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Privacy Statement

Last updated: 31 August 2017


Toluna Group Limited and any of its worldwide subsidiaries and affiliates (“We” “Our” “Us” or “Toluna”) are committed to protecting and respecting your privacy.  This privacy policy describes we collect, use, share and secure the personal information you provide on http://www.toluna.com (our ”Website” or “site”) and Toluna mobile application. The mobile application is subject to additional privacy terms, as set out in this privacy policy. It also describes the choices available to you regarding our use of your personal information and how you can access and update this information.

This privacy policy provides you with notice about:
 

  • What information this site gathers/tracks about you.
  • What this site does with the information it gathers/tracks.
  • With whom this site shares the information it gathers/tracks.
  • This site’s policy with regards to 3rd party tracking technologies.
  • This site's opt-out policy.
  • This site's policy on correcting and updating personal information.
  • This site's policy on deleting or deactivating your name from its database.
  • Notification of changes.
  • This site's policy regarding security.
  • This site's policy regarding business transfers.
  • This site's policy regarding links to third-party sites.
  • This site's policy regarding legal disclaimers.
  • This site's policy regarding children's privacy.
  • This site's policy regarding Social Media Widgets.
  • This site's policy regarding Single Sign-On.
  • This site’s policy regarding Referral
  • This site’s policy regarding Adding Contacts
  • This site’s policy regarding Mobile Applications


Our Privacy Commitment to you

Toluna is an online data collection group focused on providing high-quality data to our clients who are mainly in the market and marketing research industries, as well as being in other many other business sectors. We build and maintain large online consumer panels, providing real-time digital consumer insights to our clients via our market research survey and analytics platforms. You can be assured your privacy and the confidentiality of your information is of the utmost importance to us. All of the data we collect via our research studies are provided to our clients in aggregate form i.e. information is provided about groups of individuals and not on an individual level. Personal information about you would only be provided to our clients in specific research studies and we would never provide your personal information to our clients unless we have first received your consent. All personal information you do provide to us is held securely, in confidence and in accordance with the terms of this Privacy Policy.
 

The information we collect

Your participation in any of our panels and surveys is voluntary. To become a panel member, you must fill out a registration form, available on our Website and mobile application or via links displayed on our partners’ websites, that gathers some personal and general consumer information about you. By doing so, you acknowledge and agree that you provide personal information to our USA based company; Toluna USA Inc., (“Toluna USA”) and that such information will be stored on servers owned by us and located in the USA. We ask for your email address so that we can send you email invitations to participate in our upcoming surveys. The other information we gather, such as your name, address, gender, birthday, household size, income, education and employment status is for matching you with the appropriate marketing research projects. Your birthday is used to automatically update your age for us to target age-related marketing groups. We ask you for this information as a means to see if you might qualify for particular projects. All email contact from Toluna will be sent to your primary email address that you gave to us upon registration. If you become a panel member, your information (name and full postal address) is also used for the purposes of incentive fulfillment. When incentive points are deposited in your account and you wish to redeem them, this information is required so that we may send your reward to the appropriate recipient address. From time to time, a third party may be used for issuing cheques or processing the delivery of rewards; your personal information will not be used for any other reason.
After registration, you may complete your profile and provide us with more personal information so that we may invite you to appropriate surveys.  

In some circumstances, Toluna may ask you to inform us of your sensitive personal information and if required by law, we will ask you for your consent to the processing of such sensitive personal information. Examples of sensitive personal information are; your racial or ethnic origin; your political opinions; you physical or mental health or condition; and your sexual life.  This information will only be shared with third parties if necessary for specific research studies and only if you have provided your prior consent to the participation in such studies.  We may provide sensitive personal information about you if required by a court order to do.

If you take a survey or provide us with personal information without being a member of our panel, the only personal information we will preserve is your email address, gender, age and zip/postal code, machine ID and IP address and (if permitted by law; your ethnicity).  We do this so we may contact you if you have won a prize or are entitled to an incentive, to match you to appropriate surveys and improve the user experience. Unless you elect to become a member of the Toluna panel, we will not contact you for any reason other than to notify you that you have won a prize or are eligible for an incentive. If you are entitled to a prize or an incentive, we will collect and maintain such personal information, as we are required to maintain or report by virtue of any law or regulation.

You should be aware that any personal information 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, or used by other users and could be used to send you unsolicited messages. We are not responsible for the personal information 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. Our website offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at privacy@toluna.com. In some cases, we may not be able to remove your personal information, (unless required by law) in which case we will let you know if we are unable to do so and why.
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 name. If you wish to update or delete your testimonial, you can contact us at privacy@toluna.com.

EU-U.S. and the Swiss-U.S. Privacy Privacy Shield Framework

Toluna, (including its USA based company Toluna USA Inc.,) recognises that the EU and Switzerland have established strict protections regarding the handling of Personal Data from the EU and Switzerland, including requirements to provide adequate protection for such Personal Data transferred outside of the EU and Switzerland.  To provide adequate protection for certain EU and Swiss Personal Data about individuals (including about you and our corporate clients, suppliers, business partners, job applicants and employees received in the USA, Toluna has elected to self-certify to the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework administered by the US Department of Commerce ("Privacy Shield"). Toluna is responsible for the processing of personal information it receives, under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf. Toluna 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 terms of this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.

For purposes of enforcing compliance with the Privacy Shield, Toluna is subject to the investigatory and enforcement authority of the US Federal Trade Commission.  For more information about the Privacy Shield, see the US Department of Commerce's Privacy Shield website located at https://www.privacyshield.gov. To review Toluna’s representation on the Privacy Shield list, see the US Department of Commerce's Privacy Shield self-certification list located at https://www.privacyshield.gov/list.
 

Binding Arbitration

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 Questions or Complaints paragraph; 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 US Department of Commerce's Privacy Shield Framework: Annex I (Binding Arbitration).
 

U.S. - Swiss Safe Harbor Framework

Toluna complies with the U.S. – Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from Switzerland. Toluna has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Toluna’s certification, please visit https://safeharbor.export.gov/swisslist.aspx.
 

Use of this information

The information you provide to us is processed for the purpose of building and operating a worldwide proprietary database of panelists, in order to conduct marketing and market research studies.  If you are a member of the Toluna panel, your information is stored in our proprietary database so we may call upon it to determine which people match up with specific research studies. Our proprietary database is hosted with and managed by Toluna USA and your data may be accessed and used by other Toluna Group companies worldwide to conduct studies. If we think your profile makes you a potential candidate for a study, we will Email you an invitation to make you aware of this opportunity. 
 

Sharing

We do not sell or transfer the personal information collected about our panel members or the individuals that take surveys for us. Information which is personally identifiable will only be transferred with your prior permission on a case by case basis, except for the narrow exceptions specified below.
Though we make every effort to preserve your privacy, we may need to disclose your personal information in response to lawful 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 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.  We may also in certain specific market research programs (and with your express prior consent) disclose your personal information to third parties for the purposes of providing such specific market research services to our clients.

From time to time, Toluna may use third-party software for email list management and email distribution or may use third party list management providers to match our panel members to members of other lists or panels or to validate the accuracy of personal information you provide.  We may use third parties to provide us with their data they have previously collected about you and append this data to your demographic profile.  In such cases only aggregated information based on your responses to our surveys and/or your applicable Toluna panel id number are transferred to these third parties so as to enable them to perform specific functions on our behalf or on our clients’ behalf.  We may also share your personal information with our service providers for the purposes of administering and/or providing prizes you have won or other incentives we grant to you in return for your participation in our panels.
When your personal information is transferred from a Toluna entity located in the European Union to a country that has not been recognised as providing equivalent protection, including the United States, Toluna has put in place transfer agreements using the standard model contracts for the transfer of personal information to third countries as decreed by the European Commission.
 

The Use of Cookies on our website

We use cookies on our website to distinguish you from other users of the website, helping us to provide you with a good experience when you browse our website and allowing us to improve our site.  For detailed information on the cookies we use and the purposes for which we use them, see our Cookie Policy below:

 

Toluna Cookie Policy

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.
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.

We use the following cookies:

Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
Analytical/performance cookies. They allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies. These are used to recognize you when you return to our website. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Cookie Name Purpose More information
.toluna-group.com
(Analytical)
_ga Estimate our audience size and usage pattern Expires after 730 days.
.toluna-group.com
 (Targeting)
visitor_id[visitor#] Allow you to use our site in a way that makes your browsing experience more convenient. If you register with us or complete our online forms, we will use cookies to remember your details during your current visit, and any future visits provided the cookie was not deleted in the interim. Expires after 730 days.
go.toluna-group.com
(Analytical)
Pardot Estimate our visits and click throughs for specific campaigns to measure success Expires when browsing session ends
go.toluna-group.com
(Targeting)
visitor_id[visitor#] Allow you to use our site in a way that makes your browsing experience more convenient. If you register with us or complete our online forms, we will use cookies to remember your details during your current visit, and any future visits provided the cookie was not deleted in the interim. Expires after 730 days.
.toluna-thoughts.com
(Analytical)
_ga Estimate our audience size and usage pattern Expires after 730 days.
.quicksurveys.com
(Analytical)
_ga Estimate our audience size and usage pattern. Expires after 730 days.
.quicksurveys.com (Targeting) visitor_id[visitor#] Allow you to use our site in a way that makes your browsing experience more convenient. If you register with us or complete our online forms, we will use cookies to remember your details during your current visit, and any future visits provided the cookie was not deleted in the interim. Expires after 730 days.
.toluna-analytics.com.com (Targeting) visitor_id[visitor#] Allow you to use our site in a way that makes your browsing experience more convenient. If you register with us or complete our online forms, we will use cookies to remember your details during your current visit, and any future visits provided the cookie was not deleted in the interim. Expires after 730 days.


Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

How do I change my cookie settings?
You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.
Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org.
To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout
Except for essential cookies, all cookies will expire after 730 days.

The Use of Cookies on our panel survey websites

We also use cookies as part of our surveys that you may agree to participate in from time to time.
 

Other Tracking Technologies

Technologies such as cookies, web beacons/web bugs, scripts, and tags are used by Toluna and its clients, partners, affiliates, or analytics and service providers. These technologies are used in analyzing trends, administering the site, tracking users’ movements around the site and the Internet, and to gather demographic information about our user base including for example marketing research studies that involve us understanding more about whether the items you have bought have been affected by any online advertisements and understanding what items you may have bought from third parties. Our clients may combine your survey responses, demographic information, and web surfing behavior with those of others to produce “aggregated” reports. They may also create scientific reports based upon modeled information. “Modelled information” is data developed based upon demographic and behavioral characteristics (like your gender, age, and websites visited) to predict what people with similar or matching characteristics would watch or buy. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.
We use Local Shared Objects, such as HTML5, to store content information and preferences. Third parties with whom we partner to provide certain features on our website or to display advertising based upon your web browsing activity also use HTML5 to collect and store information. Various browsers may offer their own management tools for removing HTML5. 

Log Files

As is true of most websites, we gather certain information automatically and store it in log files. This information may include Internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.  We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you, to improve analytics, marketing, and site functionality.
 

Advertising

We partner with a third party to either display advertising on our website or to manage our advertising on other sites. Our third party partner may use technologies such as cookies to gather information about your activities on this site and other sites in order to 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 (or if located in the European Union click 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 track your computer.  We will not use digital fingerprinting technology (the “Technology”) to collect your personal information, or track 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 w/ill use the Technology to assist our clients in ensuring the integrity of survey results. The Technology will analyze 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 results, we may; (a) link or associate your unique identifier to you and any of your Personal Information; (b) share your unique identifier with our 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 basis.  In addition, any unique identifier(s) received or obtained by us and linked to you will be protected in accordance with this privacy policy and if required by law, we will 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 privacy policy, (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 Web 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 policy of the company providing it. 
 

Access to Your Information; Member Services Area/Update, Correct, Delete Information

Upon request, Toluna will provide you with information about whether we hold any of your personal information. You may access, correct, or request deletion of your personal information, 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 information yourself via the Account, you may write to us at the postal address found at the end of this Privacy Policy, or contact us by email at privacy@toluna.com. We will respond to all requests within a reasonable timeframe.

If you are a panel member and terminate your membership, we will no longer use your personal information for any purposes, but in accordance with our backup procedures, we will retain your personal information until your personal information is eventually destroyed in accordance with our policies and we will continue to employ the security procedures and technologies to keep your Personal Information safe.
 

Opt-Out Policy

By becoming a Toluna panel member, you agree to receive Emails inviting you to participate in surveys that we feel may match your experiences, background and demographic statistics or information. We will automatically ensure you are eligible for prize draws and your personal information will be used to set up your personal prize account. From time to time, we will also email newsletters to you to make you aware of new features or contests running on our site. You may opt out of such emails by doing do in the Account
 

Delete/Deactivate policy

If you choose to end your membership with Toluna or to require us to cease processing your personal information, you may automatically discontinue your membership by going to “Account” and selecting “Unsubscribe Options” on the bottom left-hand corner, then “Cancel your account”. 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 opt out. 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 finalized. In the meantime, you may receive emails from us. As an alternative, you may send an email directly to contact@toluna.com 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; please allow two to three business days for us to get back to you.
 

Questions or Complaints

You can direct any questions or complaints about the use or disclosure of your Personal information to our Privacy Contact. We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your Personal information within 45 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-a-Complaint], you may invoke binding arbitration when other dispute resolution procedures have been exhausted.  
 

Winner’s policy and privacy guarantee

Panel members and others who take our surveys are randomly selected to win prizes for participation in surveys, polls, and other promotions. All winners are notified by email of their winnings. For more information, please visit our Terms and Conditions page. Cash and other prizes awarded to non-panel members will be awarded directly. Toluna shall post the usernames of winners on our site and on our own blogs and newsletters. 
 

Notification of changes

If we decide to change our privacy policy, 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.
We reserve the right to modify this privacy statement at any time, so please review it frequently. If we 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. 
 

Security

We take stringent measures to ensure every aspect of your information is kept secure. Access to all personal information is restricted and limited to few key personnel. Our website security is reviewed periodically and can only be accessed via our password policy.  We will never ask you for financial information such your credit card details or other highly sensitive information such as your social security number to be used as part of our research.  However, we may be required by law to ask for your social security number or another government-issued identifier to comply with reporting laws and regulations if you are the recipient of survey incentives. We use SSL encryption when collecting or transmitting such sensitive information.
 

Business Transfers

As we continue to develop our business, we might sell or buy additional assets. In such transactions, Toluna's right to contact its panel members and the information you have voluntarily provided in your user profile would generally be one of the transferred business assets. Any sale or transfer of Toluna or substantially all of its business assets, which included our panel, would be to an entity that agreed to comply with all of the material terms of our privacy policy. You will be notified via email and/or a prominent notice on our Web site of any change in ownership. 
 

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. 
 

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 the option to share certain personally identifiable information with us such as your name and email address to pre-populate our sign up form. Services like Facebook Connect give you the option to post information about your activities on this Website 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, we will ask you for your friend's name and email address.  You should ensure that your friend has given his/her permission to pass his/her email address to us before doing so.  We will then send your friend a one-time email inviting him or her to visit our site.  We store this information for the sole purpose of sending this one-time email and tracking the success of the referral program.  Your friend may contact us at privacy@toluna.com to request that we remove this information from our database.
 

Add/Import Contacts

Provided you have permission to do so, you can import contacts from your Outlook or other email account address book to invite them to become members of our site.  We collect the username and password for the email you wish to import your contacts from and will treat such contact information in accordance with the paragraph above, so it is important you have the individuals whose contact information you import have given you their permission to do so.  If you believe that one of your contacts has provided us with your personal information and you would like to request that it be removed from our database, please contact us at privacy@toluna.com.
 

Mobile Applications

When you download and use our mobile application, 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 Policy 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 Policy. 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.
 

Mobile Analytics

We use mobile analytics software to allow us to better understand the functionality of our mobile application on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personally identifiable information you submit within the mobile application. 
 

Geo Location

We collect your location based information for the purpose of calculating user country so we can route a visitor to the correct country site. We will only share this information with our mapping provider for the sole purpose of providing you this service.
You may opt-out of location based services at any time by editing the setting at the device level or by emailing us at privacy@toluna.com
 

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 authorized user of the wireless device on which messages will be received and that you are authorized to approve the applicable charges. Data obtained from you in connection with this SMS Service may include your name, address, cell phone number, your provider's name, and the date, time, and content of your messages. The use of this information will be in accordance with this Policy. If fees are charged to your wireless account invoice, we may provide your carrier with your applicable information 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 liable 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 replying "TOLSTOP" to the SMS text message you have received or by going to your account page and unticking the option “I agree to receive invitations to surveys by SMS” in the Personal Details tab.

Legal disclaimer

We may disclose personal information when required by law or in the good-faith belief that such action is necessary to conform to applicable law or to comply with a legal process served on our site. 
 

Children’s privacy

Toluna will not knowingly collect any information from any child under the age of 13 without permission from his/her parents, legal guardian or an adult responsible for the care of the child. Eligible ‘young people’ (individuals aged between 13 and 17) may be invited to participate in our Teens panel from time to time.  We comply with COPPA, the EU “Safer Internet programme” and the ESOMAR guidelines in relation to surveys concerning children and young people. 
 

Privacy Contact

The Privacy Officer
Toluna SAS
1 bis rue Collange
France
E-Mail: privacy@Toluna.com

 

Toluna Consumer Insights Program Privacy Policy

Last updated: July 11, 2017


Toluna Group Limited and any of its worldwide subsidiaries and affiliates (“We” “Our” “Us” or “Toluna”) are committed to protecting and respecting your privacy.  This Consumer Insights Program Privacy Policy describes how we collect, use, share and secure the personal information you provide us as part of your agreement to be Toluna community member and take part in the Consumer Insights Program. This policy also describes the choices available to you regarding our use of your personal information and how you can opt-out of our Consumer Insights Program.

This Consumer Insights Program Privacy Policy provides you with notice about:

  • What information we gather/track about you.
  • What we do with the information we gather/track.
  • With whom this site shares the information we gather/track.
  • Our policy on:
    • Third party tracking technologies
    • Opting-out
    • Correcting and updating personal information
    • Deleting or deactivating your name from its database
    • Security
    • Business Transfers
    • Legal disclaimers
    • Children's privacy
    • Mobile Applications
  • Notification of changes.


Our Privacy Commitment to you

Toluna is an online data collection group focused on providing high-quality data to our clients who are mainly in the market and marketing research industries, as well as being in other many other business sectors. We build and maintain large online consumer communities, providing real-time digital consumer insights to our clients via our market research studies and analytics platforms. You can be assured your privacy and the confidentiality of your information is of the utmost importance to us.  All data we collect via online tracking are provided to our clients in aggregate form i.e. information is provided about groups of individuals and not on an individual level. We would never use your personal information to advertise or promote or sell goods or services to you.  All personal information you provide us when you become a community member for our Consumer Insights Program studies is held securely, in confidence and in accordance with the terms of this Consumer Insights Program Privacy Policy.
 

The information we collect

Your participation in our Consumer Insights Program is voluntary.  To become a Toluna community member and take part in the Consumer Insights Program, you must fill out a registration form, via our website (www.toluna.com) (“site”) available on our mobile application, that gathers some personal and general consumer information about you. By doing so, you acknowledge and agree that you provide such personal information to our USA based company; Toluna USA Inc., (“Toluna USA”) and that such information will be stored on servers owned by us and located in the USA.
 

EU-U.S. and the Swiss-U.S. Privacy Shield Framework

Toluna, (including its USA based company Toluna USA Inc.,) recognizes that the EU and Switzerland have established strict protections regarding the handling of Personal Data from the EU and Switzerland, including requirements to provide adequate protection for such Personal Data transferred outside of the EU and Switzerland.  To provide adequate protection for certain EU and Swiss Personal Data about individuals (including about you and our corporate clients, suppliers, business partners, job applicants and employees received in the USA, Toluna has elected to self-certify to the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework administered by the US Department of Commerce ("Privacy Shield"). Toluna is responsible for the processing of personal information it receives, under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf. Toluna 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 terms of this Consumer Insights Program Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.

For purposes of enforcing compliance with the Privacy Shield, Toluna is subject to the investigatory and enforcement authority of the US Federal Trade Commission.  For more information about the Privacy Shield, see the US Department of Commerce's Privacy Shield website located at https://www.privacyshield.gov. To review Toluna’s representation on the Privacy Shield list, see the US Department of Commerce's Privacy Shield self-certification list located at https://www.privacyshield.gov/list.
 

Binding Arbitration

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 Questions or Complaints paragraph; 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 US Department of Commerce's Privacy Shield Framework: Annex I (Binding Arbitration).
 

Use of this information

The information you provide us is used to provide a variety of research insights to our clients.  As a member of the Toluna community and the Consumer Insights Program, your information (including, without limitation, your contact details, age, gender and demographic information, as well as other data you may provide through surveys, online discussions, activities and data collected through the Toluna App) are stored in our proprietary database so we may use them to determine if you are eligible to be invited to participate in specific research studies. Our proprietary database is hosted and managed by Toluna USA and your data may be accessed and used by other Toluna Group companies worldwide to conduct similar studies. If we think your profile makes you a potential candidate for a study, we will notify you via the mobile app, by email or through the Toluna.com Survey Centre with an invitation to make you aware of this opportunity.

As a Toluna community member, we may use or share your personal information with our service providers for the purposes of administering and/or providing prizes you have won or other incentives we grant you in return for your participation in our studies.  We will retain your information for so long as is necessary for us to maintain or report by virtue of any applicable law or regulation. 
 

Sharing

We do not sell your personal information and we would never use your personal information to advertise or promote or sell goods or services to you.  Though we make every effort to preserve your privacy, we may need to disclose your personal information in response to lawful 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 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. 

If you are located in the European Economic Area (EEA) and your personal information is transferred by a Toluna entity to a country that has not been recognised as providing adequate protection, Toluna has put in place transfer agreements using the standard model contracts for the transfer of personal information to third countries as decreed by the European Commission.
 

Our Mobile Application

We use a mobile app, which may in the future with your permission, include a location-based geo fencing mobile app. If you agree to download and use our mobile application on your mobile phone, tablet or PC, 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 and app version and this may in the future include your current location.  Amongst other purposes, we will use the information we collect via our Mobile App to provide real-time insights to our clients, including:
 

  • Retail: capturing your ‘in-the-moment’ thoughts and opinions on customer satisfaction, quality, in-store displays, etc. through diaries, ethnography, and tracking across multiple topics in multiple languages; evaluating your purchases at point of sale and understanding your consumption volumes and choices.

  • Browsing history: we research on which websites are browsed and what apps are downloaded.  This helps us understand what services receive the most traffic, what online shoppers are doing before, during and after they shop, what price they paid and search items they use, as well as how people use their mobile devices, apps they download.
     

We use the information gained about you, for administering the site, tracking users’ movements around the site and the Internet, and to gather demographic information about our user base as a whole, including for example, more generally for analysing trends marketing research studies that involve us understanding more about whether the items you have bought have been affected by any online advertisements and understanding what items you may have bought from third parties. Our clients may combine that information with those of others to produce “aggregated” reports. They may also create scientific reports based upon modelled information. “Modelled information” is data developed based upon demographic and behavioral characteristics (like your gender, age, and websites visited) to predict what people with similar or matching characteristics would watch or buy. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.

We send you push notifications, based on your location and demographics from time-to-time in order to notify you about studies and ask you if you would like to participate in certain marketing research studies in accordance with this Consumer Insights Program Privacy Policy. 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.
 

Geo Location

We collect your location based information for the purpose of calculating user country so we can route a visitor to the correct country site. We will only share this information with our mapping provider for the sole purpose of providing you this service.
 

Access to Your Information; Member Services Area/Update, Correct, Delete Information

Upon request, Toluna will provide you with information about whether we hold any of your personal information. You may access, correct, or request deletion of your personal information, 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 information yourself via the Account, you may write to us at the postal address found at the end of this Consumer Insights Program Privacy Policy, or contact us by email at privacy@toluna.com. We will respond to all requests within a reasonable timeframe.

If you are a community member and terminate your membership, we will no longer use your personal information for any purposes, but in accordance with our backup procedures, we will retain your personal information until your personal information is eventually destroyed in accordance with our policies and we will continue to employ the security procedures and technologies to keep your Personal Information safe.
 

Opt-Out Policy

By becoming a Toluna community member, you agree to receive invitations on your mobile device inviting you to participate in studies that we feel may match your experiences, background and demographic statistics or information. We will automatically ensure you are eligible for prize draws and your personal information will be used to set up your personal prize account. From time to time, we will also email newsletters to you to make you aware of new features or contests running on our site. You may opt-out of the Customer Insights Program at any time by editing the setting on the Toluna App at the device level or by emailing us at privacy@toluna.com
 

Delete/Deactivate policy

If you choose to end your membership with Toluna or to require us to cease processing your personal information, you may automatically discontinue your membership by going to “Account” and selecting “Unsubscribe Options” on the bottom left-hand corner, then “Cancel your account”. Please refer to our standard community privacy policy on www.toluna.com for more details on deleting or deactivating your account.
 

Questions or Complaints

You can direct any questions or complaints about the use or disclosure of your Personal information to our Privacy Contact. Please refer to our standard community privacy policy on www.toluna.com for more details on how you may make complaints or queries.  
 

Notification of changes

If we decide to change our Consumer Insights Program Privacy Policy, we will post those changes to this privacy statement on the home page, or other places we deem appropriate so that you are aware of what information we collect, how we use them, and under what circumstances, if any, we disclose them.  We reserve the right to modify this privacy statement at any time, so please review it frequently. If we 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. 
 

Security

We take stringent measures to ensure every aspect of your information is kept secure. Access to all personal information is restricted and limited to few key personnel. Our website security is reviewed periodically and can only be accessed via our password policy.  We will never ask you for financial information such your credit card details or other highly sensitive information such as your social security number to be used as part of our research.  However, we may be required by law to ask for your social security number or other government-issued identifiers to comply with reporting laws and regulations in relation to any incentives you may receive. We use SSL encryption when collecting or transmitting such sensitive information.
 

Business Transfers

As we continue to develop our business, we might sell or buy additional assets. In such transactions, Toluna's right to contact its community members and the information you have voluntarily provided in your user profile would generally be one of the transferred business assets. Any sale or transfer of Toluna or substantially all of its business assets, which included our community, would be to an entity that agreed to comply with all of the material terms of our Consumer Insights Program Privacy Policy. You will be notified via email and/or a prominent notice on our Web site of any change in ownership. 
 

Legal disclaimer

We may disclose personal information when required by law or in the good-faith belief that such action is necessary to conform to applicable law or to comply with a legal process served on our site. 
 

Children’s privacy

Toluna will not knowingly collect any information from any child under the age of 13 without permission from his/her parents, legal guardian or an adult responsible for the care of the child. Eligible ‘young people’ (individuals aged between 13 and 17) may be invited to participate in our Teens community from time to time.  We comply with COPPA, the EU “Safer Internet programme” and the ESOMAR guidelines in relation to studies concerning children and young people.  
 

Privacy Contact

The Privacy Officer
Toluna SAS
1 bis rue Collange
France
E-Mail: privacy@Toluna.com

 

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