Note: Updates to ensure compliance with the Privacy Shield
Our privacy commitment to you
The information we collect
Toluna gathers personal information when an individual registers to become a member of our panel. Your participation in any of our panels and surveys is voluntary. After registration we ask Community members to provide us with more personal information so that we may invite them to appropriate surveys. To become a Finance Buddy Community member (the "Community"), we ask that you fill out a registration survey that gathers some personal and general consumer information. We ask for your email address so that we can send you email invitations to participate in our upcoming surveys and subject to the preferences you expressed when registering, to send you newsletters to make you aware of new features or contests running on the site. The other information we gather, such as your name, address, gender, birthday and employment status is for matching you with the appropriate marketing research projects. Your birthday is used to automatically update your age for us to target age-related marketing groups. We ask you for this information as a means to see if you might qualify for particular projects. All email contact from Community will be sent to your primary email address that you gave to us upon registration. If you become a Community member, your relevant personal information (i.e. name, postal/email address, mobile number, et.al.) is also used for the purposes of incentive fulfilment. When incentive points are deposited in your account and you wish to redeem them, this information is required so that we may send your reward to the appropriate recipient address. From time to time, a third party may be used for issuing cheques or processing the delivery of rewards; your personal information will not be used for any other reason, but to mail you your reward.
In some circumstances, Toluna may ask you to inform us of your sensitive personal information and if required by law, we will ask you for your consent to the processing of such sensitive personal information. Examples of sensitive personal information are; your racial or ethnic origin; your political opinions; you physical or mental health or condition; and your sexual life. This information is not shared with any third party, except as required by law or as part of a transfer of the Toluna business.
You should be aware that any personal information you choose to make public on the site, in the Community area (as an opinion or topic in a message board or live chat or any other public area or forum) can be read, collected, or used by other users and could be used to send you unsolicited messages. We are not responsible for the personal information you choose to submit or make public. In addition, we are not responsible for the content you publicly post on the site that can be found via web-based search engines. To request removal of your personal information from our blog or community forum, contact us at firstname.lastname@example.org. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why
We display personal testimonials of satisfied customers on our site in addition to other endorsements. With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at email@example.com.
EU-U.S. Privacy Shield Framework
Toluna, (including its USA based company Toluna USA Inc.,) recognises that the EU has established strict protections regarding the handling of EU Personal Data, including requirements to provide adequate protection for EU Personal Data transferred outside of the EU. To provide adequate protection for certain EU Personal Data about individuals (including about you and our corporate clients, suppliers, business partners, job applicants and employees received in the USA, Toluna has elected to self-certify to the EU-US Privacy Shield Framework administered by the US Department of Commerce ("Privacy Shield"). Toluna is responsible for the processing of personal information it receives, under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf. Toluna adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement, and Liability
For purposes of enforcing compliance with the Privacy Shield, Toluna is subject to the investigatory and enforcement authority of the US Federal Trade Commission. For more information about the Privacy Shield, see the US Department of Commerce's Privacy Shield website located at: https://www.privacyshield.gov. To review Toluna's representation on the Privacy Shield list, see the US Department of Commerce's Privacy Shield self-certification list located at: https://www.privacyshield.gov/list.
You may have the option to select binding arbitration for the resolution of your complaint under certain circumstances, provided you have taken the following steps: (1) raised your compliant directly with Toluna and provided us the opportunity to resolve the issue; (2) made use of the independent dispute resolution mechanism identified under the Questions or Complaints paragraph; and (3) raised the issue through the relevant data protection authority and allowed the US Department of Commerce an opportunity to resolve the complaint at no cost to you. For more information on binding arbitration, see US Department of Commerce's Privacy Shield Framework: Annex I (Binding Arbitration).
U.S. - Swiss Safe Harbor Framework
Toluna complies with the U.S. – Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal data from Switzerland. Toluna has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Toluna's certification, please visit https://safeharbor.export.gov/swisslist.aspx.
Use of this information
The information you provide to us is processed for the purpose of building and operating a proprietary database of panellists, in order to conduct marketing and market research studies. If you are a member of the Community, your information is stored in our proprietary database so we may call upon it to determine which people match up with specific research studies. If we think your profile makes you a potential candidate for a study, we will email you an invitation to make you aware of this opportunity. From time to time Toluna may use third-party software for email list management and email distribution, or may use third party list management providers to match the members of our Community to members of other lists or panels, or to validate accuracy of personal information you provide. We may use third parties to provide us with data they have collected about you, and append this data to your demographic profile. In such cases only a minimum amount of information is transferred to these third parties so as to enable them to perform specific functions on our behalf. We also may share your information with our service providers, such as to provide prizes you have won or other incentives for your participation in our panels.
We do not sell or transfer the personal information collected about our Community members or the individuals that take surveys for us. Information which is personally identifiable will only be transferred with your prior permission on a case by case basis, except for the narrow exceptions specified below.
Though we make every effort to preserve your privacy, we may need to disclose your personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also disclose your personal information as required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, to protect your safety or the safety of others, to investigate fraud or breaches of our site terms, or to respond to a government request. We may also in certain specific market research programs (and with your express prior consent) disclose your personal information to third parties for the purposes of providing such specific market research services to our client.
Other Tracking Technologies
Technologies such as cookies, web beacons/web bugs, scripts and tags are used by Toluna and its clients, partners, affiliates, or analytics and service providers. These technologies are used in analysing trends, administering the site, and to gather demographic information about our user base as a whole. Our clients may combine your survey responses and demographic information with those of others to produce "aggregated" reports. They may also create scientific reports based upon modelled information. "Modelled information" is data developed based upon demographic and behavioural characteristics (like your gender, age, and websites visited) to predict what people with similar or matching characteristics would watch or buy. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.
We use Local Shared Objects, such as HTML5, to store content information and preferences. Third parties with whom we partner to provide certain features on our website also use HTML5 to collect and store information. Various browsers may offer their own management tools for removing HTML5.
As is true of most websites, we gather certain information automatically and store it in log files. This information may include Internet protocol (IP) addresses, browser type, referring/exit pages, operating system, date/time stamp, and/or clickstream data. We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you, to improve analytics, marketing and site functionality.
Digital Finger printing
In the event that we discover or learn of any unethical conduct in connection with the use of the Technology, or that the Technology is being used in a manner that is inconsistent with the statements and/or disclosures made by us to you or is in breach of applicable laws and the market research codes of conduct, we will take immediate action to prohibit such unethical conduct and to ensure the proper administration of the Technology.
Social Media Widgets
Access to Your Information; Member Services Area/Update, Correct, Delete Information
If you are a Community member and terminate your membership, we will no longer use your personal information for any purposes other than accumulative reporting, but in accordance with our backup procedures. We will retain your personal information until it is eventually destroyed in accordance with our policies and we will continue to employ the security procedures and technologies to keep your Personal Information safe.
By becoming a Community member, you agree to receive Emails inviting you to participate in surveys that we feel may match your experiences, background and demographic statistics or information. From time to time, we will also email newsletters to you to make you aware of new features or contests running on our site.
If you choose to end your membership with the Community or to require us to cease processing your personal information, you may automatically discontinue your membership by clicking Unsubscribe in the footer of our Homepage. As an alternative, you may send an email directly to firstname.lastname@example.org requesting to be removed. By following the appropriate directions, your record will be marked as "unsubscribed", and you will no longer receive communications from the Community. In addition, you will forfeit any incentive balance that has not been requested as of the time you opt out. In most cases it will take 2 to 3 days to process this change, but please allow up to two full weeks for your status to be finalised. In the meantime, you may receive emails from us. Email links are provided on the site so that you may contact us directly with any questions or concerns you may have. Each email we receive is read and responded to individually; please allow two to three business days for us to get back to you.
Questions or Complaints
You can direct any questions or complaints about the use or disclosure of your Personal information to our Privacy Contact. We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your Personal information within 45 days of receiving your complaint. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request. Under certain conditions, more fully described on the Privacy Shield website https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
Notification of changes
We reserve the right to modify this privacy statement at any time, so please review it frequently. If we make material changes to this policy, we will notify you here, by email, or by means of a notice on our home page prior to the change becoming effective.
We take stringent measures to ensure every aspect of your information is kept secure. Access to all personal information is restricted and limited to few key personnel. Our website security is reviewed periodically and can only be accessed via our password policy. We will never ask you for financial information such your credit card details or other highly sensitive information such as your social security number to be used as part of our research. However, we may be required by law to ask for your social security number or other government-issued identifier to comply with reporting laws and regulations if you are the recipient of survey incentives. We use SSL encryption when collecting or transmitting such sensitive information.
From time to time we may offer visitors the ability to voluntarily link to other sites. Toluna does not review, and is not responsible for, the content or effect of the privacy policies of these sites.
You may be able to log in to our site using sign-in services such as Facebook Connect or an Open ID provider. These services will authenticate your identity and provide you the option to share certain personally identifiable information with us such as your name and email address to pre-populate our sign up form. Services like Facebook Connect give you the option to post information about your activities on this Web site to your profile page to share with others within your network.
We may disclose personal information when required by law or in the good-faith belief that such action is necessary to conform to applicable law or to comply with a legal process served on our site.
Toluna will not knowingly collect any information from any child under the age of 13 without permission from his/her parents, legal guardian or an adult responsible for the care of the child. We comply with COPPA, the EU "Safer Internet Programme" and the ESOMAR guidelines in relation to surveys concerning children and young people.
The Privacy Officer:
Toluna USA Inc.
21 River Road
Wilton, Connecticut 06897