- when you visit our website(s);
- when you have downloaded and installed one of our Applications onto your mobile phone or tablet device (“mobile device”);
- when responding to one of our online or email surveys or questionnaires; or
- when using one of our products or services, (together, our “Services”).
We may also receive information about you from any business or organisation to whom we are providing services (our “Clients”) so that they can better understand consumer behaviour, or with whom we are working to develop, distribute or market a particular product or service (our “Partners”).
If we tell you that you are taking part in a market research survey or market research project, we will make sure that your data will only be used for research purposes, you will not be identified as an individual and no sales approach will be directed at you personally as a result of providing your information. If it is not for market research we will make it clear that the data is being collected to help our client improve the service provided to you personally and this may result in a sales approach.
Our Role and Our Clients’ Role
In certain situations, we may be asked to collect or process information about you by our Clients. In those cases, we will be acting in accordance with the instructions and requirements of those Clients, and are required to comply with their directions as to how they want us to use your information, subject always to applicable laws, and the terms of any assurances they have given you about privacy.
If you are using one of our Applications, then it’s also important that you read the relevant Terms and Conditions contained within that Application, which set out the legal terms on which that Application is made available to you, including the extent of your and our rights, obligations and liabilities.
What information do we collect and what do we use it for?
We collect and process a range of information about you (together, the “Information”):
- Biographical Information such as your name, telephone number, email address, date of birth or gender that you provide to us or our Client or Partner directly. We use this information to create and maintain a profile of you so that we can keep track of the other Information you provide us with (such as Survey Information or Mobile Usage Information), and also so that we may contact you from time to time in relation to installing, removing or administering one of our products or Applications. Where you have agreed, we, our Clients and our Partners may contact you from time to time with marketing information about various products and services which you might be interested in. Such contact may be via email, telephone call, text message or push notifications in one of our Applications. You can opt out of receiving such marketing information at any time by following the instructions contained in such email or text message, by emailing us at email@example.com. You can disable in-app push notifications using the settings on your mobile device.
- Survey Information which refers to responses you provide to surveys and questionnaires that we may send to you from time to time. Because we carry out surveys for a range of Clients and Partners who are interested in a diverse range of topics, this Survey Information could include a wide range of personal information that you choose to provide. This Survey Information is used by us, our Clients and our Partners to analyse your responses and identify your preferences with regard to products and services.
- Mobile Usage Information, which refers to information about your use of your mobile device which we are able to collect if you have downloaded and installed one of our Applications on your device. Please note this information is collected and transmitted to us ‘in the background’, and does not require any further activation on your part. We call this ‘passive tracking’. This information can include the following:
- Information about the time and duration of calls you make or receive on your mobile device. We do not collect or record the content of your calls.
- Information about when you send or receive text messages, SMS or MMS. We do not collect or record the content of your text messages or MMS.
- Information about emails that you send on your mobile device – the time they are sent and how long you spend composing emails. We do not collect or record the content of your emails.
- Information about your location (please see below).
- Information about your internet browsing habits – how much time you spend browsing the internet on your mobile device, the websites you visit, and the terms of any search you carry out.
- Whether people you call, email or send SMS or MMS to are already in your ‘Contacts’ in your mobile device.
- Information about the type of mobile device you own, when and for how long you charge it, its battery status, whether it is switched on, off or in a stand-by or ‘Airplane’ mode.
- Information about which mobile network you use, which wi-fi networks you connect to, and at what times.
- Information about the volume of data downloaded to your mobile device, the times that you download that data and the method of connection you use (wi-fi or mobile network).
- Information about your usage of other apps on your mobile device, including the identity of the apps, when you downloaded them, how often you use them and how long for
- Information we can deduce from combining the above information – e.g., what apps you were using just before you searched for particular information using your mobile device’s internet browser, or how often you call, email or text a particular contact, or the geographic location in which you are most likely to charge your device, make a telephone call, or download an app.
- Location Information, meaning data which reveals the geographic location of you and your mobile device, where you have given us your consent to collect such information. When you first download one of our Applications, you will be asked if you agree to your location information being disclosed to us. If you consent, then we will collect and transmit this information on a semi-continuous and passive basis, which does not require any further activation on your part. If you wish at any stage to turn off this passive location tracking, you can restrict this in most smartphones under location settings.
- Information you provide. In some cases, we may ask you to send video, audio or image content to us. That content may include personal information, for example in the form of an identifiable image of you.
- Sensitive personal information. Although we do not actively seek out sensitive information about you (such as information relating to your health, ethnicity, religious beliefs or sexuality), some of the other information we collect may allow us to deduce sensitive information about you. For example, if you conduct an internet search on a particular medical condition.
We use this Information to perform, or to provide to our Clients and Partners, data analysis services, so that trends and preferences can be identified in your behaviour and the behaviour of people who fit a similar demographic profile to you, and so that we, our Clients and Partners can assess the likely popularity of goods or services to you and people like you.
The range of Information that we or our Clients and Partners might collect about you means that a detailed profile about you can be developed. This allows us and our Clients and Partners to identify and predict trends and preferences in your behaviour, your likes and dislikes, and what kinds of products or services you might be interested in.
Information About Children
None of our applications, products and services are directed at children under the age of 13, and we do not knowingly collect information from children under 13. If we become aware that a child under 13 has provided us with personal information, we will delete such information from our systems. Parents with concerns should contact us at firstname.lastname@example.org.
You will only be asked to give your consent once, and so if at any time you change your mind and decide that you no longer want us to process your Information, you will need to contact us by writing to us at email@example.com.
Sharing Information with Third Parties
We do not disclose any Information about you to any third party for marketing, advertising or promotional purposes.
- Our Partners. We work with other companies and organisations to co-develop new technologies, carry out research programmes and campaigns, and distribute and resell each other’s products and services. In the course of that collaboration, we may share your Information with those Partners to help us fulfil those purposes, and the purposes described in this Policy.
- Service Providers. We employ third party companies and individuals to help us manage and operate computer systems, and to manage and analyse the data obtained by us (including your Information). Those third parties include, without limitation, companies who own and manage the servers and other hardware on which the Information is stored, companies who help us to develop and maintain our Services, and companies who provide analytical services in respect of the Information at our request or the request of our Client. These third parties have access to your Information only to perform these tasks on our or the Client’s behalf and are obligated not to disclose or use it for any other purpose.
- Compliance with Laws and Law Enforcement. We may disclose your Information if we believe that it is reasonably necessary to comply with a law, regulation or legal request. This may include disclosure of your Information to a law enforcement agency.
- Business Transfers. We may sell, transfer or otherwise share some or all of our assets, including your Information, in connection with a merger, acquisition, reorganisation or sale of assets or in the event of bankruptcy.
We may also compile aggregated and/or anonymised reports and profiles using Information you have provided, which we share with other third parties (including potential clients) or make publicly available generally. We take steps to ensure that you are not personally identifiable from those reports and profiles.
We take the privacy of your Information very seriously, and use a number of methods to try to keep it secure from loss or unauthorized use or access when it is in our possession or control, including reasonable physical, technical and organizational measures which restrict who may access your Information. For example, your Information is encrypted when stored or transmitted by us using secure socket technology (SSL).
Where required by applicable laws, we will notify you of any loss of or unauthorized access to your Information and comply with the appropriate regulatory authorities in investigating such incidents, in accordance with applicable laws.
International Transfers of Information
We are a global company with Partners, Service Providers and Clients operating in several countries around the world. In particular, some of our Service Providers use ‘cloud-based’ storage solutions, meaning that your Information may be transferred and stored in locations outside of your state, province or country, where the privacy laws may not be as protective as those in your jurisdiction. Our Clients and Partners may also operate in such locations, and may require that we transfer your Information to them in those locations.
Retention of Your Information
You can request that we delete any Information we hold about you at any time by emailing firstname.lastname@example.org.
We regularly audit the information we hold to ensure that it remains relevant to our current requirements, and those of our Clients.
We maintain a record of anonymised location, demographic and survey data following collection. This data is used to produce aggregated and/or anonymised reports, result and profiles, and may be used and disclosed by us for the purposes described in this Policy and to promote our capabilities as a business. You are not identifiable from this anonymised data.
How can you access and correct your information?
It’s in everyone’s interests to make sure the Information we hold about you is correct, so please let us know if you believe any changes need to be made and we will do our best to correct it. Likewise, we will delete any personal Information we hold about you on request.