This Version: Effective November 4, 2020
1. Personal Data That May Be Collected About You
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:
- 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, etc.
- 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.
- First party and third party cookies and other similar or related technology and device identifiers (e.g., IDFAs, AAIDs, etc.) may be placed, written, set, and/or read for several purposes including, without limitation, to provide a better survey experience, quality control, validation, to enable or facilitate survey participation, tracking of completed surveys or other completed actions, for fraud detection and/or prevention, online ad effectiveness research, website tracking and audience measurement, to develop audience insights and/or look-alike models in connection with marketing campaigns, and for the purpose of targeting advertisements and other content to individuals, subject to your consent where required by applicable law. However, for certain cookies and/or similar or related technology, if you decide not to accept cookies, you will not be able to use the Service.
- With respect to the linking of data collected through the Service to third party data management platform (“DMP”) data, Survey Wing uses such data itself and/or permits Survey Wing’s clients and/or the DMP itself to use such data to provide you with survey opportunities, to measure advertising effectiveness (as described in more detail below), to segment audiences; to design advertising campaigns using “look alike” cohort groups based on survey and third party data; and/or to market such third party’s products/services to you.
- Audience Insights/Look-alikes. Survey Wing 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.
- Online Advertising Effectiveness. In connection with Survey Wing’s online ad effectiveness program, you can participate in surveys regarding ads, promotions, content, campaigns, and/or websites that Survey Wing is testing for its clients. To facilitate the completion of these surveys, Survey Wing’s clients may write, set, or read cookies, locally shared/stored objects, flash cookies and/or any other related technology (each a “Third Party Technology” and collectively the “Third Party Technologies”). The Third-Party Technologies may be written, set or read in various locations, including, without limitation, Survey Wing’s servers or systems. If you participate, your UID will be stored in or associated with the Third-Party Technology to allow you to be re-contacted about the online ad or promotion and Survey Wing’s client will use the Third-Party Technology to determine whether you have seen, clicked on, or otherwise interacted with the online ad or promotion. If you have interacted with the online ad or promotion, Survey Wing’s client will send your UID and the specific survey to Survey Wing and Survey Wing will provide you with the opportunity to complete the survey.
- Audience Measurement Data. In addition to the use and sharing of Audience Measurement Data (as defined below) in connection with online advertising effectiveness research, as such research is described above, Survey Wing may share your UID and data previously collected by Survey Wing, including, without limitation, age, gender, income, number of people in your household, education/education level, and employment status, (“Audience Measurement Data”), to third parties, including, without limitation, Survey Wing’s subcontractors, partners, and/or clients for the purpose of audience measurement reporting on the content, advertisements, campaigns, and websites that you visit, view, and/or click on. The Audience Measurement Data will be used in connection with online advertising effectiveness research, and to assist in the creation, development, and implementation of websites, online advertisements, and other Internet and digital media features, functionality, and campaigns. Audience Measurement Data may be shared in a single summary form (i.e. individual respondent level) or aggregate summary form (i.e. group of respondents).
- 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 Survey Wing is testing for its business clients, you may see these ads or promotions in several places, including in non-Survey Wing mobile apps (e.g., in a gaming app). Once you have been exposed to the relevant ads and promotions, Survey Wing 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, Survey Wing has partnered with ad companies that provide, measure or facilitate advertisements, including in other mobile apps. The Service 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 Survey Wing is measuring for one of our business clients. The ad company may then inform Survey Wing that the device associated with your UID has just received an ad or promotion, which allows Survey Wing 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.
If you are located in the European Economic Area, we may collect and use your Personal Data when:
- To offer you the opportunity to participate in research activities, including to join a panel, participate in surveys administered by Survey Wing 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 Survey Wing’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 Survey Wing, 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 Survey Wing 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 Survey Wing and third parties products and services.
- To update Survey Wing’s records, perform data analyses for Survey Wing 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.
- For data suppression or exclusion purposes, including, without limitation, preventing the same respondent from taking a survey more than once, complying with opt-out/unsubscribe requests, etc.
- To share your Personal Data with third parties (e.g., clients, sample suppliers, etc.) for suppression and exclusion purposes, including, without limitation, preventing a respondent from taking the same survey more than once, preventing an individual from being invited to a survey through more than one source, to comply with opt-out and unsubscribe requests for communications from or on behalf of Survey Wing, etc.
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:
- 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.
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:
- 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, and sourcing suppliers. 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. In connection with sharing Personal Data with service providers as set forth above, such service providers may use such Personal Data to improve and enhance their services, in which event they are acting as data controllers and not as data processors engaged by Survey Wing. For a list of the service providers acting as data controllers for your Personal Data and their privacy policies, please click here.
- 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.
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
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. Survey Wing does not respond to DNT signals. If you object to Survey Wing’s practice with regards to DNT signals, you may opt-out from participation or use of Survey Wing’s services as described below.
In connection with Survey Wing’s online ad effectiveness program, Survey Wing permits Survey Wing’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. Survey Wing 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 13. We do not knowingly collect Personal Data from children under the age of 13, and if we became aware that we have inadvertently collected Personal Data from a child under the age of 13, we will undertake reasonable commercial efforts to delete such Personal Data.
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
- 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.
- 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.