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The EU Privacy Policy of PaidViewPoint.com

First Published: May 25th, 2018

Introduction.


Welcome to the PaidViewpoint.com EU Privacy Policy.


The PaidViewpoint.com (PV) website is owned and operated by Umongous, Inc., a U.S.-based privately held market research company, with headquarters in San Francisco, CA ("Umongous", "Company" "we" or "us").


Umongous is in the market research and opinion research business. Umongous operates this Website for the purpose of gaining opinions, such as your opinions, in order to help its customers who utilize data, such as answers to surveys and other forms of research data obtained from you, as described in this Privacy Policy. Research by Umongous’ clients helps them gain a better understanding of their business, marketing, product or service development, strategic opportunities, etc. Other uses may include the social sciences and other fields that can benefit from opinion research.


We, at Umongous, recognize the importance of protecting the privacy of our visitors, users, survey respondents and others (collectively or individually "Users" or "you") who use our PaidViewpoint.com website (the "Website").


This Privacy Policy details important information about how we look after your personal data when you visit our Website from the European Union or when you answer one of our surveys ("Services") through our Website, and about your privacy rights regarding your personal data.


This notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this Privacy


1. Important information and who we are


Purpose of this Privacy Policy


This Privacy Policy aims to give you information on how Umongous collects and processes your personal data through your use of the PaidViewpoint.com domain, including its subdomains (collectively the “Website”), including any data you may provide through the Website when you register to create an account with us, or when you contact us by post, email, telephone, or fax.


This Website is not intended for children under 16 years of age. No one under age 16 may provide any information to or on this Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website or on or through any of its features, use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us.


It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other notices and is not intended to override them.

Controller


Umongous, Inc. is the controller and responsible for your personal data.


We have appointed a data privacy manager who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.


Contact details


Our full details are:
Umongous, Inc.
Data Privacy Manager
Email address: [email protected]
Postal address: 3000 Atrium Way, Suite 260, Mount Laurel, New Jersey, 08054, USA
As an EU resident, you also have the right to make a complaint at any time to your local supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the regulator so please contact us in the first instance.


Changes to the Privacy Policy and your duty to inform us of changes


This version was first published on May 25th, 2018.


Please note that the data protection law in the EU will change on 25 May 2018. Although this Privacy Policy sets out most of your rights under the new laws, we may not yet be able to respond to some of your requests (for example, a request for the transfer of your personal data) until May 25th, 2018 as we are still working towards getting our systems ready for some of these changes.


We reserve the right to change the terms of this Privacy Policy at any time. If we change our Privacy Policy, we will notify you of such changes by way of a pop-up notice on the Website announcing that the Privacy Policy has changed. It is important that the personal data we hold about you is accurate and current. We therefore invite you to regularly check this policy to ensure that you have the most recent version. Please keep us informed if your personal data changes during your relationship with us.



Our Website includes social media features, such as the Facebook, Google, LinkedIn, Yahoo, Twitter, and Windows social login buttons. These features may collect your IP address, information about which page you are visiting on our Website, and may set a cookie to enable the feature to function properly, even if you are not signed into your social media account when browsing our Website. Social media features and widgets are hosted by a third party.


Our Website may also include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you.


We do not control these third-party websites, website features and widgets, nor are we responsible for their privacy practices and statements. When you leave our Website, we encourage you to read the privacy notice of every website you visit.


Our PV Referral System


When you invite a friend to join PV or when you use the Website automatically-generated unique referral code you receive to invite other people to join PV, you will be able to see the following information about the individuals who accepted your invitation: their avatar, username, registration status, and earnings. They will also be able to see your username. This information will appear in the “Friends Connection” section of your user account.


2. The data we collect about you


Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).


We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:


  • Identity Data includes information such as, first name, last name, username or similar identifier, title, photo, video recording, job title, country of residency, time zone, date of birth, marital status, parental status (including number of children, gender, age and whether or not they live with you), level of education, employment status, chosen career, gender as well as, household income and race/ethnicity.

  • Contact Data includes postal address, email address, PayPal email address, and landline or mobile telephone number.

  • Transaction Data includes details about payments to you.

  • Technical Data includes information such as, internet protocol (IP) address, your login data, browser type and version, 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 this Website.

  • Profile Data includes information such as, your username and password, feedback and survey responses, categories of house tags; personal habits, wealth & wellness, hobbies & interests, work / career, home and family, politics & religion, purchasing habits, life changes, transportation, phone, gadgets & devices, travel, sports, food & beverage, personal care, digital life, media, games, money management, green life, skills, brand awareness.

  • Usage Data includes information about how you use our Website and Services, such as the buttons you click on, the pages of our Website that you visit, the time spent on those pages, and the dates and times of your visits.

  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

  • Survey Data includes answers that provide to questions in surveys that you choose to participate in, whether the survey is created by us or one of our customers. If you choose to include personal data, or even Special Categories of Personal Data (as defined below) in your survey answers, these will be shared with our customers who purchase our Services.


We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Identity Data, including certain Special categories of Personal Data, as defined below, about you to give our customers statistical information regarding such data from participants to their surveys, or we may aggregate your Usage Data to calculate the percentage of users accessing a specific Website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.


We may from time to time collect directly from you Special Categories of Personal Data about you (this includesdetails about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data) through a number of short “Trait Surveys” we send you and which enable us to learn more about you. Your participation in any such survey is however entirely optional. In addition, should you wish not to answer any particular question(s) in any given Trait Survey, you may at any time click the “Exit” button in the survey, in which case none of your answers to the survey will be stored in our database. We do not collect any information about criminal convictions and offences.


If you fail to provide personal data
Where we need to collect personal data by law, or to perform services we’ve agreed to provide to you under our terms of use and you fail to provide that data when requested, we may not be able to perform our services to you or to register you as a user of our services. In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.


3. How is your personal data collected?


We use different methods to collect data from and about you including through:


  • Direct interactions. You may give us your Identity, Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

    • register to open an account with us; or

    • register to open an account with us; or

  • Automated technologies or interactions. As you interact with our Website, we may automatically collect Technical Data about your equipment. We collect this personal data by using cookies, server logs and other similar technologies. We may also use technology such as, digital fingerprinting to place a unique identifier on the mobile device or computer you use to access our Website and Services, as well as Local Storage Objects (LSOs) such as HTML5 to be able to identify an individual in order to enforce our rules and prevent fraud. Please see our cookie policy for further details.

  • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

    • Technical Data from analytics providers such as Google based outside the EU;

  • Contact, Identity and Transaction Data from providers of payment services such as PayPal based outside the EU.

  • Identity and Contact Data from publicly available sources such as search engines based inside and outside the EU.

  • Identity, Profile and Contact Data from social networks such as Facebook, Twitter, LinkedIn, Yahoo, Microsoft, or Google based outside the EU when you log in through your account with such networks, when you like, follow, or subscribe to our company page on such networks, or when you otherwise link your PV account to your account information on any of those networks.


4. How we use your personal data


We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the services we have offered to provide to use under our terms of use.

  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

  • Where we need to comply with a legal or regulatory obligation.

Click to find out more about the types of lawful basis that we will rely on to process your personal data


Purposes for which we will use your personal data


We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.


Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us at [email protected] if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.


Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new user (a) Identity
(b) Contact
Performance of a contract with you
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to take a Trait Survey
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(e) Survey Data
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to know you better as a user of our Services)
To enable you to complete a survey (a) Identity
(b) Contact
(d) Usage
(e) Marketing and Communications
(f) Survey Data
(a) Necessary for our legitimate interests (to study how our users use our Services, to develop them and grow our business, but also to help us better direct surveys to our customers)
(b) Consent (including when you are invited to record a video response or share your screen as part of the response, or to submit photos; if you record the video, you will also have an opportunity to review the recording and not submit the video, screenshots or photos)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity
(b) Contact
(c) Technical
(a) Performance of a contract with you (to enforce our terms of use and Privacy Policy terms)
(b) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)
(c) Necessary to comply with a legal obligation
To send you survey invitations via email, text messages, browser notifications, or automated phone calls (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
Necessary for our legitimate interests (increase speed and convenience for timely survey completion).
To use data analytics to improve our website, services, marketing, customer relationships and experiences (a) Technical
(b) Usage
Necessary for our legitimate interests (to define types of users for our services, to keep our Website updated and relevant, to develop our business and to inform our marketing strategy)

Opting out of invitations to take a survey


You may opt out of receiving email invitations to take a survey by clicking on the "unsubscribe" link at the bottom of each email or selecting the opt-out link in the email or on the “Settings” page.


You may also opt out of receiving SMS invitations to take a survey by turning off SMS notifications under the “Settings” page or reply STOP to any SMS notification.


Where you opt out of receiving these invitation to take surveys messages, this will not apply to personal data provided to us as a result of service experience or other transactions.


Cookies


You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this Website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.


Change of purpose


We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at [email protected] .


If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.


Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.


5. Disclosures of your personal data


We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.


  • Third Parties as set out in the Glossary.

  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.


We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.


6. International transfers


We share our users’ personal data within our company. If you are based in the European Union this will involve transferring your personal data outside the European Economic Area (EEA).


Many of our external third parties are also based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.


Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:


Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.


7. Data security


We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.


We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.


8. Data retention


How long will you use my personal data for?


We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.


To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.


Details of retention periods for different aspects of your personal data are available by contacting us at [email protected] .


In some circumstances you can ask us to delete your data: see [Request erasure] below for further information.


In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.



Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:


If you wish to exercise any of the rights set out above, please contact us at [email protected] Notwithstanding your right to contact us at any time at the above email address to exercise your legal rights, you may exercise your legal right to access or correct your personal data by logging into your account on the Website and clicking on the dashboard link on the top right-hand corner of the page and choosing the “My demographics” link. You can change your email address, phone number, avatar, and/or PayPal account by logging into your PV account and clicking on the dashboard link on the top right-hand corner of the page and choosing the “Settings” link. Please note that, in order to prevent fraud, once you change your email address or telephone number your ability to withdraw any vested earnings from your account will be suspended for 180 days. You may also delete your registration information by accessing your account settings and selecting to close your account.


Without prejudice to your right at any time to exercise any of your legal rights by contacting us at the above email address, If you wish to cancel your account or request that we no longer use your information and survey answers, please use the “Close account” button at the bottom of the “Settings” page, or you can contact us by email. When you close your account your information and survey answers will no longer be available to our survey customers for use in new surveys


No fee usually required


You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.


What we may need from you


We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.


Time limit to respond


We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.


10. Glossary


LAWFUL BASIS


Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at [email protected] .


Performance of Contract (Terms of Use) means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.


Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.


THIRD PARTIES


  • Service providers acting as processors based inside or outside the EU who provide services such as market research professional service providers, IT, and system administration services

  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based inside or outside the EU who provide consultancy, banking, legal, insurance and accounting services.

  • Regulators and other government authorities acting as processors or joint controllers based inside or outside the EU who require reporting of processing activities in certain circumstances.


Should you wish to obtain more specific information about any third party recipients of your personal data please contact us at [email protected] .



You have the right to:

  • Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.



SUPPORT