We Toluna Holdings Limited worldwide group (“We” “Our” “Us” or “Toluna”). You can see who our group members are by clicking on the link below:

https://tolunacorporate.com/locations/

Toluna are an online data collection group focused on providing high-quality market research data to its clients who are in various business sectors, including other market research agencies and other global and corporate clients of all sizes. We also build and maintain large online consumer panels, providing real-time digital consumer insights to our clients via our market research surveys and analytics platforms.

Toluna is the controller and responsible for your personal data.  We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO at Toluna@toluna.com.

We respect your privacy and are committed to protecting your personal data. This privacy notice describes how we collect, use, share and secure personal data you provide on https://www.tolunacorporate.com https://www.samplexpress.com/ and https://www.tolunastart.com (our “site(s)”) including any data you may provide through this sites when you sign up to our newsletters, purchase a product or service or take part in a competition. It also explains your privacy rights and how laws that are applicable to you may protect you.

Your use of and access to our systems and media (“Services”) is subject to this privacy notice.

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.

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?
• What 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?
• International Transfers.
• What cookies do we use on our sites?
• What security measures do we undertake to protect your personal data?
• What are data retention and destruction policies?
• Business Transfers
• Links
• Children’s privacy
• Your rights
• How do you access your information, or update, correct or delete your information?
• How do I unsubscribe from marketing communications?
• Data retention
• How do you ask a question or make a complaint?
  • Your other rights
  • Your rights in California
  • Your rights in the EEA, Switzerland and UK
• Changes to the privacy notice and your duty to inform us of changes
• Privacy contact details
• Changes to the privacy notice.
• Privacy contact details

• Information you give us. This is information about you that you give us by filling in forms on our sites or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our sites, subscribe to our mailing lists, including participating in discussion boards or other social media functions on our sites and when you report a problem with our sites. 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 sites 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.

If you fail to provide personal data:  Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

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 (examples include; first, last, maiden and married names), your image or voice, marital status, gender and suffixes.
• 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.
• Financial data includes your company bank account and/or payment card details.
• Transaction data includes details about payments to and from you and other details of products and services you have purchased from us.
• 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 the sites.
• 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).

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 services;
• create an account on our sites;
• subscribe to our service or publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey; 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://tolunacorporate.com/legal/cookies/  for further details.
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
• Technical Data from the following parties:
  • analytics providers such as Google based outside the EU;
  • advertising networks based inside or outside the EU; and
  • search information providers inside or outside the EU.
• Contact data, Financial data and Transaction Data from providers of technical, payment and delivery outside the EU.
• Identity data and Contact Data from data brokers or aggregators based outside the EU.
• Identity data and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.

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.

Purposes for which we will use your personal data: We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

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 Toluna@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.

Processing activities table

Promotional offers from us: We may use your Identity data, Contact data, Technical data, Usage data and Profile data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (i.e. marketing).

You will receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Third-party marketing: We will get your express opt-in consent before we share your personal data with any controller outside the Toluna group of companies for marketing purposes.

Opting out: If you wish to opt out of our marketing communications, you may do so in accordance with the process under the sub-paragraph How do I unsubscribe from marketing communications? below.

Change of purpose: We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us by emailing Toluna@toluna.com.

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.

Disclosures of your personal data: We may have to share your personal data with the parties set out below for the purposes set out in the processing activities table above.

• Our Toluna group of companies, listed at may be acting as joint controllers or processors and are based in countries throughout the world, including countries that are not recognised as providing equivalent protection.
• External third parties based in countries throughout the world, including countries that are not recognised as providing equivalent protection such as;
  • Service providers acting as processors including those who provide us with Customer Relationship Management solutions (Salesforce) and other services such as; IT and system administration services.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
  • Tax authorities, regulators and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances.
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

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

Toluna is a global company and your personal data is transferred to other members of the Toluna group of companies and our trusted service providers, who may be located in a country other than where you live. Please be aware that laws in other countries may differ from the laws applicable in your own country of residence..  See attached a list of all the Toluna companies.

https://tolunacorporate.com/locations

To comply with the General Data Protection Regulation and UK privacy laws, (GDPR), Toluna has put in place adequate safeguards to protect your data and your rights, including standard contractual clauses for the transfer of personal data to third parties in non-adequate countries as decreed by the European Commission (“SCC’s”).

Toluna USA Inc., – EU-U.S. and Swiss-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 Toluna 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 and Swiss U.S. Privacy Shield Framework administered by the US Department of Commerce (“Privacy Shield“) in respect of the collection, use and retention (processing) of personal data transferred 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 pursuant to the Standard Contractual Clauses published by the European Commission (“SCC’s”) and subsequently transfers to a third party acting as an agent on its behalf (Iron Mountain) for offsite back up purposes. Toluna USA complies with and has 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 Transfers 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.  if you have an enquiry or complaint regarding our Privacy Shield policy, you should first contact us at Toluna@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.

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 sites and click throughs for specific campaigns. Cookies also help us to provide you with a good experience when you browse our sites 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.

For more information about the cookies we use, please see https://tolunacorporate.com/legal/cookies/.

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 long will you use my personal data for?

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 in the EEA, Switzerland or the UK, in some circumstances you can ask us to delete your data: see the section entitled Your rights below for further information.

As we continue to develop our business, we might sell or buy additional assets. In such transactions, Toluna’s right to contact you for the purpose specified herein and the information you have voluntarily provided on our Sites, as part of a contract with us, or otherwise would generally be one of the transferred business assets. Any merger, sale or transfer of Toluna of substantially or all of its business assets, or other fundamental corporate transaction would be to an entity that agreed to comply with all of the material terms of our privacy notice. You will be notified via email and/or a prominent notice will be posted on our site if any transaction may result in any new proposed uses of your personal data which are incompatible with the uses set out in this Privacy Notice and of the choices you may have regarding your personal data.

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.

These sites are not intended for children and we do not knowingly collect data relating to children.

How do you access your information, or update, correct or delete your information?

Upon request, Toluna will provide you with information about whether we hold any of your personal data.  You may access, correct, or request deletion of your personal data emailing us at Toluna@toluna.com or writing to us at postal address under the Privacy Contact section below.  We will respond to all requests within a reasonable timeframe.

How do I unsubscribe from marketing communications?

We and our selected third parties may process your personal data to send direct email marketing communications about our solutions. You may withdraw your consent at any time by clicking the “unsubscribe” link in the email communications we send to you.  Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.

Data retention

If you unsubscribe from our mailing lists, we will no longer use your personal data to contact you, but in accordance with our backup procedures, we will retain your personal data until your personal data are eventually destroyed in accordance with our data retention and destruction policies and we will continue to employ the security procedures and technologies to keep your personal data safe.

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 at Toluna@toluna.com. 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, Switzerland or the UK and have an unresolved privacy or data use concern that we have not addressed satisfactorily, 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 in the EEA or Switzerland, we have registered with La Commission Nationale de l’informatique et des Libertés (CNIL) as our Lead Supervisory Authority.  If you have an unresolved complaint that we have not addressed satisfactorily, then you may make a complaint to the CNIL

If you are in the UK, you may make a complaint to the Information Commissioners Office at https://ico.org.uk/make-a-complaint/

We would, however, appreciate the chance to deal with your concerns before you approach the data protection regulator so please contact us at Toluna@toluna.com in the first instance.

Your other rights

You may:

• request access to your personal data and we may conduct ID checks before we can respond to your request.
• have your personal data erased, corrected or restricted if it is inaccurate or requires updating. You may also have the right under certain circumstances to request deletion of your personal data; however, this is not always possible due to legal requirements and other obligations and factors. You can update your personal data by contacting us at Toluna@toluna.com or by writing to the address given in the Privacy Contact section below.
• object to the processing your personal data if we are not using your personal data for the purposes set out in this privacy policy.

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.

Your rights in California

You have certain rights under the California Consumer Privacy Act 2018 (CCPA) if you are citizen of California. You can exercise the above rights by:

• calling us on the toll-free number: # 866-242-3693
• emailing us at Toluna@toluna.com
• writing to us at the address given under the Privacy Contact Details; or
• following the process under the paragraph How do you terminate your influencers panel membership? above

If you wish to opt out of our marketing communications, you may do so in accordance with the process under the sub-paragraph How do I unsubscribe from marketing communications? above. Once you make an opt-out request, we will remove you from our customer marketing lists and we will not contact you for these purposes again, unless you decide to re-register with us.

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not exclude you from participating in any Surveys you may be eligible for on the basis of you exercising your CCPA rights.

Your rights in the EEA, Switzerland or the UK

If you are in the EEA, Switzerland or the UK, you additionally have the right to have your personal data transferred to you or a third party in a readable format.  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.

This version was last updated on the date at the top of this privacy notice.

We reserve the right to modify this privacy notice at any time, so please review it frequently. If we do decide to change our privacy notice, we will post those changes to this privacy statement on the homepage, 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. 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.

It is important that the personal data we hold about you is accurate and current, so please do keep us updated on any changes to your status or other personal data.

The Toluna Corporate Webmaster
21 River Road
Wilton
CT 06897
U.S.A.

E-Mail: Toluna@toluna.com
Phone: US Phone # 866-242-3693

If you are in the EEA, Switzerland or the UK please contact us at :

The Data Protection Officer
Toluna SAS
5, avenue du Château
94300 Vincennes
France

E-Mail: DPO@toluna.com