Global Survey Hub Privacy Policy

Last Updated: 06.08.2019

INTRODUCTION

 

This website is operated and wholly owned by Submission Technology Ltd, registered in England with the company number 04456811. For the purposes of the EU General Data Protection Regulation (2016), Submission Technology Ltd is the registered data controller with the Information Commissioner's Office (ICO); our registration number is Z7981900.

Submission Technology Ltd. ("Submission Technology," "we," “our” or "us"), respects your privacy and is committed to protecting it through our compliance with this Privacy Notice.

This Privacy Notice (together with our Terms & Conditions) sets out the basis on which any personal data you provide to us, will be processed.

 

As a company with a global presence, we are subject to the varying requirements of data protection and privacy legislation in jurisdictions where we operate. Our aim is to be as consistent as possible and obey all applicable laws operating with a high standard in our approach. For example, if you are a resident of the EU, we are bound by EU local laws including the General Data Protection Regulation (“GDPR”) or if you are a resident of California, we also respect the local laws of California, The Californian Consumer Privacy Act (“CCPA”).

 

 

INFORMATION CATEGORIES WE COLLECT ABOUT YOU

 

Personal Data

As permitted by applicable law, we may collect, use, store and transfer different kinds of Personal Data about you when you use our services. We have grouped these into the following categories of Personal Data:

 

  • Identity Data such as first name, last name, social media profile, username, gender
  • Contact Data such as billing addresses, email addresses and telephone numbers
  • Financial Data such as bank account details
  • Transaction Data such as details about payments to you and details regarding offers you have signed up to or services that you have subscribed to in relation to this website
  • Technical Data such as your device IDs, your login data, access dates and times, browser type and version, device information, cookie data, 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 the website
  • Profile Data such as your username, additional personal data added to your account (e.g. your home address), preferences, survey answers
  • Usage Data such as information about how you use our website, products and services
  • Marketing and Communications Data such as your preferences in receiving marketing from us and our third parties
  • Cookies when you visit our site or receive an email - see Cookie section

 

Non-Personal Data

We also collect aggregated data such as statistical or demographic data which does not directly or indirectly reveal your identity. We use aggregate data for analysing our website usage, for example, to calculate the percentage of users accessing a specific feature on our website.

 

HOW YOUR DATA IS COLLECTED

 

Directly Sourced

 

You may give us your identity, contact, profile data, and marketing and communications data by filling in a form or corresponding with us by post, phone, e-mail or otherwise. This includes Personal data you provide when you:

  • Create an account on our website
  • Register for surveys and offers
  • Update your profile
  • Choose your marketing preferences for both email and push notifications
  • Give us feedback
  • Speak with customer service or our data protection team
  • Request information be sent to you

 

Indirectly Sourced

 

We may collect your transaction data, technical data and usage data when you interact with our website. We collect this Personal and Non-Personal Data by using cookies, server logs and other similar technologies. We may receive this data from our various third-party vendors who assist us with the service.

 

We may also receive Technical Data and Usage Data about you if you visit other websites employing our Cookies or Tracking Technologies (defined below). Please see more information about this in our Cookies and Other Technologies section below.

 

HOW WE USE YOUR DATA

 

When we use or process personal data about you, we do so only as necessary to provide the services and products you use (e.g. to meet our contractual and legal obligations), or otherwise with your consent, to comply with applicable law, or to fulfil other legitimate interests of you or us as described in this Privacy Notice. Through our website, you will be provided with the choice of which types of communications you will receive with us.

We use information held about you in the following ways:

  • Fulfilling Contractual Obligations
  • To carry out our obligations arising from any contracts/agreements entered into between you and us, and to provide you with the information and services that you request from us;
  • To verify your identity for security purposes;
  • To provide our products and services, which includes updating, securing and troubleshooting, as well as providing support. We may also provide your personal data to third-party sub-contractors that provide services to support our business (i.e. payment processors, website-hosting companies, third-party content platforms etc.).
  • We supply your contact details (email and telephone number) to our advertising partners who sponsor this website for the purposes of their marketing
  • We will continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.

 

Consent

With your consent we and our advertising partners will supply you with offers, newsletters and marketing for our products. With your consent we and our advertising partners will also contact you by SMS, telephone and pre-recorded message. We facilitate contact by our Advertising partners by sending them your email and telephone number. We would encourage you to check their Privacy Notices to see how they process your personal data. We do not control the Privacy Notices of our Adverting Clients. If you choose not to consent to marketing, or opt out of selling your data, you are not discriminated against for this reason and you may still participate in the activities and services we offer on this website.

 

 

Legally Required Release of Information

We may be legally required to disclose your personal data if such disclosure is (a) required by subpoena, law, or other legal processes; (b) necessary to assist law enforcement officials or government enforcement agencies; (c) necessary to investigate violations of or otherwise enforce our Legal Terms; (d) necessary to protect us from legal action or claims from third parties including you; and/or (e) necessary to protect the legal rights, personal/real property, or personal safety of our company, customers, third-party partners, employees, and affiliates.

 

Legitimate Interest

We may process information or use it to communicate with you on the basis that doing so is necessary to achieve our legitimate interest to service and administer your account with us.

 

This includes operating our business, analysing our performance, meeting our legal obligations, developing our workforce, and performing research;

record-keeping for the proper and necessary administration of our business;

responding to customer complaints or service requests;

responding to unsolicited communications from you to which we believe you would expect a response;

protecting and asserting the legal rights of any party;

maintain suppression or opt-out lists that we may share with third parties so that a user is not contacted when the user has asked not to be;

insuring against or obtaining professional advice that is required to manage business risk;

protecting your interests where we believe we have a duty to do so; and,

 

We will continue to use this information for this purpose until the legitimate interest no longer exists or such use is not necessary to achieve the legitimate interest.

 

DISCLOSURE OF YOUR DATA (CATEGORIES)

 

Internal Parties

Employees of Submission Technology will process your data when you need to speak to the customer service team or our Data Protection Officer. Access to your Personal Data will be controlled and only granted where necessary to provide our services to you and/or allow us to perform any necessary or legitimate functions.

 

External Parties

Service providers who process your Personal Data on our behalf to support our business and help provide our services to you. These include, but are not limited to, our Email Service Provider (ESP), Cloud Providers, Outsourced Consultants and Contractors.

 

We disclose your data to our advertising partners who sponsor this website for the purposes of marketing.   We refer to the Survey providers and Advertising Clients as Sponsors and a list can be found here by clicking this link. SPONSORS

 

 

Fraud prevention and identity verification services where we believe that disclosure is necessary or appropriate to protect the rights, property, or safety of Submission Technology, our customers or others.

 

Professional advisers such as lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance, financial, auditing, and accounting services to us so we can operate our business.

 

Law enforcement agencies, courts, supervisory authorities, regulatory bodies and related third-parties, to the extent that we are permitted or required to do so by law, or in order to comply with our legal and regulatory obligations, or in the interests of national security, or to respond to verified requests relating to a criminal investigation or alleged or suspected illegal activity.

 

From time-to-time, we may run contests, special offers, or other events or activities with a third-party sponsor. If you provide consent to the third party, you give them permission to use it for the purpose of that promotion. We cannot control the use of your Personal Data after you have submitted it to the third-party.

 

Customer information is considered to be an asset of Submission Technology Ltd. and as such shall survive any sale of assets, merger, consolidation, or other change in the corporate structure of Submission Technology Ltd .

 

We allow our sub-contractors to collect certain information when you visit our web site. These companies may utilise cookies and other technologies to collect and use both personally identifiable information (e.g., your name, phone number, physical or electronic address) and non-personally identifiable information (e.g., click stream information, browser type, time and date, subject of advertisements clicked or scrolled over) during your visits to this and other web sites in order to provide tailored advertisements about goods and services likely to be of greater interest to you.  To learn more about this behavioural advertising practice or to opt-out of this type of advertising, you can visit the websites of the Digital Advertising Alliance at WWW.ABOUTADS.INFO or Networking Advertising Initiative at WWW.NETWORKADVERTISING.ORG/CHOICES.

 

Parties we do not transfer your data to

Our Website contains affiliate links to third-party websites. You may click on these to complete offers provided by third parties. Please note, if you follow a link to any such website, we do not accept any liability or responsibility, because these websites have their own Terms & Conditions and Privacy Policies.

 

Where in the world your data is transferred

 

Submission Technology is headquartered in the UK. The information that you provide or that we collect as a result of your interaction with the Website and/or the user of the Services will be stored in the UK and transferred to parties in the USA. Where applicable, we rely on the EU-US Privacy Shield Frameworks (“Privacy Shield”) to ensure recipients adhere to the Privacy Shield Principles. We have written contracts to protect your data when we share this with our subcontractors and consultants who are all based in the USA or UK.

 

HOW LONG YOUR DATA IS KEPT

We do not retain your personal data for longer than necessary for the purposes set out in this report. The length of time we hold your data will depend on our ongoing relationship with you, our legal obligation, any request you may make to delete your personal data, and our legitimate interest in relation to the management of our own rights.

Typically, we store Identity Data, Contact Data, Marketing Data and Profile Data for a period of 12 months since your most recent activity in your account to answer customer queries, maintain an account in case you wish to come back to our website and monitor the site for fraudulent activity.

Once we no longer have a purpose to retain your personal data, we will securely destroy your personal data subject to the foregoing and in accordance with applicable laws and regulations. If you request to receive no further contact from us, we will keep some of your basic Identity and Contact Data on a suppression list to avoid sending you unwanted communication in the future.

 

CALIFORNIAN CONSUMER RIGHTS

As a Californian resident, under the Californian Consumer Privacy Act, you are entitled to 

Right to Access

You may review certain information that we hold about you by signing into your account on our Website. To obtain a full copy of all information we maintain about you, you may send us a request using the contact information at the end of this Notice. After receiving the request, we will tell you when we expect to provide you with the information. We offer this service for free unless your request is excessive or manifestly unfound.

Right to Opt-Out

If you wish us to opt you out of receiving direct marketing from us or our partners, you may click the unsubscribe button at the bottom of the email, or through the unsubscribe link at the bottom of our website or contact us using the information at the end of this Notice.

Right to Erasure

If you wish us to remove or change personal data you have provided us with, you may contact us using the information at the end of this Notice.

Right to Equal Services and Price

The “right to equal service and price” refers to the Californian Consumer Privacy Act (2018)’s prohibition against discriminating against consumers who exercise their rights under the CCPA. Where a consumer exercises a right, a business is prohibited from denying goods or services, charging a different price, imposing penalties, providing a different level or quality of service, or suggesting the consumer will receive a different price or rate or different level or quality of goods or services.

 

When we receive any request to access, edit or delete personal data, we will first take reasonable steps to verify your identity.

For non-Californian residents, for any opt-out or deletion requests, please email info@globalsurveyhub.com  .

 

SECURITY AND STORAGE OF YOUR PERSONAL DATA

Submission Technology is committed to protecting the security of your personal data. We protect your data with security measures under the laws that apply, and we meet international standards. We use a variety of technologies to help protect your personal data from unauthorised access, use, or disclosure.

Unfortunately, the Internet is not a 100% secure medium for communication and, accordingly, Submission Technology cannot guarantee the security of any information you send to us via the Internet. In the event of a data breach that affects your data, we will notify you when legally required to do so.

To access your Submission Technology account, you must type in the correct password. It is your responsibility to keep this password secure. Please consider changing your password at least every month and do not use the same password across multiple websites. Ideally, your password should be at least 8 characters long, contain at least one capital letter, some numbers and a special character (e.g. ? ! , _). If you believe that your login details have been compromised, please contact us immediately.

Submission Technology is not responsible for any loss or damage you or others may suffer as a result of the loss of confidentiality of your data.

The safety and security of your Personal Data also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of our website, you are responsible for keeping this password confidential.  We ask you not to share your login or account credentials with anyone and keep your account information secure. We urge you to be careful about giving out information in public areas of the website like message boards, where information will be available to other users of the website.  If you believe that your access credentials or Personal Data have been compromised, please contact us immediately.

 

PROTECTING YOUR CHILD’S PRIVACY

We follow the Children’s Online Privacy Protection Act (COPPA). Our website is not designed for use by anyone under the age of 18, however, we are aware that a child may attempt to access our website. We do not allow anyone under the age of 18 to create an account and do not knowingly collect personal data from a child. If you are a parent or guardian and believe your child is using our website, please contact us. We may ask for proof of identification before we remove any information to prevent malicious removal of account information. If we discover on our own that a child is accessing our website, we will delete the information as soon as we discover it, we will not use the information for any purpose, and we will not disclose the information to third parties. You acknowledge that we do not verify the age of our users any further than asking for an accurate date of birth nor do we have any liability to do so. If you are a child, please seek the permission of a parent or guardian before accessing our website.

 

OUR EMAIL POLICY

We comply with the federal CAN-SPAM Act. You can always opt-out of receipt of further email correspondence from us or our affiliates.

 

OTHER WEBSITES

Our website may contain links to other websites. These websites are not under our control and are not subject to our Privacy Notice. These websites will likely have their own privacy Notices, and we urge you to read those Privacy Notices before using the website.  We have no responsibility for these websites and provide links to these websites solely for your convenience. You acknowledge that your use and access of these other websites is solely at your own risk. It is your responsibility to check the Privacy Notices of these other websites to see how they treat your personal information.

 

COOKIES AND OTHER TECHNOLOGIES

To enhance your experience with the website we use “Cookies”.

 

  1. What are Cookies

 

Cookies are small pieces of text used to store information on web browsers. Cookies are used to store and receive identifiers and other information on computers, phones and other devices. Cookies are created when you use your browser to visit a website or if we send them to you in an email. Cookies are used to keep track of your movements within the site, help you resume where you left off, remember your registered login, theme selection, preferences, and other customisation functions. Cookie technology encompasses the use of pixels, text files, web beacons and java script. We refer to all of these technologies as Cookies.

 

Why do we use Cookies?

Cookies help us deliver, protect and improve our website product by personalising content, tailoring services and advertisements, improving performance with the use of metrics and providing security measures to keep you safe and secure.

 

Do other parties use Cookies on our site?

Yes, other parties use Cookies on our site to help tailor advertisements to you on other applications and websites.

 

  1. Cookies we use

Strictly Necessary & Functional Cookies

These Cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. Functional Cookies enable the website to provide enhanced functionality and personalisation. They may be set by us or by third party providers whose services we have added to our pages. You can set your browser to block these Cookies, but some parts of the site will not then work.

 

Performance & Analytical Cookies

These Cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. If you do not allow these Cookies we will not know when you have visited our site, and will not be able to monitor its performance. We use Analytical cookies in our emails to improve our service to you which can detect, Email Client Version, Date and time of opening, Dwell time, IP address and Geo-location.

 

 

Targeting Cookies

These Cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store direct personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these Cookies, you will experience less targeted advertising.

 

Multiple users


If more than one person uses your device, the choices set up by other people will apply to you as well unless you change them. For example, if you share a computer with your family, you may see adverts based on sites they have visited as well as sites you have visited.

 

To find out more about Cookies visit www.allaboutcookies.org

 

Cookies and Do Not Track Disclosure (“DNT”)

Currently, various browsers (including internet explorer, Firefox and Safari) offer a DNT option that relies on a technology known as a DNT header, that sends a signal to a website visited by the browser user about the user’s DNT preference. You can usually access your browser’s DNT option in your browser preferences.

 

A “Do Not Track” standard is not available today therefore our website does not currently respond to DNT signals from browsers.

 

Automated decision making and profiling

We do not engage in any processing related to automated decision-making activity that would deny you a service. From the data you enter on our website we may send you (with your consent), marketing material or surveys that are tailored to your answers and may be of more interest to you. This is a form of profiling.

 

CHANGES TO OUR PRIVACY NOTICE

We reserve the right to change this Privacy Notice at any time. If our company decides to change this Privacy NOTICE, we will post those changes on our website, so our users and customers are always aware of what information we collect, use, and disclose. This Privacy Notice was last updated on 4th June 2020.

 

CONTACT US

Type of Enquiry

Email Address

Telephone

Postal Address

Data Subject Information Requests

DPO@SUBMISSIONTECHNOLOGY.CO.UK

011 44 888 683789

The Beater House

Turkey Mill

Maidstone

Kent

ME14 5PP

Customer Service Enquiries

info@globalsurveyhub.com

011 44 888 683789

The Beater House

Turkey Mill

Maidstone

Kent

ME14 5PP