PRIVACY
POLICY (updated January 1, 2020)
Who
We Are and Why We Collect Your Information
Consumer Insights, Inc. (“CI,”
“Sonar Strategies” “we,” “us,” “our”) conducts market research on behalf of clients
using software applications, smartphones, websites, surveys, computers,
tablets, and other means of collecting data (collectively, “Research Tools”).
Ultimately, this research allows our clients to deliver better products and
services to consumers.
Sonar Strategies is committed to protecting
the confidentiality, integrity, and security of your personal information. We
take this responsibility seriously. This Privacy Policy is intended to help you
understand how we collect and safeguard your information. Additionally, prior
to interacting with certain Research Tools, we may present you with a participation
agreement, confidentiality agreement, instructions, and/or a privacy policy or
information specific to the relevant research project (collectively,
“Project-Specific Documentation”), which may contain further terms governing
how we treat your information, as discussed more thoroughly in Section I below.
By accepting the terms of this Privacy Policy, you hereby consent to our
collection, use, and sharing of your information in the following ways:
I.
What Does This Privacy Policy Cover?
This Privacy Policy covers our
treatment of (1) personally identifiable information, as defined by numerous
statutes in the United States, including the California Online Privacy
Protection Act (such statutes, the “PII Laws”), and (2) personal information,
as defined by the California Consumer Privacy Act (the “CCPA”, and collectively
the “Privacy Laws”) (collectively, “Personal Information”), which we gather
when you are accessing, viewing, completing, or using any of our Research
Tools. This policy does not apply to the practices of companies that we do not
own or control, or to individuals that we do not employ or manage.
Although this Privacy Policy is
intended to govern our treatment of Personal Information generally, our
Research Tools vary depending on the needs of our clients, and some Research
Tools have Project-Specific Documentation that provides additional terms and
conditions governing our treatment of your Personal Information. When that is
the case, we will provide Project-Specific Documentation to you prior to
collecting Personal Information via a Research Tool. In the event of a conflict
between the terms of Project-Specific Documentation and the terms of this
Privacy Policy, the terms in the Project-Specific Documentation will govern.
II.
What Information Does Sonar Strategies Collect?
Sonar Strategies does not collect Personal
Information indiscriminately. We limit the type of Personal Information and the
amount of Personal Information to what is necessary to fulfill the purposes
identified in this Privacy Policy and the Project-Specific Documentation. With
that in mind, we collect the following types of information:
A. Information You
Provide to Us:
We may collect Personal Information
from you when (i) you contact us with questions or concerns, and (ii) you
visit, interact with, or answer questions from any of our Research Tools. The
information we collect depends on the parameters of the research we are
conducting. Examples of Personal Information we may collect include the
following: your name and contact information; demographic information like gender,
age, and household income; home, work, school, and other locations; your buying
habits; your opinions and preferences; additional demographic data (which may
include race and/or ethnicity); or a user name or e-mail address that would
permit access to a Sonar Strategies survey you may establish as part of your
participation in any survey or other Research Tool. You can choose not to
provide us with certain information, although that may disqualify you from
using or participating in a survey or other Research Tool.
B. Information Collected
Automatically:
When you use a Research Tool,
certain information is passively collected (that is, gathered without your
actively providing the information) using various technologies and means, such
as Internet Protocol (IP) addresses, cookies, and Global Positioning System
(GPS) location data. These are described in more detail below:
C. E-mail and Other
Communications:
We may contact you, by email or
other means; for example, we may send you survey participation offers on behalf
of Sonar Strategies or other businesses, or communicate with you about the Research
Tools. When we do this, we may receive a confirmation when you open an email
from us. This confirmation helps us make emails more interesting and improve
our service. If you do not want to receive email or other mail from us, please
indicate your preference by clicking on the unsubscribe link in any of our
emails.
D. Special Categories of
Personal Information:
Except as stated otherwise in this
Privacy Policy and Project-Specific Documentation, we do not knowingly collect
special categories of Personal Information, including (1) Personal Information
revealing racial or ethnic origin, political opinion, religious or
philosophical beliefs, or trade union membership, and (2) genetic data, biometric
data, data concerning health, and data concerning a natural person’s sex life
or sexual orientation. Where Project-Specific Documentation states that we
collect and use such information, the Project-Specific Documentation will
explain the collection of such Personal Information and request your informed
consent.
E. Personal Information Sonar Strategies Has Collected in the Last 12
Months
Sonar Strategies has collected the following
categories of Personal Information in the 12 months immediately preceding the
Effective Date of this Privacy Policy, listed at the top of this document:
names; contact information; demographic information; locations where users of
Research Tools are; buying habits; opinions and preferences; user names and
e-mail addresses needed to access Sonar Strategies surveys; IP addresses; information
related to the use of third party websites and the Research Tools; users’
browser types; and confirmation when users have read Sonar Strategies emails.
III.
What Does Sonar Strategies Do With Personal Information?
A. Use of Information
Sonar Strategies collects your information
to answer questions related to the research we are conducting. These questions
and your responses allow us to qualify you for a survey, tailor survey
questions to you, and ensure that our survey participants are a representative
sample of the population we are researching. We will also use your Personal
Information to provide market research and analysis to our clients (as
described in Section IV.A below), which will allow our clients to improve the
goods and services they provide, including, but not limited to, consumer goods.
In certain circumstances, before collecting Personal Information through a
survey or software application, we may provide you in Project-Specific
Documentation with the name of the client or the category of client, as well as
a more detailed description of the purpose for which Sonar Strategies and the client
will use your Personal Information. We store Personal Information on our own
servers.
We may:
We use your IP address to diagnose
problems with our server, report aggregate information, determine the fastest
route for your computer to use in connecting to our site, and administer and
improve the site. We may use information collected by cookies to retrieve
certain information you have previously provided, to help to customize our survey
based on your preferences, to tell our website server information such as your
IP address and your browser type, to improve navigation on our surveys, to
indicate how many times a page is opened and what information is consulted, to
improve the content of our surveys, to administer our surveys, and to manage
users’ movements around our surveys. We may also use that information for
system management and market research purposes.
We may convert Personal Information
to nonpersonal information and store and use the nonpersonal information. For
example, we may permanently delete the connection between a person’s
identifying information and location information and retain the location
information and knowledge it pertains to a single (unidentifiable) individual.
We may also disclose the nonpersonal information to third parties.
B. Storage of Information
Unless noted otherwise in this
Privacy Policy or in Project-Specific Documentation, we store and process all
electronic Personal Information that we collect from you on electronic
information systems in the United States. Hard copies of personal information
remain in the United States.
IV.
Will Sonar Strategies Share Any of the Personal Information it Collects?
We share your Personal Information
with third parties as described below.
A. Clients that Have
Retained Sonar Strategies to Perform Research
We disclose Personal Information,
nonpersonal information that has been derived from Personal Information, and
aggregate information to our client(s), unless such disclosures are
specifically precluded by the Project-Specific Documentation. Our clients
include, but are not limited to, manufacturers of consumer goods and providers
of consumer services. At times, we may provide you with more information in
Project-Specific Documentation about one or more specific clients, the
categories of one or more clients, and/or one or more clients’ industry or
sector. Our clients are typically based in the United States.
B. Third Party Businesses
We Do Not Control
In certain situations, we will share
Personal Information with third party businesses that may contact you by email
or phone to assist Sonar Strategies to complete surveys and other Research Tools on
behalf of our clients. Sonar Strategies may disclose contact information, including
your name, phone number, email address, and physical address, to such third
party businesses to facilitate your completion of the Research Tools. Depending
on the Research Tool, Sonar Strategies may also share your contact information with
third party businesses that we partner with to send rewards to individuals who
complete certain surveys. The third party businesses described in this section
are typically based in the United States.
C. Business Transfers
We may choose to buy or sell assets.
In these types of transactions, customer information is typically one of the
business assets that is transferred. Also, if we (or substantially all of our
assets) are acquired, or if we go out of business, enter bankruptcy, or go
through some other change of control, Personal Information would be one of the
assets transferred to or acquired by a third party.
D. Legal Obligations, Our
Protection, and the Protection of Others
We reserve the right to access,
read, preserve, and disclose any information that we reasonably believe is
necessary to comply with law or court order; enforce or apply our conditions of
use and other agreements; or protect the rights, property, or safety of Sonar Strategies,
our employees, our users, or others. This includes exchanging information with
other companies and organizations for fraud protection.
E. With Your Consent
Except as set forth above, we will
obtain your consent before disclosing your Personal Information with third
parties, and you will be able to prevent the sharing of this information.
F. Personal Information Sonar Strategies
Has Disclosed to Clients in the Last 12 Months
Sonar Strategies has disclosed the following
categories of Personal Information to our clients in the 12 months immediately
preceding the Effective Date of this Privacy Policy, listed at the top of this
document: contact information; demographic information; locations where users
of Research Tools are located; buying habits; opinions and preferences; and
further Personal Information Sonar Strategies infers based on Personal Information and
nonpersonal Sonar Strategies obtains.
G. Personal Information Sonar Strategies
Has Disclosed to Third Parties in the Last 12 Months
Sonar Strategies has disclosed the following
categories of Personal Information to third parties for business purposes in
the 12 months immediately preceding the Effective Date of this Privacy Policy,
listed at the top of this document: : contact information; demographic
information; locations where users of Research Tools are located; buying
habits; opinions and preferences; and further Personal Information Sonar Strategies
infers based on Personal Information and nonpersonal Sonar Strategies obtains.
V.
Sonar Strategies’s Legal Basis for Collecting and Using Your Personal Information
Sonar Strategies collects and uses your
Personal Information pursuant to your informed consent, which you have granted
by (a) confirming the prompts produced by each Research Tool, and (b)
continuing to use each Research Tool, consistent with this Privacy Policy and
any Project-Specific Documentation. Please note that without your consent to
collect and use the Personal Information required in any particular survey or
other Research Tool, Sonar Strategies may disqualify you from using or participating in
a survey or other Research Tool. If you have any questions concerning the terms
of this Privacy Policy and the conditions of your consent, please contact us at
info@consumerinsights.com
To the extent that you provide Sonar Strategies
with the Personal Information of other people, you warrant and represent that
each such person who is required under the Privacy Laws to give consent, or the
person who is required to give consent, if the Privacy Laws require the consent
of another person, has granted his or her consent to you sharing his or her
Personal Information with Sonar Strategies for the use described in this Privacy Policy
and any Project-Specific Documentation.
VI.
How Long Will Sonar Strategies Retain Your Personal Information?
Except upon the request of an
individual, as explained in Section VII below, and except as the law permits
and requires, Sonar Strategies maintains Personal Information as follows:
a. When our contract with a client
requires that we delete all information that we have collected and processed at
the end of a project or after a defined period of time, we will do so.
b. Other than that, we will determine the retention period based on the
following criteria:
VII.
What Are Your Rights to Control Your Personal Information?
Except where permitted or required
by law (including, but not limited to, compliance with a legal obligation, to
further a public interest, and establishing and/or exercising a legal claim or
defense), you have the following rights regarding Sonar Strategies’s collection and use
of your Personal Information.
A. Requests to Sonar Strategies:
You may request (1) the deletion or
restriction of collection, use, sale, and/or transmission of your Personal
Information, (2) the categories of Personal Information Sonar Strategies has collected,
and (3) the specific pieces of Personal Information Sonar Strategies has collected
about you. We will respond to all such requests within 45 days, although there
may be a brief delay in processing a request while we verify that the request
is valid and originates from you as opposed to an unauthorized third party. If
you request that your Personal Information be deleted or that Sonar Strategies
otherwise limit its use of your Personal Information, we reserve the right to
terminate and/or limit your access to our Research Tools, and any financial
incentives we have provided, subject to the terms of Section VII.G below. If we
do not have your Personal Information, have not collected your Personal
Information, or have not disclosed or transferred your Personal Information to
another party, we will inform you in response to a request regarding your
Personal Information.
To exercise the access and deletion rights described
here, please submit a verifiable consumer request to us by either:
·
Calling us at 1-800-333-0533
·
Emailing us at info@consumerinsights.com
Only you may make a verifiable consumer request related
to your personal information. You may also make a verifiable consumer request
on behalf of your minor child. For residents of California, only you or a
person registered with the California Secretary of State that you authorize to
act on your behalf, may make a verifiable consumer request related to your
personal information.
You may only make a verifiable consumer request twice
within a 12-month period. The verifiable consumer request must:
·
Provide sufficient information that allows
us to reasonably verify you are the person about whom we collected personal
information or an authorized representative.
·
Describe your request with sufficient detail
that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with
personal information if we cannot verify your identity or authority to make the
request and confirm the personal information relates to you.
We will only use personal information provided in a
verifiable consumer request to verify the requestor’s identity or authority to
make the request.
When you update information, we may
maintain a copy of the unrevised information in our records. Please note that
some information may remain in our private records after your deletion of such
information from your account. We may use any aggregated data derived from or
incorporating your Personal Information after you update or delete it, but not
in a manner that would identify you personally.
B. Withdrawal of Consent
You may withdraw your consent at any
time by either
·
Calling us at 1-800-333-0533
·
Emailing us at info@consumerinsights.com
Please be aware that such withdrawal
does not affect the lawfulness of Sonar Strategies’s use of your Personal Information
before such withdrawal. Withdrawal of consent may affect your ability to
participate in surveys and other Research Tools.
C. Non-Discrimination
Sonar Strategies will not discriminate
against you because you have exercised any of the rights above or any other
rights you retain pursuant to Privacy Laws.
Consistent with Privacy Laws, Sonar Strategies:
(i) retains the right to provide a different level or quality of survey services
to you, if that difference is reasonably related to the value provided to Sonar Strategies
by your Personal Information; (ii) may offer financial incentives, including
payments to you as compensation, for the collection or disclosure of your
Personal Information; (iii) may enter you into a financial incentive program
only if Sonar Strategies clearly describes the material terms of the financial
incentive program, so long as you give Sonar Strategies prior opt-in consent, which you
may revoke at any time; and (iv) shall not use financial incentive practices
that are unjust, unreasonable, coercive, or usurious in nature.
VIII.
Is Personal Information About Me Secure?
We use appropriate technical,
administrative, and physical safeguards to protect against loss, unauthorized
access, destruction, misuse, modification, and improper disclosure of the
personal information we collect, in both physical and electronic format. To
that end, we use encryption and cloud services that comply with various
globally recognized security practices and standards to protect the personal
information submitted to us, both during transmission and once we receive it.
We take reasonable and appropriate steps to contract for and monitor the services
we use to determine that they remain compliant with such practices and
standards. We also provide information security awareness training to our staff
and conduct periodic quality assurance audits. We endeavor to protect the
privacy of your Personal Information that we hold in our records, but we cannot
guarantee complete security. Unauthorized entry or use, hardware or software
failure, and other factors, may compromise the security of information at any
time.
Our Research Tools may contain links
to other sites. We are not responsible for the privacy policies and/or
practices on other sites. When following a link to another site you should read
that site’s privacy policy.
IX.
Children’s Privacy
Except as stated otherwise in
Project-Specific Documentation, we do not knowingly collect or solicit personal
information from anyone under the age of 16 or knowingly allow such persons to
participate in Research Tools. If you are under 16, please do not attempt to
register for Research Tools or send any information about yourself to us,
including your name, telephone number, or email address. No one under age 16
may provide any Personal Information to us or through the Research Tools. In
the event that we learn that we have collected Personal Information from a child
under age 16 without verification of parental consent, we will delete that
information as quickly as possible. If you believe that we might have any
information from a child under age 16, please contact us by either:
·
Calling us at 1-800-333-0533
·
Emailing us at info@consumerinsights.com
X.
Failure to Provide Personal Information
You can always opt not to disclose
information to us, but keep in mind some information may be needed to
participate in some surveys or other Research Tools.
XI. Transfer of Data
When we transfer personal
information from a country of origin to the United States, we do so in
compliance with all laws of the originating country.
XII. Changes to this Privacy Policy
We may amend this Privacy Policy
from time to time. Use of information we collect now is subject to the Privacy
Policy in effect at the time such information is used. If we make changes in
the way we use Personal Information, we will notify you by posting an
announcement on our website or sending you an email. You are bound by any
changes to the Privacy Policy when you use this website or any Research Tool
after such changes have been first posted.