TOLUNA USA ONLINE PANEL COMMUNITY PRIVACY POLICY

Policy Statement

The Toluna online panel community is owned and operated by Toluna USA, a participating member of the Safe Harbor program.

Respondent Bill of Rights

Since Toluna is a member of Your Opinion Counts® (YOC), your rights as a respondent are important to us and we agree to only use information provided to us only to improve products, services, or programs. To review the respondent Bill of Rights, go to www.youropinioncounts.org and select “Your Rights” from the menu.

Safe Harbor Principles

Toluna adheres to Safe Harbor, and in doing so, agrees to adhere to principles pertaining to protecting panelist privacy and personal information. This policy applies to personal information received by Toluna from panelists or outside respondents.

Notice: Panel responses are held in aggregate and used for legitimate marketing purposes. Information collected for purposes of corresponding demographic criteria to applicable survey types is not distributed outside of Toluna, except for the purpose of validation. Additionally, Toluna will not release panelist names or addresses to third parties without the express consent of the panelist.
Choice: the following opt-in/opt-out procedures are offered:
1. By default, private information supplied by panelists is hidden from view. Panelists who wish to display their names on the profile page agree to public display of any such data.
2. Individuals are informed in advance if an interview is to be audio or video recorded (as in the case of telephone or in-person studies). Respondents will be explained the intended use of the recording.
3. Parents wishing to opt-out their child from the panel may do so by logging into their account and updating the Main profile by changing contact permission and removing the child’s contact information.
4. Panelists may opt-out or be removed from the “My Account” area.
Onward Transfer (Transfer to Third Parties): Toluna does not disclose personal information without the express permission of the owner of the information. However, during the sign-up process, information is validated using a Safe Harbor-certified third party. Whenever the need arises to disclose information to a third party, Toluna utilizes the notice and choice principles detailed above. The only exception to this policy is as compelled by law to provide personal information.
Access: Panel member’s may update their profile information in two ways:
1. On the Toluna.com website
2. Contact Toluna using the email form on the panel website
Security: Toluna takes reasonable precautions to secure personal information in its possession from corruption, theft, loss, misuse, alteration, unauthorized access, and destruction.
Data Integrity: Responses are always held in aggregate and used for marketing research purposes. Data and surveys are never used to solicit or sell a product. Panelists are never responsible for buying any product or service at any time, nor will any company solicit panel members as a result of their panel membership.
Enforcement: Toluna is obligated to investigate any complaint regarding violation of the published privacy policy. In the event complaints cannot be resolved by Toluna Support or other internal means, an individual may submit the matter to our third party independent resource http://www.youropinioncounts.org who will investigate independently of Toluna.

Cookies

One or more "cookies" will be placed on the hard disk of the participant’s computer in order to allow Toluna to recognize the participant when they connect to the Toluna website, in order to facilitate the management of Toluna and for statistical purposes (pages consulted, date and time of consultations etc.)

Only information collected by cookies as specified in this section of our privacy policy is automatically collected from users of the Site. In the event we do collect any personal data about visitors to the Site it is available only to Toluna.

The participant authorizes cookies to be put in place and their use by Toluna. The participant is informed of the possibility of opposing the installation of "cookies". To do so you should modify your browser settings click on the help section of your Internet browser and follow the instructions.

How to Contact Us

Toluna has a Privacy Officer who is responsible for compliance with and enforcement of the above stated policy. To contact the Privacy Officer, the details are as follows:

Toluna USA

16200 Dallas Parkway, Suite 140

Dallas, Texas 75248-6897

Attention: Privacy Officer

PrivacyOfficer@Toluna.com

Changes to this Policy

This policy is amended as is necessary, and will be published as approved by Toluna or the parent company Toluna plc. This policy is effective as of March 1, 2009.

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