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Privacy policy

1                Purpose of this privacy notice

At Savanta we provide various market research services including designing market research surveys, hosting opinion panels and providing audience research services and statistical analytics to global businesses (“Services”).  We are committed to protecting the privacy of our website visitors, clients and, as a market research group, the privacy of research respondents in connection with the provision of our Services. We want to provide a safe and secure service where we deal with your personal data.

This Privacy Notice sets out how processes your personal data in connection with the provision of our Services (including our services offered through our Vue Product Range) and our websites at and https://opinionpanel.co.uk (“Sites”). This Privacy Notice also sets out your rights in respect of our processing of your personal .

When we talk about “personal data”, we mean any information which relates to an identified or identifiable living individual. Individuals might be identified by reference to a name, an identification number, location data, an online identifier (such as an IP address) or to other factors that are specific to them, such as their physical appearance.

This Privacy Notice is intended to assist you in making informed decisions when using our Sites and our Services. Please take a moment to read and understand it. It should be read in conjunction with our .

Please note your access to and use of our Sites and/or Vue Product Range including your -Vue account page and any secure area, is subject at all times to separate Terms of Use and/or Terms of Service.

2                Changes to this Privacy Notice

We will update this Privacy Notice from time-to-time to reflect any changes or proposed changes to our use of your personal data, or to comply with changes in applicable law or regulatory requirements. We may notify you by email of any significant changes to this Privacy Notice, but we encourage you to review this Privacy Notice periodically to keep up to date on how we use your personal data.

3                About Us

The Sites and our Services are made available by various companies in the Savanta group of companies (each a “Group ”).

Where this Privacy Notice refers to “Savanta”, “we”, “us, “our”, this means Savanta Group Limited, or one or more of the particular Group Companies that provide the particular Site or Services to you.

We set out below more information about our Group Companies, including their location and respective roles and responsibilities.

 

Location: United Kingdom

Savanta Group Limited (company no: SC 281 352) is a company established under the laws of Scotland with its registered office at 3 Melville Street, Edinburgh, EH3 7PE.

 

Location: USA

 

Location: Canada

Savanta Analytics Ltd (BN 749932919, Registry ID BC1167318, registered in Vancouver, CA)

 

Location: India

Savanta Analytics Private Limited (CIN U74999UP2020PTC133576, PAN ABECS3099M, TAN MRTS20085C

 

Except as stated otherwise, each Group Company is an independent controller of your personal data. However, in connection with the provision of our Services, we may carry out certain activities referred to in this Privacy Notice in our capacity as a data processor acting on behalf of our clients. We have made this distinction clear in the Privacy Notice.

 

4               How to contact us

If you have any questions about this Privacy Notice or want to exercise your rights as a data subject set out in this Privacy Notice, you can contact us using the following methods:

On Site Contact us using our Enquiry Form.
Email Send us an email at: [email protected]
Post Write to us at: Savanta DPO, 60 Great Portland Street, London, W1W 7RT.
Telephone Call us on: +44 (0)20 7632 3434 (UK \ EMEA) or +1 (917) 768-2710 (Canada \ ).

5                What personal data we collect

In providing our Sites and Services, we may collect and process different types of personal data about you for different processing purposes. The types of personal data we collect depends on who you are and how you use our Site and Services and includes the following:

Identity Data First name; last name.
Contact Data Home address; billing and/or delivery address; email address; telephone number.
Respondent Data Account username; password; first name; last name; date of birth; gender; country; nationality; username; job title; social status; sexual orientation; whether you have participated in any survey or questionnaire responses and feedback; survey responses, participation in any promotions or competitions.
Image Data Photos; video recordings.
Financial Data Bank account details: partial payment card details and details about payments made between you and us.
Behavioural Data Data relating to your browsing activity or interaction with our emails, obtained through the use of cookies, pixel tags and other similar technologies; information about when your current or previous sessions started; details about any products you viewed or purchased through the Sites.
Technical Data IP address; browser type and operating system; geolocation, to ensure we’re showing you the correct notices and information; any other unique numbers assigned to a device.
Job Applicant Data Date of birth; gender; country; nationality; CVs; work experience; dietary requirements; any other personal data you may provide in advance of/during your supply of services to us.
Marketing and Communications Data Marketing preferences; service communication preferences.
Publicly Available Data Information about articles (or similar) that you may have published; information about your interests or affiliations or publicly stated positions on political matters, corporate matters and similar.

6                How we collect and receive personal data

We collect and receive personal data using different methods:

Personal data you provide to us You may give us your personal data directly, for example, when you agree to take part in market research opinion panels, or when you provide your Contact Data as part of a survey, purchase services via our Site, contact us with enquiries, complete forms on our Site, subscribe to receive our marketing communications or provide feedback to us.
Personal data we collect using cookies and other similar technologies When you access and use our Site, we will collect certain Behavioural Data and Technical Data. We collect this personal data by using cookies and other similar technologies (see the “Insight, analysis and retargeting through Cookies” section below).
Personal data received from third parties We may receive personal data about you from third parties. Such third parties may include our clients, market research sample and list suppliers, analytics providers, data brokers and third party directories.
Publicly available personal data From time to time, we may collect personal data about you (Identity Data and Contact Data) that is contained in publicly available sources (including open source data sets or media reports) or that you or a third party may otherwise make publicly available (for example through speeches at events or publishing articles or other news stories or posts on social media platforms).

7                Who we collect personal data about

We collect and process personal data from the following people:

Site visitors If you browse our Site or register an account on our Site, we will collect and process your personal data in connection with your interaction with us and our Site.
People who contact us with enquiries If you contact us with an enquiry through our Site, submit a complaint through our Site or provide any feedback, we will collect and process your personal data in connection with your interaction with us and our Site.
Respondents If you participate in one of our surveys or panels, we will process your data including Respondent Data and Financial Data in connection with your participation.
People who work for our clients and suppliers If you work for one of our clients or suppliers and have responsibility for placing orders with us, administering your organisation’s account with us or handling our orders or our account with your organisation, we will process your personal data in connection with your organisation’s relationship with us.
Talent If you supply services and/or content to us and work with us to provide services to our client (including feature in content we produce), we may collect and process your personal data, such as your Identity Data, Contact Data, Financial Data, CVs in connection with such supply of services and/or content to us and our clients.
Partner/supplier personnel If you (or your organisation) supply products or services to us or otherwise partner with us, we may collect and process your personal data in connection with our receipt of those products and services and/or partnership. This may include personal data included in any email or telephone communications or recorded on any document relating to an order for the products or services, such as your Contact Data.
Visitors to our physical locations If you attend one of our offices or other locations, we may process personal data that you volunteer in connection with your visit and any enquiries you make. For example, you may volunteer personal data when asking us to assist you in finding accommodation or transportation suitable for your needs, or when signing in as a guest. CCTV footage may also be collected for security purposes.
Event attendees If you attend one of our events, we will process personal data about you in connection with your attendance at the event. For example, we may ask you to complete a registration or feedback form, or other document relating to the event.
Job applicants If you apply for a job with us, whether through the Site or otherwise, we will collect and process your personal data in connection with your application.
Members of the public We may collect and process your data that you volunteer or where you have indicated to us, market research sample or list providers that you are willing to take part in market research and/or opinion panels in connection with the provision of Services to our clients.

8                How we use your personal data

We use your personal data for the purposes set out in this section. If we wish to make any changes to these purposes, or if we wish to use your personal data for any purpose that is not listed in this section, we will notify you using the contact details we hold for you.

A: Use of our Sites

If you browse our Sites When you browse our Sites, we collect and process Behavioural Data and Technical Data to help us understand how you are using and navigating our Sites. We do this so that we can better understand which parts of our Sites are more or less popular and improve the structure and navigation of our Sites.

Our legal basis for processing

It is in our legitimate interest to use personal data in such a way to ensure that we provide access to our Sites in a secure and effective way and so that we can make improvements to our Sites or it is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you for the Services.

If you use the interactive features on our Site We will collect and use personal data about you when you use certain features on our Site. For example, depending on the nature of your enquiry, we may process your Identity Data, Contact Data and certain Behavioural Data and Technical Data when you use the Enquiry Form to get in touch with us.

Our legal basis for processing

It is in our legitimate interest to use personal data in such a way to ensure that we can respond to your enquiries, provide access to our Sites in a secure and effective way and make improvements to our Site.

If you link to social media sites and interact with our social media pages If you click on one of the social media links on our Sites or otherwise interact with our social media pages such as on Twitter or Instagram or YouTube (including interacting with any ‘like’ or similar embedded features on our Sites or social media accounts), we and the relevant social media platform may receive information relating to such interaction and may share your personal data in connection with this purpose, such as certain Behavioural Data and Technical Data. For more information about how we use this personal data, please see the “Insight, analysis and retargeting through Cookies” section below.

The relevant social media platform may also be a controller in respect of the personal data that is collected via your use of our social media pages and may use that personal data for additional purposes. For details of how the relevant social media platform uses your personal data, please see the privacy policy of the relevant social media platform.

Our legal basis for processing

It is in our legitimate interest to use personal data in the ways described above to ensure that we provide the Site in an effective way and to promote our Site via social media.

 

B: Fulfilment of our Services 

Carrying out surveys and reporting We collect and maintain personal data that you submit and/or third parties provide to us for in connection with your participation in one of our surveys that we carry out on behalf of our clients or for our own market analysis purposes.

The information you provide will normally be used to help a client better understand how they are doing in the marketplace, or to help them improve a service or similar. Data is typically presented back to our client as part of our Services in an aggregated, anonymised format, unless you consent to us providing them your Contact Data appended. For example, to enable you to collect a reward if completing a survey requires it.

The personal data we process may include your Identity Data, Contact Data, Respondent Data, and Financial Data (where applicable). We process this information so that we can fulfil the supply of our Services, maintain our user databases and to keep a record of how we provide our Services.

Our legal basis for processing 

To the extent the above involves personal data and we are considered a controller of your data, it may be necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you. Or it is in our legitimate interest or a third party’s legitimate interest for us to use personal data in such a way to ensure that we provide the Services in an effective, safe and efficient way. Where we do this on behalf of our clients as a data processor, we do not require a legal basis for such processing.

We will not process any special (or sensitive) categories of personal data or personal data relating to criminal convictions or offences except where we are able to do so under applicable legislation or with your explicit consent.

Please note that often such services will relate to anonymous data sets (aggregated data sets, statistical data sets and similar) and are used for high-level market analytics or understanding macro consumer habits (amongst other things). When we do this, we and our clients are not processing personal data.

Managing our Panels If you sign up to one of our market research opinion panels, we will process personal data about you which you provide to us when you complete your profile as part of the sign-up profile. This will usually include your Contact Data, Respondent Data, Financial Data and any other personal data you volunteer.

If you are a parent or guardian of a minor who signs up for a youth market research opinion panel, we may also process your personal data to record that you have consented to the minor taking part in the panel and completing a profile. We may process this type of consent by recording a telephone call with you.

Once you have created a profile, we will be able to use this information provided to select you to take part in relevant surveys.

Our legal basis for processing 

To the extent the above involves personal data, it may be necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you. Or it is in our legitimate interest or a third party’s legitimate interest for us to use personal data in such a way to ensure that we provide the Services in an effective, safe and efficient way.

Provision of market insight through our Vue Product Range  

In additional to providing bespoke market research services to clients, we can create aggregated and anonymised market insights through our Vue Product Range for our benefit and that of our clients using a wide range of software tools to extract information about target markets, customers, and marketing efforts from data provided to us by our clients or from information you provide to us through completing our surveys or through third party providers.

Our legal basis for processing 

To the extent the above involves personal data, it is in our legitimate interest or a third party’s legitimate interest for us to use personal data in such a way to ensure our services are easy to use providing us and our clients with up to date and valuable insights. Where we do this on behalf of our clients as a data processor, we do not require a legal basis for such processing.

Use of our Vue Product Range.  

You may be required to register an account with us in order to gain access to our Vue Product Range. Account applicants will need to complete the registration form, providing all required Identity Data and Contact Data (including their first name, last name, email address, telephone number, and organisation). We will use this data in order to process your registration.

Once the account is registered, we will process your Identity Data to identify you when you log in to your account and access secure areas of the Vue Product Range. We will also process certain Technical Data and Marketing and Communications Data so that we can administer your account and contact you about your account.

We will also collect and process Behavioural Data and Technical Data when you use certain features and functionality on our Vue Product Range. This data helps us understand how you use our Vue Product Range so that we can improve it.

Our legal basis for processing

It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you, or it is in our legitimate interest to use personal data in such a way to ensure that we provide access to the Services in a secure and effective way and so that we can make improvements to our Services.

If you complete our surveys or provide feedback on your experience of our Site and/or our Services  

From time to time, we will invite you to provide feedback about us, our Site and our Services in the form of online surveys. These are separate to the market research surveys we provide. We will collect and process your Identity Data and Contact Data as well as any other personal data you choose to volunteer in your survey response or other feedback.

We use this information to help us to monitor and improve our Site and our Services, to assist with the selection of future service lines and to train our personnel.

You can also voluntarily provide feedback by email or via our Enquiry Form.

Our legal basis for processing

It is in our legitimate interest to use the personal data provided by you so that we can improve our Site and our Services and provide them in an effective way.

If you participate in one of our promotions  

From time to time, we may incentivize participation in our market research activities by running prize draws, prize competitions and other promotions on our Sites, client sites and/or on our social media accounts. For the purposes of administering such promotions, we may process your Identity Data, Contact Data and any other personal data volunteered by you in relation to your promotion entry.

Our promotions are subject to separate terms and conditions, which you may be required to accept as a condition of entry.

Our legal basis for processing

It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you (e.g. the promotion terms and conditions) or it is in our legitimate interest to use your personal data to enable us to administer our promotion fairly and effectively and to ensure that we comply with self-regulatory codes governing the operation of promotions.

 

If you have a general question or need help with any issue concerning our Sites or our Services

 

There are various ways in which you are able to contact us (see the “How to Contact us” section above). In particular, our Site features a “Contact Us” page, which invites you to submit general enquiries about our Sites by email or via our Enquiry Form. From time to time, you may also be able to submit specific enquiries on other pages of our Sites, including in secure account areas.

When you make an enquiry, we will collect and process your Identity Data, Contact Data as well as any other personal data you volunteer that is relevant to your enquiry. If you have a technical issue concerning our Sites, we may also collect and process Behavioural Data and Technical Data to help us diagnose the technical issues you are experiencing and to help us resolve them in an efficient way. We use this information to manage and respond to your enquiry.

We may record telephone conversations to improve how we train our personnel and the quality of our services.

Our legal basis for processing

It is in our legitimate interest to use your personal data in the ways described above to ensure that we are able to help you with your enquiry, provide a good standard of service and improve our customer services.

C: Hosting and managing

If you sign up for and/or attend one of our events From time to time, we may organise and host events for the purpose of promoting our business or for charitable causes or other reasons. We may process your Identity Data and Contact Data to communicate with you about such events where you have specifically requested information about such events or where we have another lawful basis for sending that information to you.

If you attend one of our events, we may use your Identity Data and Contact Data to record your attendance at the event and for related record-keeping purposes and, if relevant, we may collect and process any dietary requirements you may have. You may also feature in photographs taken at our events and such photographs may appear in publications that we make available.

Our legal basis for processing

It is necessary for us to use your personal data in this way to perform our obligations in accordance with any contract that we may have with you where you have signed up to attend an event, or it is in our legitimate interest or a third party’s legitimate interest to use personal data in such a way to ensure that the event is operated in an effective way.

We may specifically ask your permission to use your photographs, quotes, testimonials, or other content that you make available or publish at the event. Where this is the case, our processing of your such personal data will be based on consent.

D: Insight, analysis and retargeting through Cookies

If we use cookies to help us understand more about you and your use of our Site and our Products and Services We and our third-party partners use cookies, web beacons, pixel tags and other similar technologies (which we generically refer to as “Cookies”) to collect data from the devices that you use to access our Site and Services and any emails that you receive from . The data that is collected includes Behavioural Data and Technical Data Please see our Cookie Policy for further information, including details of our third-party partners.

We and our third-party partners use this data to analyse how you use our Sites and Services and the effectiveness of our Sites and Services, including:

·       to count users who have visited our Sites or opened an email and collect other types of information, including insights about visitor browsing habits, which helps us to improve our Sites and Services and the effectiveness of our emails;

·       to measure the effectiveness of our content;

·       to learn what parts of our Sites are most attractive to our users, which parts of our Sites are the most interesting and what kind of features and functionalities our visitors like to see;

·       to help us understand the type of marketing content that is most likely to appeal to our visitors and customers; and

·       to help us with the selection of future service lines, website design and to remember your preferences.

In some of our email messages, we use a “click-through URL” linked to certain websites administered by us or on our behalf. We may track click-through data to assist in determining interest in particular topics and measure the effectiveness of these communications.

Our legal basis for processing

 

In certain circumstances, we may rely on another lawful basis when we use your personal data collected via the use of cookies. For example, where we use personal data collected through the use of analytics cookies to analyse how you use our Sites, it is in our legitimate interest to use your personal data in such a way to improve our Sites and Services.

E: Advertising and marketing activities

If we send you marketing communications by post and/or email/SMS We use your Identity Data, Contact Data and Marketing and Communications Data to send you (or the organisation you represent) marketing communications by post and/or email/SMS. Our marketing will include press releases and information about us, our Site, our Services, any events we may hold and the offers and promotions we offer from time to time.

Our marketing communications will include personalised and non-personalised marketing. Personalised marketing has been specifically tailored to you and will include content that we think is most relevant to you, based on what we know about you. Non-personalised marketing is marketing that is not tailored to you.

Where we are sending you personalised marketing, we may also use Transaction Data and Behavioural Data to help us decide what sort of personalised marketing to send you (please see the “Insight, analysis and retargeting through Cookies” section above for more details).

Our legal basis for processing

It is in our legitimate interest to use your personal data for marketing purposes, for example to decide what marketing content we think may appeal to you.

It is in our legitimate interest to use your personal data to send our marketing to you by post.

However, we will only send marketing communications to you by email and/or SMS where you have consented to receive such content by email and/or SMS, or where we have another lawful right to send marketing to you using email and/or SMS. For example, in certain circumstances we may rely on our legitimate interest to send marketing by email and/or SMS to consumers who have purchased our Services. We may also rely on our legitimate interest to send marketing by email and/or SMS to certain business users of our Sites and Services.

Blogs and Newsletters We may also provide individuals with the opportunity to sign up for newsletters or to receive copies of blogs and other information that we make available. Where an individual signs up to receive such information, Contact Data may be requested as well as other information to ensure our communications are suitably tailored.

Our legal basis for processing

It is in our legitimate interests (and those of our clients) to process personal data in this way to ensure we provide the Services requested by our clients in an effective and efficient way and that we provide the right information to those who request it.

Media and Informational inquiries We may collect personal data (including Identity Data, Contact Data and Publicly Available Data) about journalists, client contacts or industry contacts for interview requests, for media questions, or requests for information about Savanta. This information is used in order to enable us to respond to individual requests or media requests.

Our legal basis for processing

It is in our legitimate interests (and those of our clients) to process personal data in this way to ensure we provide the Services requested by our clients in an effective and efficient way and that we provide the right information to those who request it.

F: Recruitment

If we use your personal data in connection with our recruitment activities We use your personal data for recruitment purposes, in particular, to assess your suitability for any of our positions that you apply for, whether such application has been received by us online, by email or by hard copy and whether submitted directly by you or by a third-party recruitment agency on your behalf. We also use your Identity Data and Contact Data to communicate with you about the recruitment process, to keep records about our recruitment process and to comply with our legal and regulatory obligations in relation to recruitment.

We will process any personal data about you that you volunteer, including during any interview, when you apply for a position with us. We may also process your personal data obtained from any third parties we work with in relation to our recruitment activities, including without limitation, recruitment agencies, background check providers, credit reference agencies and your referees.

The personal data we process may include your Identity Data, Contact Data, Job Application Data and any other personal data that you volunteer during an interview or your interactions with us, or any personal data which is contained in any reference about you that we receive. Such information may also include special categories of personal data (such as information about your health, any medical conditions and your health and sickness records) and information relating to criminal convictions and offences if that information is relevant to the role you are applying for.

We also use your personal data for the purposes of reviewing our equal opportunity profile in accordance with applicable legislation. We do not discriminate on the grounds of gender, race, ethnic origin, age, religion, sexual orientation, disability or any other basis covered by local legislation. All employment-related decisions are made entirely on merit.

Our legal basis for processing

Where we use your personal data in connection with recruitment and talent management, it will be in connection with us taking steps at your request to enter into a contract we may have with you, or it is in our legitimate interest to use personal data in such a way to ensure that we can make the best recruitment and talent management decisions.

We will not process any special (or sensitive) categories of personal data or personal data relating to criminal convictions or offences except where we are able to do so under applicable legislation or with your explicit consent.

G: Receipt of products and services from our suppliers

If we have engaged you or the organisation you represent to provide us with products or services If we have engaged you or the organisation you represent to provide us with products or services (for example, if you or the organisation you represent provide us with services such as IT support or financial advice), we will collect and process your personal data in order to manage our relationship with you or the organisation you represent, to receive products and services from you or the organisation you represent and, where relevant, to provide our Services to others. The personal data we collect from you may include your Identity Data and Contact Data and any other personal data you volunteer which is relevant to our relationship with you or the organisation you represent.

Our legal basis for processing

It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you or the organisation you represent, or it is in our legitimate interest to use personal data in such a way to ensure that we have an effective working relationship with you or the organisation you represent and are able to receive the products and services that you or your organisation provides, and provide our Services to others, in an effective way.

H:

If we need to use your personal data in connection with the administration of our security measures We have security measures in place at our premises, including CCTV and building access controls. There are signs in place showing that CCTV is in operation. The images captured are securely stored and only accessed on a need-to-know basis (e.g. to look into an incident). CCTV recordings are typically automatically overwritten after a short period of time unless an issue is identified that requires investigation (such as a theft).

We may require visitors to our premises to sign in on arrival and where that is the case, we will keep a record of visitors for a short period of time. Our visitor records are securely stored and only accessible on a need-to-know basis (e.g. to look into an incident).

Our legal basis for processing

It is in our legitimate interests to process your personal data so that we can keep our premises secure and provide a safe environment for our personnel and visitors to our premises.

I: Business administration and legal compliance

If we need to use your personal data to comply with our legal obligations or in connection with the administration of our business We may use your personal data: (i) to comply with our legal obligations; (ii) to enforce or protect our legal rights; (iii) to protect the rights of third parties; and (iv) in connection with a business transition such as a merger, reorganisation, acquisition by another company, or sale of any of our assets.

Our legal basis for processing

Where we use your personal data in connection with a business transition, to enforce or protect our legal rights or to protect the rights of third parties, it is in our legitimate interest to do so. For all other purposes described in this section, we have a legal obligation to use your personal data to comply with any legal obligations imposed upon us, such as a court order.

We will not process any special (or sensitive) categories of personal data or personal data relating to criminal convictions or offences except where we are able to do so under applicable legislation or with your explicit consent.

9                If you fail to provide your personal data

Where we are required by law to collect your personal data, or we need to collect your personal data under the terms of a contract we have with you, and you fail to provide that personal data when we request it, we may not be able to perform the contract we have or are trying to enter into with you. This may apply where you do not provide the personal data we need in order to provide the Services you have requested from us or to process an application for employment with us. In these circumstances, we may have to cancel your application or the provision of the relevant Services to you, in which case we will notify you.

10             How we obtain your consent

Where our use of your personal data requires consent, you can provide such consent at the time we collect your personal data following the instructions provided, or by informing us using the contact details set out in the “How to Contact Us” section above.

11             Third-party links

This Privacy Notice only applies to personal data processed by us through your use of our Sites and/or in connection with our business operations. However, from time to time, our Sites may contain links to third-party websites and services. We have no control over these websites and services and this Privacy Notice does not apply to your interaction with the relevant third parties.

When you use a link to go from our Site to another website (even if you don’t leave our Site) or you request a service from a third party, your browsing and interactions on any other websites, or your dealings with any other third-party service provider, is subject to that website’s or third-party service provider’s own rules and policies. For example, our Site invites you to connect with us on social media platforms such as Twitter and LinkedIn. When you click on the links we provide to such third-party platforms, you will be transferred from our Site to the relevant third-party platform and the privacy notice (and other terms and conditions) of that platform will apply to you.

We do not monitor, control or endorse the privacy practices of any third parties. We encourage you to become familiar with the privacy practices of every website you visit or third-party service provider that you use in connection with your interaction with us and to contact them if you have any questions about their respective privacy notices and practices.

12             Sharing Your personal data

We only share personal data with others when we are legally permitted to do so. When we share personal data with others, we put contractual arrangements and security mechanisms in place to protect the personal data shared and to comply with our data protection, confidentiality and security standards and obligations.

When processing your personal data, we may need to share it with third parties (including other entities within our group of companies), as set out in the table below. This list is non-exhaustive and there may be circumstances where we need to share personal data with other third parties.

Our clients We may share personal data with our clients for the purposes of providing them with our Services.
Our specialist suppliers/partners We use various specialist suppliers and/or partners in order to provide our Services including sample suppliers.
Third-party suppliers who provide applications/ functionality, data processing or IT services We share personal data with third parties who support us in providing our Sites and help provide, run and manage our internal IT systems. Such third parties may also include, for example, providers of information technology, cloud-based software-as-a-service providers, identity management, website design, hosting and management, data analysis, data back-up, security and storage services. The servers powering and facilitating that cloud infrastructure are located in secure data centres around the world, and personal data may be stored in any one of them. We also share your personal data with third-party service providers to assist us with insight analytics. These providers are described in our  Cookie Policy.
Payment providers and banks We share personal data with third parties who assist us with the processing of payments and refunds.
Third-party post/email marketing and CRM specialists We share personal data with specialist suppliers who assist us in managing our marketing database and sending out our post and email marketing communications and account-related communications.
Third-party suppliers who assist us in administering our promotions We share personal data with specialist suppliers who assist us in administering our prize draws, prize competitions and other promotions.
Event partners and suppliers When we run events, we will share your personal data with third-party service providers that are assisting us with the operation and administration of that event. If we are running an event in partnership with other organisations, we will share your personal data with such organisations for use in relation to the event.
Recruitment agencies and related organisations We share personal data with external recruiters, third-party providers that undertake background checks on our behalf and other entities within our group of companies.
Auditors, lawyers, accountants and other professional advisers We share personal data with professional services firms who advise and assist us in relation to the lawful and effective management of our organisation and in relation to any disputes we may become involved in.
Law enforcement or other government and regulatory agencies and bodies We share personal data with law enforcement or other government and regulatory agencies or other third parties as required by, and in accordance with, applicable law or regulation.
Other third parties Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, or to establish, exercise or defend legal rights. We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.

In respect of personal data that we process in connection with the supply of our Services, we may retain your personal data for up to seven years from the date of supply of the relevant Services and in compliance with our data protection obligations. We may then destroy such files without further notice or liability.

Where we process personal data in connection with the registration and use of an account on our Sites, we may retain your personal data for up to seven years from the date that the relevant account is terminated (and in compliance with our data protection obligations). We may then destroy such files without further notice or liability.

Where we process any other personal data, we will retain relevant personal data for up to three years from the date of our last interaction with you (and in compliance with our data protection obligations). We may then destroy such files without further notice or liability.

If any personal data is only useful for a short period (e.g. for a specific market research activity, promotion or marketing campaign), we will not retain it for longer than the period for which it is used by us.

If you have opted out of receiving marketing communications from us, we will need to retain certain personal data on a suppression list indefinitely so that we know not to send you further marketing communications in the future. However, we will not use this personal data to send you further marketing unless you subsequently opt back in to receive such marketing.

14             Confidentiality and security of your personal data

We are committed to keeping the personal data you provide to us secure and we have implemented information security policies, rules and technical measures to protect the personal data under our control from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss. In addition, all our employees and data processors (i.e. those who process your personal data on our behalf) are obliged to respect the confidentiality of the personal data of all users of our Site and those who purchase our Services.

15             Personal data of minors

We may process personal data of minors (individuals aged 13 to 18 years old) in connection with the provision of our Services including through our youth service. We rely on the lawful bases set out above to process such personal data and where legally required we will obtain parental consent in order to process such personal data.

16             Your rights as a data subject

You have certain rights in relation to the personal data we hold about you. These rights include the right: (i) to obtain copies of your personal data; (ii) to have your personal data corrected or deleted; (iii) to limit the way in which your personal data is used; (iv) to object to our use of your personal data; (v) to transfer your personal data; (vi) not to be subject to decisions based on automated processing (including profiling); and (vii) to complain to a supervisory authority. If you would like to exercise any of these rights, please contact us using the details set out in the “above.

For more information about your specific data subject rights in certain jurisdictions, please see relevant jurisdiction specific section below.

17                COUNTRY SPECIFIC PROVISIONS

UNITED KINGDOM (“UK”) AND EUROPEAN ECONOMIC AREA (“EEA”)

This UK and EEA Privacy Statement supplements the Savanta Privacy Notice.  It applies to the extent our processing of your data is caught by the requirements of the UK GDPR and/or EU GDPR.

Transfers outside the UK and the European Economic Area (“EEA”)

We may transmit personal data outside the UK and EEA to certain categories (as listed above in Sharing your Personal Data and more specifically to (1) our headquarters in San Francisco (“US”); (2) Savanta Group entities, networks or partner agencies in for example, India and other locations globally.

Therefore, when you submit personal data to us, whether through your interactions with our Site, and branch offices or our headquarters in the US, you acknowledge that your personal data will be transferred outside the UK and the EEA to the US and other global locations where it will be stored and processed by us and our suppliers for the purposes set out in this Privacy Notice.

Where necessary in order to provide our Site and our Services, we will transfer personal data to countries outside the UK and the EEA.

Non-EEA countries do not have the same data protection laws as the UK and the EEA. In particular, non-EEA countries may not provide the same degree of protection for your personal data, may not give you the same rights in relation to your personal data and may not have a data protection supervisory authority to help you if you have any concerns about the processing of your personal data.

However, when transferring your personal data outside the UK or the EEA, we will comply with our legal and regulatory obligations in relation to your personal data, including having a lawful basis for transferring personal data and putting appropriate safeguards in place to ensure an adequate level of protection for the personal data. We will take reasonable steps to ensure the security of your personal data in accordance with applicable data protection laws.

When transferring your personal data outside the UK or the EEA, we will, where required by applicable law, implement at least one of the safeguards set out below. Please contact us if you would like further information on the specific mechanisms used by us when transferring your personal data outside the UK or the EEA.

Adequacy decisions We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission and/or the UK Government (as applicable).
Standard Contractual Clauses Where we use certain service providers, we may use specific standard contractual clauses approved by the European Commission and/or the UK Government which give personal data the same protection it has in Europe and/or the UK.

Your rights as a data subject

To the extent our processing of your data as a Data Controller is caught by the UK GDPR and/or EU GDPR, you have the following rights. If you would like to exercise any of these rights, please contact us using the details set out in the “How to Contact Us” section above.

 

Your right of access If you ask us, we will confirm whether we are processing your personal data and, if so, provide you with a copy of that personal data (along with certain other details). If you require additional copies, we may charge a reasonable fee for producing those additional copies.
Your right to rectification If the personal data we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If we have shared your personal data with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we will also tell you who we’ve shared your personal data with so that you can contact them.
Your right to erasure You can ask us to delete or remove your personal data in some circumstances, such as where we no longer need it or where you withdraw your consent (where applicable). If we have shared your personal data with others, we will let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal data with so that you can contact them directly.
Your right to restrict processing You can ask us to “block” or suppress the processing of your personal data in certain circumstances such as where you contest the accuracy of that personal data or you object to us processing it for a particular purpose. This may not mean that we will stop storing your personal data but, where we do keep it, we will tell you if we remove any restriction that we have placed on your personal data to stop us processing it further. If we’ve shared your personal data with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal data with so that you can contact them directly.
Your right to data portability You have the right, in certain circumstances, to obtain personal data you have provided to us (in a structured, commonly used and machine-readable format) and to reuse it elsewhere or to ask us to transfer it to your chosen third party.
Your right to object You can ask us to stop processing your personal data, and we will do so, if we are: (i) relying on our own or someone else’s legitimate interest to process your personal data, except if we can demonstrate compelling legal grounds for the processing; or (ii) processing your personal data for direct marketing purposes.
Your rights in relation to automated decision-making and profiling You have the right not to be subject to a decision when it is based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for the entering into, or the performance of, a contract between you and us.
Your right to withdraw consent If we rely on your consent (or explicit consent) as our legal basis for processing your personal data, you have the right to withdraw that consent at any time. You can exercise your right of withdrawal by contacting us using our contact details in the ““How to Contact Us” section above or by using any other opt-out mechanism we may provide, such as an unsubscribe link in an email.
Your right to lodge a complaint with the supervisory authority If you have a concern about any aspect of our privacy practices, including the way we have handled your personal data, please contact us using the contact details provided in the “How to Contact Us” section above. You can also report any issues or concerns to a national supervisory authority in the Member State of your residence or the place of the alleged infringement. You can find a list of contact details for all EU supervisory authorities at

As we are incorporated in the United Kingdom, our regulatory authority is the Information Commissioner’s Office (“ICO”). Contact details for the ICO can be found on its website at https://ico.org.uk.

UNITED STATES

California Consumer Privacy Statement

This California Consumer Privacy Statement (“Statement”) supplements the Savanta Privacy Notice.  It applies solely to California consumers and addresses personal information we collect online and offline.  This Statement does not apply to Savanta personnel.  Sections 2-5 of this Statement do not apply to job applicants.

 

This Statement uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 and its implementing regulations (the “CCPA”).

  1. Notice of Collection and Use of Personal Information 

We may collect (and may have collected during the 12-month period prior to the effective date of this Statement) the following categories of personal information about you:

  • Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, account name, Social Security number, driver’s license number, passport number, and other similar identifiers
  • Additional Data Subject to Cal. Civ. Code § 1798.80: signature, physical characteristics or description, state identification card number, insurance policy number, education, bank account number, credit card number, debit card number, and other financial information, medical information, and health insurance information
  • Protected Classifications: characteristics of protected classifications under California or federal law, such as race, color, national origin, religion, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, medical condition, ancestry, genetic information, disability, citizenship status, and military and veteran status
  • Commercial Information: commercial information, including records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies
  • Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements
  • Sensory Information: audio, electronic, visual, and similar information
  • Employment Information: professional or employment-related information
  • Education Information: education information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99)
  • Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behaviour, attitudes, intelligence, abilities, and aptitudes.

We may use (and may have used during the 12-month period prior to the effective date of this Statement) your personal information for the purposes described in our Privacy Notice and for the following business purposes specified in the CCPA:

  • Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services
  • Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance
  • Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction
  • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
  • Debugging to identify and repair errors that impair existing intended functionality
  • Undertaking internal research for technological development and demonstration
  • Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.
  • Managing career opportunities with Savanta.

 

  1. Sources of Personal Information

During the 12-month period prior to the effective date of this Statement, we may have obtained personal information about you from the following categories of sources:

  •  Directly from you, such as when you contact us with a question or comment
  •  From your devices, such as when you visit our Site
  •  Vendors who provide services on our behalf
  •  Social networks
  •  Government entities
  •  Data brokers

 

  1. Sale of Personal Information

We do not and will not sell your personal information.

  1. Sharing of Personal Information

During the 12-month period prior to the effective date of this Statement, we may have shared your personal information with certain categories of third parties, as described below.

We may have disclosed the following categories of personal information about you for a business purpose to the following categories of third parties:

 

Category of Personal Information Category of Third Party
Identifiers Our affiliates and subsidiaries; Vendors who provide services on our behalf; Professional services organizations, such as auditors and law firms; Our business partners; Advertising networks; Internet service providers; Data analytics providers; Operating systems and platforms; Social networks
Additional Our affiliates and subsidiaries; Vendors who provide services on our behalf; Professional services organizations, such as auditors and law firms; Our business partners; Advertising networks; Internet service providers; Data analytics providers; Operating systems and platforms; Social networks
Protected Classifications Our affiliates and subsidiaries; Vendors who provide services on our behalf; Professional services organizations, such as auditors and law firms; Our business partners; Advertising networks; Internet service providers; Data analytics providers; Operating systems and platforms; Social networks
Commercial Our affiliates and subsidiaries; Vendors who provide services on our behalf; Professional services organizations, such as auditors and law firms; Our business partners; Advertising networks; Internet service providers; Data analytics providers; Operating systems and platforms; Social networks
Online Activity Our affiliates and subsidiaries; Vendors who provide services on our behalf; Professional services organizations, such as auditors and law firms; Our business partners; Advertising networks; Internet service providers; Data analytics providers; Operating systems and platforms; Social networks
Employment Information Our affiliates and subsidiaries; Vendors who provide services on our behalf; Professional services organizations, such as auditors and law firms; Our business partners; Advertising networks; Internet service providers; Data analytics providers; Operating systems and platforms; Social networks
Education Information Our affiliates and subsidiaries; Vendors who provide services on our behalf; Professional services organizations, such as auditors and law firms; Our business partners; Advertising networks; Internet service providers; Data analytics providers; Operating systems and platforms; Social networks
Inferences Our affiliates and subsidiaries; Vendors who provide services on our behalf; Professional services organizations, such as auditors and law firms; Our business partners; Advertising networks; Internet service providers; Data analytics providers; Operating systems and platforms; Social networks

In addition to the categories of third parties identified above, during the 12-month period prior to the effective date of this Statement, we may have shared personal information about you with the following additional categories of third parties: Government entities.

  1. California Consumer Privacy Rights 

You have certain choices regarding our use and disclosure of your personal information, as described below.

 

Access: You may have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold about you during the past 12 months.

 

Deletion: You have the right to request that we delete certain personal information we have collected from you.

 

How to Submit a Request: To submit an access or deletion request (or to submit a request as an authorized agent on behalf of a consumer), please contact us as described in “How to Contact Us” section above.

 

Verifying Requests: To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. If you request access to or deletion of your personal information, we may require you to provide any of the following information:  your email address, the name of the Savanta representative with whom you typically interact, and the date of your last interaction with a Savanta representative.  In addition, if you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.

 

Additional Information: If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us.  To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.