Global Survey Hub Privacy Policy

Last Updated: 12.30.2019

INTRODUCTION

For your information, this website (“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," or "us"), respects your privacy and is committed to protecting it through our compliance with this Privacy Policy. This Privacy Policy (together with our Terms & Conditions) sets out the basis on which any personal data you provide to us, will be processed. By accessing and using the Website, you agree to the terms of this Privacy Policy.

INFORMATION 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

Non-Personal Data

We also collect, use and share 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

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

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 various third-parties such as analytics providers or advertising networks.

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 Policy. 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

We use information held about you in the following ways:

• 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 processors that provide services to support our business (i.e. payment processors, website-hosting companies, third party content platforms etc.).

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

We rely on your consent to:

• Send your data to third party advertisers who may wish to contact you by SMS or telephone under the Telephone Consumer Protection Act (TCPA);
• Send your data to third party advertisers who may wish to contact you by email; and
• By using this Site or selecting one or more Offers on an offer placement or offer page, (1) you consent to the collection, use and disclosure of your personal and non-personal information as described in this Privacy Policy and the privacy policy of the Advertiser Client, and (2) you agree to be bound by the terms of this Privacy Policy. If you do not consent and agree to the practices described and terms of this Privacy Policy, you may not access this Site or select any Offers; and,
• Reply to messages you send us in which you would reasonably expect us to reply.

If we are not able to process your personal data because you have not provided your consent or you have withdrawn your consent, then we will not be able to achieve all of the purposes listed above.

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. For example, we may process your data or communicate with you for any of the following purposes:

• advertising and marketing to you, which includes sending promotional communications, targeting advertising, and presenting you relevant offers based on the information you provide or our prior dealings;
• operating our business, which includes analyzing our performance, meeting our legal obligations, developing our workforce, and doing 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,
• sending your data to third party advertisers where you have selected their advertising offer. By selecting an Advertiser Client’s Offer, you authorize US Product Testing to pass any information we have about you, including your personal information, to that Advertiser Client. We strongly encourage you to review the privacy policies of each applicable Advertiser Client before selecting Offers. US Product Testing does not control the use of your personal information by Advertiser Clients.

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

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) Get Response and push notification provider One Signal. Please read their Privacy Policies for more information on how they secure your Personal Data:

• Get Response: https://www.getresponse.com/legal/privacy.html
• OneSignal: https://onesignal.com/privacy_policy

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.

Third-parties where you have expressly consented to the disclosure of your Personal Data, for example, for direct marketing purposes under the Telephone Consumer Protection Act (TCPA).

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.

Third-parties who wish to contact you with marketing offers and promotions. Please find details of these third parties on our sponsors list.

From time-to-time, we may run contests, special offers, or other events or activities with a third-party sponsor. If you provide information 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. If you do not want your information to be processed by the third-party, you can choose not to participate in the promotion.

SolveMedia collects NON - Personal information (PII) cookie information and shares this data with third parties in relation to user activity on our website. This data is presented to third parties in a hashed format for the purpose of serving users targeted advertising based on our users presumed interests: If you would like to opt out of SolveMedia services please click here: HTTP://WWW.NETWORKADVERTISING.ORG/CHOICES

LiveIntent collect Non - Personal information from the emails we send, these contain a piece of code known as a "web beacon." This code allows us to understand the time and date of when a user has opened an email and when he/she has utilised a link within the email to visit a website. Our web beacons do not collect personally identifiable information. Users wishing to disable our web beacons should do so by turning images "off" in their email client (e.g., Outlook, Outlook Express). Please see your email client for more information.” If you wish to unsubscribe from our emails you can do so here on our UNSUBSCRIBE PAGE

Acxiom Limited trading as Liveramp MatchPartners (225 Bush Street, San Francisco, CA 94104) and its partners may use the data you provide to this website, together with other data collected elsewhere, to place cookies on your device. Other types of information that may be linked to the consumer’s personal information, such as IP address, browser or OS type and version, and demographic or inferred-interest information. Data through these cookies, in conjunction with other data collected about you and others, will be used to improve the relevance of online advertisements displayed to you when you visit this and/or other unrelated websites. Match Partner may share personal information, e.g. email address, with these third parties if the consumer submitted such information to the Match Partner, 3rd parties will use such information to re-identify specific individuals on unaffiliated websites, apps, or online services for advertising, analytics, attribution, and reporting purposes, including to send marketing emails based on the fact that a consumer visited a particular website.

To opt-out of data collection, please go to HTTP://WWW.ACXIOM.COM/ABOUT-ACXIOM/PRIVACY/US-CONSUMER-CHOICES/ Acxiom will then add an opt-out flag to this cookie which will ensure it is no longer used by Acxiom for targeted advertising. Digital Advertising Alliance’s (DAA) Consumer Choice Page at HTTP://WWW.ABOUTADS.INFO/CHOICES

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 ST.

We allow third-party companies to collect certain information when you visit our web site. These companies may utilize cookies, pixels or 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 advertisements about goods and services likely to be of greater interest to you. To learn more about this behavioral 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.

We do not transfer your data to these third-parties but to improve your user experience when you click on a third-party offer and are transferred to the third-party website, we may pre-populate the third-party form with your Personal Data. It is your choice to submit this data to the third-party, we will never do this for you.

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.

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 in to 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 Policy or, if available, through the OneTrust tool on our Website. After receiving the request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.

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, contact us using the information at the end of this Policy or, if available, through the OneTrust tool on our Website.

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 Policy or, if available, through the OneTrust tool on our Website.

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; consider changing your password every 3-6 months. Ideally, your password should be at least 8 characters long, contain at least one capital letter, some numbers and a special character (e.g. ? ! , _) and should not be disclosed to anyone. 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. You understand that these websites are not under our control and are not subject to our Privacy Policy. These websites will likely have their own privacy policies, and we urge you to read those policies 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 policies 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”. A cookie is a small piece of data stored on your computer or mobile device by your web browser. Cookies are used by your computer’s browser to store your preferences. Cookies, by themselves, do not tell us your e-mail address or other personally identifiable information. We use cookies to understand Site usage and to improve the content and offerings on the Site. You may set your browser to warn you that cookies are in use, or to block the use of cookies. Most browsers are set to accept cookies. If your browser is not set to accept cookies, certain uses of the Site may require you to go to your browser user preferences to enable cookies. Each browser is different, so check the ''Help'' menu of your browser to learn how to change your cookie preferences. If you change computers, operating systems or browsers, or use multiple computers or browsers, you will need to repeat this process for each computer and each browser. To find out more about cookies, please visit WWW.COOKIECENTRAL.COM.

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic in an anonymous format using cookies. It allows us to see the number of visitors to our site, where they are from and what pages they have visited. If you wish to to find out more about Google Analytics and your privacy then please visit: HTTP://WWW.GOOGLE.COM/INTL/USA/POLICIES/PRIVACY/

CHANGES TO OUR PRIVACY POLICY

We reserve the right to change this privacy policy at any time. If our company decides to change this Privacy Policy, we will post those changes on our website so our users and customers are always aware of what information we collect, use, and disclose. In all cases, your continued use of our Website or our services and products after any change to this Privacy Policy will constitute your acceptance of such change.

CONTACT US

Type of Enquiry Email Address Telephone Postal Address
Data Subject Information / Access Requests DPO@SUBMISSIONTECHNOLOGY.CO.UK +44 (0)20 7183 5039 The Beater House
Turkey Mill
Maidstone
Kent
ME14 5PP
Customer Service Enquiries info@globalsurveyhub.com +44 (0)20 7183 1653 The Beater House
Turkey Mill
Maidstone
Kent
ME14 5PP