REP DATA Inc. PRIVACY POLICY
Last updated: July 24th, 2020
This Privacy Policy (this “Policy”) is posted by Rep Data Inc. (“Rep Data,” “us,” “we,” “our”) and governs our collection, use, sharing, and storage of the personal information of our clients, prospective clients, and research participants (“you” or “your”).
Please read this Policy to understand how your personal information will be treated as you use our website, communicate with us, or otherwise give us personal information as necessary to utilize or participate in services that Rep Data offers, including without limitation our sampling, programming, hosting, cleaning, and other research services (collectively, the “Services”).
As used in this Policy, the term “personal information” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual.
Please be advised that even in the absence of a full name, certain pieces of information, such as demographic information, a mailing address or other location information, or even device ID’s or IP addresses, may be deemed personal information.
Any personal information provided by you is kept strictly confidential and is used by Rep Data only as described in this Policy. By using our website or using our Services, you consent to the terms of this Policy.
COLLECTION OF AND ACCESS TO PERSONAL INFORMATION
Sampling and Other Services
As a general matter, we do not collect personal information of individual respondents if we are providing clients with sampling services (i.e., providing them access to sample), or if we are hosting or programming a survey for clients.
However, when accessing such sample from our third-party business partners, or when programming or hosting a survey, we may have access to limited information about respondents, including IP addresses and aggregate and anonymized demographic information (e.g., age, sex, occupation).
We only use such information for quality assurance purposes. We only store such information in our own records as long as necessary to complete the associated project, typically no more than a month.
The primary exchange where we access sample provided to our clients is hosted by Lucid Holdings, LLC. For more information about Lucid’s exchange, and their privacy practices, please see their Privacy Policy.
Research Services
If we are administering a survey, we may collect personal information from individual respondents in connection with that process. Information we collect from respondents may include, without limitation, demographic information, information about past purchases or product/service preferences, and professional or employment-related information.
We may also collect personal information form you in connection with other research studies, such as in-home use testing studies, focus groups, or in-person, telephone, or video interviews. This information may include the information described above collected in connection with surveys, in addition to audio or video data.
In connection with the surveys and studies described above you know what information we collect because you provide it to us directly. If you participate as a respondent you acknowledge and agree that your participation is completely voluntary, and that our use of your personal information is carried out with your consent.
Any personal information you provide in connection with surveys and other studies administered by our clients, partners or other third parties is not subject to this Policy, but rather the privacy polices of such third parties, which you are strongly encouraged to review and understand.
Client Information
If you are a client or prospective client, we will also connect basic information about you, such as your name, company name, email and mailing address, payment information, and other information necessary to manage our business relationship with you.
Anyone who uses our website may also may have the opportunity to enter their name, email address, or other contact information.
USE OF PERSONAL INFORMATION
Rep Data may use your personal information:
· To communicate with you
· To tailor and advertise our Services to you
· To help our clients analyze trends and develop insights
· To comply with our legal obligations
· To comply with any data suppression obligations or requirements
· For fraud detection and/or prevention purposes
· For quality assurance purposes
· To validate information you provide to us
· As otherwise permitted pursuant to this Policy or as otherwise authorized by you
DISCLOSURE OF PERSONAL INFORMATION
If you are a respondent, we may share personal information associated with your survey or research study results with our clients. This is done on an aggregate and anonymized basis, unless we have your express consent.
We may also share your personal information with our service providers, such as parties assisting us with programming a survey or cleaning data, or other third parties as necessary to run our business and provide Services to you, subject to appropriate confidentiality and security agreements between Rep Data and such service providers or other third parties.
Otherwise, Rep Data will not disclose personal information collected by or provided to Rep Data without your express consent. The following are exceptions:
· We may be required or permitted by law or court orders to disclose personal information.
· We may disclose personal information where it is necessary to identify, contact, or bring legal action against someone who may be violating their agreement with us or may be causing injury to or interference with the rights or property of Rep Data or a third party.
· We may disclose personal information in the event of a sale, merger, liquidation, dissolution, financing, or reorganization of Rep Data to those involved in the negotiation or transfer.
DATA SECURITY
Rep Data is committed to keeping personal information secure and will take reasonable precautions to protect personal information from loss, misuse, unauthorized access, disclosure or alteration.
No method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee, warrant or otherwise covenant to its absolute security.
DATA RETENTION
We will retain your information, including personal information, for as long as necessary to fulfill the purposes for which we collected it and as permissible by applicable law. In connection with our sampling and research services, we typically delete any personal information associated with a particular project once the project is completed and research results and/or sample have been delivered to our clients.
Otherwise, to determine the appropriate retention period for information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of your information, the purposes for which we process your information and whether we can achieve those purposes through other means, and the applicable legal requirements.
THIRD-PARTY WEBSITES
Our website or other Services may contain hyperlinks to websites outside of Rep Data. Data collection and privacy policies may be different on such hyperlinked sites. We strongly recommend that you read the privacy policies for each site visited.
COOKIES
A cookie is a small amount of data that is sent to your browser from a web server and stored on your computer’s hard drive. We do not utilize cookies on our website or in connection with our services.
YOUR CHOICES
If you do not wish to receive communications from Rep Data, or would like to access, correct, or delete your personal information, contact us at the info in the “Contact Us” section below.
“DO NOT TRACK”
Rep Data does not respond to “do not track” (DNT) signals in browsers because no DNT standard has been adopted. In any case, Rep Data does not utilize behavioral advertising, analytics services, or other “tracking” tools.
Children
Rep Data does not knowingly make direct contact with children under 13 years of age. If we unknowingly receive personal information from a child under 13 years of age, we will promptly delete such personal information.
Information for Users in Europe
The website and the Services may be accessed abroad. All personal information collected by Rep Data will be stored and processed in the United States or any other country in which Rep Data or its affiliates, contractors or agents maintain facilities. By using the Services or our website, you consent to any such transfer of information outside of your country.
Users in Europe have the right to request access to and rectification or erasure of personal information, to restrict of processing of their personal information, and to object to processing. Users in Europe also have the right to lodge a complaint with a supervisory authority. If you would like to exercise any of your data protection rights, please contact us using the “Contact Us” below.
We will not process your personal information unless you have given your consent to our processing for a specific purpose, processing is necessary for the performance of a contract with you or to comply with a legal obligation, or processing is necessary for the purposes of the legitimate interests pursued by Rep Data or a third-party controller.
In cases where the purpose of our processing is the “legitimate interest” purpose, we will also carefully balance those interests against your fundamental rights and freedoms related to your Information. Where processing is based on your consent, we will identify the processing purposes and provide you with relevant information to make the processing fair and transparent.
INFORMATION FOR CALIFORNIA RESIDENTS
If you are a California resident, you have certain special rights under the California Consumer Privacy Act (“CCPA”), in addition to your other rights outlined in this Policy.
Your Right to “Know” and to Request Deletion
You have the right to know the categories and specific pieces of personal information we have collected about you. You have the right to know the categories of sources from which the personal information has been collected, the business or commercial purpose for collecting or selling personal information, and the categories of third parties with whom we share personal information.
You also have the right to request deletion of personal information we’ve collected or maintain. Please note, however, that our deletion of your personal information may negatively affect our ability to provide you with services or your ability to participate in research.
To exercise these rights please contact us as provided below.
We may ask you to provide additional information, such as your name, email address, or other basic personal information about you that we already have on file, in order to verify who is making the request. Please note that any requested disclosures will only apply to the 12-month period preceding the request, and you are entitled to request disclosure regarding your personal information twice in any 12-month period.
Your Right to Opt Out
We will never disclose personal information such as your name or address to third parties in exchange for monetary consideration without your consent.
However, under CCPA’s broad definition, “personal information” may also include (in addition to names, addresses, and the like) unique identifiers, IP addresses, and even inferences which may be drawn from any of the above. CCPA also defines the term “sell” broadly. Its meaning includes “renting, releasing, disclosing, disseminating, making available, [and] transferring…for monetary or other valuable consideration.”
Under these broad definitions, certain transfers of information we make in connection with providing our services could arguably be deemed a “sale” of “personal information” under CCPA. You have the right to opt out of this “sale.” For more information on how to opt out, click here.
Please be advised that your decision to opt out may prevent us from providing services to you or prevent you from participating in research.
Personal Information “Sold” or Disclosed
You have the right to know what categories of personal information we’ve “sold,” as that term is broadly defined under CCPA, or disclosed for a business purpose, and the third parties to whom that information was “sold” or disclosed.
As discussed above, we will never disclose personal information such as your name or address to third parties for consideration without your consent. However, in the last 12 months, in certain narrow circumstances where you have agreed to participate in one of our research studies, we have “sold” the following categories of information to our clients, as that word is broadly defined under CCPA, in connection with delivery of our research results: IP addresses and unique identifiers; demographic and ethnographic data (such as age, sex, race/ethnicity, parental status, marital status, address/ZIP code, income and education levels); purchasing or consuming histories or tendencies; and respondent photos, video, and audio collected during qualitative research.
In the last 12 months we’ve disclosed the following categories of information to the following parties for a business purpose: (1) the categories of information described in the preceding paragraph to our service providers (e.g., data collection partners, data cleaning services, and programming partners) to help us administer surveys, deliver research results, and otherwise operate our business; and (2) names, emails, and phone numbers to our service providers for use in sending survey invites and fielding surveys.
Your Right to Non-Discrimination
You have the right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA, including but not limited to by denying you services, charging different prices or rates, or providing you with a different level or quality of services.
Your Right to Use an Authorized Agent
You have the right to designate an authorized agent to make a request under the CCPA on your behalf. To designate an authorized agent, please contact us as provided below. In order to verify you have authorized an agent we will require a signed, written authorization from you.
CHANGES TO THIS PRIVACY POLICY
This Policy may be changed at any time. When we do so, we will post the new Policy on this page, change the date at the top of the Policy, and otherwise notify you as appropriate.
CONTACT US
If you wish to access or request changes to any of your personal information, or if have any questions or concerns about this Policy, you may contact us through any of the following means. Please be sure to specify the reason for your communication.
Email: reps@repdata.com
Phone: (817) 542-2520
Online Contact Form: repdata.com/contact