Privacy Policy

PRIVACY POLICY

Updated as of January 1, 2020

Escalent, Inc. and its affiliates (collectively, “Escalent”, formerly known as Market Strategies International-Morpace) is committed to protecting the privacy of our clients and research participants.

We make our website, including this privacy policy, accessible to individuals with disabilities. If you are having trouble accessing the website or this privacy policy, please contact us as provided in the “Contact Us” section below.

This privacy policy applies to all client and personal information that we collect or use in the course of conducting our business, as well as all client information and research participant data housed at any Escalent facility or stored on the Escalent network. Anyone who has access to such information or data must follow this privacy policy.

This Privacy Policy constitutes a binding agreement between you and Escalent. Your use of our website or our services, or your participation in research, constitutes your consent to the terms and conditions in this Privacy Policy.

Client Information

We treat all information we receive from clients as confidential and do not use the information for any purpose other than to fulfill our obligations to them. We keep client information secure at all times, and prevent the misuse and unauthorized disclosure of it by our employees or any third parties.

Research Participant Information

In order to provide our services to clients, we may employ the use of client contact lists which would contain personal information such as names, email addresses, phone numbers, and mailing addresses. On studies involving European citizens or other individuals covered by the General Data Protection Regulation (“GDPR”), client contact lists or other personal data will only be processed in accordance with the parameters described with more particularity in the “EU-U.S. Privacy Shield” section below.

All responses to our research are completely confidential. We collect data in our studies for research purposes only, and our use of that information will be limited to that purpose. Research participant answers will not be used by any entity as an aid for sales.

Research participation is voluntary, and sample members always have the opportunity to decline involvement or to “opt out” of the research after agreeing to participate.

Your Personal Information

Under a number of privacy laws, “personal information” includes information like real names, addresses, and social security numbers. Under recent laws like the GDPR and the California Consumer Privacy Act (“CCPA”), “personal information” 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 consumer.

We may collect personal information for the purpose of conducting market research, as expressly stated and agreed to by you, and as otherwise provided in this privacy policy.

In the previous 12 months, we’ve collected, used, and shared personal information as described below:

Info Collected Sources of Info Business Purposes Shared With
Respondent names, email addresses, IP addresses, unique identifiers Respondents, third-party sample providers; clients; other collaboration partners Survey follow-up; communicating with you; newsletters; advertising survey opportunities; validating Respondents’ identities (data quality) Vendors (e.g., as required for secure database management, recruiting, and honoraria distribution)
Demographic data, such as age, sex, race/ethnicity, parental status, marital status, ZIP code, income and education levels Collected directly from respondents; clients; third-party sample providers Use in research results (e.g., aggregate survey results, survey insights, etc.) Clients; Data collection partners
Log files, browser type, operating system, and other device information Collected directly from online users; received in aggregate form from third-party service providers Analyzing web traffic and survey usage, optimizing survey platforms for different operating systems Third-party service providers; Clients (anonymized or aggregate only)
Respondent photos, video, and audio Collected with permission directly from respondents during the course of research studies Communicating research insights Clients; Vendors (e.g., focus group facilities);

Contractors (e.g., focus group moderators, videographers)

Business partner employee names, addresses, phone numbers, and email addresses Collected with permission directly from our business partners Administration of our business relationships with clients and vendors/suppliers Third-party service providers, under confidentiality agreements
Social media information (e.g., handles, basic information available on profiles) Collected when you interact with us or our Sites using social media platforms Interacting with Clients and respondents Third-party service providers
Biometric information and geolocation data Collected with permission directly from respondents Use in research results (e.g., behavior patterns, ad effectiveness) Clients; Data collection partners
Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. Clients; collected with permission directly from respondents during the course of research studies Use in research results (e.g., aggregate survey results, survey insights, etc.) Clients; Data collection partners

Personal Information We Sell and 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,” 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.

Categories of information we’ve “sold” in the previous 12 months include: demographic data, such as age, sex, race/ethnicity, parental status, marital status, ZIP code, income and education levels; Respondent photos, video, and audio; and other anonymized or aggregated information from research and survey results.

Categories of information we’ve otherwise disclosed for a business or commercial purpose (for example, for confidential use by our service providers) in the previous 12 months include: the above categories of information we’ve “sold,” as well as log files, browser type, operating system, and other machine information.

We do not rent, sell or give personal information to any third party for the purpose of directly marketing any products or services. In some cases, we may need to share personal information with third parties that provide research services in support of the research project. Any third party that receives personal information is obligated to follow all of the same privacy protection regulations as followed by Escalent.

At their request, we give research participants access to the personal information we have collected about them. We correct any information that is inaccurate or incomplete, change their consent status, or have their personal information deleted.

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 information 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) 631-3505 or by filling out this webform link. We may ask you to provide additional information 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 Escalent 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 research and survey results 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 Escalent.

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

Escalent may offer opportunities for you to earn money and rewards by answering surveys or any other forms of research. Participation in these offerings may require you to provide personal information. 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.

Other Sharing of Information

In addition to the sharing discussed above, we may also share your information in the following ways: (a) as reasonably necessary to comply with law or a legal process (including a court or government order or subpoena), to detect, prevent, or otherwise address fraud, security or technical issues, to enforce this privacy policy, and to protect the rights, property or safety of Escalent, our users, and/or the public; (b) if we sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a corporate transaction such as a merger, consolidation, acquisition, reorganization or sale of assets or in the event of bankruptcy, in which case we will make reasonable efforts to require the recipient to honor this privacy policy; or (c) with your express consent.

Cookies

A cookie is a small amount of data that is sent to your browser from a web server and stored on your computer’s hard drive. As part of offering and providing customizable and personalized services, we may use cookies to store and sometimes track information about you. Cookies which may be utilized by Escalent are within the following four primary categories or uses:

  1. Business cookies which operate as a quality control and verification mechanism in connection with the survey process
  2. Performance cookies so that traffic patterns and uses on the website may be measured and optimized
  3. User cookies so that user information may be recorded so as to enhance performance and user experience on the website
  4. Targeting cookies that measure web-viewing for market research purposes

For more information about how to control what cookies are placed on your computer and to manage your browser’s opt outs, visit: http://optout.networkadvertising.org/

Children

We do not knowingly collect personal information under any circumstances from anyone under the age of thirteen (13), and if we become aware that we have inadvertently collected personal information from anyone under this age threshold, we will promptly delete such information.

Opt-Out Policy

If you wish to be removed from Escalent email or phone contact lists, please complete our Do Not Contact form.

Information Security

We maintain all necessary physical, electronic and procedural security measures to help safeguard client data and personal information. All of our employees undergo security awareness at the time of hire and then annually thereafter. Third parties that provide us with support or services may also receive client data or personal information, and we require them to maintain security measures similar to ours with respect to such information. Nevertheless, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. If any information under our control is compromised, we will take reasonable steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised, and also take other steps as necessary in accordance with any applicable laws and regulations.

Data Integrity

Escalent will take reasonable steps to ensure the personal data is accurate, complete, current and relevant, and is used only as described in the “Data Retention” section below. While we accept responsibility for the management and confidentiality of the personal information collected, please note that we do not always have control over the accuracy of the information provided directly to us, and accept no responsibility for information’s accuracy in such cases.

Data Retention

In general, to determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. We may also process data on behalf of third parties who have engaged us. We keep personal information processed on behalf of third parties for as long as needed to provide services to the third party in question. Notwithstanding anything above to the contrary, we reserve the right to retain personal information for any period required by law or to comply with our legal obligations, resolve disputes, and enforce our agreements.

Third Parties

Our website may contain links to external websites, and areas where you can provide information to third parties. These are provided for your convenience only, and we do not have control over the content or privacy and security practices and policies of such third parties or third-party sites. Any personal information you provide in such areas, and on such linked pages, is provided directly to that third party and is subject to that third party’s privacy policy. Please learn about the privacy and security practices and policies of external websites and third-parties before providing them with personal information.

EU-U.S. Privacy Shield

Escalent complies with the EU-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 the United Kingdom to the United States. Escalent has self-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, please visit https://www.privacyshield.gov/.

For a list of all certified parties, and to view our certification, visit https://www.privacyshield.gov/list.

In compliance with the Privacy Shield Principles, Escalent commits to resolve complaints about our collection or use of your personal information. Individuals in the European Union (EU) with inquiries or complaints regarding our Privacy Shield policy should first contact Escalent at privacy@escalent.co.

Escalent has further committed to cooperate with EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact the EU DPAs for more information or to file a complaint. The services of EU DPAs are provided at no cost to you.

Escalent may be required to disclose personal information in response to a lawful request by public authorities, including meeting national security or law enforcement requirements. Under certain limited conditions, individuals may invoke binding arbitration before the Privacy Shield Panel created by the U.S. Department of Commerce and the European Commission.

Any data to be transferred for any reason is limited and for specified research purposes only. Any vendors or third parties working with or for Escalent are contractually obligated to comply with Escalent guidelines for confidentiality and data security, and in compliance with Insights Association requirements. When transferring data to a third party, such third parties are obligated to maintain at least the same level of privacy protection as required by Privacy Shield. In any case of onward transfer to third parties, Escalent is potentially liable unless it can be proven that we are not responsible for the event giving rise to the damage.

Escalent strictly abides by Insights Association Code of Conduct. You can opt out of any and all participation at any time with no penalty or hesitation. Your participation is entirely voluntary. If you wish to be removed from Escalent’ email or phone contact lists, please complete our Do Not Contact form. If there’s an opportunity to participate in a research activity that does not include surveys, and if this opportunity includes any sort of media or self-identification, you will always be asked for permission to participate in said activities prior to collection of data. You can continue participation in other research activities and choose not to participate in anything that identifies you in special research requests, with no penalty or hesitation. All participation is by permission only. You may discontinue your participation in research with Escalent at any time. Any communication requesting participation by others in the household will be clearly communicated to the primary research participation, with no requirement for participation.

We will not process your personal data unless: (a) you have given your consent to our processing for a specific purpose; (b) processing is necessary for the performance of a contract with you or to comply with a legal obligation; or (c) processing is necessary for the purposes of the legitimate interests pursued by Escalent or a third-party controller. In cases where the purpose of our processing is the “legitimate interest” purpose, we will also carefully balance those interests against your fundamental rights and freedoms related to your Information. Where processing is based on your consent, we will identify the processing purposes and provide you with relevant information to make the processing fair and transparent.

Do Not Track Signals

We do not monitor or follow “Do Not Track” (DNT) signals because there is no standard interpretation or practice for DNT signals. Therefore, we handle all user information consistent with this Privacy Policy. We will never use browsing activity information from our survey respondents or other website visitors to provide or offer third party advertising content. We will treat any “do not sell” or similar signals as opt-out requests under CCPA.

Compliance, Data Protection Officer

As members of the Insights Association and European Society of Opinion and Marketing Research (ESOMAR), we strive to model our policies according to those guidelines. As a company based in the United States, and being Privacy Shield certified, Escalent is also subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). If you are concerned about our use of personal or client information, please contact us by email at privacy@escalent.co.

If you are a citizen of the European Union and would like to contact our Data Protection Officer, please email dataprotectionofficer@escalent.co.

Changes in the Privacy Policy

We reserve the right to modify this privacy policy at any time. If we decide to change our policy, we will prominently post those changes here and any other place we deem appropriate, so you are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If we make any material changes, we will notify you either by way of an email or by a notice on our website. We will use information in accordance with the policy as it was in effect at the time information was collected.

Class Action Waiver

Any arbitration or court trial, whether before a judge or jury or pursuant to judicial reference, related to any claim under this privacy policy 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 PRIVACY 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.

Legal Obligations

Under certain circumstances permitted or required by law (for example, in connection with law enforcement investigations), we may be required to disclose client data or personal information without giving notice.

Contact Us

17430 College Parkway
Livonia, MI 48152

P: 734.542.7600
F: 734.542.7620

privacy@escalent.co

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