Fresh Perspectives Research
Effective Date: June 8, 2018
This Policy applies to all of our Services, regardless of how you use them. This Policy only applies to how we collect, store, share, and use information. This Policy does not apply to any entity that we do not own or control, or to any person that we do not employ or manage. If, at any time during the course of using our Services, you are directed to a third-party site, you understand and agree that the policies of the third-party site govern.
Types of Information We Process
Information You Provide
We collect information that you voluntarily submit to us. For example, we collect information when you contact us to submit a questionnaire or e-mail us to provide the information. The information we collect may include information that identifies or could identify you (whether alone or in combination), such as your name, email address, or physical address. With your explicit permission, we collect information that personally identifies you including your photograph, likeness, image, voice and/or statements (collectively, “Likeness”). Do not submit any information to us that we have not requested.
Information we process with your consent
Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our Website or ask us to provide you more information about our business, including job opportunities and our products and services including market research opportunities, you provide your consent to us to process information that may be PII.
Wherever possible, we aim to obtain your explicit consent to process this information, for example, by asking you to agree to receive communications from us. In all cases where we communicate to you by e-mail without having an established business relationship with you, there will be an opportunity to “unsubscribe” from receiving any further e-mails from us.
Sometimes you might give your consent implicitly, such as when you send us a message by e-
mail to which you would reasonably expect us to reply.
When we communicate with you about our business, we will use the contact information you
provided to us to discuss technical issues, new products and services, market research
opportunities, and other information of interest to you, including opportunities to participate in
market research activities. You have a choice about whether or not you wish to receive
communications from us.
Except where you have consented to our use of your information for a specific purpose, we do not use your information in any way that would identify you personally. We may aggregate it in a general way and use it to provide class information, for example to monitor the performance of a particular page on our Website.
We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.
You may withdraw your consent at any time by instructing us using the contact information at the end of this Policy. However, if you do so, you may not be able to use our Website or our services further.
Information Collected Automatically. We may automatically collect certain information about how you access or use our Services, and by using our Services you consent to the collection of that information. Examples include but are not limited to Internet browser, operating system, device and application identifiers, IP address and geo-location information, access times and dates, referring and exit pages and URLs, clickstream data, search terms, pages viewed, time spent on pages, bounce rate and login frequency.
What these Technologies Are. “Cookies” are small data files placed on your computer or other device which record information. For example, a cookie could enable our Services to recognize your browser, while another cookie could store your account preferences and other information to help make our Services more customized. We may use two kinds of cookies, “session cookies” and “persistent cookies.” Session cookies normally expire when you close your browser, while persistent cookies remain on your device until they expire or are deleted. “Web beacons” (also known as “pixel tags” or “clear GIFS”) are pieces of code or pixels embedded in a web page or email to track engagement with and responses to emails, web pages or ads, or to access or communicate with cookies. “Tracking URLs” are special URLs that can be used to track engagement with and responses to emails or web pages.
Information from Other Sources. We may obtain information about you from third-party partners (such as other companies or clients on whose behalf we may conduct market research, or companies with which we may jointly offer services or conduct promotional events), third-party service providers, including but not limited to demographic information, contact information, open data, publicly available data and credit check information. We may use this information for legitimate business purposes, including the offering of market research opportunities, performance of a contract, customer support, along with other purposes described in this Policy.
How We Use the Information We Collect and Why
The information we collect helps us to operate, improve, protect, and customize our Services, and to develop new Services. The information we collect also helps us to provide customer support and make our Services more efficient for you and other Users. For the sake of transparency, it is our responsibility to outline for you the legitimate business purposes for the collection of information, and the reasons why we do so, in order for you to make an informed decision regarding the use of our Services. In addition to the other uses of information described in this Policy, we may use all of the information that we obtain from or about you for the following purposes and reasons:
to provide our Services to you, including new Services we develop later (reason: legitimate business purpose and performance of a contract);
to provide you with customer support (reason: legitimate business purpose);
to facilitate your communications or transactions with us or other Users (reason: to receive consent, and for legitimate business purpose);
to operate, improve, and customize our Services, Content, and marketing, to develop new Services, and to understand how you use and interact with our Services and Content, and the products, services, and Content of others (reason: legitimate business purpose);
to promote and maintain a trusted, safer, and more reliable environment on our Services, for example, to help detect, prevent or otherwise address fraud, security or technical issues, conduct investigations or risk assessments, or verify actions taken by you or associated with your account (reason: to protect the public interest and for legitimate business purpose);
to contact you (by email, postal mail, telephone, mobile devices, SMS text message, or as otherwise authorized by you) in order to address issues with your use of our Services, collect fees, send you updates about our Services or policies, or for other purposes permitted by law (reason: performance of a contract and for legitimate business purpose);
to contact you (by email, postal mail, telephone, mobile devices, SMS text message, or as otherwise authorized by you) in order to send you marketing communications, promotional messages, and offers about our Services and Content, and the products, services, and Content of others (see below for information on how to opt out of receiving certain communications from us) (reason: to receive consent, and for legitimate business purpose);
to comply with our legal obligations, resolve disputes, or enforce other Fresh Perspectives policies or agreements with Users (reason: compliance with a legal obligation);
to perform other functions as described when the information is collected or requested, or for other purposes with your prior consent (reason: legitimate business purpose).
How is the Information Stored
Data Retention. We will keep and use your data as described in this Policy for (i) as long as is necessary to comply with any tax, legal, and/or other regulatory requirements; and (ii) to protect and defend against potential legal claims. If you would like to request the deletion of your personally identifiable information or request that it be returned to you, please contact us at email@example.com.
Data Storage and handling. Fresh Perspectives takes the security of your personal data very seriously. We take every effort to protect your personal data from misuse, interference, loss, unauthorized access, modification or disclosure.
Our measures include implementing appropriate access controls, the use of Secure Sockets layer (“SSL”) technology on our website, secure servers at our location, password protection and encryption and investing in the latest Information Security Capabilities to protect the IT environments we leverage, and ensuring we encrypt and anonymize personal data wherever possible.
Access to your personal data is only permitted among our employees and agents on a need-to- know basis and subject to strict contractual confidentiality obligations when processed by third-parties. Most importantly, we don't share personal information or submit it to third parties (for example a market research client) without the knowledge and explicit consent of the person who provided the personal information.
With Whom do We Share Personal Information?
Personal Information. Under this Policy, "Personal Information" means information that by itself can be used to identify or contact a specific person (for example, a person’s name, email address, postal address or phone number), and Personal Information does not include information that has been aggregated or made anonymous so that by itself it no longer identifies and can no longer reasonably be used to contact a specific person. We will only share your Personal Information with others in the ways described in this Policy, or otherwise with your prior consent. In addition to the other sharing of Personal Information described in this Policy, we may share your Personal Information with others in the following contexts.
We may aggregate or make anonymous any Personal Information that we have obtained in any way from or about you or others so that such information no longer contains any Personal Information. We may use and share any aggregated, anonymous or other non-personally identifying information for any legitimate business purposes, including research and development, marketing, and to inform others about how our Services or Content are engaged with or used.
Other Websites and Services
Fresh Perspectives is based in the United States. However, service providers, and other third parties you may interact with in connection with our Services, may be located in the United States and other countries around the world, including countries that may not offer the same level of protection for Personal Information as that offered in the United States. By accessing or using our Services in the United States or any other country or jurisdiction, you agree that your information may be transferred and processed in the United States and any other country or jurisdiction.
In cases of onward transfer to third parties of Personal Information of EU individuals received pursuant to the EU-U.S. Privacy Shield, Fresh Perspectives remains accountable for the onward transfer of such Personal Information.
Our Services are not directed to children under the age of 13, and we do not knowingly collect personal information as defined by the U.S. Children’s Privacy Protection Act (“COPPA”) in a manner that is not permitted by COPPA. If a parent or guardian learns that a child has provided us with personal information, that child's parent or guardian should email us at firstname.lastname@example.org or send us a letter to the mailing address in the section entitled “Contact Us” below.
Some jurisdictions have laws that give people the right to access or correct their Personal Information which a company has about them. We will honor any statutory right you may have to access or correct your Personal Information that we have in our records, and you can email such requests to email@example.com. Once we receive your request, we will let you know if an administrative fee will apply to fulfill your request, as permitted by applicable law. However, please note that even if you have a legal right to request access to information or to correct information, as permitted by applicable law, we may reject requests that are unreasonably repetitive, would require disproportionate technical effort (for example, developing a new system or materially changing an existing practice), would jeopardize the privacy of others, or would be extremely impractical to fulfill (for example, requests to access information located on backup systems).
Your California Privacy Rights
California’s “Shine the Light” law permits customers in California to request certain details about how certain types of their information are shared with third parties and, in some cases, affiliates, for those third parties’ and affiliates’ own direct marketing purposes. Under the law, a business should either provide California customers certain information upon request or permit California customers to opt-in to, or opt-out of, this type of sharing.
Fresh Perspectives may share personal information as defined by California’s “Shine the Light” law with third parties and/or affiliates for such third parties’ and affiliates’ own direct marketing purposes. If you are a California resident and wish to obtain information about our compliance with this law, please e-mail us at Research@freshperspectives.info or send us a letter to the mailing address in the section entitled “Contact Us” below. Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that Fresh Perspectives is not required to respond to requests made by means other than through the provided e-mail address or mail address.
Your European Privacy Rights
If you are a data subject in the European Economic Area (“EEA”), you have the right to access, rectify, or erase any personal data we have collected about you through the Service. You also have the right to data portability and the right to restrict or object to our processing of personal data we have collected about you through the Service.
To exercise any of these rights, please e-mail us at firstname.lastname@example.org or send us a letter to the mailing address in the section entitled “Contact Us” below and specify which right you intend to exercise. We will respond to your request within 30 days. We may require additional information from you to allow us to confirm your identity. Please note that we store information as necessary to fulfill the purposes for which it was collected, and may continue to retain and use the information even after a data subject request as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
If you have any issues with our compliance, you may have the right to lodge a complaint with an EEA supervisory authority.
EEA Withdrawal of Consent
If you are a data subject in the EEA, you have the right to opt out or withdraw your consent for us processing your personal data collected through the Service (or providing it to third parties to process) for direct marketing purposes (including promotional emails) or purposes materially different than for which it was originally collected or subsequently authorized by you. You may also withdraw your consent at any time for any data processing we do based on consent you have provided to us. Please note that withdrawal of your consent does not impact any data that was processed on the basis of that consent before it was withdrawn.
To exercise this right, please e-mail us at research@Freshperspectives.info or send us a letter to the mailing address in the section entitled “Contact Us” below and specify your withdrawal of consent. We will make the requested changes in our active databases as soon as reasonably practical.