Directions Research Privacy Policy

Privacy Policy
Directions Research, Inc. (“DIRECTIONS”) is a full-service custom market research firm that conducts qualitative and quantitative studies with consumers and businesses. Market research is a tool used by all sorts of organizations to obtain feedback from customers, potential customers and other stakeholders. The information collected in a research context may be used to plan new products or services, gauge customer satisfaction, measure awareness of products or services, or to test reaction to products, services or communications. DIRECTIONS is committed to respecting and protecting your privacy whether you are a research respondent who is participating in a study or an individual visiting DIRECTIONS’ website to obtain information about DIRECTIONS’ services. This policy explains how DIRECTIONS collects and uses data that DIRECTIONS obtains via DIRECTIONS’ website or through surveys and other primary research methods that DIRECTIONS uses on behalf of DIRECTIONS’ clients. This policy will explain this in a way that is easy to understand and DIRECTIONS provides ways for you to seek additional information or clarification. In addition, DIRECTIONS provides a means of resolving issues or complaints. DIRECTIONS is a member of the Counsel of American Survey Research Organizations (CASRO) and adheres to their Code of Standards and Ethics for Survey Research which includes specific responsibilities to individuals who participate in our market research surveys. You may read this code at CASRO.org. If you are visiting DIRECTIONS’ website or participating in one of DIRECTIONS’ research studies from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States. This Privacy Policy applies to all personal information received by DIRECTIONS whether in electronic, paper or verbal format.

PERSONAL INFORMATION
“Personal Information” or “PI” is information recorded in any form that identifies an individual or can be used to identify an individual. It includes an individual’s name, identification numbers, date of birth, gender, mailing address, phone numbers, email address and other similar information. It may include information about an individual’s personal opinions and preferences. It does not include information that has been converted to be anonymous, aggregated information or information that is publicly available.
US-EU AND US-SWISS SAFE HARBOR
DIRECTIONS complies with the US-EU Safe Harbor Framework and US-Swiss Safe Harbor Framework established by the US Department of Commerce which relates to the collection, use, and retention of personal information from EU member countries and Switzerland. DIRECTIONS has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view our certification, please visit http://www.export.gov/safeharbor/
COLLECTION OF PERSONAL INFORMATION - NOTICE
DIRECTIONS collects your Personal Information in the following ways: You provide it to DIRECTIONS on the DIRECTIONS website (or otherwise) in connection with an inquiry about DIRECTIONS’ services or participation in DIRECTIONS surveys. You provide it to DIRECTIONS in the course of participating in research, either directly to DIRECTIONS or to a third party that conducts research services (such as surveys) on our behalf. We obtain it from clients who ask DIRECTIONS to conduct research on their behalf; or we obtain it from list or survey panel providers. When DIRECTIONS obtains contact PI from third parties, DIRECTIONS requires those third parties to provide assurances that their lists are made up only of individuals who have given their permission to be included in the list, participate in the survey panel and/or be contacted for market research purposes. In such cases, DIRECTIONS will comply with the contact limitations and data protections to which you agreed when you provided that permission. DIRECTIONS may collect and use PI obtained from publicly available sources, where this is permitted by law. Most research surveys include demographic questions such as racial or ethnic origin, age, gender or income. DIRECTIONS uses these questions to help confirm that the research reflects a representative sample of the population DIRECTIONS is studying. DIRECTIONS will never ask you for certain information which, if stolen or misused, could give rise to economic crimes against you, such as bank account or credit card numbers, social security or other similar government-issued ID numbers. DIRECTIONS also automatically collects information that is made available by the device you use to access DIRECTIONS’ website for system administration, service improvement, data analysis, and data integrity purposes to ensure that survey respondents do not impermissibly duplicate participation in the same survey. The information automatically collected for this purpose, as well as other PI, may be shared with third parties for the purposes of detecting and preventing impermissible duplicate participation in the same survey.
HOW WE USE YOUR INFORMATION
If you provide PI to DIRECTIONS in order to inquire about DIRECTIONS’ services, DIRECTIONS will use that PI only to contact you about DIRECTIONS’ services.
CHOICE
DIRECTIONS will not sell or provide your information to any third party for any other use. If DIRECTIONS receives your PI from a list or panel company, DIRECTIONS will use it only to ask you to participate in market research, to conduct survey research with you, to validate answers that you give, or to respond to requests to DIRECTIONS from you. DIRECTIONS will also not use your PI in any way that is inconsistent with the research or other purpose for which you agreed to be contacted. If DIRECTIONS receives your contact PI from DIRECTIONS’ client and you are a customer of that client, DIRECTIONS will use your contact PI only to ask you to participate in market research and, if you agree to participate, as otherwise described in the paragraph above. Your participation is voluntary. You are entitled at any stage of the interview or survey, or afterward, to ask that part or all of your information be destroyed. Wherever reasonable and practical, we will carry out such a request. Should you wish to opt-out of any survey please notify us at privacy@directionsresearch.com or through the mechanism provided in the survey invitation.
ONWARD TRANSFER
DIRECTIONS will protect your anonymity when communicating your research responses to clients. DIRECTIONS will share your PI with its clients only with your express permission or request, or as otherwise permitted by the CASRO Code of Standards and Ethics for Survey Research. DIRECTIONS will provide your PI to DIRECTIONS’ contractors who perform market research functions on behalf of DIRECTIONS, but only to perform such functions on our behalf and for our purposes under confidentiality agreements or other appropriate confidentiality assurances. Whether DIRECTIONS obtains your PI directly, through a contractor performing services for DIRECTIONS, or from a third party, DIRECTIONS will not use this information to sell you any goods or services and DIRECTIONS will not provide your PI to any other party so that they may contact you for the purpose of selling you goods or services. DIRECTIONS may, itself or through a contracted third party, occasionally re-contact you to validate your participation in a research study; DIRECTIONS will identify itself or be identified by the third party and DIRECTIONS’ will state its purpose when DIRECTIONS conducts such validation contacts. DIRECTIONS may share your PI as required by law or in the interest of protecting or exercising the legal rights of DIRECTIONS or others, including, for example and without limitation, in connection with requests from law enforcement officials and in connection with court proceedings. DIRECTIONS may share or transfer your PI in connection with a prospective or actual sale, merger, transfer or other reorganization of all or parts of DIRECTIONS’ business.
ACCESS
You may access the personal information DIRECTIONS holds about you in order to correct, amend, or delete that information where it is inaccurate by contacting privacy@directionsresearch.com.
SECURITY
DIRECTIONS takes reasonable precautions to protect your personal information from loss, unauthorized access, disclosure, alteration and destruction. Included on our website is information outlining such security precautions.
DATA INTEGRITY
Personal information collected by DIRECTIONS is relevant for its intended purpose and, to the extent necessary, reasonable steps are taken to ensure data is reliable for its intended use, accurate, complete and current. Our experienced market researchers, average 15+ years of industry experience, many with advanced degrees. They understand the limits of data extrapolation and have developed processes to ensure accurate data handling and quality assurance steps throughout the data handling process.
COOKIES AND DIGITAL FINGERPRINTING
A cookie is a small text file containing information about the user of a website that is placed by the website on the hard drive of the user’s device, including the IP address of the user’s device. DIRECTIONS uses cookies to recognize you when you visit DIRECTIONS website and to maintain the state of your session on the DIRECTIONS website throughout your activities there. DIRECTIONS also uses information regarding those activities for the purposes of system administration and to improve the user experience on the DIRECTIONS website. DIRECTIONS might from time to time use digital fingerprinting technologies. In general, digital fingerprinting technologies assign a unique identifier or “Machine-ID” to a user’s computer to identify and track the computer’s survey activity. DIRECTIONS will use this technology only to ensure the integrity of survey results, such as ensuring that a survey respondent is not taking the same survey multiple times. DIRECTIONS will not use digital fingerprinting technology to collect personal information, track the online activities of the user of a computer, disrupt or interfere with the use or control of a computer, or alter, modify or change the settings or functionality of a computer.
THIRD-PARTY SITES AND EXTERNAL LINKS
If you have provided your contact PI to a third party that has, in turn, provided it to DIRECTIONS, or if DIRECTIONS’ general website or any survey DIRECTIONS conducts links you to other sites (or, in the case of a survey, is hosted on another site), those sites do not operate under this Privacy Policy. DIRECTIONS recommends that you examine the privacy statements posted on those other websites to understand their procedures for collecting, using, and disclosing PI.
TO CONTACT US WITH A COMPLAINT OR INQUIRY
If you have any questions, complaints or problems related to the way DIRECTIONS collects or uses your information, if you wish to opt out of any contact list, or have a concern with DIRECTIONS’ privacy policy in general, please contact DIRECTIONS. DIRECTIONS will attempt to respond to your inquiry and correct any problem within 30 days.
Write to DIRECTIONS at:
Privacy Officer
Directions Research, Inc.
401 East Court Street
Suite 200
Cincinnati, OH 45202
513.651.2990 (phone)
513.651.2998 (fax)

DIRECTIONS has further committed to refer unresolved privacy complaints under the US-EU and US-Swiss Safe Harbor Privacy Principles to an independent dispute resolution mechanism, the CASRO SAFE HARBOR PROGRAM. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by Directions Research, Inc., please visit the CASRO SAFE HARBOR PROGRAM website at https://www.casro.org/?complaintcasrosh for more information and to file a complaint.
CHANGES TO THIS PRIVACY POLICY
DIRECTIONS may update this Privacy Policy in the future. DIRECTIONS reserves the right to update this Privacy Policy and communicating that change simply by posting the updated policy and without any express notice to you. DIRECTIONS encourages you to check this Privacy Policy from time to time to ensure that you have reviewed and are aware of any updates.
Effective Date: May, 2014
Last Updated: May, 2015