e-Rewards Medical Privacy Policy

First Effective: May 12, 2012

This Version: Effective April, 20, 2018

The Privacy Policy describes how Dynata Global UK Limited (f/k/a Research Now Limited) and Dynata, LLC (f/k/a Survey Sampling International LLC) and their parents, subsidiaries and affiliated companies (collectively “Dynata”, “We”, “us, or “our”) processes Personal Data in the context of online panel communities, surveys, reward programs, websites and mobile applications (collectively the “Service”). In particular, it describes the types of Personal Data we collect in connection with the Service, the purposes for which we collect that Personal Data, the other parties with whom we may share it, and the measures we take to protect the security of the data. It also tells you about your rights and choices with respect to your Personal Data, and how you can contact us to update your contact information or ask questions about our privacy practices.

This Privacy Policy does not apply to the processing of your Personal Data in the context of surveys administered by third parties. In these situations, Dynata is not the sponsor of the survey and the survey instrument, and the survey results or survey data are and will be controlled by the sponsor of the survey. Please refer to the relevant sponsor’s privacy policy to learn more about that sponsor’s privacy practices.

Registration with, use of, and access to the Service is subject to this Privacy Policy and our Terms and Conditions .

 

1. Personal Data That May Be Collected About You

We collect Personal Data in various ways described below. For the purpose of this Privacy Policy, “Personal Data” means any information relating to an identified or identifiable individual. Where applicable, we indicate whether and why you must provide us with your Personal Data, as well as the consequences of failing to do so. If you do not provide Personal Data when requested, you may not be able to benefit from the Service if that information is necessary to provide you with the Service or if we are legally required to collect it.

• a. Personal Data Provided by You

• We ask you to provide certain Personal Data when you register for an account through our websites or mobile application, including your name, address, email address, phone number, date of birth, occupation, education, and gender.

• In addition, we collect Personal Data you provide in the context of a panel, when you participate in a survey or in connection with the receipt and redemption of rewards and incentives. Such information includes a unique panelist/respondent identification number we assign to you when you sign up for an account and the responses you provide when completing the survey. In this context, you may choose to provide sensitive Personal Data about you, such as Personal Data that discloses or reveals health and medical conditions, sexual orientation or sexual life, political opinions/views, race/ethnic origin, religious and philosophical beliefs and trade-union membership. Where required by law, we obtain your explicit consent to the processing of your sensitive Personal Data. We may also collect content that you submit, upload or transmit when using the Service, such as photos and videos.

• b. Location Data

• We may request your permission to obtain location information from your mobile device. We may use your location information to offer you the option to participate in location-based surveys and market research, or to share such location data with third party clients to demonstrate certain location traffic patterns of participants, including but not limited to purchasing behavior based on locations visited.

• We collect your location information for the above purposes with your consent. If you no longer wish to share your geo-location information with us, please change the privacy settings of your device. Where required by law, we obtain your explicit consent to share your location information with third parties.

• c. Social Media Accounts

• You may also have the opportunity to access the Services through third party social media platforms. If you select to access the Services in this manner, we may collect certain profile information stored in your social media platform account, such as name, gender and email address.

• d. Personal Data Obtained Via Automated Means

• When you use the Service, we may collect certain information by automated means, such as cookies and similar technologies. Cookies are small files that store certain data on a device. Cookies create a unique ID that is associated with your browser. Session cookies expire when you close your browser, whereas persistent cookies remain on your device until deleted or once they reach a defined expiration date.

• The information we collect via cookies and similar technologies may include information about your device and its capabilities, including, the device type and operating system, other applications on your device, network and Internet service provider, time zone, network status, browser type, referring/exiting pages, operating system, date/time stamp, click stream data, and unique identification numbers such as your device IP address, device unique identification number, Media Access Control (MAC) address, or browser identifier. We may also use digital fingerprinting and watermarking technologies to collect the above information.

• We may also collect information from certain applications and functionality available on your device if you grant us access to these. Such information includes the number and type of applications installed, push notifications, camera, microphone, accessing photo library, file storage access, We use this information to improve the Service by assessing how many users access or use the Service, which content, products, and features of our Service most interest our visitors, what types of offers our customers like to see, and how our Service performs from a technical point of view.

• In some cases, we may use information collected via automated means, along with other information, to recognize users (or households) across platforms or devices, such as smartphones, computers, tablets or related browsers, for the purposes described in this Privacy Policy. Information collected via digital fingerprinting and watermarking technologies may also be used for quality control, validation, and fraud detection and prevention purposes.

• Audience Insights/Look-alikes. Dynata and/or third parties may use Personal Data and/or may link Personal Data to a third-party cookie to develop audience insights and/or look-alike models in connection with marketing campaigns.

• For more information on the types of cookies we use, the purposes for which we use information collected via cookies please see our Cookie Consent Tool

• e. Personal Data We Process in relation to Survey about Clients’ Advertising

• When you use the Service to participate in surveys regarding specific ads and promotions that Dynata is testing for its business clients, you may see these ads or promotions in several places, including in non-Dynata mobile apps (e.g., in a gaming app). Once you have been exposed to the relevant ads and promotions, Dynata will provide you with access to, or contact you to complete, a survey about these ads or promotions and/or may provide certain demographic data about you to the advertiser or the advertiser’s agent regarding the demographic profiles of individuals who have viewed the ad.

• To facilitate the completion of such surveys on ads or promotions, Dynata has partnered with ad companies that provide, measure or facilitate advertisements, including in other mobile apps. The Application/Services provides ad networks with the UID, your unique device identifier, and other information collected via automated means. Then, when you use a mobile app that has partnered with one of the ad companies, the ad company can use your unique device identifier or other automatically collected information to recognize your device. The ad company may then show you an ad or promotion that Dynata is measuring for one of our business clients. The ad company may then inform Dynata that the device associated with your UID has just received an ad or promotion, which allows Dynata to provide you with access to, or to contact you to complete, a survey regarding the ad or promotion.

• f. Personal Data Provided by Third Parties

• We may obtain Personal Data, behavioral and/or demographic information from third parties, such as data management platforms, ad networks, information service bureaus, and sample suppliers. This collection may include, but is not limited to, age, gender, geography, location, presence of children, mobile ad IDs, purchase history, advertising exposures, look-a-like segments.

 

2. How We May Use Your Personal Data

We may use the Personal Data we obtain from or about you for a variety of purposes, including:

• To offer you the opportunity to participate in research activities, including to join a panel, participate in surveys administered by Dynata or by third parties (whether as a panel member or a non-panel member), or use websites and mobile applications associated with panels or surveys.
• To administer, manage, fulfill, facilitate entry into, and communicate about Dynata’s reward, incentive programs and other promotions, including sweepstakes offered in connection with panel membership and/or the completion of surveys.
• To communicate with you regarding your membership with a panel owned by Dynata, or to send you notifications of your participation in a survey and tailored survey opportunities.
• To arrange for advertisements to be displayed to you outside the Service for the purposes of facilitating the completion of recall surveys.
• To provide you with Services and advertisements tailored to you based on criteria such as your interests or location information and to enable Dynata and third parties to develop marketing insights, audience/look alike models based on individual and/or aggregated profile data, and segment audiences. For example, we may develop marketing and advertising campaigns designed to target individuals who have a social and demographic profile similar to yours.
• To assess the effectiveness of online advertising and for website audience measurement, and to assist in the creation, development, and implementation of websites, online advertisements, and other Internet and digital media features, functionality, and campaigns.
• To send tailored marketing communications about Dynata and third parties products and services.
• To update Dynata’s records, perform data analyses for Dynata purposes or for our clients.
• To provide a better survey experience, including quality control, validation, tracking of completed surveys or other completed actions
• To ensure safety and security and to detect and prevent fraud
• To comply with our legal obligations, including, without limitation, tax obligations, or otherwise enforce or protect our rights.
• As otherwise permitted pursuant to this Privacy Policy or as otherwise authorized by you

If you are located in the European Economic Area, we may collect and use your Personal Data when:

• You consented to the use of your Personal Data. For example, we may seek to obtain your consent for our uses of cookies or similar technologies, to send you marketing communications, or to process Personal Data deemed sensitive pursuant to applicable law.
• Necessary to provide you with products and services, or to respond to your inquiries.
• We are required or authorized by applicable law to use your Personal Data.
• We, or a third party, have a legitimate interest in using your Personal Data, such as to ensure and improve the safety, security, and performance of our products and services, to anonymize Personal Data and carry out data analyses.

 

3. How We Share Your Personal Data

We may disclose the Personal Data we collect about you as described below or otherwise disclosed to you at the time the data is collected, including with:

• Our parent, subsidiary, and affiliates for the purposes described in this Privacy Policy.
• Our service providers who perform services and process Personal Data on our behalf. Examples of our service providers include our cloud storage providers, fraud tool providers, survey data collection platform. We may also share Personal Data with data brokers and data aggregators acting under our instructions and on our behalf to add to enrich our database for the development of audience insights and/or look-alike models, analytics, and marketing intelligence. We require these service providers by contract to only process Personal Data in accordance with our instructions and as necessary to perform services on our behalf or comply with legal requirements. We also require them to have safeguards designed to protect the security and confidentiality of the Personal Data they process on our behalf.
• Program partners who invited you to join the Service and that you have enrolled through.
• Our clients for market research-related purposes (including for the creation and validation of models, fraud detection and prevention, data market segmentation and database matching, and reward, incentive, or sweepstakes redemption, fulfillment and/or entry), to enable them to develop marketing campaigns, audience insights, look-alike models and/or to market third party’s products/services to you, and for the purposes of identifying respondents for re-contact surveys or communications.
• Our client or their customers, if we believe that you have or may violate the intellectual property rights of a third party or our Terms of Service .
• With a third party in connection with any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
• As otherwise permitted pursuant to this Policy or (i) if we are required to disclose Personal Data about you by law or legal process, (ii) in response to a request from a court, law enforcement authorities, or government officials, or (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity.

We may allow a client to collect Personal Data directly from you. You are free to provide them with your Personal Data. In these situations, we enter into a written agreement with our clients to, among other things, limit their use of the Personal Data.

 

4. Your Rights and Choices

Subject to applicable law, you may have the right to:

• Opt out of certain collection and use of your Personal Data when we provide the Service. For more information, please log into your account and change your preferences.
• Opt out of the collection and use of certain information, which we collect about you by automated means. In certain jurisdictions, you can exercise your choice regarding the use of cookies and similar technologies via the Cookie Consent tool . Your browser may tell you how to be notified of and opt out of having certain types of cookies placed on your device. Note that without certain cookies you may not be able to use all of the features of our websites, apps or online services.
• Request access to and receive information about the Personal Data we maintain about you, to update and correct inaccuracies in your Personal Data, to restrict or to object to the processing of your Personal Data, to have the information anonymized or deleted, as appropriate, or to exercise your right to data portability to easily transfer information to another company. In addition, you may also have the right to lodge a complaint with a supervisory authority, including in your country of residence, place of work or where an incident took place.
• Withdraw any consent you previously provided regarding the processing of your Personal Data, at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before your consent withdrawal.

Those rights may be limited in some circumstances by local law requirements.

You can stop all collection of Personal Data and other information by us by uninstalling the Services or terminating your participation in all panels. You may use the standard uninstall processes available as part of your mobile device or via the mobile application marketplace or network or you may cancel your panelist account on the panel site. Please note that if you delete the mobile application, but maintain a profile with one of our websites, we may still collect Personal Data and other data from you through our websites. Uninstalling the mobile application will not delete all information collected by us prior to uninstalling the Services. To delete all information collected by us please contact us as set forth below.

If you would like to exercise your rights described above or terminate your account, please contact us as specified in the “How to Contact Us” section below.

 

5. Data Security and Data Retention

We maintain appropriate technical, administrative, and physical safeguards to protect Personal Data and other information disclosed or collected by us against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. We review, monitor, and evaluate our privacy practices and protection systems on a regular basis. Despite the safeguards we implement, transmissions over the Internet or a mobile network are not totally secure, and therefore we cannot guarantee the security of online transmissions. We are not responsible for any errors by individuals in submitting Personal Data to us.

We also take measures to delete your Personal Data or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it, unless we are required by law to keep this information for a longer period. When determining the retention period, we take into account various criteria, such as the type of products and services requested by or provided to you, the nature and length of our relationship with you, possible re-enrolment with our products or services, the impact on the services we provide to you if we delete some information from or about you, mandatory retention periods provided by law and the statute of limitations.

 

6. Data Transfers

Your Personal Data may be transferred to recipients in countries other than the country where you are located, including to the United States where Research Now’s parent company and Survey Sampling International is headquartered. These countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your Personal Data to other countries, we will protect that information as described in this Privacy Policy or as disclosed to you at the time of the collection.

If you are located in the European Economic Area or Switzerland, we comply with applicable legal requirements providing adequate safeguards for the transfer of Personal Data to third countries.

 

7. Do Not Track

Do Not Track (“DNT”) is a preference in your browser that you can set to notify websites that you visit that you do not want the websites to collect certain information about you. Dynata does not respond to DNT signals. If you object to Dynata’s practice with regards to DNT signals, you may opt-out from participation or use of Dynata’s services as described below.

In connection with Dynata’s online ad effectiveness program, Dynata permits Dynata’s subcontractors, partners and/or clients to drop, set, and/or write third party technologies for the purpose of facilitating audience measurement and ad recall survey activities. Dynata is not responsible for any third party’s compliance with or response to DNT signals.

 

8. No Children

The Service is not designed for, or intended for use by, any individual under the age of 16 We do not knowingly collect Personal Data from children under the age of 16, and if we became aware that we have inadvertently collected Personal Data from a child under the age of 16, we will undertake reasonable commercial efforts to delete such Personal Data.

 

9. Updates to This Privacy Policy

This Global Privacy Notice may be updated periodically to reflect changes in our Personal Data practices. We will post a prominent notice on relevant websites to notify you of any significant changes to our Global Privacy Notice and indicate at the top of the Notice when it was most recently updated. If we update our Global Privacy Notice, in certain circumstances, we may seek your consent.

 

10. How to Contact Us

If you have any questions or comments regarding our privacy practices or this Privacy Policy or if you would like to opt out of certain uses of your Personal Data, exercise your rights in relation to the Personal Data we hold about you or make a complaint about our privacy practice, please feel free to contact Dynata Global UK Limited (f/k/a Research Now Limited) or Dynata, LLC (f/k/a Survey Sampling International LLC) as described below.

• Dynata Global UK Limited (f/k/a Research Now Limited): write to us at privacy@dynata.com or to 160 Queen Victoria Street, Ground Floor, London, United Kingdom EC4V 4BF, Attention: Data Protection Officer.
• Dynata, LLC (f/k/a Survey Sampling International LLC): write to us at privacy@dynata.com or to 6 Research Drive, Shelton, CT 06484 United States.