Last updated: 30th September, 2016
Toluna-Group.com and QuickSuveys.com
Toluna recognises the privacy concerns of visitors to its sites on the Internet. Specifically, Toluna recognises the importance of protecting the privacy of personally identifiable information collected about the visitors to the Toluna websites. Toluna Group Limited and any of its worldwide subsidiaries and affiliates (“we” “our” and “us”) are committed to protecting and respecting your privacy.
Information you give us. You may give us information about you by filling in forms on our sites or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our sites, subscribe to any of our services search for a product, place an order on any of our sites and when you report a problem with any of our sites. The information you give us may include your name, address, e-mail address and phone number and billing address. If you create a survey using Toluna QuickSurveys and choose to use advanced survey features, we will collect your billing information for payment of those premium services. Your billing information will only be shared with our service providers so that we can process your payment.
Information we collect about you. With regard to each of your visits to any of our sites we may automatically collect the following information:
- technical information, 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), products 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), methods used to browse away from the page and any phone number used to call our customer service number.
Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or the other services we provide .
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 analysing trends, administering the site, tracking users’ movements around the site and the Internet, and to gather demographic information about our user base as a whole.
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.
Uses made of the information: We use information held about you in the following ways:
Information you give to us. We will use this information:
- to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
- to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
- to provide you with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, we will contact you by electronic means only if you have consented to this;
- to notify you about changes to our service;
- to ensure that content from our sites is presented in the most effective manner for you and for your computer.
Information we collect about you. We will use this information:
- to administer our sites and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our sites to ensure that content is presented in the most effective manner for you and for your computer;
- to allow you to participate in interactive features of our service, when you choose to do so;
- as part of our efforts to keep our sites safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- to make suggestions and recommendations to you and other users of our sites about goods or services that may interest you or them.
Disclosure of your information: We may share your personal information with any of our worldwide subsidiaries and affiliates and with carefully selected third parties including:
- Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you.
- Analytics and search engine providers that assist us in the improvement and optimization of our sites.
Though we make every effort to preserve your privacy, we may need to your personal information to third parties:
- In the event that we sell or buy any business or assets, in which case we may disclose your personal information to the prospective seller or buyer of such business or assets.
- If Toluna or substantially all of its assets are acquired by a third party, in which case personal information held by it about its customers will be one of the transferred assets.
EU-U.S. Privacy Shield Framework: Toluna, (including its USA based company Toluna USA Inc., and each member of the Toluna Group of companies) recognises that the EU has established strict protections regarding the handling of EU Personal Data, including requirements to provide adequate protection for EU Personal Data transferred outside of the EU. To provide adequate protection for certain EU 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 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.
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 compliant 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.
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. f 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.
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.
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The Privacy Officer
1 bis rue Collange
92593 Levallois-Perret Cedex