Privacy Policy

Who are we?

We are ITWP Acquisitions Limited.  The ITWP group of companies incorporate Toluna and Harris (“We” “Our” “Us” or “ITWP”) are committed to protecting and respecting your privacy.  You can find a list of our Interactive worldwide subsidiaries and affiliates by clicking on the link below: http://www.toluna-group.com/en-gb/search-results/contact-us-main

The Insights On Demand Consortium

The Insights on Demand (IoD) Industry consortium is comprised of a diverse group of members from numerous industries and geographies, with the common mission to further evolve, refine, and promote new ways of insight creation and delivery. The community will be collaborating by openly sharing opinions, experiences, and even challenges with fellow members to advance the cause. The ultimate vision for Insights on Demand is democratised market research, where insights into consumer intent and behaviour are accessible and achievable for all business professionals in companies of all sizes.

Toluna

Toluna is a leading provider of real-time digital consumer insights and empowers companies to brainstorm ideas, uncover new business opportunities and answer their questions in real time. Toluna is transforming the way marketing decisions are made by bringing consumers and brands together via the world’s largest social voting community of 13+ million members across 68 countries. This real-time access to consumers is coupled with its state-of-the-art, market research survey and analytics platform. Toluna has 21 offices in Europe, North America, and Asia Pacific. For more information, please visit  http://www.toluna-group.com/

Harris Interactive Europe

Harris Interactive Europe (comprising Harris Interactive SAS in France, Harris Interactive AG in Germany, and Harris Interactive UK) is a full service, consultative custom market research agency. Working internationally from our offices, our activities span both business-to-business and consumer markets: specialising in; automotive; consumer packaged goods; energy; entertainment; financial services; healthcare; media; technology; telecoms; and travel.
We blend focused sector expertise with award winning research designs and innovative tools and approaches to deliver tailored solutions built on industry best practice. Our engagements range from tactical one-off projects to ongoing strategic tracking studies.
Harris Interactive Europe has in-house expertise covering all areas of research design, implementation, analysis, and reporting, with particular strengths in loyalty, brand and new product development. For more information about Harris Interactive Europe, please visit: http://www.harrisinteractive.fr/ http://www.harrisinteractive.de/ or, www.harrisinteractive.com/uk.
This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

  • Who are we?
  • The Insight on Demand Consortium
  • What is the purpose of this privacy notice and what is our privacy commitment to you?
  • What personal data do we collect about you?
  • How do we collect your personal data?
  • How do we use your personal data?
  • Who do we share your personal data with?
  • What cookies do we use on our sites?
  • International Transfers.
  • How do you ask a question or make a complaint?
  • What security measures do we undertake to protect your personal data?
  • What are our access, data retention and destruction policies?
  • Your legal rights if you are in the EEA
  • What are the legal bases we rely on when processing your personal data?
  • Who is the data controller?
  • Changes to the privacy notice.
  • Privacy contact details

What is the purpose of this privacy notice and what is our Privacy Commitment to you?

We respect your privacy and are committed to protecting your personal data. This privacy notice aims to give you information on how we collect and process your personal data through your use of our site www.insightondemand.org (“site”) including any data you may provide through this site when you sign up to our newsletters, purchase a product or service or take part in a competition (our “sites”).  It also explains your privacy rights and how laws that are applicable to you may protect you.
This site is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

What personal data do we collect about you?

  • Information you give us. This is information about you that you give us by filling in forms on our site or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our site, subscribe to our Consortium, including participating in discussion boards or other social media functions on our site and when you report a problem with our site. The information you give us may include your Identity data and your Contact data.
  • Information we collect about you. With regard to each of your visits to our site we will automatically collect the following information:
    • Technical data, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.
    • Information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our sites (including date and time), publications or news you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific websites feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you.

Personal data, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

      • Identity data – name (includes first, last, maiden and married names), date of birth, marital status, gender, panellist id and username.
      • Contact data – postal address, email address and telephone number.
      • Special categories of personal data – ethnic/racial origin, health, genetics, political opinion, religion, sexual orientation and sex life and biometrics (used for ID purposes).
      • Profile data - includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
      • Technical data includes internet protocol (IP) addresses, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this websites.
      • Usage data includes information about how you use our sites, products and services.
      • Marketing and Communications data includes your preferences in receiving marketing from us and our third parties and your communication preferences

Information we receive from other sources. This is information we receive about you if you use any of the other websites we operate or the other services we provide. We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers and search information providers).

How do we collect your personal data?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity data, Contact data and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • apply for our products or service;
    • subscribe to IoD Consootium or publications;
    • request marketing to be sent to you; or
    • give us some feedback.
      • Automated technologies or interactions. As you interact with our sites, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. We may also receive Technical Data about you if you visit other websites that deploy our cookies.  Please see our cookie policy https://www.insightsondemand.org/cookie-policy for further details.

How do we use your personal data?

  • Personal data you give to us. We will use your personal data:
    • to provide you, or permit selected third parties, including members of the IoD Consortium to provide you, with their insights into their thoughts, concepts and ideas on the future for market research, including providing educational resources.
    • for you to participate as a full member of the IoD Consortium, including using our forums, attending and participating in events, podcasts and webinars; and/or
    • to ensure that content from our site is presented in the most effective manner for you and for your computer.
  • We will use your personal data:
    • to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
    • to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
    • to allow you to participate in interactive features of our service, when you choose to do so; and
    • as part of our efforts to keep our site safe and secure.

Information we receive from other sources. We will combine this information with personal data you give to us and that we collect about you. We will use the combined information for the purposes set out above (depending on the types of information we receive).

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

Who do we share your personal data with?

  • You agree that we have the right to share your personal data with:
    • Any member of ITWP group of companies listed at http://www.toluna-group.com/en-gb/search-results/contact-us-main who may be acting as joint controllers or processors and who are based in countries throughout the world, including countries that are not recognised as providing equivalent protection.
    • Selected third parties including:
      • Other members of the Insights on Demand Consortium for the purposes of the Insights on Demand programs;
      • analytics and search engine providers that assist us in the improvement and optimisation of our site; and
      • Service providers acting as processors and who provide us with IT and system administration services.
  • We will disclose your personal data to third parties:
    • In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
    • If ITWP or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
    • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation in response to a lawful request by public authorities, or in order to enforce or apply our IoD Consortium Rules https://www.insightsondemand.org/membership-rules or website terms www.insightsondemand.org/terms-of-use-policy and other agreements; or to protect the rights, property, or safety of ITWP, our IoD Consortium members, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us by emailing privacy@toluna.com if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

What Cookies do we use on our sites?

We use site cookies to distinguish you from other users of our sites.  This helps us to understand the profile of our visitors, estimate visits to our site and click throughs for specific campaigns. Cookies also help us to provide you with a good experience when you browse our site and they also help to improve our sites. These cookies expire when your browsing session ends. 

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

International transfers

From time to time your personal data is transferred from an EEA country to a member of the ITWP group of companies and our trusted service providers, which may be located in a country that has not been recognised as providing equivalent protection. Toluna has put in place transfer agreements using the standard model contracts for the transfer of personal data to third parties in non-adequate countries as decreed by the European Commission.  See in the attached list of all the ITWP companies.
https://www.toluna-group.com/search-results/contact-us-main

Toluna USA Inc., - EU-U.S. Privacy Shield Framework: Our global back up and hosting service centre is located in the USA.  Toluna USA Inc., (“Toluna USA”) is a member of the ITWP group of companies and all data we use are transferred to Toluna USA for those purposes.  Toluna USA recognises that the EEA have established strict protections regarding the handling of personal data from the EEA, including requirements to provide adequate protection for such personal data transferred outside of the EEA. Toluna ensures that it provides adequate protection for the processing of certain EEA personal data about all individuals (including about you).

Toluna USA participates in and has certified its compliance with the EU-US Privacy Shield Framework administered by the US Department of Commerce ("Privacy Shield") in respect of the collection, use and retention (processing) of personal data from the EEA to the U.S.A.

Toluna USA is responsible for the processing of personal data it receives, under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf. Toluna USA complies with and had certified to the U.S, Department of Commerce that it adheres to the Privacy Shield Principles of Notice, Choice, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement, Liability and including in particular, the Accountability for Onward Transfer when transferring personal data to its third party service providers and agents. If there is any conflict between the terms of this privacy notice and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield framework and view the Toluna USA certification, please visit https://www.privacyshield.gov/list.

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. In certain circumstances, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

In compliance with the Privacy Shield Principles, Toluna USA commits to resolve complaints about its collection or use of your personal data.  EEA individuals with enquiries or complaints regarding our Privacy Shield policy should first contact the Data Protection Officer at privacy@toluna.com. 

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 complaint directly with Toluna and provided us the opportunity to resolve the issue; (2) made use of the independent dispute resolution mechanism identified under the How do you ask a question or make a complaint? Paragraph below; 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 the US Department of Commerce Privacy Shield Framework: Annex 1 (Binding Arbitration) at https://www.privacyshield.gov/EU-US-Framework.

What security measures do we undertake to protect your personal data?

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

How do you ask a question or make a complaint?

You can direct any questions or complaints about the use or disclosure of your personal data to our Privacy Contact. We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your personal data within 30 days of receiving your complaint.

If you are based outside the EEA and 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.

If you are based in the EEA and have an unresolved privacy or data use concern that we have not addressed satisfactorily, then please refer to your rights to make a complaint under the section entitled Your legal rights if you are in the EEA.

What are our access, data retention and destruction policies?

Upon request, Toluna USA will provide you with information about whether we hold any of your personal data.  You can access, correct or request deletion of your personal data by emailing us at toluna@toluna.com at any time and we will respond to your request within a reasonable time.

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

If you are a citizen or resident of the EEA, or we are processing your personal data in the EEA, in some circumstances you can ask us to delete your data: see the section entitled Your legal rights if you are in the EEA below for further information.

Your legal rights if you are in the EEA

If you are a EEA citizen or resident, you have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. This is in addition to the access right

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

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If you wish to exercise any of the rights set out above, please contact us by emailing to privacy@toluna.com

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

What are the legal bases we rely on when using your personal data?

The law on data protection in the EEA sets out a number of different reasons for which a company that is processing personal data may collect and process such personal data, including:

Consent - Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by emailing privacy@toluna.com

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us by email to privacy@toluna.com .

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Changes to our privacy notice

Any changes we make to our privacy notice in the future will be posted on this page, do please check back frequently to see any updates or changes to our privacy notice.

Privacy contact

The Data Protection Officer
Toluna SAS
5, avenue du Château
94300 Vincennes
France
E-Mail:  privacy@Toluna.com