Effective Date: 26 September 2018

Last Revised: 26 September 2018

This Privacy Notice applies to Full Circle Research (“Full Circle”) and all of Full Circle’s online panel communities, including but not limited to, Survey Roundtable. This Privacy Notice defines how Full Circle collects, stores, uses and discloses your Personal Data (as defined below). Full Circle will, and will cause its affiliates to, establish and maintain business procedures that are consistent with this Privacy Notice.

WE PROTECT YOUR PRIVACY

Full Circle is a leading market research company. Full Circle is strongly committed to the protection of the confidentiality of Personal Data (“Personal Data”). Full Circle strives to conform its privacy practices to applicable laws, codes, and regulations, and the codes of standards of applicable market and opinion survey research associations, including, without limitation, the Insights Association (www.insightsassociation.org).

HOW DO WE COLLECT YOUR PERSONAL DATA

We will always collect your Personal Data by fair and lawful means. For example, we may collect your Personal Data when you complete a survey or participate in another research program. Note that Personal Data may be referred to as PII is some jurisdictions.

Full Circle only collects Personal Data for market research purposes

WHAT PERSONAL DATA DO WE COLLECT AND PROCESS?

The Personal Data that is processed may include your name, address, telephone number, e-mail address, date of birth, and other similar information. Full Circle may collect Personal Data directly from you when you voluntarily provide it to Full Circle. Full Circle will collect data in accordance with their instructions.

Full Circle may also obtain Personal Data from database owners who have assured us that their databases comprise only individuals who have consented to be included and have their Personal Data shared. Finally, Full Circle may collect and use Personal Data obtained from publicly available sources, such as telephone directories.

From time to time Full Circle may collect Sensitive Personal Data which depending on the country in which you live may include, racial or ethnic origin, health records, financial information, political opinions and religious or philosophical beliefs. If Full Circle collects your Sensitive Personal Data, Full Circle will always obtain your explicit consent.

You may also submit, upload or transmit content or material, including photos, videos, and/or any other similar or related content or material which may include your Personal Data, for example, when participating in surveys or other market research programs. Such Personal data may be used and disclosed as described in this Privacy Notice and should not include audio, video, images, or the likeness of anyone other than you.

HOW IS PERSONAL DATA COLLECTED AND PROCESSED?

When you participate in one of our surveys or other research programs, we combine the information you provide with the information of all other research participants and report aggregate responses. Additionally, we may use data we collect in statistical modeling to better understand trends among the general population. When we conduct such statistical modeling, we never release your Personal Data.

We will not make your Personal Data available to any third party without your consent, unless it is for research purposes or required by law, as further specified below.

We may use Personal Data for a variety of reasons, including but not limited to:

  • enable your participation in a panel;
  • gather profiling information about you so Full Circle can better target specific surveys and other market research programs to you;
  • contact you to invite you to participate in surveys or other market research programs;
  • update our records of your Personal Data;
  • manage our incentives programs and fulfill your requests for such incentives;
  • allow you to participate in sweepstakes (if permitted);
  • to respond to any messages or requests you may send to us;
  • validate your profiling information or answers you provided to a survey or other market research program;
  • provide service and support to you;
  • detect and prevent violation of our Terms & Conditions;
  • to investigate suspected fraudulent activity or violation of another party’s rights;
  • to respond to duly authorized information requests of governmental authorities or where required by law;
  • in connection with the sale, assignment, or other transfer of our business, in which case Full Circle will make commercially reasonable efforts to ensure that any such buyer agrees to treat Personal Data in accordance with this Privacy Notice; or
  • as otherwise authorized by you.

Please note that receiving email communications, may be a requirement of your participation in our surveys or other research programs. You can opt out from receiving these emails by unsubscribing from the survey or other research program.

Full Circle always ensures that it is permitted to process your Personal Data. Full Circle generally does this by obtaining your consent, however in limited cases, Full Circle may use a statutory condition to process Personal Data.

If a statutory condition applies allowing Full to process your Personal Data and you withdraw consent to process your Personal Data this will not necessarily mean that Full Circle will cease to process your Personal Data as it may, for example, be under a statutory duty to continue to process your Personal Data for some purposes, e.g. to keep copies of commercial transactions for a minimum of seven years.

WHAT INFORMATION DO WE COLLECT BY AUTOMATED TECHNOLOGIES?

As further specified below, we may automatically collect a variety of machine readable information about you, including the date and time you visited our website, the pages you visited, the website you came from, the type of browser you are using (e.g., Internet Explorer, Firefox, Safari, Chrome, etc.), the type of operating system you are using (e.g., Windows, mac OS, etc.), your Internet Protocol address and the domain name and address of your Internet service provider.

We may also collect the following:

  • website name (full URL of the website homepage);
  • date and time you visited the site;
  • number of pages you viewed;
  • time in seconds you spend on each page; and
  • details of the any website you visited before and/or after participation in one of our surveys or other research program.

Cookies:

Cookies are small text files stored on your computer by a website that assigns a numerical user ID and stores certain information about your online browsing. We may use cookies on our survey site to help us recognize you as a prior user. No Personal Data is stored on any cookie that we use.

If you wish, you can adjust your web browser’s privacy settings to delete cookies upon exiting websites or when you close your browser. You may also configure your browser to block cookies, however doing so may negatively impact your user experience when participating in one of our surveys or other research programs.

Web Beacons:

A web beacon (also known as a tag, clear gif or 1x1 pixel), consists of a small string of code that is embedded within a web page or email. There may or may not be a visible graphic image associated with the web beacon, and often the image is designed to blend into the background of a web page or email.

We may use web beacons in our email messages to help determine whether our messages are opened and to verify any clicks through to links within the email. We may use this information to determine which of our emails are more interesting to users, to improve the quality of the emails that we send and to query users who do not open our emails as to whether they wish to continue receiving them. The web beacon is deleted when you delete the email.

If you would prefer not to have web beacons in the emails that you receive, you should adjust your email program to receive messages in plain text rather than HTML. It is also possible to detect and control web beacons that are present on web pages by downloading a plug-in for your browser.

Log Files:

Full Circle may use logging throughout your survey-taking and research program experiences. When you access any of these services, our servers automatically record information that your browser sends whenever you visit a website. These server logs may include information such as your web request, Internet Protocol (IP) address, browser type, browser language, the date and time of your request and one or more cookies that may uniquely identify your browser. This information is periodically deleted as part of normal maintenance routines.

Geo-Location Data:

Full Circle may collect geo-location information from your computer or device. Full Circle may use your geo-location data for fraud prevention or for market research purposes, including but not limited to advertising research or other tracking-based market research activities. Full Circle will obtain your consent if Full Circle collects or uses your geo-location information.

Digital Fingerprinting:

Full Circle may use digital fingerprinting technology, also known as "machine identification" technology (“Digital Fingerprinting”), to gather certain data about you and/or your computer. This data may include Personal Data an Internet Protocol (IP) address, as well as other data such as a computer operating system or browser version number. This technology creates a unique computer identifier (“ID”) that may be used to identify and track your participation in a survey or other research program and limit participation.

Full Circle may utilize Digital Fingerprinting technology to assist our clients in ensuring the integrity of survey results by enabling us to authenticate users and to help ensure users participate in surveys no more than the maximum allowable participation. In furtherance of Full Circle’s efforts to assist its clients in protecting and ensuring the integrity of survey results, Full Circle may: (a) link or associate an ID to an individual or to Personal Data of an individual; (b) share an ID with Full Circle’s clients and/or sample or panel providers; and/or (c) receive or obtain a unique identifier that is linked to an identified or identifiable individual. Any unique identifier(s) received or obtained by Full Circle that are linked to an identified or identifiable individual will be protected in accordance with this Privacy Notice.

WITH WHO DOES FULL CIRCLE SHARE PERSONAL DATA?

Full Circle will not make your Personal Data available to any third party without your consent, unless it is required by law, as further specified below.

If a survey or other market research program or other activity includes making Personal Data available to a third party, Full Circle will only share your Personal Data with your consent. If data collected is used statistical modeling to better understand trends and preferences amongst specific groups or audiences within the general population, only limited Personal Data shared will be used only for market research purposes and again only with your consent.

Full Circle may disclose your Personal Data, profiling data, or other research data to third parties as follows:

  • in connection with market research services (including our incentives programs), to our agents, contractors or Partners that facilitate such services; provided, however, such parties are restricted from using your Personal Data in any way other than to provide services to Full Circle;
  • with agents, contractors or Partners of Full Circle in connection with services that these individuals or entities perform for, or with, Full Circle. These agents, contractors or Partners are restricted from using this information in any way other than to provide services for Full Circle. Full Circle may, for example, provide Personal Data to agents, contractors or Partners for hosting our survey websites, for data collection or processing services, or for sending you information that you requested, but those parties cannot use your Personal Data for their own purposes unrelated to the work they are doing for us;
  • with Clients of Full Circle, but in these cases your Personal Data will only be shared with Clients: i) with your consent, or ii) for permitted research purposes in accordance with the codes of the Insights Association and ESOMAR.
  • in connection with the request or requirement of any lawful request by public authorities, to meet national security or law enforcement requirements;
  • pursuant to required legal process, to the related compelling party;
  • when Full Circle believes that disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with suspected or actual illegal activity;
  • In connection with the sale, assignment, or other transfer of Full Circle, in which case Full Circle will require any such buyer to agree to treat Personal Data in accordance with this Privacy Notice. In the event that a sale, assignment, or other transfer of Full Circle is not consummated with a prospective buyer, Full Circle will require the third party not to use or disclose your Personal Data in any manner whatsoever and to completely erase the same; or
  • as otherwise authorized by you.

Full Circle may license certain limited Personal Data to third parties (e.g., data brokers, data aggregators, etc.) for market research purposes, including, but without limitation, the licensing of individual-level and/or aggregated-level data (e.g., product and/or service purchasing or usage activity, website visitation data, internet search history, etc.) for the development of audience insights and/or look-alike models, for the purpose of sale of such data to the third party’s customers for the purpose of performing analytics and providing marketing intelligence. This information may be shared via a cookie (cookie ID), a mobile advertising identifier, an email address or other method. After look-alike modeling or aggregation have been performed, Personal Data is deleted.

Additionally, identifying information and information collected by automated means may be provided to third parties, including, without limitation, Clients, Partners, agents and/or vendors for the purposes of identifying respondents for re-contact surveys or communications, fraud detection and/or prevention, database matching, data validation, data append, coding, data segmentation, and reward, incentive, and/or sweepstakes or promotion related services.

Full Circle may maintain Personal Data or machine identifiable information in order to satisfy your requests and/or Full Circle’s business requirements. For instance, Full Circle may retain the email address of Participants who opted out to ensure Full Circle conform to any such wish. Any retention Personal Data is done in compliance with applicable laws and regulations.

Again, Full Circle will only share your personal data with your consent.

DO WE COLLECT INFORMATION FROM CHILDREN?

Full Circle does not knowingly collect Personal Data from children below the age where parental consent is required. If Full Circle becomes aware that Full Circle has inadvertently collected Personal Data from a child below the age where parental consent is required, Full Circle will use delete such Personal Data from our database.

EARNING VIA OUR REFER-A-FRIEND PROGRAM

The purpose of our Refer-a-Friend Program is to grow our panels and communities; and reward you with additional incentives for helping us do so. If you submit friends' and family members' email address to us, we send those addresses one (1) email invitation to join us. We will not disclose these emails to any third parties. We will not send any additional emails to the referred email addresses unless they opt-in to a panel.

COMMUNICATING WITH MEMBERS OF OUR COMMUNITIES

If you participate in one of our research communities, our invitations to participate in research as well as service-related notices will be sent to you via a variety of electronic methods, including email, social media and SMS. You will be able to to select the method(s) of communication you prefer.

WHAT SAFEGUARDS HAVE WE IMPLEMENTED TO HELP ENSURE THE SECURITY YOUR PERSONAL DATA?

The security of your Personal Data is very important to us. We have put in place reasonable physical, electronic, and administrative procedures to safeguard the information we collect.

Only those employees who need access to your information in order to perform their duties are authorized to have access to your Personal Data.

We cannot guarantee that all communications between us or information stored on our servers will be free from unauthorized access by third parties such as hackers, and your use of our services demonstrates your assumption of this risk.

HOW CAN YOU REVIEW YOUR PERSONAL DATA THAT WE HAVE COLLECTED, USED OR DISCLOSED?

We will make available to you Personal Data in our custody or control that we have collected, use or disclosed, upon your written request, to the extent required and/or permitted by law. You have the right to review, correct, or delete your Personal Data, subject to applicable laws and regulations. Specifically:

  • Right of access — You have the right to obtain confirmation and information about the processing of your Personal Data
  • Right to rectification — You have the right to have any inaccuracies about your Personal Data corrected
  • Right to erasure — You have the right to have your Personal Data deleted (this right is limited to data which according to law and regulation may only be processed with your consent, if you withdraw your consent for processing)
  • Right to restriction of data processing — You have the right to require that the processing of your Personal Data be restricted (during the course of any investigation into honoring your request, Cint’s access your Personal Data will be limited)
  • Right to data portability — You have the right to have your Personal Data transferred to another party (this right is limited to data provided by you)

To request access to Personal Data that we hold about you, we require that you submit your request in writing at the e-mail address or postal address shown below in the Contact section. When we receive an access request from an individual, we will attempt to fulfill the requested information within 30 days, including requests regarding the Personal Data we have in our possession or control about the individual, what it is being used for, and to whom it has been disclosed, if applicable.

HOW DO YOU KNOW THAT THE PERSONAL DATA WE HAVE ON YOU IS ACCURATE?

Full Circle makes reasonable efforts to keep Personal Data in its possession or control accurate and complete, based on the most recent information available to us. If you believe your Personal Data is inaccurate, you can demonstrate in writing the accuracy or completeness of the Personal Data we have on you by emailing privacy@ilovefullcircle.com. If you successfully demonstrate that the Personal Data we have on you is inaccurate or incomplete, we will amend as required.

HOW DO I OPT-OUT OF SURVEYS OR OTHER RESEARCH PROGRAMS?

Your decision to participate in a survey or other research program, respond to any specific survey question or provide Personal Data or Sensitive Personal Data, will always be respected. You may choose whether or not to participate in a particular survey or research program or discontinue participation at any time. However, failure to provide certain information or fully participate in a particular survey may preclude you from receiving incentive compensation or participation in future certain research studies.

If you decide not to participate in a survey or other research program, you can click the unsubscribe hyperlink within the e-mail and you will no longer receive survey or other research program invitations. You can also e-mail us at privacy@ilovefullcircle.com.

INFORMATION FOR CITIZENS OF THE EU AND SWITZERLAND ABOUT CROSS-BORDER TRANSFERS

Privacy Shield complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. Full Circle has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

In compliance with the EU-US and Swiss-US Privacy Shield Principles, Full Circle commits to resolve complaints about your privacy and our collection or use of your personal information. European Union and Swiss individuals with inquiries or complaints regarding this privacy policy should first contact Full Circle at:

Privacy Compliance Officer
Full Circle Research
11701A Falls Road
Potomac, MD 20854

Full Circle has further committed to refer unresolved privacy complaints under the EU-US and Swiss-US Privacy Shield Principles to the INSIGHTS ASSOCIATION PRIVACY SHIELD PROGRAM, a non-profit alternative dispute resolution provider located in the United States and operated by Insights Association. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://www.insightsassociation.org/get-support/privacy-shield-program/privacy-shield-eu-swiss-citizens-file-complaint for more information and to file a complaint. These dispute resolution services are available at no cost to you.

Full Circle is under the enforcement authority of the Federal Trade Commission. Full Circle recognizes that under certain limited conditions, individuals may be able to invoke binding arbitration before the Privacy Shield Panel to be created by the U.S. Department of Commerce and the European Commission.

Full Circle recognizes its potential liability in cases of onward transfer to third parties.

LINKS TO THIRD PARTY WEBSITES

This Privacy Notice applies solely to surveys and other research programs operated by Full Circle, and not to any other product or service. This website may contain links to a number of third party websites that we believe may offer useful information. The policies and procedures we described here do not apply to those websites. We recommend that you carefully read the privacy notices or policies of each site that you visit for information on their privacy, security, data collection and distribution policies.

CONTACT US

We value your opinion. If you have questions, comments or suggestions, or if you would like to opt-out of our surveys or other research programs, please contact us at privacy@ilovefullcircle.com or via mail at:

Full Circle Research
11701A Falls Road
Potomac, MD 20854