Privacy Policy

Toluna Group Limited and any of its worldwide subsidiaries and affiliates ("We" "Our" "Us" or "Toluna") are committed to protecting and respecting your privacy.  This privacy policy describes we collect, use, share and secure the personal information you provide to us and also describes the choices available to you regarding our use of your personal information and how you can access and update this information.

Our privacy commitment to you

Toluna is an online data collection group focused on providing high quality data to our clients who are mainly in the market and marketing research industries, as well as being in other many other business sectors. We build and maintain large online consumer panels, providing real-time digital consumer insights to our clients via our market research survey and analytics platforms. You can be assured your privacy and the confidentiality of your information is of the utmost importance to us. All of the data we collect via our research studies are provided to our clients in aggregate form i.e. information is provided about groups of individuals and not on an individual level. Personal information about you would only be provided to our clients in specific research studies and we would never provide your personal information to our clients unless we have first received your consent. All personal information you do provide to us is held securely, in confidence and in accordance with the terms of this Privacy Policy.

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 Tiny Prints Voice 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 information (e.g. name, postal/email address, etc.) is also used for the purposes of incentive fulfillment. When incentive points are deposited in your account and you wish to redeem them or you are determined as the winner of physical gift card in a sweepstakes, 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 checks 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 support@tinyprintsvoice.com.  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 support@tinyprintsvoice.com.

EU-U.S. Privacy Shield Framework

Toluna, (including its USA based company Toluna USA Inc.,) recognizes 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.

Binding Arbitration

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 panelists, 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.

Sharing

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.

The Use of Cookies on the Community website

We use cookies on our website to distinguish you from other users of the website, helping us to provide you with a good experience when you browse our website and allowing us to improve our site.

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 analysis 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 modeled information. "Modeled information" is data developed based upon demographic and behavioral 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. 

Log Files

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 general, digital Fingerprinting technologies assign a unique identifier or "Machine-ID" to a user's computer to identify and track your computer.  We will not use digital fingerprinting technology (the "Technology") to collect your personal information, or track your online activities; and will not disrupt or interfere with the use or control of your computer or alter, modify or change its settings or functionality. Occasionally, in specific market research programs, we w/ill use the Technology to assist our clients in ensuring the integrity of survey results. The Technology will analyse publicly available information and data obtained from your computer's web browser and from other publicly available data points, including the technical settings of your computer, the characteristics of your computer, and its IP Address, to create a unique identifier, which will be assigned to your computer. The unique identifier will be an alpha-numeric ID  In order to assist our clients in protecting and ensuring the integrity of survey results, we may; (a) link or associate your unique identifier to you and any of your Personal Information; (b) share your unique identifier with our clients and with other sample or panel providers; and (c) receive or obtain a unique identifier linked to you from a third party, including without limitation a sample or panel provider or our client, however we will only provide such information to any third parties (including our clients) on an aggregated and anonymised basis.  In addition, any unique identifier(s) received or obtained by us and linked to you will be protected in accordance with this privacy policy and if required by law, we will ask for your consent in advance.

We shall do everything we can to ensure that the Technology is safe, secure and does not cause undue privacy or data security risks and we shall use and distribute the Technology in a professional and ethical manner and in accordance with (a) this privacy policy, (b) any other statements and/or disclosures made by us to you and (c) applicable laws and market research codes of practice.

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

The Community Website may include social media features, such as the Facebook Like button (and widgets, such as the Share this button or interactive mini-programs that run on our site). These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on the Community website. Your interactions with these features are governed by the privacy policy of the company providing it. 

Access to Your Information; Member Services Area/Update, Correct, Delete Information

Upon request, Toluna will provide you with information about whether we hold any of your personal information. You may access, update or correct any of your information by clicking on Your Profile after logging in. By following the appropriate directions, your information should be automatically updated in our database. For these purposes, and if you are unable to correct your personal information yourself via your Community Account you may write to us at the postal address found at the end of this Privacy Policy, or contact us by email at support@tinyprintsvoice.com. We will respond to all requests within a reasonable timeframe.

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.

Opt-Out Policy

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.

Delete/Deactivate policy

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 support@tinyprintsvoice.com 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 finalized. 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.  

Winners Policy

Community members are randomly selected to win prizes for participation in surveys, polls, and other promotions. All winners are notified by email of their winnings. For more information, please visit our Terms and Conditions page. Toluna shall post the usernames or first name and first initial of last name of winners on the Reward Page or communicate them via newsletter to all panelists.

Notification of changes

If we decide to change our privacy policy, we will post those changes to this privacy statement on the home page, or other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.

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. 

Security

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.

Links

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. 

Single Sign-On

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. 

Legal disclaimer

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. 

Children's privacy

Toluna will not knowingly collect any information from any child under the age of 14 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. 

Privacy contact

The Privacy Officer:


Privacy contact:
Privacy Officer
Toluna USA Inc.
21 River Road
Wilton, Connecticut 06897
USA
E-Mail: support@tinyprintsvoice.com

 

Last Updated: January 2017