“TRUSTe”/

Toluna Group Privacy Policy

Last updated: 25th May 2018

Who are we?

We are Toluna Group Limited, part of the ITWP Acquisitions Limited worldwide group (“We” “Our” “Us” or “Toluna”). You can see who our group members are by clicking on the link below: http://www.toluna-group.com/en-gb/search-results/contact-us-main

Toluna are an online data collection group focused on providing high-quality market research data to its clients who are in various business sectors, including other market research agencies and other global and corporate clients of all sizes. We also build and maintain large online consumer panels, providing real-time digital consumer insights to our clients via our market research surveys and analytics platforms.

  • Who are we?
  • What is the purpose of this privacy policy and what is our privacy commitment to you?
  • What personal data do we collect about you?
  • How do we collect your personal data?
  • How do we use your personal data?
  • What cookies do we use on our sites?
  • International Transfers.
  • What security measures do we undertake to protect your personal data?
  • What are our data retention and destruction policies?
  • Your legal rights if you are in the EEA
  • What are the legal bases we rely on when processing your personal data?
  • Who is the data controller?
  • Changes to the privacy policy.
  • Privacy contact details

What is the purpose of this privacy policy and what is our Privacy Commitment to you?

We respect your privacy and are committed to protecting your personal data. This privacy policy aims to give you information on how we collect and process your personal data through your use of our sites  http://www.toluna-group.com, http://itwp.com and/or www.quicksurveys.com (“sites”) including any data you may provide through this sites when you sign up to our newsletters, purchase a product or service or take part in a competition (our “sites”).  It also explains your privacy rights and how laws that are applicable to you may protect you.

These sites are not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and/or policies and is not intended to override them.

What personal data do we collect about you?

  • Information you give us. This is information about you that you give us by filling in forms on our sites or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our sites, subscribe to our mailing lists, including participating in discussion boards or other social media functions on our sites and when you report a problem with our sites. The information you give us may include your Identity data and your Contact data.
  • Information we collect about you. With regard to each of your visits to our sites we will automatically collect the following information:
    • Technical data, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.
    • Information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our sites (including date and time), publications or news you viewed or searched for, 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 the page.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific websites feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you.

If you fail to provide personal data:  Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

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 (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

  1. Identity data – name (includes first, last, maiden and married names), date of birth, marital status, gender, panellist id and username.
  2. Contact data – postal address, email address and telephone number.
  3. Special categories of personal data – ethnic/racial origin, health, genetics, political opinion, religion, sexual orientation and sex life and biometrics (used for ID purposes).
  4. Profile data - includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  5. Financial data includes bank account and payment card details.
  6. Transaction data includes details about payments to and from you and other details of products and services you have purchased from us.
  7. 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 websites.
  8. Usage data includes information about how you use our sites, products and services.
  9. Marketing and Communications data includes your preferences in receiving marketing from us and our third parties and your communication preferences

Information we receive from other sources. This is information we receive about you if you use any of the other websites we operate or the other services we provide. We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers and search information providers).

How do we collect your personal data?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity data, Contact data and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • apply for our products or services;
    • enter you contact data or Identity data
    • create an account on our sites;
    • subscribe to our service or publications;
    • request marketing to be sent to you;
    • enter a competition, promotion or survey; or
    • give us some feedback.
  • Automated technologies or interactions. As you interact with our sites, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. We may also receive Technical Data about you if you visit other websites that deploy our cookies.Please see our cookie policy http://www.toluna-group.com/about-toluna/cookies for further details.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
    • Technical Data from the following parties:
      1. analytics providers such as Google based outside the EU;
      2. advertising networks based inside or outside the EU (such as Linked-In); and
      3. search information providers inside or outside the EU (Google or Yahoo listing our websites near the tops of the list).
  • Contact data, Financial data and Transaction Data from providers of technical, payment and delivery outside the EU.
  • Identity data and Contact Data from data brokers or aggregators based inside or outside the EU (such as Zoom Info).
  • Identity data and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.

How do we use your personal data?

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

Purposes for which we will use your personal data: We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us by emailing toluna@toluna.com if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

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