features footer or
from main menu options). For questions relating to our privacy practices (other than
California residents making CCPA requests), please visit the Privacy section of the
appropriate Help Center. If your question is not answered in the Help Center, you can
submit a privacy-related request by submitting a ticket to our Customer Support team
for the appropriate Service. To contact us by mail, send your correspondence to the
following address and specify the Prodege Sites and Features or our Services you are
using along with your request, question or concern:
Prodege, LLC, 8605 Santa Monica Blvd, PMB 36227, West Hollywood, California 900694109, Attention: Privacy
U.S. STATE PRIVACY NOTICE
This U.S. State Privacy Notice (“Notice”) applies to “Consumers” as defined respectively
under the California Consumer Privacy Act, as amended by the California Privacy Rights
Act (together, the “CCPA”), the Colorado Privacy Act, Connecticut’s Act Concerning
Personal Data Privacy and Online Monitoring, Chapter 603A of the Nevada Revised
Statutes, the Utah Consumer Privacy Act, and the Virginia Consumer Data Protection
Act, and all laws implementing, supplementing, or amending the foregoing, including
regulations promulgated thereunder, as well as any additional U.S. state privacy laws
now or hereafter applicable to the Company (collectively, “U.S. State Privacy
Laws”). Capitalized terms used but not defined in this Notice shall have the meanings
given to them under the relevant U.S. State Privacy Laws or (if applicable) in other
sections of our Privacy Policy.
Applicability:
Section A of this Notice provides notice of our data practices, including our
collection, use, disclosure, and sale of Consumers’ personal information or
personal data under relevant U.S. State Privacy Laws (collectively, “PI”).
Sections B-F of this Notice provide information regarding Consumer rights under
applicable U.S. State Privacy Laws and how you may exercise them.
Section G of this Notice provides additional information for California residents
only.
For California residents, the term “Consumer” is not limited to data subjects acting as
individuals regarding household goods and services and includes data subjects in a
business-to-business context (e.g., as a service provider or customer, or an employee
of a service provider or customer). This is not the case in the other states.
Non-Applicability, Human Resources: This Notice does not apply to our job applicants,
current or former employees, or independent contractors (“Personnel”) in connection
with their PI collected in connection with such relationship with the Company; however,
our California Personnel may obtain a separate privacy notice that applies to them by
contacting our Human Resources department at [email protected].
A. Notice of Data Practices
The description of our data practices in this Notice covers the twelve (12) months prior
to the Effective Date and will be updated at least annually. Our data practices may
differ between updates to this Notice; however, if materially different from this Notice,
we will provide supplemental pre-collection notice of the current practices, which may
include references to other privacy policies, notices, or statements. Otherwise, this
Notice serves as our notice at collection.
We may receive or collect your PI directly from you or from your Devices, from Third
Party Services, or from other individuals and businesses, as well as public sources of
data.
Generally, we Process your PI to provide you our Services and as otherwise related to
the operation of our business, including for one or more of the following Business
Purposes: Performing Services; Managing Interactions and Transactions;
Security; Debugging; Providing Advertising & Marketing Services; Quality Assurance;
Processing Interactions and Transactions; and Research and Development. We may
also use PI for other Business Purposes in a context that is not a Sale or Share under
applicable U.S. State Privacy Laws, such as disclosing it to our Service Providers,
Contractors, or Processors that perform services for us (“Vendors”), to you, or to other
parties at your direction or through your action (e.g., Third Party Services that you
interact with in response to Offers); for the additional purposes explained at the time
of collection (such as in the applicable privacy policy or notice); as required or
permitted by applicable law; to the government or private parties to comply with law or
legal process; and in Business Transactions (collectively, “Additional Business
Purposes”). Subject to restrictions and obligations under U.S. State Privacy Laws, our
Vendors may also use your PI for Business Purposes and Additional Business Purposes
and may engage their own vendors to enable them to perform services for us.
We may also use and disclose your PI under this Notice for Commercial Purposes,
which may be considered a “Sale” or “Share” under applicable U.S. State Privacy Laws,
such as when Trusted Third Parties collect your PI via third-party cookies, and when we
Process PI for certain advertising purposes. In addition, we may make your PI available
to third parties for their own use via third-party cookies or otherwise.
As permitted by applicable law, we do not treat deidentified data or aggregate
consumer information as PI and we reserve the right to convert, or permit others to
convert, your PI into deidentified or aggregate consumer information, and may elect
not to treat publicly available information as PI. We have no obligation to re-identify
information or keep it longer than we need it to respond to your requests. Data
exempt from U.S. State Privacy Laws are not included in this Notice.
We provide more detail on our data practices in the two charts that follow.
i.
PI Collection, Disclosure, and Retention – By Category of PI
We collect, disclose, and retain PI as follows:
Category of PI
Examples of PI Collected and Retained
1. Identifiers
This may include, but is not limited to: a real name,
alias, postal address, unique personal identifier,
online identifier, Internet Protocol address, email
address, account name, social security number,
driver's license number, or other similar
identifiers.
2. Personal
Records
This may include, but is not limited to: physical
characteristics or description, signature, telephone
number, education, employment, employment
history, bank account number, credit card number,
debit card number, or any other financial
information.
3. Personal
Characteristics
or Traits
This may include, but is not limited to: age, gender,
nationality, race, or information related to medical
conditions.
4. Customer
Account Details/
Commercial
Information
This may include but is not limited to: records of
personal property, products or services
purchased, obtained, or considered, or other
purchasing or consuming histories or tendencies.
5. Internet
Usage
Information
This may include, but is not limited to: browsing
history, search history, and information regarding
your interaction with an Internet Web site,
application, or advertisement.
6. Geo-location
Data
This may include, but is not limited to: precise
physical location or movements and travel
patterns.
7. Sensory
Data
This may include, but is not limited to: audio
recordings of customer care calls, electronic,
visual, thermal, olfactory, or similar information.
8. Professional
or Employment
Information
This may include, but is not limited to:
professional, educational, or employment-related
information
Categories of
Recipients
Business Purpose
Disclosure:
Service
Providers
(e.g., data
processors,
IT service
providers,
storage
vendors,
marketing
service
providers,
security
providers,
and
professional
advisors)
Affiliates
Government
entities
(where we
are under a
duty to
disclose or
to protect
our rights
or the rights
of others)
Other parties
within the
limits of
Additional
Business
Purposes
(e.g., when
you engage
Category of PI
Examples of PI Collected and Retained
9. Inferences
from PI
Collected
This may include, but is not limited to: creating a
profile about a Consumer reflecting the
Consumer’s preferences, characteristics,
psychological trends, predispositions, behavior,
attitudes, intelligence, abilities, and aptitudes.
10. Sensitive PI
Precise Geo-location (any data that is derived from
a device and that may locate a consumer within a
geographic area with a radius of 1,850 feet or less)
Sensitive Personal Characteristics (e.g., racial or
ethnic origin, religious or philosophical beliefs,
citizenship or immigration status, or union
membership)
Health Information (PI collected and analyzed
concerning a consumer’s health, medical history,
mental or physical health, diagnosis/condition, and
medical treatment)
Categories of
Recipients
in Offer
actions with
Third Party
Services)
Sale/Share:
Cookie
Operators
(only to the
extent such
data is
collected by
a cookie or
other
Tracking
Technology)
Licensees
Sex Life / Sexual Orientation (PI collected and
analyzed concerning a consumer’s sex life or
sexual orientation)
Financial Data (e.g., a consumer’s account log-in,
financial account, debit card, or credit card
number in combination with any required security
or access code, password, or credentials allowing
access to an account)
Government Issued Identification Numbers (e.g.,
social security, driver’s license, state identification
card, or passport number)
Communication Content (e.g., the contents of a
consumer’s mail, email, and text messages, unless
the business is the intended recipient of the
communication)
Business Purpose
Disclosure:
Service
Providers
(e.g., data
processors,
IT service
providers,
storage
vendors,
marketing
service
providers,
security
providers,
and
Category of PI
Examples of PI Collected and Retained
Categories of
Recipients
professional
advisors)
Affiliates
Government
entities
(where we
are under a
duty to
disclose or
to protect
our rights
or the rights
of others)
Other parties
within the
limits of
Additional
Business
Purposes
(e.g., when
you engage
in Offer
actions with
Third Party
Services)
Sale/Share:
None
We retain your PI based on how long we believe we have a legitimate purpose for the
retention. In general, we retain all categories of PI listed in the chart above for as long
as a customer account is open and for an additional 3 years after the account is closed;
however, some data may be retained for a shorter or longer period. When deciding
how long to keep your PI, we consider (among other things) whether we have an active
relationship with you, whether we need to retain the PI to provide you our Services,
whether we are subject to any legal obligations (e.g., any contracts or laws that require
us to maintain certain data for a certain period of time), our Data Purposes, and our
Business Purposes and Additional Business Purposes. Rather than delete your PI, we
might deidentify it by removing identifying details so it is no longer considered PI, in
which event we will not attempt to re-identify that data.
There may be additional information we collect that meets the definition of PI under
applicable U.S. State Privacy Laws but is not reflected by a category above, in which
case we will treat it as PI as required but will not include it when we describe our
practices by PI category.
ii.
PI Use and Disclosure – By Processing Purpose
We use and disclose PI for the processing purposes described below. For the categories
of recipients for each purpose, please refer to the chart above at Section A(i) (PI
Collection, Disclosure, and Retention – By Category of PI), as indicated by relevant
category of PI below:
Processing
Purpose(s)
1. Performing
Services
Example(s) of Processing Purpose
Provide our Services: to provide you with
Prodege Sites and Features and our Services,
including Offers
Enable additional features: to provide you
with additional Prodege Sites and Features
and enhance our Services
Process orders: to process or fulfil an order or
transaction
Contact You: to contact and communicate
with you about your use of our Services,
including changes to our Services or our
Services’ policies
Account management: to process your
registration with our Services, verify your info
is active and valid, and otherwise manage
your account
Customer Service: to respond to any
questions, comments, or requests you have
for us or for other customer service purposes
Payment and other purchase-related
purposes: to facilitate a purchase made using
our Services, including payment processing
Categories of PI
Implicated
Identifiers, Customer
Account
Details/Commercial
Information, Internet
Usage Information,
Geo-location Data,
Sensory Data,
Inferences
Processing
Purpose(s)
Example(s) of Processing Purpose
Categories of PI
Implicated
Other: marketing, administrative, operational,
business, and commercial purposes subject to
applicable law and not inconsistent with this
Privacy Policy or other notice by us at
collection
2. Managing
Interactions and
Transactions
Auditing: related to counting ad
impressions to unique visitors, verifying
positioning and quality of ad impressions, and
auditing compliance with user interaction or
transaction specifications and standards
Identifiers, Customer
Account
Details/Commercial
Information, Internet
Usage Information
3. Security
Security/fraud prevention: to protect the
security of Company, our Services, and its
users and to prevent and address fraud and
violations of our terms and policies
Identifiers, Internet
Usage Information,
Customer Account
Details/Commercial
Information
4. Debugging
Repairs: identify and repair errors that impair
existing intended functionality of our Services
Identifiers, Internet
Usage Information,
Customer Account
Details/Commercial
Information
5. Providing
Advertising &
Marketing
Services
Content and offers customization: to
customize your experience on our Services, or
to serve you specific content and Offers that
are relevant to/customized for you
Identifiers, Internet
Usage Information,
Customer Account
Details/Commercial
Information, Geolocation
Data, Inferences
Advertising, marketing, and promotions: to
assist us in determining relevant Offers; to
develop and evaluate marketing and
advertising campaigns; and for promotional
activities, such as running sweepstakes,
contests, and other promotions.
6. Quality
Assurance
Quality and Safety of Service: undertaking
activities to verify or maintain the quality or
safety of our Services, and to improve,
upgrade, or enhance our Services
Identifiers, Internet
Usage Information,
Customer Account
Details/Commercial
Information, Geolocation
Data, Inferences
Processing
Purpose(s)
Example(s) of Processing Purpose
Categories of PI
Implicated
7. Processing
Interactions and
Transactions
Short-term, transient use: including, but not
limited to, non-personalized advertising
shown as part of a Consumer’s current
interactions related to your use of our
Services
Identifiers, Internet
Usage Information,
Customer Account
Details/Commercial
Information, Geolocation Data, Sensory
Data, Inferences
8. Research and
Development
Research and analytics: to better understand
how Consumers access and use our Services,
both on an aggregated and individualized
basis, to improve our Services and respond to
user preferences, and for other research and
analytical purposes
Identifiers, Internet
Usage Information,
Customer Account
Details/Commercial
Information, Geolocation Data,
Inferences
Market research and customer satisfaction
surveys: to administer surveys and
questionnaires, such as for market research
or customer satisfaction purposes
9. Additional
Business
Purposes
Compliance with legal obligations: to comply
with legal obligations, as part of our general
business operations, and for other business
administration purposes
Prevention of illegal activities, fraud, injury to
others, or violation of our terms and policies:
to investigate, prevent or take action if
someone may be using info for illegal
activities, fraud, or in ways that may threaten
someone’s safety or violate of our terms or
policies
Purposes disclosed at PI collection: We may
provide additional disclosures at the time of PI
collection, such as on an Offer page
Related or compatible purposes: for purposes
that are related to and/or compatible with any
of the foregoing purposes
Identifiers, Personal
Records, Personal
Characteristics or Traits,
Customer Account
Details/Commercial
Information, Internet
Usage Information,
Geo-location Data,
Sensory Data,
Professional or
Employment
Information, Inferences
Processing
Purpose(s)
10. Commercial
Purposes
Example(s) of Processing Purpose
We may collect and use your PI for
commercial purposes such as for interestbased advertising and sharing PI in a manner
that is deemed a sale under the CCPA or other
applicable U.S. State Privacy Laws.
Categories of PI
Implicated
Identifiers, Personal
Records, Personal
Characteristics or Traits,
Customer Account
Details/Commercial
Information, Internet
Usage Information,
Geo-location Data,
Sensory Data,
Professional or
Employment
Information, Inferences
B. Your Consumer Rights and How to Exercise Them
We provide Consumers the privacy rights described in this section pursuant to the
requirements of their applicable state’s law, provided any such request meets the
requirements for a Verifiable Consumer Request (defined below). For residents of
states without applicable U.S. State Privacy Laws, we may consider requests under this
section but will apply our discretion in whether and how we process them. We may
also apply state law rights in states with U.S. State Privacy Laws prior to the effective
date of such laws in our discretion.
To submit a request to exercise your Consumer privacy rights under U.S. State Privacy
Laws, or to submit a request as an authorized agent, please follow the instructions at
our Consumer Rights Request page here or mail your request to the following
address: Prodege, LLC, 8605 Santa Monica Blvd, PMB 36227, West Hollywood,
California 90069-4109, Attention: Privacy, and respond to any follow-up inquiries we
make. Please be aware that we do not accept or process requests through other means
(via phone, fax, chats, social media, etc.). More details on the request and verification
process are provided in Section C (How We Process Your Consumer Privacy Requests)
below. The Consumer rights we accommodate are as follows:
i.
Right to Limit Sensitive PI Processing
With regard to PI that qualifies as Sensitive PI under U.S. State Privacy Laws, if you elect
to provide us with that Sensitive PI, you will have consented to our collection and
processing of such Sensitive PI. You may submit an opt-out request here. However,
under applicable U.S. State Privacy Laws, you can limit certain Sensitive PI Processing
with the exception of the following processing purposes or any other permitted
purposes under such U.S. State Privacy Laws:
To perform our Services at your request or at your direction;
To prevent, detect, and investigate security incidents, fraudulent activity, illegal
actions, etc.;
For short term transient use, including, but not limited to, non-personalized
advertising as part of your interaction with our Services; and
To maintain or service accounts, provide customer service, process or fulfill Offers,
orders and transactions, verify customer information, process payments, or
provide similar services.
ii.
Right to Know/Access
Residents of California, Colorado, and Virginia are entitled to access PI maintained by
the Company up to twice in a 12-month period. Residents of Connecticut and Utah are
entitled to access PI maintained by Company once in a 12-month period, with
subsequent requests subject to a service fee.
a)
Categories (available for California Residents only)
California residents have a right to submit a request for any of the following for the
period that is 12-months prior to the request date:
The categories of PI we have collected about you.
The categories of sources from which we collected your PI.
The Business Purposes or Commercial Purposes for our collecting or Selling your
PI.
The categories of third parties to whom we have shared your PI.
A list of the categories of your PI disclosed for a Business Purpose and, for each,
the categories of recipients, or that no disclosure occurred.
A list of the categories of your PI sold and, for each, the categories of recipients, or
that no sale occurred.
b)
Specific Pieces (Transportable Copies)
You may request to confirm if we are Processing your PI and, if we are, to obtain a
transportable copy of your PI that we have collected and are maintaining, as required
by applicable U.S. State Privacy Laws. If you wish to receive specific pieces of your PI,
we will attempt to honor requests for specific pieces of your PI where reasonably
possible. We have no obligation to re-identify information or to keep PI longer than we
normally retain it or longer than we are required to under applicable law to comply
with access requests.
iii.
Do Not Sell / Share / Target for Advertising
Various U.S. State Privacy Laws have broad and differing concepts of “Selling” PI for
which an opt-out is required, with some states including PI transfers for non-monetary
consideration and other states only including PI transfers for monetary consideration.
California also has an opt-out from “Sharing” for Cross-Context Behavioral Advertising
purposes (use of PI from different businesses or services to target advertisements
across websites or apps). Other states have an opt-out of “Targeted Advertising”
(defined differently, but also addressing tracking, profiling, and targeting of
advertisements). We may Sell or Share your PI and/or use your PI for Targeted
Advertising, as these terms apply under U.S. State Privacy Laws. However, we provide
you with an opt-out of Sale/Sharing/Targeting that is intended to combine all of these
various state opt-outs into a single opt-out available regardless of which U.S. State
Privacy Law is applicable to your PI.
Ad Networks and other Trusted Third Parties may associate cookies and other Tracking
Technologies that collect PI about you on Prodege Sites and Features or in connection
with our Services, or otherwise Collect and Process PI that we make available about
you. We understand that making your PI available on Prodege Sites and Features or in
connection with our Services, or otherwise, to Trusted Third Parties could be deemed a
Sale and/or Share under some U.S. State Privacy Laws and thus we will treat such PI
(e.g., cookie ID, IP address, and other online IDs and internet or other digital activity
information) collected by Trusted Third Parties that are not limited to acting as our
Service Provider (or Contractor or Processor), as a Sale and/or Share and subject to
your right to make a Do Not Sell/Share/Target opt-out request. We will not Sell your PI,
Share your PI for Cross-Context Behavioral Advertising, or Process your PI for Targeted
Advertising if you make a Do Not Sell/Share/Target opt-out request as follows:
Opt-out for non-cookie PI: If you want to limit our Processing of your non-cookie PI
(e.g., your email address or web browsing activity) for Targeted Advertising, or opt-out
of the Sale/Sharing of such PI, you may make an opt-out request here.
Opt-out for cookie PI: If you want to limit our Processing of your cookie-related PI for
Targeted Advertising, or opt-out of the Sale/Sharing of such PI, you may exercise an
opt-out request by following the instructions on our Consumer Rights Request
page here, or by clicking the link to update Your Cookie Choices. This cookie
management tool enables you to exercise such an opt-out request and enable certain
cookie preferences on your Device. Since your browser opt-out is designated by a
cookie, if you clear or block cookies on your Device, your preferences may no longer be
effective, and you will need to enable them again via our cookie management tool.
Opt-out preference signals ("OOPS", as they are known in California; also known as
global privacy control or GPC): Some of the U.S. Privacy Laws require businesses to
process OOPS or GPC signals, which are signals sent by a platform, technology, or
mechanism, enabled by individuals on their devices or browsers, that communicate the
individual's choice to opt-out of the Sale and Sharing of PI. To use an OOPS/GPC, you
can download a compatible internet browser or a plugin for on your current internet
browser and follow the settings to enable to OOPS/GPC. We have configured the
settings of our consent management platform to receive and process OOPS/GPC
signals on our website, as explained by our consent management platform here. We
process OOPS/GPC signals with respect to any Sales and Sharing of PI with Trusted
Third Parties that may occur via cookies or other Tracking Technologies, as discussed
above and apply it to the specific browser on which you enable OOPS/GPC. We do not:
(1) charge a fee for use of our service if you have enabled OOPS/GPC; (2) change your
experience with any product or service if you use OOPS/GPC, although it may affect our
ability to accurately track your activities for crediting your account with qualified
rewards; or (3) display a notification, pop-up, text, graphic, animation, sound, video, or
any interstitial in response to the OOPS/GPC, except for indicating whether we
recognize the signal.
We may disclose your PI for the following purposes, which are not a Sale or Share: (i) if
you direct us to disclose PI; (ii) to comply with a Consumer rights request you submit to
us; (iii) disclosures amongst the entities that constitute Company as defined above, or
as part of a Business Transaction; and (iv) as otherwise required or permitted by
applicable law.
iv.
Right to Delete
Except to the extent we have retention rights under applicable law, you may request
that we delete your PI. Our retention rights include, without limitation:
To complete transactions and services that you have requested;
For security purposes;
For legitimate internal Business Purposes (e.g., maintaining business records);
To comply with law and to cooperate with law enforcement; and
To exercise or defend legal claims.
Please also be aware that making a deletion request does not ensure complete or
comprehensive removal or deletion of PI or content you may have posted.
Under certain U.S. State Privacy Laws, your deletion right may apply only to PI that we
collected directly from you.
v.
Correct Your PI
Consumers may bring inaccuracies they find in their PI that we maintain to our
attention, and we will act upon such a report as required by applicable law.
You can also make changes to your PI in your online account in the account settings
section of the account. That will not, however, necessarily change your PI in other
places where we may maintain it.
C. How We Process Your Consumer Privacy Requests
To submit a request to exercise your Consumer privacy rights, or to submit a request
as an authorized agent, please follow the instructions at our Consumer Rights Request
page here or mail your request to the following address: Prodege, LLC, 8605 Santa
Monica Blvd, PMB 36227, West Hollywood, California 90069-4109, Attention: Privacy,
and respond to any follow-up inquiries we make. In addition, you may
email [email protected] and we will respond with the appropriate web
submission form for you to use for the submission of your request. To submit a Do Not
Sell/Share/Targeting Request for cookie-related PI or the right to limit Sensitive PI
processing, click here. Please be aware that we do not accept or process requests
through other means (via phone, fax, chats, social media, etc.).
i.
Your Request Must be a Verifiable Consumer Request
As permitted or required by applicable U.S. State Privacy Laws, any request you submit
to us must be a Verifiable Consumer Request, meaning that when you make a
request, we may ask you to provide verifying information, such as your name, e-mail,
phone number and/or account information. We will review the information provided
and may request additional information (e.g., transaction history) to ensure we are
interacting with the correct individual. We will not fulfill your Right to Know
(Categories), Right to Know (Specific Pieces), Right to Delete, or Right to Correction
request unless you have provided sufficient information for us to reasonably verify you
are the Consumer about whom we collected PI. We do not verify opt-outs of
Sell/Share/Target or Limitation of Sensitive PI requests unless we suspect fraud.
You are not required to create a password-protected account with us to make a
Verifiable Consumer Request, but you may use your password-protected account to do
so. If we suspect fraudulent or malicious activity on or from the password-protected
account, we may decline a request or request that you provide further verifying
information.
We verify each request as follows:
Right to Know (Categories) (available for California residents only): If you do not have
a password-protected account, we verify your Request to Know Categories of PI to
a reasonable degree of certainty, which may include matching at least two data
points provided by you with data points maintained by us, which we have
determined to be reliable for the purpose of verifying you. If we cannot do so, we
will refer you to this Notice for a general description of our data practices.
Right to Know (Specific Pieces): If you do not have a password-protected account, we
verify your Request To Know Specific Pieces of PI to a reasonably high degree of
certainty, which may include matching at least three data points provided by you
with data points maintained by us, which we have determined to be reliable for
the purpose of verifying you together with a signed declaration under penalty of
perjury that you are the Consumer whose PI is the subject of the request. If you
fail to provide requested information, we will be unable to verify you sufficiently to
honor your request, but we will then treat it as a Right to Know Categories Request
if you are a California resident.
Do Not Sell/Share/Target & Limit Sensitive PI: No specific verification required unless
we suspect fraud.
Right to Delete: If you do not have a password-protected account, we verify your
Request to Delete to either (i) a reasonable degree of certainty, which may include
matching at least two data points provided by you with data points maintained by
us, or (ii) a reasonably high degree of certainty, which may include matching at
least three data points provided by you with data points maintained by us,
depending on the sensitivity of the PI and the risk of harm to the Consumer posed
by unauthorized deletion. If we cannot verify you sufficiently to honor a deletion
request, you can still make a Do Not Sell/Share/Target and/or Limit Sensitive PI
request.
Correction: If you do not have a password-protected account, we verify your
Request to Correct PI to either (i) a reasonable degree of certainty, which may
include matching at least two data points provided by you with data points
maintained by us, or (ii) a reasonably high degree of certainty, which may include
matching at least three data points provided by you with data points maintained
by us, depending on the sensitivity of the PI and the risk of harm to the Consumer
posed by unauthorized correction.
To protect Consumers, if we are unable to verify you sufficiently, we will be unable to
honor your request. We will use PI provided in a Verifiable Consumer Request only to
verify your identity or authority to make the request and to track and document
request responses, unless you also gave it to us for another purpose.
ii.
Agent Requests
Authorized agents may exercise rights on behalf of California Consumers, but we
reserve the right to also verify the Consumer’s identity directly as described above.
Authorized agents must contact us by submitting a request through our Consumer
Rights Request page here and indicating in the open text field that they are submitting
the request as an agent. We will require the agent to demonstrate authority to act on
behalf of the Consumer by providing, for example, evidence of the agent’s identity,
proof of registration with the California Secretary of State (if the agent is a business),
and at least one of the following evidencing proof of the agent’s legal authority to act
on behalf of the individual Consumer: (i) presenting a Power of Attorney granted under
the Probate Code that we can reasonably verify; or (ii) signed permission by the
Consumer.
We may also require the Consumer to verify their own identity directly with us and to
directly confirm with us that they provided the authorized agent permission to submit
the request.
In addition, residents of Colorado and Connecticut may use an agent to make an optout request subject to reasonable verification of agent authority and consumer
identity.
In the absence of any of the general conditions detailed above, we are entitled to reject
any request submitted through an agent. In addition, the agent is subject to the
verification standards applicable to the type of request(s) made.
iii.
Appeals (Colorado, Connecticut, and Virginia residents only)
If you are a resident of Colorado, Connecticut, or Virginia, you may appeal Company’s
decision regarding a request by contacting us at [email protected] with the
following subject line: "CRR Appeals Request".
iv.
Our Responses
Some PI that we maintain is insufficiently specific for us to be able to associate it with a
Consumer (e.g., clickstream data tied only to a pseudonymous browser ID). We do not
include that PI in response to those requests. If we deny a request, in whole or in part,
we will explain the reasons in our response.
We will make commercially reasonable efforts to identify Consumer PI that we Process
to respond to your Consumer request(s). In some cases, particularly with voluminous
and/or typically irrelevant data, we may suggest you receive the most recent or a
summary of your PI and give you the opportunity to elect whether you want the
rest. We reserve the right to direct you to where you may access and copy responsive
PI yourself. We may also refuse to act upon a request that is excessive, repetitive,
unfounded, or overly burdensome.
Consistent with applicable U.S. State Privacy Laws and our interest in the security of
your PI, we will not deliver to you your Social Security number, driver’s license number,
or other government-issued ID number, financial account number, an account
password, or security questions or answers, in response to a Consumer privacy rights
request; however, you may be able to access some of this information yourself through
your account if you have an active account with us.
D. Non-Discrimination/Non-Retaliation
We will not discriminate or retaliate against you in a manner prohibited by applicable
U.S. State Privacy Laws for your exercise of your Consumer privacy rights. We may
charge a different price or rate, or offer a different level or quality of good or service, to
the extent that doing so is reasonably related to the value of the applicable data.
E. Notice of Financial Incentive Programs
We may offer rewards or other benefits (“Incentives”) from time-to-time to Consumers
that provide us with PI, such as name, phone number, e-mail address, IP address, or
geo-location. You may opt-in to Incentives by subscribing to our [Incentive programs
we may offer from time-to-time. If you subsequently wish to withdraw from such
programs, the method for doing so will be explained in the program Terms of Use, and
you may do so at any time. For more information, including valuation notice, see our
Notice of Financial Incentives here.
F. Our Rights and the Rights of Others
Notwithstanding anything to the contrary, we may collect, use and disclose your PI as
required or permitted by applicable law and this may limit or affect your rights under
U.S. State Privacy Laws. In addition, we are not required to honor your requests to the
extent that doing so would infringe upon our or another person’s rights or conflict with
applicable law.
G. Additional Notices for California Residents
This Notice provides additional information on our online practices and the rights of
California residents related to Prodege Sites and Features and our Services.
i.
California Minors Erasure
If you are a California resident under eighteen (18) years of ago who has posted
content or information on Prodege Sites and Features or our Services, you can request
removal by contacting us at the mailing address set forth in the Contact Us section
above detailing where the content or information is posted and attesting that you
posted it. We will then make reasonably good faith efforts to remove the post from
prospective public view or anonymize it so you cannot be individually identified to the
extent required by applicable law. This removal process cannot ensure complete or
comprehensive removal. For instance, third parties may have republished or archived
content by search engines and other means that we do not control.
ii. Affirmative Opt-In for Sale or Sharing of PI of California Residents Under 16
Years of Age
We do not knowingly Sell or Share the PI of California residents under the age of
sixteen (16), unless we receive affirmative opt-in authorization from (i) the under-16
California resident if he or she is at least 13 years of age, or (ii) the parent or guardian
of the California resident if he or she is less than 13 years of age. If you think we may
have unknowingly Sold or Shared PI of a California resident under 16 years of age
without the appropriate affirmative opt-in authorization, please report that to us as
described in the Contact Us section above.
iii.
Shine the Light
We provide California residents with the option to opt-out to sharing of “personal
information,” as defined by California’s “Shine the Light” law, with third parties (other
than with Company affiliates) for such third parties own direct marketing purposes.
California residents may exercise this opt-out, request information about our Shine the
Light law compliance, and/or obtain a disclosure of third parties we have shared
information with and the categories of information shared. California residents may
make such a request, or inquire further about our compliance with this law, by
emailing [email protected] or mailing us at the address set forth in
the Contact Us section above. You must put the statement “Shine the Light Request” in
the body of your correspondence. In your request, please attest to the fact that you are
a California resident and provide a current California address for your response. This
right is different than, and in addition to, CCPA rights, and must be requested
separately. We are only required to respond to one request per person each year. We
are not required to respond to requests made by means other than through the
provided e-mail address or mailing address (requests by phone, fax, chats, social
media, etc.). We are not responsible for requests that are incomplete or not labeled
and sent properly.
Terms of Use
Privacy Policy
PRIVACY POLICY
Website Policy
Privacy Policy
Your Privacy
Quest Global Research Group Inc. (“Quest”) is committed to respecting the
privacy of survey respondents and other online users of Quest's services.
Quest's Privacy Policy governs the collection, use, retention and security of
information gathered from survey respondents and other online users of
Quest's services.
Quest does not disclose any personally identifiable information (“Personally
Identifiable Information” or “PII”) about survey respondents to third parties,
except in reporting the survey responses to those of Quest's clients
commissioning such surveys or as required by law. PII means information that
individually identifies you, such as your name, address, or email a ddress.
Consent
Your consent is the most important part of any transaction involving both
the information you’ve previously provided Quest and any requests for
information.
Quest will never disclose any non -aggregated and non-anonymized
information you’ve previously provided us without explicit consent from you
regarding
the
release
of
that
information
to
another
individual/company/organization. By non -aggregated and non-anonymized
information we mean the specific information you’ve provided as opposed to a
depersonalized data set that uses your information as part of the whole dataset
in a manner that doesn’t provide any personal identification.
Requests for your PII will generally be preceded by messaging that informs
you of this request, its purpose, and the proposed use(s), so you can decide
if you want to provide consent.
You have the right to know how the information you provide is being used.
Before you consent to providing PII, you have the right to know about any
entities or organizations that can access the PII you provide.
{L2197713.2}
Collected Information
Quest collects a wide range of information about survey respondents
depending on the information needs of our surveys. For example, survey
respondents may be requested to provide certain personally identifiable,
financial or demographic information, as well as specific opinions about a
variety of goods and services. Responses to all survey questions are
completely voluntary. A survey respondent should only provide responses to
questions they are comfortable answering and survey respondents may decline
to answer any survey question.
Quest reserves the right to report information gathered through the survey
(e.g., demographic data, preferences, etc.) to Quest's clients commissioning
such surveys. Further, you acknowledge and agree that any information you
voluntarily disclose in the survey may be provided to the commissioner of the
survey. Quest does not disclose a survey respondent's personally identifiable
information to anyone unless the survey respondent has consented to such
disclosure or a disclosure is required by law .
You have the right to the information and data you have provided Quest. You
may request a copy of the information and data you provide, and Quest will
provide a copy of your information to you in a timely manner, subject to
exceptions under applicable law.
Additional Information From Survey Respondents
Quest's servers may automatically recognize data relating to a survey
respondent, which may include a respondent's domain name, IP addresses,
location data, or other information about a respondent’s internet connection
(“Meta Data”).
Quest may gather anonymous "Traffic Data" that does not personally identify
a survey respondent but that may be helpful for improving the services Quest
offers. “Traffic Data” can include the full Uniform Resource Locators (URLs),
clickstream to, through and from our website (including date and time), page
response times, download errors, length of visits to certain pages, page
interaction information (such as scrolling, clicks, and mouse -overs) and
methods used to browse away from Quest’s website.
Quest may also use cookies on our platform to help us provide panelists with
a better experience and to provide quality control and validation functions. You
can choose whether to accept cookies by changing the settings on your
browser. However, if you choose to disable this function, your experience at
our website may be diminished and some features may not work as they were
intended.
{L2197713.2}
Quest may use and gather any Meta Data, Traffic Data or any other data that
is not PII, which you have provided to Quest (collectively, “ User Content”).
Opt-Out
You have the right to opt out of information request at any time. This means
that even though you’ve previously given consent to the collection and use of
your information, you can subsequently decide that you want any portion of
the information you’ve provided to no longer be used by Quest.
Quest also honors respondents' requests to be excluded from marketing
solicitations and, as dictated by the applicable laws, only sends such
messages if requisite implied or express consents have been obtained . To be
removed from this mailing list, simply email your request to
[email protected].
Protecting Respondent Information
Quest is committed to handling the personal ly identifiable information and data
of survey respondents with care , integrity and in accordance with applicable
laws. Quest uses industry standard security practices to protect such
information and data. However, regardless of the security protections and
precautions Quest undertakes, there is always a risk that personal data may
be viewed and used by unauthorized third parties. Should an unauthorized
third party breach Quest’s security measures, Quest will follow all applicable
procedures related to breach reporting and remediation.
Disputes Concerning Privacy Policy
If you have any complaint concerning how Quest has handled your personal
information, please contact Quest using the contact information described
below. Quest will comply with all applicable laws and make every reasonable
effort to address and resolve your concerns.
Compliance
By signing up to and participating in a Quest panel, you agree to Quest's
privacy policy and any other related terms of use. If you do not agree with our
policies and practices, your choice is not to use our website or participate in a
Quest panel.
Contact Quest
If you have questions about this Privacy Policy, Quest's practices related to
the handling of data from survey respondents, or if you would like to have
{L2197713.2}
Quest remove your information from our database, please feel free to contact
Quest’s Privacy Officer at:
Quest Global Research Group In c.
125 Lakeshore Road East, Suite 305
Oakville, ON L6J 1H3
Canada
E-mail: [email protected]
You have the right to your information/data you’ve provided Quest. It is your
information. You may request a copy of the information you provide to Quest,
and Quest will provide it to you in a timely manner , subject to exceptions
under applicable law.
{L2197713.2}
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Privacy Policy | SaySo Rewards
U
a
Privacy Policy
Français / Deutsch / Español / Português
Research For Good Research Participant Privacy Notice
Last Updated: October 3, 2023
Effective Date: October 10, 2023
This Privacy Notice applies to Research for Good Inc (“RFG”) and all of RFG’s online market
research sample sources, including but not limited to SaySo Rewards (“SaySo”),
www.SaySoRewards.com. This Privacy Notice defines how RFG collects, stores, uses and
discloses your “personal data” or “personal information” or “personally identifiable
information” (as defined below). RFG will, and will cause its affiliates to, establish and
maintain business procedures that are consistent with this Privacy Notice.
We strive to make our websites, including this Privacy Notice, accessible to individuals with
disabilities. If you are having trouble accessing the RFG website or this Privacy Notice,
please contact us as provided in the “Contact Us” section below.
We use cookies on our website to give you the most relevant experience by remembering your
preferences and repeat visits. By clicking “Accept”, you consent to the use of ALL the cookies.
This privacy notice constitutes a binding agreement between you and RFG. Your use of our
Do not sell my personal information.
website or services, or your participation in research, constitutes your consent to the
of this privacy
ACCEPT notice.
Cookieterms
settings
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Privacy Policy | SaySo Rewards
WE PROTECT YOUR PRIVACY
RFG is a leading market research company. RFG is strongly committed to protecting the
privacy and security of “personal data” or “personal information” or “personally
identifiable information” (referred to in this Privacy Notice as “Personal Data”) and
conforms its privacy and security practices to applicable laws, and regulations, including,
without limitation, the California Consumer Privacy Act (“CCPA”), the California Privacy
Rights Act (“CPRA”) and other applicable US State laws, including Virginia, Connecticut
Colorado and Utah, the General Data Protection Regulation (“GDPR”) and UK GDPR. . RFG
also conforms its privacy and security practices with the codes of standards of applicable
market and opinion survey research associations, including, without limitation, ESOMAR
(www.esomar.org) and the Insights Association (www.insightsassociation.com).
RFG offers research participants opportunities to take part in market research and express
their opinions on a broad range of topics. Our clients and research partners depend on
this information to make many decisions that effect the products and services in the global
marketplace.
WHAT PERSONAL DATA DO WE COLLECT AND PROCESS?
As used in this Notice, Personal Data means information that identifies, relates to,
describes, is capable of being associated with, or could reasonably be linked with a
particular data subject, consumer, or household. Personal Data includes information such
as real names, postal addresses, email addresses, and social security numbers.
Personal Data may also include unique identifiers, IP addresses, biometric information,
internet or other network activity (such as browsing history, search history, etc.),
geolocation data, audio/visual data, and even inferences which may be drawn from any of
the above to create a profile about a data subject or consumer.
We may collect Personal Data for the purpose of conducting market research, as expressly
stated and agreed to by you, and as otherwise provided in this Privacy Notice. Personal
Data collected in connection with market research includes participant names; email
addresses; postal addresses; phone numbers; IP addresses; browser fingerprints; device
ID; unique identifiers; cookies; geolocation data; web beacons; demographic data, such as
age, gender, race/ethnicity, parental status, marital status, postal code, income and
education levels; and other information collected through automated means, as described
below.
We use cookies on our website to give you the most relevant experience by remembering your
You may
submit,
upload
or transmit
content
material,
including
preferences
andalso
repeat
visits.
By clicking
“Accept”,
you or
consent
to the
use ofphotos,
ALL thevideos,
cookies.
other similar
or related content or material which may include your Personal
Do not and/or
sell myany
personal
information.
Data, for example, when participating in surveys or other research programs. Such
ACCEPT
Cookie settings
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Personal Data may be used and disclosed as described in this Privacy Notice and should
not include audio, video, images, or the likeness of anyone other than you.
SENSITIVE INFORMATION
From time-to-time RFG may collect “sensitive personal data” or “sensitive personal
information” or “special categories of personal data” (referred to in this Privacy Notice as
“Sensitive Personal Data”) which, depending on the country in which you live may include,
racial or ethnic origin, health records, financial information, political opinions and religious
or philosophical beliefs. If RFG collects your Sensitive Personal Data, RFG will always obtain
your explicit consent.
USE OF AUTOMATED DECISION MAKING
If permitted by applicable laws and regulations, we may use automated decision-making to
determine the likelihood of fraudulent activity. If our systems determine that your activities
associated with you are fraudulent, you may be banned from our services and your profile
may be deleted. If you believe that your profile has been wrongfully deleted, please reach
us using the contact details in section “Contact Us” at the end of this Privacy Notice.
Automatically collected data may be sent to third-party data processors for the purpose of
fraud prevention.
OTHER USES AND SHARING OF INFORMATION
In addition to the uses listed in the table above, we may also use and share your Personal
Data:
in connection with the request or requirement of any lawful request by public
authorities;
to meet national security or law enforcement requirements;
in connection with the sale, assignment, or other transfer of our business, in which case
RFG will make commercially reasonable efforts to ensure that any such buyer agrees to
treat Personal Data in accordance with this Privacy Notice;
if RFG believes that disclosure is necessary or appropriate to prevent physical harm or
financial loss or in connection with suspected or actual illegal activity; or
as otherwise authorized by you.
a statutory
condition
applies
to process
Personalby
Data
and you your
We useIfcookies
on our
website
to giveallowing
you theRFG
most
relevantyour
experience
remembering
withdraw
to process
your Personal
will not
mean
RFG
preferences
and consent
repeat visits.
By clicking
“Accept”,Data
youthis
consent
to necessarily
the use of ALL
thethat
cookies.
to process
your Personal Data as it may, for example, be under a statutory duty
Do not will
sell cease
my personal
information.
to continue to process your Personal Data for some purposes, e.g. to keep copies of
ACCEPT
Cookiecommercial
settings transactions
for a minimum of seven years.
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Privacy Policy | SaySo Rewards
Please note that receiving email communications may be a requirement of your
participation in our surveys or research programs. You can opt out from receiving these
emails by unsubscribing from the survey or research program.
ADDITIONAL INFORMATION ON INFORMATION COLLECTED THROUGH AUTOMATED
MEANS
Cookies
Cookies are small text files stored on your computer by a website that assigns a numerical
user ID and stores certain information about your online browsing. We may use cookies on
our survey site to help us recognize you as a prior user.
If you wish, you can adjust your web browser’s privacy settings to delete cookies upon
exiting websites or when you close your browser. You may also configure your browser to
block cookies, however doing so may negatively impact your user experience when
participating in one of our surveys or other research programs.
Web Beacons
A web beacon (also known as a tag, clear gif or 1×1 pixel), consists of a small string of code
that is embedded within a web page or email. There may or may not be a visible graphic
image associated with the web beacon, and often the image is designed to blend into the
background of a web page or email.
We may use web beacons in our email messages to help determine whether our messages
are opened and to verify any clicks through to links within the email. We may use this
information to determine which of our emails are more interesting to users, to improve
the quality of the emails that we send and to query users who do not open our emails as
to whether they wish to continue receiving them. The web beacon is deleted when you
delete the email.
If you would prefer not to have web beacons in the emails that you receive, you should
adjust your email program to receive messages in plain text rather than HTML. It is also
possible to detect and control web beacons that are present on web pages by
downloading a plug-in for your browser.
Log Files
RFG may use logging throughout your survey-taking and research program experiences.
We use cookies on our website to give you the most relevant experience by remembering your
Whenand
you repeat
access visits.
any of By
these
services,
our servers
automatically
record
information
that
preferences
clicking
“Accept”,
you consent
to the use
of ALL
the cookies.
browser
sends
whenever you visit a website. These server logs may include
Do not your
sell my
personal
information.
information such as your web request, Internet Protocol (IP) address, browser type,
ACCEPT
Cookiebrowser
settingslanguage,
the date and time of your request and one or more cookies that may
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uniquely identify your browser. This information is periodically deleted as part of normal
maintenance routines.
Geo-Location Data
RFG may collect geo-location information from your computer or device. RFG may use your
geo-location data for fraud prevention or for market research purposes, including but not
limited to advertising research or other tracking-based market research activities. RFG will
obtain your consent if RFG collects or uses your geo-location information.
Digital Fingerprinting
RFG may use digital fingerprinting technology, also known as “machine identification”
technology (“Digital Fingerprinting”), to gather certain data about you and/or your
computer.
This data may include Personal Data an Internet Protocol (IP) address, as well as other data
such as a computer operating system or browser version number. This technology creates
a unique computer identifier (“ID”) that may be used to identify and track your
participation in a survey or other research program and limit participation.
RFG may utilize Digital Fingerprinting technology to assist our clients in ensuring the
integrity of survey results by enabling us to authenticate users and to help ensure users
participate in surveys no more than the maximum allowable participation. In furtherance
of RFG’s efforts to assist its clients in protecting and ensuring the integrity of survey results,
RFG may: (a) link or associate an ID to an individual or to Personal Data of an individual; (b)
share an ID with RFG’s clients and/or sample or panel providers; and/or (c) receive or
obtain a unique identifier that is linked to an identified or identifiable individual. Any
unique identifier(s) received or obtained by RFG that are linked to an identified or
identifiable individual will be protected in accordance with this Privacy Notice.
INFORMATION FOR CALIFORNIA RESIDENTS
The following information applies to residents of California.
Personal Data We Sell or Disclose
CCPA defines the term “sell” broadly. Its meaning includes “renting, releasing, disclosing,
disseminating, making available, [and] transferring…for monetary or other valuable
consideration.”
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or certain combinations of anonymized or pseudonymized demographic and other
information.
Under the CCPA’s definition, we’ve “sold” the following categories of information to our
clients: demographic data, such as age, gender, race/ethnicity, parental status, marital
status, postal code, income and education levels.
We’ve otherwise disclosed the following categories of information, subject to
confidentiality restrictions, to our third-party service providers as strictly necessary for
them to provide services to us: participant names; email addresses; postal addresses;
phone numbers; IP addresses; browser fingerprints; device ID; unique identifiers; cookies;
geolocation data; web beacons; demographic data, such as age, gender, race/ethnicity,
parental status, marital status, postal code, income and education levels; log files,
including Internet Protocol (IP) address, browser type, browser language, the date and
time of your request, operating system, referring/exiting pages, and clickstream data;
browsing information, such as date and time you visited our website(s), number of pages
you viewed, time in seconds you spend on each page, and details of the any website you
visited before and/or after participation in one of our surveys or research programs;
respondent photos, video, and audio; and social media information (e.g., handles, basic
information available on profiles).
When you participate in one of our surveys or research programs, the information you
provide or is otherwise collected may be combined with the information of other
participants and reported as part of aggregate results. Additionally, the information you
provide or is otherwise collected may be used in statistical modeling to better understand
trends among the general population. When such statistical modeling is performed, your
Personal Data will not be released.
We will not make your Personal Data available to any third party without your consent or
required by law, as further specified below.
Notice to California Residents
If you are a California resident, subject to certain exceptions and limitations, you can
exercise the rights described below:
Your Right to “Know” and to Request Deletion
You have the right to know the categories and specific pieces of Personal Data we have
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You have the right to request deletion of personal information we’ve collected or maintain.
To exercise these rights contact us at +1-855-573-2141 or by filling out the form at the
following link https://www.saysorewards.com/ccpa-privacy/. We may ask you to provide
additional information, such as name, email, and participation information in order to
verify who is making the request.
Please note that any requested disclosures will only apply to the 12-month period
preceding the request, and you are entitled to request disclosure regarding your personal
information twice in any 12-month period.
Your Right to Opt-Out of the “Sale” of Your Information
You have the right to opt out of the sale of your personal information. For more
information on how to opt out, please click here.
Your Right to Non-Discrimination
You have the right not to receive discriminatory treatment by RFG for the exercise of the
privacy rights conferred by the CCPA, including but not limited to by denying you services,
charging different prices or rates, or providing you with a different level or quality of
services. Please understand, however, that we are in the business of providing market
research services to our clients, and any financial incentives we offer to facilitate that goal
may be rewarded only if the applicable survey, research project or study is fully and
properly completed by the respondent, in the sole discretion of RFG.
Your Right to Use an Authorized Agent
You have the right to designate an authorized agent to make a request under the CCPA on
your behalf. To designate an authorized agent, please contact us as provided below. In
order to verify you have authorized an agent we will require a signed, written authorization
from you.
Your Right to Correct Inaccurate Personal Information (Personal Data)
You have the right to have any inaccuracies about your Personal Data corrected.
Your Right to Limit Use and Disclosure of Sensitive Personal Information
You have the right to limit the use and disclosure of your Sensitive Personal Information.
We use cookies on our website to give you the most relevant experience by remembering your
Verification
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preferences
and repeat
visits. By clicking “Accept”, you consent to the use of ALL the cookies.
Do not sell my personal information.
If you make a request to access or delete your information, or to opt out of the sale of your
ACCEPT we may ask you for additional information to verify your identity.
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settings information,
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This information may include: your full name, birth date, phone number, email address, or
other basic personal information about you that we already have on file.
Notice of Financial Incentive
RFG may offer opportunities for you to earn money and rewards by completing survey or
research programs. Participation in these offerings may require you to provide Personal
Data.
For more information about how to opt into these offerings, or about how to opt out once
you have opted in, see the notices and official rules accompanying these incentives.
If you have any questions or want to exercise any of these rights, you may contact us with
such a request please contact us at [email protected] or via mail at:
Research for Good
1037 NE 65th St #80212
Seattle, WA 98115
VIRGINIA, CONNECTICUT, COLORADO AND UTAH RESIDENTS
The following information applies to residents of Virginia, Connecticut, Colorado and
Utah.
If you are a resident of Virginia, Connecticut, Colorado or Utah, pursuant to your applicable
state’s privacy laws and regulations and subject to certain exceptions and limitations, you
can exercise the rights described below:
Your Right to Access Your Personal Data
You have the right to access your Personal Data.
Your Right to Obtain a Copy of Your Personal Data
You have a right to obtain a copy of your Personal Data in a portable and, to the extent
technically feasible, a readily usable format.
Your Right to Have Your Personal Data Deleted
You have the right to have your Personal Data deleted.
We use cookies on our website to give you the most relevant experience by remembering your
preferences
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visits.
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You have the right to have inaccuracies in your Personal Data corrected.
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Your Right to Opt-Out of the Processing of Your Personal Data
You have the right to to opt out of the processing of your Personal Data for specific
purposes subject to the applicable law and regulation in your state.
If you have any questions or want to exercise any of these rights, you may contact us with
such a request please contact us at [email protected] or via mail at:
Research for Good
1037 NE 65th St #80212
Seattle, WA 98115
INFORMATION FOR CITIZENS OF THE EU, UK AND SWITZERLAND
Cross-Border Transfers
Research for Good complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the
UK Extension to the EU-U.S. DPF, and adheres to the Swiss-U.S. Data Privacy Framework
(Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Research for Good has
certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy
Framework Principles (EU-U.S. DPF Principles) with regard to the processing of Personal
Data received from the European Union in reliance on the EU-U.S. DPF and from the
United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF.
Research for Good has certified to the U.S. Department of Commerce that it adheres to the
Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the
processing of Personal Data received from Switzerland in reliance on the Swiss-U.S. DPF. If
there is any conflict between the terms in this privacy notice and the EU-U.S. DPF Principles
and/or the Swiss-U.S. DPF Principles, the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF
Principles shall govern. To learn more about the Data Privacy Framework (DPF) program,
and to view our certification, please visit https://www.dataprivacyframework.gov/.
With respect to Personal Data received or transferred pursuant to the EU-U.S. DPF, the UK
extension to the EU-US DPF and the Swiss-U.S. DPF, RFG is subject to the regulatory
enforcement powers of the U.S. Federal Trade Commission.
Pursuant to the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, EU, UK and
Swiss individuals have the right to obtain our confirmation of whether we maintain
Personal Data relating to you in the United States. Upon request, we will provide you with
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their query to [email protected]. If requested to remove data, we will respond
within a reasonable timeframe.
We will provide an individual opt-out choice (for Personal Data) or opt-in choice (for
sensitive data) before we share your data with third parties other than our agents, or
before we use it for a purpose other than which it was originally collected or subsequently
authorized. To request to limit the use and disclosure of your Personal Data, please submit
a written request to [email protected].
RFG’s accountability for Personal Data that it receives in the United States under the EUU.S. DPF Principles and/or the Swiss-U.S. DPF Principles and subsequently transfers to a
third party is described in the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles.
In particular, RFG remains responsible and liable under the EU-U.S. DPF Principles and/or
the Swiss-U.S. DPF Principles if third-party agents that it engages to process the Personal
Data on its behalf do so in a manner inconsistent with the EU-U.S. DPF Principles and/or
the Swiss-U.S. DPF Principles, unless RFG proves that it is not responsible for the event
giving rise to the damage.
In compliance with the DPF Principles, RFG commits to resolve complaints about your
privacy and our collection or use of your Personal Data transferred to the United States
pursuant to the Data Privacy Framework. European Union, United Kingdom, and Swiss
individuals with DPF inquiries or complaints should first contact RFG at:
Privacy Compliance Officer
Research for Good
1037 NE 65th St #80212
Seattle, WA 98115
In compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to
the EU-U.S. DPF, and adherence to the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF),
Research for Good commits to resolve complaints about our collection or use of your
personal information transferred to the U.S. pursuant to the EU-U.S. DPF, the UK extension
to the EU-U.S. DPF, and the Swiss-U.S. DPF. EU, UK, and Swiss individuals with inquiries or
complaints should first contact Research for Good.
Research for Good has further committed to refer unresolved DPF Principles-related
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If your DPF complaint cannot be resolved through the above channels, under certain
conditions, you may invoke binding arbitration for some residual claims not resolved by
other redress mechanisms. See https://www.dataprivacyframework.gov/s/article/ANNEX-Iintroduction-dpf
Notice to EU, UK (and Gibraltar) and Swiss Residents
You have the right to review, correct, or delete your Personal Data. Specifically:
Right of access
You have the right to obtain confirmation and information about the processing of your
Personal Data.
Right to rectification
You have the right to have any inaccuracies about your Personal Data corrected.
Right to erasure
You have the right to have your Personal Data deleted (this right is limited to data which
according to law and regulation may only be processed with your consent, if you withdraw
your consent for processing)
Right to restriction of data processing
You have the right to require that the processing of your Personal Data be restricted
(during the course of any investigation into honoring your request, RFG’s access your
Personal Data will be limited)
Right to data portability
You have the right to have your Personal Data transferred to another party (this right is
limited to data provided by you)
If you have any questions or want to exercise any of these rights, you may contact us with
such a request please contact us at [email protected] or via mail at:
Research for Good
1037 NE 65th St #80212
We use cookies on our website to give you the most relevant experience by remembering your
Seattle,
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preferences
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privacy and our collection or use of your Personal Data these citizens or residents can
address inquiries or complaints regarding this Privacy Notice should contact RFG
at [email protected].
DO WE COLLECT INFORMATION FROM CHILDREN?
RFG does not knowingly collect Personal Data from children below 16. If RFG becomes
aware that RFG has inadvertently collected Personal Data from a child below the age
where parental consent is required, RFG will delete such Personal Data from our database.
WHAT SAFEGUARDS HAVE WE IMPLEMENTED TO HELP ENSURE THE SECURITY OF YOUR
PERSONAL INFORMATION?
The security of your Personal Data is very important to us. We have put in place
reasonable physical, electronic, and administrative procedures to safeguard the
information we collect.
Only those employees who need access to your information in order to perform their
duties are authorized to have access to your Personal Data.
We cannot guarantee that all communications between us or information stored on our
servers will be free from unauthorized access by third parties such as hackers, and your
use of our services demonstrates your assumption of this risk.
HOW DO I OPT-OUT OF SURVEYS OR OTHER RESEARCH PROGRAMS?
Your decision to participate in a survey or other research program, respond to any specific
survey question or provide Personal Data or Sensitive Personal Data, will always be
respected.
You may choose whether or not to participate in a particular survey or research program
or discontinue participation at any time. However, failure to provide certain information or
fully participate in a particular survey may preclude you from receiving incentive
compensation or participation in future certain research studies.
If you decide not to participate in a survey or other research program, you can click the
unsubscribe hyperlink within the e-mail and you will no longer receive survey or other
research program invitations. You can also e-mail us at [email protected].
LINKS TO THIRD PARTY WEBSITES
We use cookies on our website to give you the most relevant experience by remembering your
This Privacy
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applies
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of third-party websites that we believe may offer useful information. The policies and
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described here do not apply to those websites. We recommend that you
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carefully read the privacy notices or policies of each site that you visit for information on
their privacy, security, data collection and distribution policies.
CLASS ACTION WAIVER
Any arbitration or court trial, related to any claim under this Privacy Notice, whether
before a judge or jury or pursuant to judicial reference, will take place on an individual
basis, without resort to any form of class or representative action (“Class Action Waiver”).
THIS CLASS ACTION WAIVER PRECLUDES ANY PARTY FROM PARTICIPATING IN OR BEING
REPRESENTED IN ANY CLASS OR REPRESENTATIVE ACTION REGARDING A CLAIM UNDER
THIS NOTICE. Regardless of anything else herein, the validity and effect of the Class Action
Waiver may be determined only by a court and not by an arbitrator. THIS CLASS ACTION
WAIVER IS VOID WHERE LIMITED OR PROHIBITED BY LAW.
CONTACT US
We value your opinion. If you have questions, comments or suggestions, or if you would
like to opt-out of our surveys or other research programs, please contact us
at [email protected] or via mail at:
Research for Good
1037 NE 65th St #80212
Seattle, WA 98115
Attn: Privacy Compliance Officer
Need more info? Send us a message, we love hearing
from you.
Say Hi
We use cookies on our website to give you the most relevant experience by remembering your
you
preferences and repeat visits. By clicking “Accept”,
consent to the use of ALL the cookies.
Do not sell my personal information.
Cookie settings
ACCEPT
https://www.saysorewards.com/privacy-policy-2/
13/13
What personally identifiable information does Torfac collect from me?
Torfac collects information in several ways from different parts of our website and
network. Some information is gathered when you sign up. During member
registration, Torfac asks for your name, email address, zip code and household
information. The more information you volunteer to provide accurately, the better we are
able to offer you services and rewards. Additionally, if you ever contact Torfac through
any means, we may keep a record of that correspondence. Whenever Torfac collects any
such information, we aim to include a link to this Privacy Policy on that page.
What are cookies and how does Torfac use them?
A cookie is a packet of electronic data sent to your browser, from a web server and stored
on your computer’s hard drive. As part of offering your specific surveys, information, and
personalized services, Torfac may use cookies to store and sometimes track information
about you. Torfac may require that you accept cookies for preparing such specific
content for you. This also avoids you having to enter your login information every time.
Who is collecting information and for what purpose?
Torfac collects several information through surveys and registration and other means,
which helps its research clients develop new products and services for consumers. You are
sharing that information with Torfac only, unless it is specifically stated otherwise on any
survey you participate in. If data is being collected and/or maintained by any company
other than Torfac sites, you will be notified prior to the time of the data collection or
transfer. If you do not want your data to be shared, you may choose not to allow the
transfer by not using that particular survey or product.
Rewards and promotions that we offer on Torfac may be either sponsored by other
companies independently, or may be co-sponsored by Torfac and another company.
Some data collected during such a promotion may be shared with the sponsor. However,
you will be notified prior to the time of data collection or transfer. You can decide not to
participate in that particular promotion if you do not want to share your data.
Any specific Sensitive Information (like information specifying medical or health
conditions, racial or ethnic origin, political views, religious or spiritual beliefs, trades and
union membership or information specifying the sex life of the individual) will be treated
with additional care. If Torfac intends to share such information to another company for a
different purpose than originally collected, then you will be expressly asked permission
prior to any such disclosure.
With whom does Torfac share my information?
We take privacy very seriously. Torfac will not disclose any of your personally identifiable
information except when we have your explicit permission or under any special
circumstances that the law requires it or under the circumstances specified in detail
below. The following describes some of the ways that your information may be disclosed.
Please see the Terms of Service for our services for more detailed information about how
your personal information may be shared.
Business Partners, Clients & Sponsors:
Torfac may disclose your personal information to our partners, clients or sponsors.
However, if any personal data about you were ever to be shared, we will tell you before
we collect or transfer the data. Many activities we offer request additional information
from sponsors. By requesting more information, you give Torfac permission to share your
information with the sponsor so they can fulfil your request. In many instances, only your
email address will be shared. If more information will be shared with our partners, you will
be notified in advance. From time to time, you may be offered the opportunity to receive
test materials, or other products or special offers from our partners. If you opt-in to
receive information from these third parties, Torfac will (with your permission) share your
name and email address with them.
Torfac may also disclose personal information in some special cases when disclosing this
information is necessary to identify, contact or bring legal action against someone who
may be violating Torfac‘s policies and Terms of Service or may be causing any injury to or
interference with (either intentionally or unintentionally) Torfac‘s products, services,
rights or property, other Torfac members and users, or anyone else that could be
affected by any such activities. Torfac may disclose or access account information when
we believe in good faith that the law requires it and for administrative and other
purposes that we deem necessary to maintain, service, and improve our products and
services.
What are the legal bases we use for processing your information?
Torfac is committed to Privacy and Data protection. Our privacy policy adopts the
principles of General Data Protection Regulation issued by the European Union (“GDPR”)
as a benchmark to which we, our employees and suppliers adhere.
What are my choices regarding collection, use, and distribution of my information?
Only Torfac (or partners working with Torfac under confidentiality agreements) will send
you any direct mails, only if you indicate that you do not object to these. You also have
choices with respect to how cookies work. By changing your internet browser settings,
you have the choice to accept all cookies, notified when a cookie is set, or to reject all
cookies requested. If you choose to reject all cookies, you will be unable to use
those Torfac services that do require prior registration in order to
participate. Torfac does not sell or lease any user information to anyone. We will always
notify you at the time of data collection or transfer if your data will be shared with any
third party and you will always have the option of not allowing it to be shared.
What else should I know about my privacy?
Please keep in mind that whenever (and wherever) you choose to disclose personal
information online – for example through emails, social networking websites, blogs, or in
chat areas that information can be collected and used by any other user. If you post
personal information online that is accessible to the public, you may receive unsolicited
messages from other parties in return. Ultimately, you are solely responsible for
maintaining the secrecy of your passwords and/or any account information. Please be
careful and responsible whenever you’re online.
How does Torfac protect the privacy of my children?
Torfac obtains prior parental consent where surveys require children to participate and
parental supervision is also required for any such surveys with children ages 6-15. We take
special extra care to protect the safety and privacy of young users on our site, and we
encourage you to participate in your child’s experience online. We do not permit any
marketing or in children’s research and the certain topics are completely prohibited in
research among children: Name/account name/E-mail or physical address, Phone number,
Race or Ethnicity, Religion or Cast, Household income, Family illness, Marital status. of
parents or other family members, Relationship matters, Grades in school or college,
Alcohol, Sexual Issues, Tobacco and Firearms.
Special Note to International Users
The Site is hosted in the United States. If you are a User accessing the Site from the
European Union, Asia, or any other region with laws or regulations governing personal
data collection, use, and disclosure, that differ from United States laws, please note that
you are transferring your personal data to the United States which does not have the
same data protection laws as the EU and other regions, and by providing your personal
data you consent to:
The use of your personal data for the uses identified above in accordance with the Privacy
Policy; and the transfer of your personal data to the United States as indicated above.
YOU ACKNOWLEDGE THAT THE LAWS OF THE UNITED STATES TREAT YOUR
INFORMATION IN A MANNER THAT MAY BE SUBSTANTIALLY DIFFERENT FROM, AND
LESS PROTECTIVE THAN, THE TREATMENT REQUIRED UNDER THE LAWS OF OTHER
COUNTRIES AND JURISDICTIONS. IF YOU DO NOT WANT YOUR INFORMATION
TRANSFERRED TO THE UNITED STATES, YOU SHOULD NOT SHARE YOUR INFORMATION
WITH US, OR MAKE USE OF THE SITE.
TO THE EXTENT ALLOWED BY THE LAW OF THE COUNTRY IN WHICH YOU ARE LOCATED,
YOU EXPRESSLY WAIVE ANY RIGHT YOU MAY HAVE TO REQUIRE US TO TREAT YOUR
IDENTIFYING INFORMATION IN ACCORDANCE WITH THE LAWS OF ANY COUNTRY OR
JURISDICTION OTHER THAN THE UNITED STATES. HOWEVER, THE FOREGOING WAIVER
MAY NOT BE LEGALLY BINDING IN SOME COUNTRIES, SUCH AS THE MEMBER STATES OF
THE EUROPEAN UNION. TO THE EXTENT IT IS NOT LEGALLY BINDING IN THE COUNTRY
IN WHICH YOU ARE LOCATED, THIS FOREGOING WAIVER DOES NOT APPLY TO YOU.
Changes and Updates to this Privacy Policy
Torfac reserves the right, at our discretion, to change, modify, add, or remove portions of
this Privacy Policy at any time for any reason. Each time Torfac exercises such a right, you
shall be required to affirmatively accept the updated Privacy Policy, and if you fail to do
so, you will no longer be able to access or use the Site.
Additional Information
Any other questions regarding this should be sent to [email protected]
5/30/24, 9:07 AM
Privacy Policy | Survey incentives and rewards| Take surveys and earn money
Privacy Policy
Summary
−
BEFORE USING OUR SERVICES, PLEASE READ THE ENTIRE TERMS OF SERVICE BELOW. THIS SUMMARY ONLY INCLUDES SOME KEY
POINTS REGARDING YOUR MEMBERSHIP.
Sampoolish is only for your personal, noncommercial use. By participating as a panelist, you agree to deal fairly and professionally with us
and with other Sampoolish members. While you control how often you participate, our clients control administration of their own surveys.
Points may be accrued at varying rates but can only be redeemed in 25,000-point ($25 equivalent) increments. The Sampoolish system
only works properly if our members answer surveys thoughtfully and truthfully, and do not try to “game the system” by speeding through
surveys, providing meaningless answers, or otherwise taking surveys in bad faith. We reserve the right to deactivate a member’s account
for any reason.
Welcome to the Sampoolish website (the “Site”), owned and operated by Solugo (referred to herein as “Sampoolish”). By accessing,
browsing, or using the Site or other services described below, you acknowledge you have read, understood, and agreed to be bound by
these Terms of Service (“Terms”). These Terms govern your use of Sampoolish’s services, including but not limited to: (1) use of the Site; (2)
registration as a member (“Member”); (3) participation on a panel; (4) use of any mobile applications operated by Sampoolish (also
included as part of the “Site”); and (5) participation in any survey or study offered, provided, hosted, or administered by or through
Sampoolish (collectively, and inclusive of items 1 through 5, the “Service(s)”). If you do not agree to these Terms, you should not access the
Services. Sampoolish reserves the right to refuse, restrict, prohibit, or reject your access to the Services, at any time, for any reason. Our
collection and use of your personal information is also governed by our Privacy Policy, and our administration of sweepstakes is governed
by the Sampoolish DailySweeps Official Rules, each of which are incorporated into these Terms by this reference. Sampoolish reserves the
right to revise these Terms at any time by updating this posting. You are encouraged to review these Terms each time you use the Services
because your use of the Services after the posting of changes will constitute your acceptance of the changes.
1. We protect your privacy
−
SurveyExchange is committed to respecting individual and client privacy, to safeguarding confidential information and to ensuring the
security of all personal information. When you decide to share your information with us, we feel it is important to assure you your
information will be safely protected. This statement discloses our information collecting, handling, and disclosure practices.
2. what do we do?
−
SurveyExchange is an online panel company focused on providing quality survey responses to our clients which represent the Market
Research industry. SurveyExchange is headquartered in Faridabad, Haryana with offices around India.
3. Personal Information
−
We collect personal information from you when you communicate with us by any media. The personal information collected on this
website may be e.g., your name, company, title, phone number, email address, or other information you provide. The collection of
personal information is voluntary. Other than as set forth in this Privacy Policy, SurveyExchange will not disclose any of your personally
identifiable information except when we have your permission or under special circumstances, such as when we believe in good faith the
law requires it or under certain circumstances. The following describes some of the ways your information may be disclosed.
4. Business Partners & Sponsors
−
Subject to the other applicable provisions herein, SurveyExchange may disclose your personal information to business partners or
sponsors. Our members are occasionally presented opportunities to request additional information from sponsors about said sponsors
promotions. By requesting more information on the opportunities, you give SurveyExchange permission to transfer your personal
information to the sponsor so they can fulfil your request. In many instances, only your email address will be shared.
5. Third Party Data & Data in the Aggregate
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−
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Under confidentiality agreements, SurveyExchange may match user information with third party data. Also, SurveyExchange discloses
aggregated user statistics in order to describe our services to prospective partners, advertisers, and other third parties, and for other lawful
purposes. SurveyExchange may also disclose account information in special cases when we have reason to believe disclosing this
information is necessary to identify, contact, or bring legal action against someone who may be violating SurveyExchange Terms &
Conditions or may be causing injury to or interference with (either intentionally or unintentionally) SurveyExchange rights or property,
other SurveyExchange users, or anyone else who could be harmed by such activities.
Finally, if there is a sale of a majority of the shares or assets of the legal entities owning and operating SurveyExchange, you agree your
personal information and data may be transferred or assigned to such new owners.
6. Opt Out
−
We may use your personal information ourselves to conduct direct marketing when you have opted into this, but you are entitled to opt
out from receiving direct marketing communications from us at any time. You may do so by responding to the opt out option which is
included with each direct marketing communication we send.
7. European Economic Area (“EEA”)
−
Please note: information displayed on our Website or sent to SurveyExchange over the Internet may be transferred outside of the EEA, if
you have given your consent. data will only be sent to other offices within SurveyExchange in the case you require:
more information on SurveyExchange;
a quote request; or
anything else pertaining specifically to SurveyExchange.
If you have any concerns in relation to such transfers, you should not use the Internet as a means of communication with SurveyExchange.
8. How we protect your personal information
−
SurveyExchange takes reasonable steps to protect your personal information from unauthorized access, use, disclosure, or loss. This site
has security measures (including online and offline physical, electronic, and managerial safeguards) in place to protect against the loss,
misuse, and alteration of the information, including your e-mail address, under our control.
We recommend you do not divulge your password to anyone. SurveyExchange will never ask you for your password in an unsolicited
phone call or in an unsolicited email. Also remember to sign out of your SurveyExchange account and close your browser window when
you have finished your work. This is to ensure others cannot access your personal information and correspondence if you share a
computer with someone else or are using a computer in a public place like a library or Internet cafe.
Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your
personal information, SurveyExchange cannot ensure or warrant the security of any information you transmit to us or from our online
products or services, and you do so at your own risk. Once we receive your transmission, we make our best effort to ensure its security on
our systems.
9. Disclosure of your personal information
−
We do not share, sell, rent, or trade personally identifiable information with third parties; however to assist us in the delivery of our service
offerings we may share your personal information with third party suppliers such as those who provide and manage incentives in
connection with the completion of surveys, data hosting and storage services, third party technology providers, data matching providers
to facilitate analytic and related objectives, and other consultants who we retain from time to time. These third parties are bound by
confidentiality obligations and will not use your information for purposes outside of those specified herein. We also reserve the right to
disclose your personally identifiable information as required by law or when we believe the disclosure is necessary to protect our rights
and/or comply with a judicial proceeding, court order, national security requirement, or legal process served on our website.
10. Use of Cookies
−
A cookie is a small amount of data sent to your browser from a web server and stored on your computer’s hard drive. We may use
technology to track the patterns of behavior of visitors to the site. Currently, cookies are utilized by SurveyExchange within the following
four primary categories or uses:
1. business cookies which operate as a quality control and verification mechanism in connection with the survey process;
2. performance cookies so traffic patterns and uses on the SurveyExchange website may be measured and optimized;
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3. user cookies so user information may be recorded so as to enhance performance and user experience on the website; and
4. targeting cookies which are utilized to measure web viewing for market research purposes.
Tracking cooking will help us to speed up your future activities at the site and allow SurveyExchange to provide you with information
specifically tailored to your interests. You can usually modify your browser to prevent this happening.
The information collected in this way can be used to identify you unless you modify your browser settings. To modify your browser
settings, click on the help section of your Internet browser and follow the instructions. Please note: not accepting cookies may affect the
performance of our website.
From time to time, SurveyExchange collaborates with third parties (including clients) to enable the use of targeting cookies, web beacons,
pixels, SDK’s, and mobile device identifiers to measure web-viewing and mobile use activities, for behavioral measurement purposes, in
connection with ad exposure and display advertising for market research purposes and other related activities. You also agree web
beacons and pixels may appear and/or be activated to collect information from emails you open. To facilitate these services,
SurveyExchange’s clients (or their agents) or other collaboration partners may write, set, or read:
cookies,
locally shared/stored objects,
flash cookies and
other related technologies (“Third Party Technologies”).
If you participate, your Member ID will be stored in, or associated with, Third Party Technologies to allow you to be contacted about online
ads, promotions, or in connection with market research surveys. SurveyExchange’s clients (or their agents) will use the Third Party
Technologies to determine whether you have seen, clicked on, or otherwise interacted with the online ad or promotion. SurveyExchange
will share your Member ID name, postal address, email address, or Device ID with SurveyExchangeclients (or their agents) so you will have
an opportunity to receive a promotion, be contacted about an online ad, complete a survey, or so data previously collected by
SurveyExchange, such as age, gender, income, etc. (“Audience Measurement Data”) may be shared with third parties, including without
limitation SurveyExchange’s subcontractors, partners, and/or clients for the purpose of audience measurement reporting on the
advertising, advertising or other promotional campaigns, and websites you visit, view, and/or click on. The Audience Measurement Data
will be used to assist in the creation, development, and implementation of websites, online advertisements, and other Internet and digital
media features, functionality, and campaigns. Your data may be transferred outside of the country from which it was originally collected.
To learn more about interest-based advertising in general and to opt out, please visit www.aboutads.info/choices.
11. Children’s Privacy
−
SurveyExchange encourages all parents and guardians to instruct their children in the safe and responsible use of their personal
information whilst using the Internet. SurveyExchange will not (through our website or otherwise) intentionally collect information relating
to or originating from a child unless we have the consent of the child’s parent or guardian. If we become aware a user of our website is a
child who is using this website without the consent of his parent or guardian, we will use reasonable endeavours to delete any information
submitted by that child as soon as possible and to ensure such information is neither transferred to anyone else nor used by us. Please let
us know as soon as you become aware a child has submitted information about him/herself through our website without the consent of
his parent or guardian. You can contact us in the ways outlined at the end of this policy.
12. Check for changes to our Privacy Statement
−
Please check this page periodically for changes as SurveyExchange reserves the right, at its discretion, to change, modify, add, or remove
portions of the Privacy Policy and the Site at any time. Your continued use of the Site following the posting of any changes to this Policy
will mean you accept such changes. If we are going to use personal data in a manner materially different from as stated at the time of
collection, we will notify the affected individuals by posting a notice on this Site or via email.
13. Governing Law
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This Site and Privacy Policy are governed by the laws of India. Any dispute arising in connection with this Privacy Policy shall be governed
under the jurisdiction of the courts of India.
14. How to contact us and unsubscribe your email
−
Questions regarding this policy, complaints about our practices and access requests should be directed to the SurveyExchange Team via email: [email protected] To unsubscribe your email account and not receive any further emails from SurveyExchange, please
send an email (from the address used as your SurveyExchange member contact) to [email protected] with "unsubscribe" as
the subject line
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15. Termination
You agree to
a. provide accurate, current, and complete information about you as may be prompted by any registration forms on the Services;
b. maintain the security of your password and login credentials; and
c. maintain and promptly update the information you provide during registration, and any other information you provide to SurveyExchange,
so as to keep it accurate, current, and complete.
Registration requires information includes, without limitation, your full legal name, gender, primary language, your date of birth, the
country and state/province of your primary residence, your phone number, and your current working email address. Your failure to provide
accurate information, or if SurveyExchange determines fraudulent information was provided by you in connection with your registration
and/or you otherwise engaged in any other inappropriate activity (as determined by SurveyExchange in its sole discretion),
SurveyExchange may cancel or invalidate your account(s), registrations, and Rewards, deny redemption of your Rewards, or restrict, block,
limit, and prevent your access to and use of the Services and, further, all Rewards, incentives and other consideration shall be subject to
forfeiture. All points earned will be expired automatically upon 12 months of inactivity.
−
16. Non-Use and Nondisclosure
Information and content made available to you in the Services may contain trade secrets or other confidential or proprietary information
of SurveyExchange and/or SurveyExchange’s clients, suppliers or licensors. You must hold in strict confidence, and not disclose to any
other person, any information and content you access or learn in connection with your participation in any survey, project, questionnaire,
or other market research-related activity related to the Services. You are prohibited from sharing with any third party, photographic or
other imagery, information, or any other content from any and all activities within or from the Site. You must not use any such information
or content for any purpose other than your participation in the Services in accordance with this Agreement. You hereby agree to notify
SurveyExchange immediately if you learn of or suspect any use or disclosure of, or access to, any such information or content other than
as specifically authorized in this Agreement.
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17. EU-IN and Swiss-IN Privacy Shield
Although we are not yet Privacy Shield certified, SurveyExchange adheres to the Privacy Shield Principles of Notice, Choice, Accountability
for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any
conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.
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18. Complaints
In compliance with the EU-US and Swiss-US Privacy Shield Principles, SurveyExchange commits to resolve complaints about your privacy
and our collection or use of your personal information. European Union individuals with inquiries or complaints regarding this privacy
policy should first contact SurveyExchange at:
SurveyExchange
Attn: Privacy Policy Support
238-239, 2nd Floor, SRS IT Tower, Mathura Road
Faridabad, HR 121001
Email: [email protected]
© 2023 Surveyexchange | All Rights Reserved
Privacy Policy
Terms and Conditions
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Privacy policy – Savanta US
Home /
Privacy policy
Privacy policy
Last reviewed: March 2024
1 Purpose of this privacy notice
At Savanta we provide various market research services including designing
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market research surveys, hosting opinion panels and providing audience research
services and statistical analytics to global businesses (“Services”). We are
research group, the privacy of research respondents in connection with the
provision of our Services. We want to provide a safe and secure service where we
deal with your personal data.
This Privacy Notice sets out how processes your personal data in connection with
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committed to protecting the privacy of our website visitors, clients and, as a market
the provision of our Services (including our services offered through our Vue
Product Range) and our websites at and https://opinionpanel.co.uk (“Sites”). This
Privacy Notice also sets out your rights in respect of our processing of your
personal .
When we talk about “personal data”, we mean any information which relates to an
identified or identifiable living individual. Individuals might be identified by
reference to a name, an identification number, location data, an online identifier
(such as an IP address) or to other factors that are specific to them, such as their
physical appearance.
This Privacy Notice is intended to assist you in making informed decisions when
using our Sites and our Services. Please take a moment to read and understand it.
It should be read in conjunction with our .
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Please note your access to and use of our Sites and/or Vue Product Range
including your -Vue account page and any secure area, is subject at all times to
separate Terms of Use and/or Terms of Service.
2 Changes to this Privacy Notice
We will update this Privacy Notice from time-to-time to reflect any changes or
proposed changes to our use of your personal data, or to comply with changes in
applicable law or regulatory requirements. We may notify you by email of any
significant changes to this Privacy Notice, but we encourage you to review this
Privacy Notice periodically to keep up to date on how we use your personal data.
3 About Us
The Sites and our Services are made available by various companies in the Savanta
Where this Privacy Notice refers to “Savanta”, “we”, “us, “our”, this means Savanta
Group Limited, or one or more of the particular Group Companies that provide the
particular Site or Services to you.
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group of companies (each a “Group ”).
We set out below more information about our Group Companies, including their
Location: United Kingdom
Savanta Group Limited (company no: SC 281 352) is a company established under
the laws of Scotland with its registered office at C/O Bellwether Green Limited, 225
W George St, Glasgow G2 2ND.
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location and respective roles and responsibilities.
Location: USA
Savanta Group LLC (company no: 200823810071 is a company established under
the laws of the United States with its registered office at 300 California Street,
Suite 200, San Francisco, CA 94104.
Location: Canada
Savanta Analytics Ltd (BN 749932919, Registry ID BC1167318, registered in
Vancouver, CA)
Location: India
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Savanta Analytics Private Limited (CIN U74999UP2020PTC133576, PAN
ABECS3099M, TAN MRTS20085C
Except as stated otherwise, each Group Company is an independent controller of
your personal data. However, in connection with the provision of our Services, we
may carry out certain activities referred to in this Privacy Notice in our capacity as
a data processor acting on behalf of our clients. We have made this distinction
clear in the Privacy Notice.
4 How to contact us
If you have any questions about this Privacy Notice or want to exercise your rights
On Site
Contact us using our Enquiry Form.
Email
Send us an email at: [email protected].
Write to us at: Savanta DPO, 60 Great Portland Street,
London, W1W 7RT.
Call us on: +44 (0)20 7632 3434 (UK EMEA) or +1 (917)
768-2710 (Canada ).
Post
Telephone
5 What personal data we collect
In providing our Sites and Services, we may collect and process different types of
personal data about you for different processing purposes. The types of personal
data we collect depends on who you are and how you use our Site and Services
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following methods:
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as a data subject set out in this Privacy Notice, you can contact us using the
and includes the following:
Identity Data
Contact Data
Respondent Data
Image Data
Financial Data
Behavioural Data
First name; last name.
Home address; billing and/or delivery address; email
address; telephone number.
Account username; password; first name; last name;
date of birth; gender; country; nationality; username;
job title; social status; sexual orientation; whether you
have participated in any survey or questionnaire
responses and feedback; survey responses,
participation in any promotions or competitions.
Photos; video recordings.
Bank account details: partial payment card details and
details about payments made between you and us.
Data relating to your browsing activity or interaction
with our emails, obtained through the use of cookies,
pixel tags and other similar technologies; information
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about when your current or previous sessions started;
details about any products you viewed or purchased
through the Sites.
Marketing and
Communications Data
Marketing preferences; service communication
preferences.
Publicly Available Data
Information about articles (or similar) that you may
have published; information about your interests or
affiliations or publicly stated positions on political
matters, corporate matters and similar.
6 How we collect and receive personal data
We collect and receive personal data using different methods:
You may give us your personal data directly, for
example, when you agree to take part in market
research opinion panels, or when you provide your
Personal data you provide
Contact Data as part of a survey, purchase services via
to us
our Site, contact us with enquiries, complete forms on
our Site, subscribe to receive our marketing
communications or provide feedback to us.
Personal data we collect
using cookies and other
similar technologies
When you access and use our Site, we will collect
certain Behavioural Data and Technical Data. We
collect this personal data by using cookies and other
similar technologies (see the “Insight, analysis and
retargeting through Cookies” section below).
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Job Applicant Data
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Technical Data
IP address; browser type and operating system;
geolocation, to ensure we’re showing you the correct
notices and information; any other unique numbers
assigned to a device.
Date of birth; gender; country; nationality; CVs; work
experience; dietary requirements; any other personal
data you may provide in advance of/during your supply
of services to us.
We may receive personal data about you from third
Personal data received
parties. Such third parties may include our clients,
from third parties
market research sample and list suppliers, analytics
providers, data brokers and third party directories.
From time to time, we may collect personal data about
you (Identity Data and Contact Data) that is contained
in publicly available sources (including open source
Publicly available personal data sets or media reports) or that you or a third party
data
may otherwise make publicly available (for example
through speeches at events or publishing articles or
other news stories or posts on social media
platforms).
7 Who we collect personal data about
We collect and process personal data from the following people:
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Site visitors
If you browse our Site or register an account on our
Site, we will collect and process your personal data in
connection with your interaction with us and our Site.
If you contact us with an enquiry through our Site,
submit a complaint through our Site or provide any
People who contact us with
feedback, we will collect and process your personal
enquiries
data in connection with your interaction with us and
our Site.
Visitors to our physical
locations
If you attend one of our offices or other locations, we
may process personal data that you volunteer in
connection with your visit and any enquiries you make.
For example, you may volunteer personal data when
asking us to assist you in finding accommodation or
transportation suitable for your needs, or when signing
in as a guest. CCTV footage may also be collected for
security purposes.
Event attendees
If you attend one of our events, we will process
personal data about you in connection with your
attendance at the event. For example, we may ask you
to complete a registration or feedback form, or other
document relating to the event.
Job applicants
If you apply for a job with us, whether through the Site
or otherwise, we will collect and process your personal
data in connection with your application.
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If you work for one of our clients or suppliers and have
responsibility for placing orders with us, administering
People who work for our
your organisation’s account with us or handling our
clients and suppliers
orders or our account with your organisation, we will
process your personal data in connection with your
organisation’s relationship with us.
If you supply services and/or content to us and work
with us to provide services to our client (including
feature in content we produce), we may collect and
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process your personal data, such as your Identity Data,
Contact Data, Financial Data, CVs in connection with
such supply of services and/or content to us and our
clients.
If you (or your organisation) supply products or
services to us or otherwise partner with us, we may
collect and process your personal data in connection
with our receipt of those products and services and/or
Partner/supplier personnel
partnership. This may include personal data included
in any email or telephone communications or recorded
on any document relating to an order for the products
or services, such as your Contact Data.
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Respondents
If you participate in one of our surveys or panels, we
will process your data including Respondent Data and
Financial Data in connection with your participation.
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Members of the public
We may collect and process your data that you
volunteer or where you have indicated to us, market
research sample or list providers that you are willing to
take part in market research and/or opinion panels in
connection with the provision of Services to our
clients.
8 How we use your personal data
We use your personal data for the purposes set out in this section. If we wish to
make any changes to these purposes, or if we wish to use your personal data for
any purpose that is not listed in this section, we will notify you using the contact
details we hold for you.
When you browse our Sites, we collect and process
Behavioural Data and Technical Data to help us
understand how you are using and navigating our
Sites. We do this so that we can better understand
which parts of our Sites are more or less popular and
improve the structure and navigation of our Sites.
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A: Use of our Sites
Our legal basis for processing
It is in our legitimate interest to use personal data in
such a way to ensure that we provide access to our
Sites in a secure and effective way and so that we can
make improvements to our Sites or it is necessary for
us to use your personal data to perform our obligations
in accordance with any contract that we may have with
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If you browse our Sites
you for the Services.
We will collect and use personal data about you when
you use certain features on our Site. For example,
depending on the nature of your enquiry, we may
process your Identity Data, Contact Data and certain
Behavioural Data and Technical Data when you use the
Enquiry Form to get in touch with us.
If you use the interactive
features on our Site
Our legal basis for processing
It is in our legitimate interest to use personal data in
such a way to ensure that we can respond to your
enquiries, provide access to our Sites in a secure and
effective way and make improvements to our Site.
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If you click on one of the social media links on our
Sites or otherwise interact with our social media pages
such as on Twitter or Instagram or YouTube (including
interacting with any ‘like’ or similar embedded features
on our Sites or social media accounts), we and the
relevant social media platform may receive
information relating to such interaction and may share
your personal data in connection with this purpose,
such as certain Behavioural Data and Technical Data.
For more information about how we use this personal
data, please see the “Insight, analysis and retargeting
through Cookies” section below.
The relevant social media platform may also be a
If you link to social media
sites and interact with our controller in respect of the personal data that is
collected via your use of our social media pages and
social media pages
For details of how the relevant social media platform
uses your personal data, please see the privacy policy
of the relevant social media platform.
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may use that personal data for additional purposes.
Our legal basis for processing
the ways described above to ensure that we provide
the Site in an effective way and to promote our Site via
social media.
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It is in our legitimate interest to use personal data in
B: Fulfilment of our Services
Carrying out surveys and
reporting
We collect and maintain personal data that you submit
and/or third parties provide to us for in connection
with your participation in one of our surveys that we
carry out on behalf of our clients or for our own market
analysis purposes.
The information you provide will normally be used to
help a client better understand how they are doing in
the marketplace, or to help them improve a service or
similar. Data is typically presented back to our client as
part of our Services in an aggregated, anonymised
format, unless you consent to us providing them your
Contact Data appended. For example, to enable you to
collect a reward if completing a survey requires it.
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The personal data we process may include your
Identity Data, Contact Data, Respondent Data, and
Financial Data (where applicable). We process this
information so that we can fulfil the supply of our
Services, maintain our user databases and to keep a
record of how we provide our Services.
Our legal basis for processing
To the extent the above involves personal data and we
are considered a controller of your data, it may be
necessary for us to use your personal data to perform
our obligations in accordance with any contract that
we may have with you. Or it is in our legitimate interest
personal data in such a way to ensure that we provide
the Services in an effective, safe and efficient way.
Where we do this on behalf of our clients as a data
processor, we do not require a legal basis for such
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or a third party’s legitimate interest for us to use
processing.
categories of personal data or personal data relating to
criminal convictions or offences except where we are
able to do so under applicable legislation or with your
explicit consent.
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We will not process any special (or sensitive)
Please note that often such services will relate to
anonymous data sets (aggregated data sets, statistical
data sets and similar) and are used for high-level
market analytics or understanding macro consumer
habits (amongst other things). When we do this, we
and our clients are not processing personal data.
Managing our Panels
If you sign up to one of our market research opinion
panels, we will process personal data about you which
you provide to us when you complete your profile as
part of the sign-up profile. This will usually include your
Contact Data, Respondent Data, Financial Data and any
other personal data you volunteer.
If you are a parent or guardian of a minor who signs up
for a youth market research opinion panel, we may
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also process your personal data to record that you
have consented to the minor taking part in the panel
and completing a profile. We may process this type of
consent by recording a telephone call with you.
Once you have created a profile, we will be able to use
this information provided to select you to take part in
relevant surveys.
Our legal basis for processing
To the extent the above involves personal data, it may
be necessary for us to use your personal data to
perform our obligations in accordance with any
contract that we may have with you. Or it is in our
for us to use personal data in such a way to ensure
that we provide the Services in an effective, safe and
efficient way.
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legitimate interest or a third party’s legitimate interest
services to clients, we can create aggregated and
anonymised market insights through our Vue Product
Range for our benefit and that of our clients using a
wide range of software tools to extract information
about target markets, customers, and marketing
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In additional to providing bespoke market research
efforts from data provided to us by our clients or from
information you provide to us through completing our
Provision of market insight surveys or through third party providers.
through our Vue Product
Range
Our legal basis for processing
To the extent the above involves personal data, it is in
our legitimate interest or a third party’s legitimate
interest for us to use personal data in such a way to
ensure our services are easy to use providing us and
our clients with up to date and valuable insights.
Where we do this on behalf of our clients as a data
processor, we do not require a legal basis for such
processing.
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You may be required to register an account with us in
order to gain access to our Vue Product Range.
Account applicants will need to complete the
registration form, providing all required Identity Data
and Contact Data (including their first name, last name,
email address, telephone number, and organisation).
We will use this data in order to process your
registration.
Once the account is registered, we will process your
Identity Data to identify you when you log in to your
account and access secure areas of the Vue Product
and Marketing and Communications Data so that we
Use of our Vue Product
Range.
can administer your account and contact you about
your account.
We will also collect and process Behavioural Data and
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Range. We will also process certain Technical Data
Technical Data when you use certain features and
helps us understand how you use our Vue Product
Range so that we can improve it.
Our legal basis for processing
It is necessary for us to use your personal data to
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functionality on our Vue Product Range. This data
perform our obligations in accordance with any
contract that we may have with you, or it is in our
legitimate interest to use personal data in such a way
to ensure that we provide access to the Services in a
secure and effective way and so that we can make
improvements to our Services.
If you complete our
surveys or provide
feedback on your
experience of our Site
and/or our Services
From time to time, we will invite you to provide
feedback about us, our Site and our Services in the
form of online surveys. These are separate to the
market research surveys we provide. We will collect
and process your Identity Data and Contact Data as
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well as any other personal data you choose to
volunteer in your survey response or other feedback.
We use this information to help us to monitor and
improve our Site and our Services, to assist with the
selection of future service lines and to train our
personnel.
You can also voluntarily provide feedback by email or
via our Enquiry Form.
Our legal basis for processing
It is in our legitimate interest to use the personal data
provided by you so that we can improve our Site and
From time to time, we may incentivize participation in
our market research activities by running prize draws,
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our Services and provide them in an effective way.
prize competitions and other promotions on our Sites,
the purposes of administering such promotions, we
may process your Identity Data, Contact Data and any
other personal data volunteered by you in relation to
your promotion entry.
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client sites and/or on our social media accounts. For
Our promotions are subject to separate terms and
If you participate in one of conditions, which you may be required to accept as a
our promotions
condition of entry.
Our legal basis for processing
It is necessary for us to use your personal data to
perform our obligations in accordance with any
contract that we may have with you (e.g. the promotion
terms and conditions) or it is in our legitimate interest
to use your personal data to enable us to administer
our promotion fairly and effectively and to ensure that
we comply with self-regulatory codes governing the
operation of promotions.
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If you have a general
There are various ways in which you are able to contact
question or need help with us (see the “How to Contact us” section above). In
any issue concerning our particular, our Site features a “Contact Us” page, which
Sites or our Services
invites you to submit general enquiries about our Sites
by email or via our Enquiry Form. From time to time,
you may also be able to submit specific enquiries on
other pages of our Sites, including in secure account
areas.
When you make an enquiry, we will collect and process
your Identity Data, Contact Data as well as any other
personal data you volunteer that is relevant to your
enquiry. If you have a technical issue concerning our
Sites, we may also collect and process Behavioural
technical issues you are experiencing and to help us
resolve them in an efficient way. We use this
information to manage and respond to your enquiry.
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Data and Technical Data to help us diagnose the
We may record telephone conversations to improve
how we train our personnel and the quality of our
Our legal basis for processing
It is in our legitimate interest to use your personal data
in the ways described above to ensure that we are able
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services.
to help you with your enquiry, provide a good standard
of service and improve our customer services.
C: Hosting and managing
If you sign up for and/or
attend one of our events
From time to time, we may organise and host events
for the purpose of promoting our business or for
charitable causes or other reasons. We may process
your Identity Data and Contact Data to communicate
with you about such events where you have specifically
requested information about such events or where we
have another lawful basis for sending that information
to you.
If you attend one of our events, we may use your
Identity Data and Contact Data to record your
attendance at the event and for related record-keeping
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purposes and, if relevant, we may collect and process
any dietary requirements you may have. You may also
feature in photographs taken at our events and such
photographs may appear in publications that we make
available.
Our legal basis for processing
It is necessary for us to use your personal data in this
way to perform our obligations in accordance with any
contract that we may have with you where you have
signed up to attend an event, or it is in our legitimate
interest or a third party’s legitimate interest to use
personal data in such a way to ensure that the event is
We may specifically ask your permission to use your
photographs, quotes, testimonials, or other content that
you make available or publish at the event. Where this
Get in touch
operated in an effective way.
is the case, our processing of your such personal data
D: Insight, analysis and retargeting through Cookies
If we use cookies to help
us understand more about
you and your use of our
Site and our Products and
Services
We and our third-party partners use cookies, web
beacons, pixel tags and other similar technologies
(which we generically refer to as “Cookies”) to collect
data from the devices that you use to access our Site
and Services and any emails that you receive from .
The data that is collected includes Behavioural Data
and Technical Data Please see our Cookie Policy for
further information, including details of our third-party
partners.
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will be based on consent.
We and our third-party partners use this data to
analyse how you use our Sites and Services and the
effectiveness of our Sites and Services, including:
· to count users who have visited our Sites or
opened an email and collect other types of information,
including insights about visitor browsing habits, which
helps us to improve our Sites and Services and the
effectiveness of our emails;
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· to measure the effectiveness of our content;
· to learn what parts of our Sites are most attractive
to our users, which parts of our Sites are the most
interesting and what kind of features and
functionalities our visitors like to see;
· to help us understand the type of marketing
content that is most likely to appeal to our visitors and
customers; and
· to help us with the selection of future service lines,
website design and to remember your preferences.
In some of our email messages, we use a “clickby us or on our behalf. We may track click-through data
to assist in determining interest in particular topics and
measure the effectiveness of these communications.
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through URL” linked to certain websites administered
Our legal basis for processing
In certain circumstances, we may rely on another
lawful basis when we use your personal data collected
via the use of cookies. For example, where we use
personal data collected through the use of analytics
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cookies to analyse how you use our Sites, it is in our
legitimate interest to use your personal data in such a
way to improve our Sites and Services.
E: Advertising and marketing activities
If we send you marketing
communications by post
and/or email/SMS
We use your Identity Data, Contact Data and Marketing
and Communications Data to send you (or the
organisation you represent) marketing
communications by post and/or email/SMS. Our
marketing will include press releases and information
about us, our Site, our Services, any events we may
hold and the offers and promotions we offer from time
to time.
Our marketing communications will include
personalised and non-personalised marketing.
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Personalised marketing has been specifically tailored
to you and will include content that we think is most
relevant to you, based on what we know about you.
Non-personalised marketing is marketing that is not
tailored to you.
Where we are sending you personalised marketing, we
may also use Transaction Data and Behavioural Data
to help us decide what sort of personalised marketing
to send you (please see the “Insight, analysis and
retargeting through Cookies” section above for more
details).
Our legal basis for processing
for marketing purposes, for example to decide what
marketing content we think may appeal to you.
It is in our legitimate interest to use your personal data
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It is in our legitimate interest to use your personal data
to send our marketing to you by post.
to you by email and/or SMS where you have
consented to receive such content by email and/or
SMS, or where we have another lawful right to send
marketing to you using email and/or SMS. For
example, in certain circumstances we may rely on our
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However, we will only send marketing communications
legitimate interest to send marketing by email and/or
SMS to consumers who have purchased our Services.
We may also rely on our legitimate interest to send
marketing by email and/or SMS to certain business
users of our Sites and Services.
Blogs and Newsletters
We may also provide individuals with the opportunity
to sign up for newsletters or to receive copies of blogs
and other information that we make available. Where
an individual signs up to receive such information,
Contact Data may be requested as well as other
information to ensure our communications are
suitably tailored.
Our legal basis for processing
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It is in our legitimate interests (and those of our
clients) to process personal data in this way to ensure
we provide the Services requested by our clients in an
effective and efficient way and that we provide the
right information to those who request it.
We may collect personal data (including Identity Data,
Contact Data and Publicly Available Data) about
journalists, client contacts or industry contacts for
interview requests, for media questions, or requests
for information about Savanta. This information is
used in order to enable us to respond to individual
requests or media requests.
Media and Informational
inquiries
Our legal basis for processing
clients) to process personal data in this way to ensure
we provide the Services requested by our clients in an
effective and efficient way and that we provide the
right information to those who request it.
Get in touch
It is in our legitimate interests (and those of our
If we use your personal
We use your personal data for recruitment purposes, in
data in connection with
particular, to assess your suitability for any of our
our recruitment activities positions that you apply for, whether such application
has been received by us online, by email or by hard
copy and whether submitted directly by you or by a
third-party recruitment agency on your behalf. We also
use your Identity Data and Contact Data to
communicate with you about the recruitment process,
to keep records about our recruitment process and to
comply with our legal and regulatory obligations in
relation to recruitment.
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F: Recruitment
We will process any personal data about you that you
volunteer, including during any interview, when you
apply for a position with us. We may also process your
personal data obtained from any third parties we work
with in relation to our recruitment activities, including
without limitation, recruitment agencies, background
check providers, credit reference agencies and your
referees.
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The personal data we process may include your
Identity Data, Contact Data, Job Application Data and
any other personal data that you volunteer during an
interview or your interactions with us, or any personal
data which is contained in any reference about you that
we receive. Such information may also include special
categories of personal data (such as information about
your health, any medical conditions and your health
and sickness records) and information relating to
criminal convictions and offences if that information is
relevant to the role you are applying for.
We also use your personal data for the purposes of
reviewing our equal opportunity profile in accordance
the grounds of gender, race, ethnic origin, age, religion,
sexual orientation, disability or any other basis covered
by local legislation. All employment-related decisions
are made entirely on merit.
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with applicable legislation. We do not discriminate on
Where we use your personal data in connection with
recruitment and talent management, it will be in
connection with us taking steps at your request to
enter into a contract we may have with you, or it is in
our legitimate interest to use personal data in such a
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Our legal basis for processing
way to ensure that we can make the best recruitment
and talent management decisions.
We will not process any special (or sensitive)
categories of personal data or personal data relating to
criminal convictions or offences except where we are
able to do so under applicable legislation or with your
explicit consent.
G: Receipt of products and services from our suppliers
If we have engaged you or
the organisation you
represent to provide us
with products or services
If we have engaged you or the organisation you
represent to provide us with products or services (for
example, if you or the organisation you represent
provide us with services such as IT support or financial
advice), we will collect and process your personal data
in order to manage our relationship with you or the
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organisation you represent, to receive products and
services from you or the organisation you represent
and, where relevant, to provide our Services to others.
The personal data we collect from you may include
your Identity Data and Contact Data and any other
personal data you volunteer which is relevant to our
relationship with you or the organisation you represent.
Our legal basis for processing
It is necessary for us to use your personal data to
perform our obligations in accordance with any
contract that we may have with you or the organisation
you represent, or it is in our legitimate interest to use
personal data in such a way to ensure that we have an
effective working relationship with you or the
products and services that you or your organisation
provides, and provide our Services to others, in an
effective way.
Get in touch
organisation you represent and are able to receive the
We have security measures in place at our premises,
including CCTV and building access controls. There
are signs in place showing that CCTV is in operation.
The images captured are securely stored and only
accessed on a need-to-know basis (e.g. to look into an
incident). CCTV recordings are typically automatically
overwritten after a short period of time unless an issue
is identified that requires investigation (such as a
theft).
If we need to use your
personal data in
connection with the
administration of our
security measures
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H:
We may require visitors to our premises to sign in on
arrival and where that is the case, we will keep a record
of visitors for a short period of time. Our visitor
records are securely stored and only accessible on a
need-to-know basis (e.g. to look into an incident).
Our legal basis for processing
It is in our legitimate interests to process your
personal data so that we can keep our premises
secure and provide a safe environment for our
personnel and visitors to our premises.
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I: Business administration and legal compliance
We may use your personal data: (i) to comply with our
legal obligations; (ii) to enforce or protect our legal
rights; (iii) to protect the rights of third parties; and (iv)
in connection with a business transition such as a
merger, reorganisation, acquisition by another
company, or sale of any of our assets.
Our legal basis for processing
Where we use your personal data in connection with a
business transition, to enforce or protect our legal
rights or to protect the rights of third parties, it is in our
legitimate interest to do so. For all other purposes
described in this section, we have a legal obligation to
use your personal data to comply with any legal
obligations imposed upon us, such as a court order.
We will not process any special (or sensitive)
categories of personal data or personal data relating
Get in touch
If we need to use your
personal data to comply
with our legal obligations
or in connection with the
administration of our
business
to criminal convictions or offences except where we
are able to do so under applicable legislation or with
9 If you fail to provide your personal data
Where we are required by law to collect your personal data, or we need to collect
your personal data under the terms of a contract we have with you, and you fail to
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your explicit consent.
provide that personal data when we request it, we may not be able to perform the
contract we have or are trying to enter into with you. This may apply where you do
not provide the personal data we need in order to provide the Services you have
requested from us or to process an application for employment with us. In these
circumstances, we may have to cancel your application or the provision of the
relevant Services to you, in which case we will notify you.
10 How we obtain your consent
Where our use of your personal data requires consent, you can provide such
consent at the time we collect your personal data following the instructions
provided, or by informing us using the contact details set out in the “How to
Contact Us” section above.
11 Third-party links
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This Privacy Notice only applies to personal data processed by us through your use
of our Sites and/or in connection with our business operations. However, from time
to time, our Sites may contain links to third-party websites and services. We have
no control over these websites and services and this Privacy Notice does not apply
to your interaction with the relevant third parties.
When you use a link to go from our Site to another website (even if you don’t leave
our Site) or you request a service from a third party, your browsing and interactions
on any other websites, or your dealings with any other third-party service provider,
is subject to that website’s or third-party service provider’s own rules and policies.
For example, our Site invites you to connect with us on social media platforms
such as Twitter and LinkedIn. When you click on the links we provide to such thirdparty platforms, you will be transferred from our Site to the relevant third-party
platform and the privacy notice (and other terms and conditions) of that platform
We do not monitor, control or endorse the privacy practices of any third parties. We
encourage you to become familiar with the privacy practices of every website you
visit or third-party service provider that you use in connection with your interaction
Get in touch
will apply to you.
with us and to contact them if you have any questions about their respective
12 Sharing Your personal data
We only share personal data with others when we are legally permitted to do so.
When we share personal data with others, we put contractual arrangements and
security mechanisms in place to protect the personal data shared and to comply
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privacy notices and practices.
with our data protection, confidentiality and security standards and obligations.
When processing your personal data, we may need to share it with third parties
(including other entities within our group of companies), as set out in the table
below. This list is non-exhaustive and there may be circumstances where we need
to share personal data with other third parties.
Our clients
We may share personal data with our clients for the
purposes of providing them with our Services.
We use various specialist suppliers and/or partners in
order to provide our Services including sample
suppliers.
Third-party suppliers who We share personal data with third parties who support
provide applications/
us in providing our Sites and help provide, run and
functionality, data
manage our internal IT systems. Such third parties
processing or IT services may also include, for example, providers of
information technology, cloud-based software-as-aOur specialist
suppliers/partners
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We share personal data with third parties who assist
us with the processing of payments and refunds.
Third-party post/email
marketing and CRM
specialists
We share personal data with specialist suppliers who
assist us in managing our marketing database and
sending out our post and email marketing
communications and account-related
communications.
Third-party suppliers who We share personal data with specialist suppliers who
assist us in administering assist us in administering our prize draws, prize
our promotions
competitions and other promotions.
Event partners and
suppliers
When we run events, we will share your personal data
with third-party service providers that are assisting us
with the operation and administration of that event. If
we are running an event in partnership with other
organisations, we will share your personal data with
such organisations for use in relation to the event.
We share personal data with external recruiters, thirdRecruitment agencies and party providers that undertake background checks on
related organisations
our behalf and other entities within our group of
companies.
We share personal data with professional services
Auditors, lawyers,
firms who advise and assist us in relation to the lawful
accountants and other
and effective management of our organisation and in
professional advisers
relation to any disputes we may become involved in.
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Payment providers and
banks
Get in touch
service providers, identity management, website
design, hosting and management, data analysis, data
back-up, security and storage services. The servers
powering and facilitating that cloud infrastructure are
located in secure data centres around the world, and
personal data may be stored in any one of them. We
also share your personal data with third-party service
providers to assist us with insight analytics. These
providers are described in our Cookie Policy.
We share personal data with law enforcement or other
Law enforcement or other
government and regulatory agencies or other third
government and regulatory
parties as required by, and in accordance with,
agencies and bodies
applicable law or regulation.
Other third parties
Occasionally, we may receive requests from third
parties with authority to obtain disclosure of personal
data, such as to check that we are complying with
applicable law and regulation, to investigate an
alleged crime, or to establish, exercise or defend legal
rights. We will only fulfil requests for personal data
where we are permitted to do so in accordance with
applicable law or regulation.
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In respect of personal data that we process in connection with the supply of our
Services, we may retain your personal data for up to seven years from the date of
supply of the relevant Services and in compliance with our data protection
obligations. We may then destroy such files without further notice or liability.
Where we process personal data in connection with the registration and use of an
account on our Sites, we may retain your personal data for up to seven years from
the date that the relevant account is terminated (and in compliance with our data
protection obligations). We may then destroy such files without further notice or
liability.
Where we process any other personal data, we will retain relevant personal data for
up to three years from the date of our last interaction with you (and in compliance
with our data protection obligations). We may then destroy such files without
If any personal data is only useful for a short period (e.g. for a specific market
research activity, promotion or marketing campaign), we will not retain it for longer
than the period for which it is used by us.
Get in touch
further notice or liability.
If you have opted out of receiving marketing communications from us, we will need
to retain certain personal data on a suppression list indefinitely so that we know
not use this personal data to send you further marketing unless you subsequently
opt back in to receive such marketing.
14 Confidentiality and security of your personal data
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not to send you further marketing communications in the future. However, we will
We are committed to keeping the personal data you provide to us secure and we
have implemented information security policies, rules and technical measures to
protect the personal data under our control from unauthorised access, improper
use or disclosure, unauthorised modification and unlawful destruction or
accidental loss. In addition, all our employees and data processors (i.e. those who
process your personal data on our behalf) are obliged to respect the confidentiality
of the personal data of all users of our Site and those who purchase our Services.
15 Personal data of minors
We may process personal data of minors (individuals aged 13 to 18 years old) in
connection with the provision of our Services including through our youth service.
We rely on the lawful bases set out above to process such personal data and where
legally required we will obtain parental consent in order to process such personal
data.
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16 Your rights as a data subject
You have certain rights in relation to the personal data we hold about you. These
rights include the right: (i) to obtain copies of your personal data; (ii) to have your
personal data corrected or deleted; (iii) to limit the way in which your personal data
is used; (iv) to object to our use of your personal data; (v) to transfer your personal
data; (vi) not to be subject to decisions based on automated processing (including
profiling); and (vii) to complain to a supervisory authority. If you would like to
exercise any of these rights, please contact us using the details set out in the
“above.
For more information about your specific data subject rights in certain jurisdictions,
please see relevant jurisdiction specific section below.
UNITED KINGDOM (“UK”) AND EUROPEAN
ECONOMIC AREA (“EEA”)
This UK and EEA Privacy Statement supplements the Savanta Privacy Notice. It
Get in touch
17 COUNTRY SPECIFIC PROVISIONS
applies to the extent our processing of your data is caught by the requirements of
Transfers outside the UK and the European Economic Area (“EEA”)
We may transmit personal data outside the UK and EEA to certain categories (as
listed above in Sharing your Personal Data and more specifically to (1) our
headquarters in San Francisco (“US”); (2) Savanta Group entities, networks or
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the UK GDPR and/or EU GDPR.
partner agencies in for example, India and other locations globally.
Therefore, when you submit personal data to us, whether through your interactions
with our Site, and branch offices or our headquarters in the US, you acknowledge
that your personal data will be transferred outside the UK and the EEA to the US
and other global locations where it will be stored and processed by us and our
suppliers for the purposes set out in this Privacy Notice.
Where necessary in order to provide our Site and our Services, we will transfer
personal data to countries outside the UK and the EEA.
Non-EEA countries do not have the same data protection laws as the UK and the
EEA. In particular, non-EEA countries may not provide the same degree of
protection for your personal data, may not give you the same rights in relation to
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your personal data and may not have a data protection supervisory authority to
help you if you have any concerns about the processing of your personal data.
However, when transferring your personal data outside the UK or the EEA, we will
comply with our legal and regulatory obligations in relation to your personal data,
including having a lawful basis for transferring personal data and putting
appropriate safeguards in place to ensure an adequate level of protection for the
personal data. We will take reasonable steps to ensure the security of your
personal data in accordance with applicable data protection laws.
When transferring your personal data outside the UK or the EEA, we will, where
required by applicable law, implement at least one of the safeguards set out below.
Please contact us if you would like further information on the specific mechanisms
Standard Contractual
Clauses
Where we use certain service providers, we may use
specific standard contractual clauses approved by the
European Commission and/or the UK Government
which give personal data the same protection it has in
Europe and/or the UK.
Your rights as a data subject
To the extent our processing of your data as a Data Controller is caught by the UK
GDPR and/or EU GDPR, you have the following rights. If you would like to exercise
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Adequacy decisions
We may transfer your personal data to countries that
have been deemed to provide an adequate level of
protection for personal data by the European
Commission and/or the UK Government (as
applicable).
Get in touch
used by us when transferring your personal data outside the UK or the EEA.
any of these rights, please contact us using the details set out in the “How to
Contact Us” section above.
Your right of access
If you ask us, we will confirm whether we are
processing your personal data and, if so, provide you
with a copy of that personal data (along with certain
other details). If you require additional copies, we may
charge a reasonable fee for producing those additional
copies.
Your right to rectification If the personal data we hold about you is inaccurate or
incomplete, you are entitled to have it rectified. If we
have shared your personal data with others, we’ll let
them know about the rectification where possible. If
you ask us, where possible and lawful to do so, we will
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Privacy policy – Savanta US
Your right to restrict
processing
You can ask us to “block” or suppress the processing
of your personal data in certain circumstances such as
where you contest the accuracy of that personal data
or you object to us processing it for a particular
purpose. This may not mean that we will stop storing
your personal data but, where we do keep it, we will tell
you if we remove any restriction that we have placed
on your personal data to stop us processing it further.
If we’ve shared your personal data with others, we’ll let
them know about the restriction where it is possible for
us to do so. If you ask us, where it is possible and
lawful for us to do so, we’ll also tell you who we’ve
shared your personal data with so that you can contact
them directly.
Your right to data
portability
You have the right, in certain circumstances, to obtain
personal data you have provided to us (in a structured,
commonly used and machine-readable format) and to
reuse it elsewhere or to ask us to transfer it to your
chosen third party.
Your right to object
You can ask us to stop processing your personal data,
and we will do so, if we are: (i) relying on our own or
someone else’s legitimate interest to process your
personal data, except if we can demonstrate
compelling legal grounds for the processing; or (ii)
processing your personal data for direct marketing
purposes.
Your rights in relation to
automated decisionmaking and profiling
You have the right not to be subject to a decision when
it is based on automatic processing, including profiling,
if it produces a legal effect or similarly significantly
affects you, unless such profiling is necessary for the
entering into, or the performance of, a contract
between you and us.
Your right to withdraw
consent
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Your right to erasure
You can ask us to delete or remove your personal data
in some circumstances, such as where we no longer
need it or where you withdraw your consent (where
applicable). If we have shared your personal data with
others, we will let them know about the erasure where
possible. If you ask us, where it is possible and lawful
for us to do so, we will also tell you who we have
shared your personal data with so that you can contact
them directly.
Get in touch
also tell you who we’ve shared your personal data with
so that you can contact them.
If we rely on your consent (or explicit consent) as our
legal basis for processing your personal data, you have
the right to withdraw that consent at any time. You can
exercise your right of withdrawal by contacting us
using our contact details in the ““How to Contact Us”
section above or by using any other opt-out
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Privacy policy – Savanta US
Your right to lodge a
complaint with the
supervisory authority
mechanism we may provide, such as an unsubscribe
link in an email.
If you have a concern about any aspect of our privacy
practices, including the way we have handled your
personal data, please contact us using the contact
details provided in the “How to Contact Us” section
above. You can also report any issues or concerns to a
national supervisory authority in the Member State of
your residence or the place of the alleged infringement.
You can find a list of contact details for all EU
supervisory authorities at
As we are incorporated in the United Kingdom, our
regulatory authority is the Information Commissioner’s
Office (“ICO”). Contact details for the ICO can be found
UNITED STATES
Get in touch
on its website at https://ico.org.uk.
This California Consumer Privacy Statement (“Statement”) supplements
the Savanta Privacy Notice. It applies solely to California consumers and
addresses personal information we collect online and offline. This Statement does
not apply to Savanta personnel. Sections 2-5 of this Statement do not apply to job
applicants.
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California Consumer Privacy Statement
This Statement uses certain terms that have the meaning given to them in the
California Consumer Privacy Act of 2018 and its implementing regulations (the
“CCPA”).
1. Notice of Collection and Use of Personal Information
We may collect (and may have collected during the 12-month period prior to the
effective date of this Statement) the following categories of personal information
about you:
Identifiers: identifiers such as a real name, alias, postal address,
unique personal identifier (such as a device identifier; cookies,
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beacons, pixel tags, mobile ad identifiers and similar technology;
customer number, unique pseudonym, or user alias; telephone
number and other forms of persistent or probabilistic identifiers),
online identifier, internet protocol address, email address, account
name, Social Security number, driver’s license number, passport
number, and other similar identifiers
Additional Data Subject to Cal. Civ. Code § 1798.80: signature,
physical characteristics or description, state identification card
number, insurance policy number, education, bank account number,
credit card number, debit card number, and other financial
information, medical information, and health insurance information
under California or federal law, such as race, color, national origin,
religion, age, sex, gender, gender identity, gender expression, sexual
orientation, marital status, medical condition, ancestry, genetic
information, disability, citizenship status, and military and veteran
Get in touch
Protected Classifications: characteristics of protected classifications
status
of personal property, products or services purchased, obtained, or
considered, and other purchasing or consuming histories or
tendencies
Online Activity: Internet and other electronic network activity
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Commercial Information: commercial information, including records
information, including, but not limited to, browsing history, search
history, and information regarding your interaction with websites,
applications or advertisements
Sensory Information: audio, electronic, visual, and similar information
Employment Information: professional or employment-related
information
Education Information: education information that is not publicly
available personally identifiable information as defined in the Family
Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R.
Part 99)
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Inferences: inferences drawn from any of the information identified
above to create a profile about you reflecting your preferences,
characteristics, psychological trends, predispositions, behaviour,
attitudes, intelligence, abilities, and aptitudes.
We may use (and may have used during the 12-month period prior to the effective
date of this Statement) your personal information for the purposes described in
our Privacy Notice and for the following business purposes specified in the CCPA:
Performing services, including maintaining or servicing accounts,
providing customer service, processing or fulfilling orders and
transactions, verifying customer information, processing payments,
providing advertising or marketing services, providing analytics
Auditing related to a current interaction with you and concurrent
transactions, including, but not limited to, counting ad impressions to
unique visitors, verifying positioning and quality of ad impressions,
Get in touch
services, or providing similar services
and auditing compliance
customization of ads shown as part of the same interaction
Detecting security incidents, protecting against malicious, deceptive,
fraudulent, or illegal activity, and prosecuting those responsible for
that activity
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Short-term, transient use, including, but not limited to, the contextual
Debugging to identify and repair errors that impair existing intended
functionality
Undertaking internal research for technological development and
demonstration
Undertaking activities to verify or maintain the quality or safety of a
service or device that is owned, manufactured, manufactured for, or
controlled by us, and to improve, upgrade, or enhance the service or
device that is owned, manufactured, manufactured for, or controlled
by us.
Managing career opportunities with Savanta.
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1. Sources of Personal Information
During the 12-month period prior to the effective date of this Statement, we may
have obtained personal information about you from the following categories of
sources:
Directly from you, such as when you contact us with a question or
comment
From your devices, such as when you visit our Site
Vendors who provide services on our behalf
Social networks
Government entities
Get in touch
Data brokers
We do not and will not sell your personal information.
1. Sharing of Personal Information
During the 12-month period prior to the effective date of this Statement, we may
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1. Sale of Personal Information
have shared your personal information with certain categories of third parties, as
described below.
We may have disclosed the following categories of personal information about you
for a business purpose to the following categories of third parties:
Category of Personal
Information
Category of Third Party
Identifiers
Our affiliates and subsidiaries; Vendors who provide
services on our behalf; Professional services
organizations, such as auditors and law firms; Our
business partners; Advertising networks; Internet
service providers; Data analytics providers; Operating
systems and platforms; Social networks
Additional
Our affiliates and subsidiaries; Vendors who provide
services on our behalf; Professional services
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Online Activity
Our affiliates and subsidiaries; Vendors who provide
services on our behalf; Professional services
organizations, such as auditors and law firms; Our
business partners; Advertising networks; Internet
service providers; Data analytics providers; Operating
systems and platforms; Social networks
Employment Information
Our affiliates and subsidiaries; Vendors who provide
services on our behalf; Professional services
organizations, such as auditors and law firms; Our
business partners; Advertising networks; Internet
service providers; Data analytics providers; Operating
systems and platforms; Social networks
Education Information
Our affiliates and subsidiaries; Vendors who provide
services on our behalf; Professional services
organizations, such as auditors and law firms; Our
business partners; Advertising networks; Internet
service providers; Data analytics providers; Operating
systems and platforms; Social networks
Inferences
Our affiliates and subsidiaries; Vendors who provide
services on our behalf; Professional services
organizations, such as auditors and law firms; Our
business partners; Advertising networks; Internet
service providers; Data analytics providers; Operating
systems and platforms; Social networks
Get in touch
Commercial
Our affiliates and subsidiaries; Vendors who provide
services on our behalf; Professional services
organizations, such as auditors and law firms; Our
business partners; Advertising networks; Internet
service providers; Data analytics providers; Operating
systems and platforms; Social networks
Latest Thinking
Protected Classifications
organizations, such as auditors and law firms; Our
business partners; Advertising networks; Internet
service providers; Data analytics providers; Operating
systems and platforms; Social networks
Our affiliates and subsidiaries; Vendors who provide
services on our behalf; Professional services
organizations, such as auditors and law firms; Our
business partners; Advertising networks; Internet
service providers; Data analytics providers; Operating
systems and platforms; Social networks
In addition to the categories of third parties identified above, during the 12-month
period prior to the effective date of this Statement, we may have shared personal
information about you with the following additional categories of third parties:
Government entities.
1. California Consumer Privacy Rights
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You have certain choices regarding our use and disclosure of your personal
information, as described below.
Access: You may have the right to request, twice in a 12-month period, that we
disclose to you the personal information we have collected, used, disclosed and
sold about you during the past 12 months.
Deletion: You have the right to request that we delete certain personal information
we have collected from you.
request as an authorized agent on behalf of a consumer), please contact us as
described in “How to Contact Us” section above.
Get in touch
How to Submit a Request: To submit an access or deletion request (or to submit a
Verifying Requests: To help protect your privacy and maintain security, we will
information or complying with your request. If you request access to or deletion of
your personal information, we may require you to provide any of the following
information: your email address, the name of the Savanta representative with
whom you typically interact, and the date of your last interaction with a Savanta
representative. In addition, if you ask us to provide you with specific pieces of
Latest Thinking
take steps to verify your identity before granting you access to your personal
personal information, we will require you to sign a declaration under penalty of
perjury that you are the consumer whose personal information is the subject of the
request.
Additional Information: If you choose to exercise any of your rights under the
CCPA, you have the right to not receive discriminatory treatment by us. To the
extent permitted by applicable law, we may charge a reasonable fee to comply with
your request.
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Terms & conditions
Cookie policy
Accessibility statement
Privacy policy
Carbon Reduction Plan
Data protection
Modern Slavery Statement
Savanta Group 2024
Registered in Scotland (SC 281 352) | Registered Address: C/O Bellwether Green
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Get in touch
Limited, 225 W George St, Glasgow G2 2ND
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Privacy Policy - MFour Mobile Research
(https://mfour.com)
Privacy Policy
I. PRIVACY POLICY
This privacy policy is effective as of October 5, 2022. MFour Mobile Research, Inc. (“MFour,” “we,” “us,” “our”) is
committed to protecting the privacy and security of your personal information. We also want to be upfront
and clear about information we collect, how we use it, and rights you may have. MFour is a market research
technology company providing services, including sharing data, to other market research companies, third
parties operating in the ad tech sector, companies providing products and services to consumers, and other
parties (collectively “Partners”) for the purposes of market research, including ad measurement, analytics and
reporting, and other purposes. MFour does not share data with Partners that would use the data to directly
advertise or market to you.
This Privacy Policy explains how we collect, use, and share information when individuals (“you”) visit or interact
with our websites including www.surveysonthego.com, www.surveysonthego.net, www.mfour.com, and
www.mfour.net (the “Sites”), and the Surveys On The Go® mobile application (the “SOTG App”). The Sites and
the SOTG App together are called the “Services” in this Privacy Policy.
The SOTG App is available in the Apple App Store and Google Play Store. If you download the SOTG App, you
will be able to create an account and receive and respond to surveys that we conduct for our use or on behalf
of our Partners. We offer you incentives in exchange for your survey participation. As explained in more detail
below, we share survey results and other information collected through the SOTG App with our Partners who
typically use the information we provide to conduct and improve their products, services, and advertising.
From time to time, we may permit selected third parties to provide you with additional survey opportunities in
the SOTG App. If you decide to participate in those additional opportunities, your participation in those thirdparty surveys will be directly with those third parties and will not be governed by this Privacy Policy.
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The SOTG App is not offered outside the United States. For US individuals who use the SOTG App, we may use
the information that we collect
(as described below) to avoid sending you surveys from us or a third party
(https://mfour.com)
while traveling outside the United States.
1. Types of information collected and how we collect them
Personal information you provide to us
When you use the Services, we collect personal information that you provide to us. This information may
include your name, address, telephone number, email address, and linked information such as zip code,
demographic information (such as your age, gender, income, education level, etc.), and other information. We
collect this information when you voluntarily provide it to us when creating an account after downloading the
SOTG App, when you use the SOTG App to update your account information, and when you respond to
surveys.
We will use demographic and other information you provide to send you relevant surveys and for other
internal purposes. If you participate in a survey, we will collect information and responses that you provide in
the course of the survey. For some surveys, this may include photo, audio, and video information that you
provide. If you use our Facebook log-in tool, we may collect the information you choose to make publicly
available through your Facebook profile such as your name, date of birth, email address, and residence
location. You can control what specific information is made public through your use of your Facebook privacy
settings.
Personal information collected automatically
We collect certain personal information automatically through the SOTG App and when you visit the Sites.
Geographic Location Information and Digital Data (described below) will be collected automatically only if you
give permission. Personal information that is automatically collected includes the following:
Geographic Location Information. If permitted on your device and with your permission, the SOTG App may
automatically collect and use your Geographic Location Information, which includes precise location
information from your device.
You will receive prior notice and must give your consent before your Geographic Location Information is
collected through the SOTG App (in the event that you share your device with another person, please be
aware that this person could change these permissions on your behalf). If you do not want to provide your
Geographic Location Information through the SOTG App, you may use the controls available in the SOTG App
and/or available on your mobile device to limit this sharing. Some incentives and features may not be
available if you stop the collection of Geographic Location Information.
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Usage and Device Data. We may automatically collect certain types of usage and device data when you visit
our Sites or use the SOTG(https://mfour.com)
App. We use a variety of technologies to collect this data automatically, including
cookies, pixels, and similar technology. For example, we use such technologies, and the usage and device
data they collect, to make it easier for you to navigate our Services, to provide a better experience for you
when you participate in surveys, and for quality control and validation purposes. Cookies are small text files or
other forms of data which are stored on a computer by a website and can store certain information about the
internet browsing activity on that computer. You may be able to disable and/or delete cookies via your
browser and/or plug-in settings; however, this may: (1) decrease the functionality of our Sites and other
websites you visit; (2) limit your ability to use and view our Services; and (3) limit your participation in the
Services, including incentivized surveys. Even if you disable cookies, we may collect and use other information
that identifies your device over time to provide our Services.
The information we collect automatically when you visit the Sites or use the Services includes, for example, IP
address, pages visited and other activities on the Services, information about your other online activities,
streaming video services you use and the content you watch, general geographic location derived from IP
address, and time and date of your activities. We also collect information about your device and its software,
such as your mobile advertising identifier, device manufacturer, device type, device model, operating system
and version, browser type, wireless carrier/provider information, Internet service provider, and a randomized
unique ID (that allows us to uniquely identify your browser, mobile device, or SOTG account).
Digital Data. If permitted on your device and with your permission, the SOTG App may automatically collect
Digital Data about your other online activities outside the SOTG App, including webpages you visit on the
device, apps that you use on the device, information about how and for how long you use the apps, and apps
that you install and uninstall. The Digital Data collected also includes activities and purchases you make on ecommerce apps and websites.
To provide Digital Data, you must enable accessibility permissions on Android devices and download a Virtual
Private Network (VPN) tool on iOS devices. If you want to stop providing Digital Data through the SOTG App,
you can use the controls available in the SOTG App and/or available on your mobile device to disable the
collection of Digital Data. You may also stop providing Digital Data by disabling accessibility permissions on
Android devices or disabling and/or uninstalling the VPN on iOS devices. Some incentives and features may
not be available as a result of stopping the collection of Digital Data.
Personal information from third parties
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Privacy Policy - MFour Mobile Research
We also obtain personal and other information about you from third parties, which we often combine with
personal information we collect automatically or that you provide to us. For example, Partners and other
(https://mfour.com)
parties may provide us with your mobile advertising identifier, demographic and address information, and
other information.
We may also use analytics services provided by third parties. These service providers may use cookies or other
technologies to collect information about your online activities on the Sites, the SOTG App, and other sites
and apps over time for analytics purposes. For example, we use Google Analytics to understand how visitors
use our Sites. For more information from Google about how Google Analytics collects and uses data,
visit https://www.google.com/policies/privacy/partners (https://www.google.com/policies/privacy/partners). To
opt out of Google Analytics, visit https://tools.google.com/dlpage/gaoptout
(https://tools.google.com/dlpage/gaoptout).
2. Payday Program
Payday is an optional program that allows you to receive a weekly incentive in addition to survey incentives. If
you choose to participate in Payday, you may also receive more surveys. In order to be eligible for Payday,
you must consent to and allow us to automatically collect Geographic Location Information and Digital Data
as described above. We will use and share this information as described in this Privacy Policy. You will
automatically be eligible for a Payday incentive if you provide Geographic Location Information and Digital
Data for at least 15 days during a month and log into the SOTG app at least once during a month. Even if you
do not participate in Payday, we may still collect, use, and share information through the Services as described
in other sections of this Privacy Policy.
You can permanently disable or temporarily pause the collection of Geographic Location Information and/or
Digital Data at any time, but stopping this data collection will affect your eligibility for a Payday incentive. If
you want to stop providing Geographic Location Information and/or Digital Data to us through the SOTG App,
you can use the controls available in the SOTG App and/or available on your mobile device. You may also stop
providing Digital Data by disabling accessibility permissions on Android devices and disabling and/or
uninstalling the VPN on iOS devices. Some incentives and features may not be available as a result of stopping
the collection of Digital Data. Pausing or disabling our collection of Geographic Location Information and/or
Digital Data will not pause or disable any other data collection through our Services, and you will continue to
receive surveys through the SOTG App. For California residents, please see below for our Notice of Financial
Incentive for SOTG including the Payday program.
3. How we use and retain personal information
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Privacy Policy - MFour Mobile Research
We use the information we collect for purposes described in this Privacy Policy or as otherwise disclosed to
you on our Sites and in the
SOTG App, including market research. We do not use the personal information
(https://mfour.com)
that we collect through the SOTG App for direct marketing or advertising back to you. For example, we use
information we collect for:
Providing you with relevant survey opportunities. For example, demographic information may be used to
match you to types of consumers a Partner may want to survey. Or, your location data may be used to
offer you surveys while you are visiting a specific location such as a store or restaurant.
Market research, including sharing data with our Partners as further described in the next section.
Conducting our research and analysis to improve our products and services, identify consumer trends,
develop consumer segments and other market research purposes.
Our compliance with laws and legal obligations and maintaining the security of our Services and your
information.
Detecting and preventing fraudulent users of the Services and survey responses and other fraudulent
activities.
Paying incentives to you using your email address or other information.
Communicating with you such as responding to your comments or questions, authenticating your
identity, and providing you with updates to our products and services.
Monitoring, administering, and enhancing our Services, including troubleshooting, data analysis, testing,
research, statistical, and survey purposes.
We retain your SOTG App account information over time in order to provide the Services to you, including to
offer you additional survey opportunities for Partners or for our internal research.
4. Disclosures of personal information
We want you to understand when and with whom we share your personal information. We may disclose your
personal information in the ways described below. When we sell or otherwise provide personal information to
our Partners, we restrict them by contract from using personal information collected through the SOTG App
for direct marketing or advertising of products or services back to you.
To our Partners, which handle the information according to their own privacy policies. We share information
with our Partners to provide them with our services or for their own purposes. Typically, the information
we share with Partners can include personal information, survey responses, Geographic Location
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Information, Digital Data, and/or demographic information associated with unique identifiers such as
hashed email addresses,
device identifiers, or other alphanumeric identifiers used for internal purposes.
(https://mfour.com)
We may also provide Partners with aggregate reports that include combined demographic or other survey
data. We may also permit selected third parties to collect and use your Geographic Location Information
through our SOTG App to provide you additional survey opportunities from those third parties.
Authorized third-party vendors and service providers. In some cases, we share information we collect with
authorized contractors, subcontractors, vendors, and service providers who help us operate our business
and provide the Services. For example, we may share personal information with service providers that
provide services such as web hosting, data analysis and reporting, auditing and compliance, network and
data security, and identifying consumer demographics and geolocation.
Legal purposes.We disclose personal information when we believe in good faith that the law requires it,
pursuant to a court order, subpoena, warrant, in response to a law enforcement request, or as otherwise
required or requested by law, regulation, or government authority programs; when disclosing this
information is necessary to identify, contact or bring legal action against someone who may be violating
the law or our rights or interfering with (either intentionally or unintentionally) use of Services or to
protect our rights or the rights or safety of others; and for other legal related purposes.
Business event. We may disclose personal information in connection with an actual or potential sale of
stock or assets, merger, or any other change of control transaction (including in bankruptcy), or in the
case of a bulk or partial sale, or other transfer (including third party panelist administration) of
information to another research organization or entity.
With your consent. We share personal information for any other purpose disclosed to you with your
consent.
We may also share and disclose information that is aggregated, de-identified, or otherwise does not
specifically identify you or your device, in our discretion including to our Partners.
5. Third-party links & tools
Our Services may provide links to third-party websites or apps, including offers and links to additional survey
opportunities on third-party platforms. We do not control the privacy practices of those websites or apps, and
they are not covered by this Privacy Policy. You should review the privacy policies of other websites or apps to
learn about their data practices.
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Privacy Policy - MFour Mobile Research
Our Services may also include integrated social media tools, such as our Facebook log-in tool. If you use
these tools or otherwise interact
with these features on the Services, those companies may collect information
(https://mfour.com)
about you and may use and share such information in accordance with your account settings, including by
sharing such information with us and the general public. Your interactions with third-party companies and
your use of their features are governed by the privacy notices of the companies that provide those features.
We encourage you to carefully read the privacy notices of any accounts you create and use.
6. Updating your personal information, deactivating your SOTG account, and stopping information
collection
If you have a SOTG App account, you can review, change, or update some of your account information under
the “Profile” tab in the SOTG App.
You can also ask us to delete your personal information related to your SOTG App account from our active
files by emailing us at [email protected] (mailto:[email protected]). We may still retain
some personal information as needed for legal and recordkeeping purposes, where permitted by law. A
request to delete your personal information will not affect any information that we previously shared with
Partners or other third parties as described above. In all other cases, we will retain information as long as
required by law or as long as needed for our business purposes.
If you no longer want us to collect information from you via the SOTG App, you can stop responding to
surveys and delete and uninstall the SOTG App from your device. We will keep your account information in
our records in case you want to reinstall the SOTG Application and reactivate your account. We may also
continue to use and share the information that you previously provided, as described in this Privacy Policy.
7. Minors under 16
We do not knowingly collect or sell personal information about individuals under the age of 16. If we learn
that a person under 16 has provided us with personal information, we will endeavor to delete that information
from our database. If you are a parent or legal guardian and believe that your child who is under 16 may have
given us personal information, please contact us.
8. Nevada privacy rights
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Under Nevada law, Nevada residents may submit a request directing us not to make certain disclosures of
personal information we (https://mfour.com)
maintain about them. To exercise this right, you may contact us as follows:
Using this link. https://surveysonthego.com/do-not-sell-my-info/ (https://surveysonthego.com/do-notsell-my-info/)
Toll-free telephone call. You may submit requests by calling our toll-free request line at 1-800-418-9018
In the SOTG App. If you have an account with us, you may submit requests using the Privacy Center in the
SOTG App. The Privacy Center is in the Profiles section of the SOTG App.
9. California privacy rights
This section contains disclosures required by the California Consumer Privacy Act (“CCPA”) and applies only to
“personal information” that is subject to the CCPA.
Personal Information We Collect.
In the past 12 months, we collected the categories of personal information about California consumers listed
below:
Personal and online identifiers such as first and last name, email address, postal address, or IP address;
Characteristics of legally protected classifications(such as race or gender);
Commercial or transactions information (such as records of personal property or products or services
purchased, obtained, or considered);
Internet or other electronic network activity information (such as browsing history, search history, or
interactions with a website, email, application, or advertisement);
Usage and device data;
Audiovisual information (such as photos, videos, and voice recordings);
Geolocation information;
Education information;
Inferences drawn from the above information about your predicted characteristics and preferences;
Other information about you that is linked to the personal information above.
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Categories of Information Sources.
We collect this personal information
from the following categories of sources:
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Users of our Services, like you;
Partners (as defined in this Privacy Policy);
Social networks;
Service providers;
Consumer data resellers.
Our Purposes for Processing Personal Information. We collect, use, and disclose (including selling) the
personal information we collect for our commercial and business purposes, as further described in this Privacy
Policy.
Recipients of California Personal Information.
During the past 12 months, we disclosed, shared, or sold each category of personal information we collected
to the categories of third parties listed below.
Partners (as defined in this Privacy Policy);
Service providers.
Your Rights Regarding Personal Information.
California residents have certain rights with respect to the personal information collected by businesses. If you
are a California resident, you may exercise the following rights regarding your personal information, subject to
certain exceptions and limitations:
The right to know the categories and specific pieces of personal information we collect, use, disclose,
and sell about you, the categories of sources from which we collected your personal information, our
purposes for collecting or selling your personal information, the categories of your personal information
that we have either sold or disclosed for a business purpose, and the categories of third parties with
which we have shared personal information;
The right to request that we delete the personal information we have collected from you.
The right to opt out of our sale(s) of your personal information. Please note that if you opt out of certain
types of sales, we will be unable to provide you with the services that rely on such sales, including survey
opportunities.
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The right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the
CCPA.
(https://mfour.com)
To exercise any of the above rights, please contact us using the following information and submit the required
verifying information, as further described below:
Using this link. https://surveysonthego.com/do-not-sell-my-info/ (https://surveysonthego.com/do-notsell-my-info/)
Toll-free telephone call. You may submit requests by calling our toll-free request line at 1-800-418-9018
In the SOTG App. If you have an account with us, you may submit requests using the Privacy Center in the
SOTG App. The Privacy Center is in the Profiles section of the SOTG App.
Verification Process and Required Information.
Note that we may need to request additional information from you to verify your identity or understand the
scope of your request, although you will not be required to create an account with us to submit a request or
have it fulfilled. You may be required to provide the following for verification purposes:
Your first and last name
Your email address
Your telephone number
Authorized Agent.
You may designate an authorized agent to make a CCPA request on your behalf by providing us with a power
of attorney or your written permission to allow the authorized agent to submit the request on your behalf and
verification of your identity.
10. Notice of Financial Incentive for California Residents
Through the SOTG App, we provide you with opportunities to receive payments in exchange for providing
data and/or responding to surveys. Through our surveys and the SOTG App, we may collect and share your
personal information as described in this Privacy Policy. This includes all categories of personal information
listed in Section 8 of this Privacy Policy.
The terms associated with each survey, like the amount you will receive if you qualify for and complete the
survey, are presented to you in the SOTG App. Additional incentives may be available if you give permission
for us to collect and share Geographic Location Information and Digital Data, including by participating in the
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Payday program described above. Under California law, because we offer you payments related to the
collection and sharing of personal information, our surveys are considered a “financial incentive.” Payments
(https://mfour.com)
can be redeemed in various ways, such as through Venmo, credits to your PayPal account, or virtual gift cards.
You opt into these financial incentives by participating in surveys and/or allowing us to collect Geographic
Location Information and/or Digital Data. California residents have the right to withdraw from the financial
incentives we offer at any time. You can pause or disable our collection of Digital Data and/or Geographic
Location Information by using controls available in the SOTG App and/or your mobile device. You may also
stop providing Digital Data by disabling accessibility permissions on Android devices and disabling and/or
uninstalling the VPN on iOS devices. Pausing or disabling our collection of Geographic Location Information
and/or Digital Data will not pause or disable any other data collection through our Services, and you will
continue to receive surveys through the SOTG App. You can withdraw from survey participation by not
responding to surveys or deleting the SOTG App from your mobile device.
The amount of payment you receive for completing a survey and/or providing data is based on the reasonable
determination of the value that we and our partners receive from processing personal information. This
estimated value takes into account a variety of factors as permitted by law, including (but not limited to) the
expenses incurred in collecting and retaining the information, the expenses incurred in providing payments to
you, and the estimated marginal revenue derived from information related to our surveys.
11. Changes to our privacy policy
We reserve the right to modify or revise this Privacy Policy at any time and in our sole discretion. We will post
any changes to this Privacy Policy on our Services. We encourage you to revisit this policy regularly to stay
informed about how we collect, use, and share your information.
12. Contacting us
If you have questions or concerns about this Privacy Policy or the use or disclosure of your information as
described in this Privacy Policy, please contact us through support in the SOTG App or
at [email protected] (mailto:[email protected]).
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Email
(https://mfour.com)
[email protected] (mailto:[email protected])
Phone
(714) 754-1234 (tel:+17147541234)
Why MFour
Validated Consumers
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Validated Surveys
(https://mfour.com/vsurveys/)
OmniTraffic® Behavior Data
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Studio Data Platform
(https://mfour.com/mfour-studio/studio-overview/)
Products
Standard vSurveys
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vSurveys+™
(https://mfour.com/vsurveys/)
vTracker+™
(https://mfour.com/vtracker/)
OmniTraffic® Data
(https://mfour.com/omnitraffic-data/)
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Resources
Case Studies
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(https://mfour.com/resources/case-studies/)
Blogs
(https://mfour.com/resources/blogs/)
Reports
(https://mfour.com/resources/reports/)
Use Cases
(https://mfour.com/use-cases/)
Top Findings
(https://mfour.com/resources/top-findings/)
Guides
(https://mfour.com/resources/guides/)
Insights Gallery
(https://mfour.com/insights-gallery/)
Careers
(https://mfour.com/careers/)
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| File Type | application/pdf |
| Author | Davis, Andrew (US) |
| File Modified | 2024-10-06 |
| File Created | 2024-06-11 |