Effective Date: 30 November 2020
Last Revised: 30 November 2020
This Privacy Notice applies to Full Circle Research (“Full Circle”) and all of Full Circle’s online market research panel communities and sample sources including but not limited to, Survey Roundtable. This Privacy Notice defines how Full Circle collects, stores, uses and discloses your "personal data" or "personal information" (as defined below). Full Circle will, and will cause its affiliates to, establish and maintain business procedures that are consistent with this Privacy Notice.
Headquartered in Potomac, MD, we strive to make our website, including this Privacy Notice, accessible to individuals with disabilities. If you are having trouble accessing the this website or this Privacy Notice, please contact us as provided in the “Contact Us” section below.
This privacy notice constitutes a binding agreement between you and Full Circle. Your use of our website or services, or your participation in research, constitutes your consent to the terms of this privacy notice..
WE PROTECT YOUR PRIVACY
Full Circle is a leading market research company. Full Circle is strongly committed to the protection of privacy and security of "personal data” or “personal information” (referred to in this Privacy Notice as “Personal Data”) and conforms its privacy and security practices to applicable laws, and regulations, including, without limitation, the California Consumer Privacy Act (“CCPA”) and the General Data Protection Regulation (“GDPR”). Full Circle strives to conform its privacy and security practices to with the codes of standards of applicable market and opinion survey research associations, including, without limitation, ESOMAR (www.esomar.org) and the Insights Association (www.insightsassociation.org).
WHAT PERSONAL DATA DO WE COLLECT AND PROCESS?
As used in this Privacy Notice, Personal Data means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked with a particular data subject, consumer, or household. Personal Data includes information such as real names, postal addresses, email addresses, and social security numbers.
Personal Data may also include unique identifiers, IP addresses, biometric information, internet or other network activity (such as browsing history, search history, etc.), geolocation data, audio/visual data, and even inferences which may be drawn from any of the above to create a profile about a data subject or consumer.
We may collect Personal Data for the purpose of conducting market research, as expressly stated and agreed to by you, and as otherwise provided in this Privacy Notice. Personal Data collected in connection with market research includes participant names; email addresses; postal addresses; phone numbers; IP addresses; browser fingerprints; device ID; unique identifiers; cookies; geolocation data; web beacons; demographic data, such as age, gender, race/ethnicity, parental status, marital status, postal code, income and education levels; and other information collected through automated means, as described below.
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.
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, union membership, political opinions and religious or philosophical beliefs. If Full Circle collects your Sensitive Personal Data, Full Circle will always obtain your explicit consent.
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 or other sample source;
- 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.
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.
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.
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.
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.
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 ESOMAR and the Insights Association;
- 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 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 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 FullCirclePrivacy@ilovefullcircle.com.
INFORMATION FOR CALIFORNIA RESIDENTS
Personal Data We Sell or Disclose
CCPA defines the term “sell” broadly. Its meaning includes “renting, releasing, disclosing, disseminating, making available, [and] transferring…for monetary or other valuable consideration.”
Under this definition, and the CCPA’s broad definition of “personal information” (again referred to in this Privacy Notice as "Personal Data"), we may “sell personal information” about you to our clients or other collaboration partners, such as your contact information or certain combinations of anonymized or pseudonymized demographic and other information.
Under the CCPA’s definition, we’ve “sold” the following categories of information to our clients: demographic data, such as age, gender, race/ethnicity, parental status, marital status, postal code, income and education levels.
We’ve otherwise disclosed the following categories of information, subject to confidentiality restrictions, to our third-party service providers as strictly necessary for them to provide services to us: participant names; email addresses; postal addresses; phone numbers; IP addresses; browser fingerprints; device ID; unique identifiers; cookies; geolocation data; web beacons; demographic data, such as age, gender, race/ethnicity, parental status, marital status, postal code, income and education levels; log files, including Internet Protocol (IP) address, browser type, browser language, the date and time of your request, operating system, referring/exiting pages, and clickstream data; browsing information, such as date and time you visited our website(s), 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 research programs; respondent photos, video, and audio; and social media information (e.g., handles, basic information available on profiles).
When you participate in one of our surveys or research programs, the information you provide or is otherwise collected may be combined with the information of other participants and reported as part of aggregate results. Additionally, the information you provide or is otherwise collected may be used in statistical modeling to better understand trends among the general population. When such statistical modeling is performed, your Personal Data will not be released.
We will not make your Personal Data available to any third party without your consent or required by law, as further specified below.
Notice to California Residents
If you are a California resident, you also have the following special rights:
- Your Right to “Know” and to Request Deletion
You have the right to know the categories and specific pieces of Personal Data 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 have the right to request deletion of personal information we’ve collected or maintain.
To exercise these rights contact us at 877-416-6355 or by filling out the following webform. We may ask you to provide additional information, such as name and email address 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 of the “Sale” of Your Information
You have the right to opt out of the sale of your personal information. For more information on how to opt out, please click here.
- Your Right to Non-Discrimination
You have the right not to receive discriminatory treatment by Full Circle 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. Please understand, however, that we are in the business of providing market research services to our clients, and any financial incentives we offer to facilitate that goal may be rewarded only if the applicable survey, research project or study is fully and properly completed by the respondent, in the sole discretion of Full Circle.
- 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.
- Verification Process
If you make a request to access or delete your information, or to opt out of the sale of your personal information, we may ask you for additional information to verify your identity. This information may include: your full name, birth date, phone number, email address, or other basic personal information about you that we already have on file.
- Notice of Financial Incentive
Full Circle may offer opportunities for you to earn money and rewards by completing survey or research programs. Participation in these offerings may require you to provide Personal Data. For more information about how to opt in to these offerings, or about how to opt out once you have opted in, see the notices and official rules accompanying these incentives.
INFORMATION FOR CITIZENS OF THE EU AND SWITZERLAND ABOUT CROSS-BORDER TRANSFERS
Consent for Cross-Border Data Transfers
Your Personal Data may be transferred to recipients in countries other than the country where you are located, including to the United States where Full Circle is headquartered. These countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your Personal Data to other countries, we will protect that information as described in this Privacy Notice or as disclosed to you at the time of the collection.
If you are located in the European Economic Area or Switzerland, we comply with applicable legal requirements providing adequate safeguards for the transfer of Personal Data to third countries.
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.
Notice to EU Residents
You have the right to review, correct, or delete your Personal Data. 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, Full Circle’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)
If you want to exercise any of your rights, you may contact us with such a request please contact us at FullCirclePrivacy@ilovefullcircle.com or via mail at:
Full Circle Research
11701A Falls Road
Potomac, MD 20854
NON-EU/NON-SWISS CITIZENS, NON-CALIFORNIA RESIDENTS
Full Circle commits to resolve complaints about your privacy and our collection or use of your Personal Data, Non-EU/Non-Swiss citizens and U.S. citizens not in California with inquiries or complaints regarding this Privacy Notice should contact Full Circle at FullCirclePrivacy@ilovefullcircle.com or via mail at:
Full Circle Research
11701A Falls Road
Potomac, MD 20854
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.
CLASS ACTION WAIVER
Any arbitration or court trial, related to any claim under this Privacy Notice, whether before a judge or jury or pursuant to judicial reference, will take place on an individual basis, without resort to any form of class or representative action (“Class Action Waiver”). THIS CLASS ACTION WAIVER PRECLUDES ANY PARTY FROM PARTICIPATING IN OR BEING REPRESENTED IN ANY CLASS OR REPRESENTATIVE ACTION REGARDING A CLAIM UNDER THIS POLICY. Regardless of anything else herein, the validity and effect of the Class Action Waiver may be determined only by a court and not by an arbitrator. THIS CLASS ACTION WAIVER IS VOID WHERE LIMITED OR PROHIBITED BY LAW.
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 FullCirclePrivacy@ilovefullcircle.com or via mail at:
Full Circle Research
11701A Falls Road
Potomac, MD 20854