2. 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, postal address, phone numbers, email address, media (audio, images and video) which include properties sufficient to identify an individual, 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.
3. EU-US AND SWISS-US PRIVACY SHIELD
DIRECTIONS, including SEEK Company, complies with the EU-US and Swiss-US Privacy Shield frameworks 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 seven primary privacy principles of notice, choice, onward transfer, security, data integrity, access and enforcement. Certifying adherence makes DIRECTIONS subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission. It also makes it possible, under certain conditions, for you to invoke binding arbitration as described in the Frameworks. DIRECTIONS also adheres to the sixteen supplemental privacy principles found in the EU-US and Swiss-US Privacy Shield Frameworks. To learn more about these programmes, and to view our certification, please visit https://www.privacyshield.gov/list.
4. 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.
5. 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.
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 afterwards, to ask that part or all of your personal data 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 email@example.com or through the mechanism provided in the survey invitation.
7. 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 Insights Association Code of Standards and Ethics for Market Research and Data Analytics. DIRECTIONS will provide your PI to DIRECTIONS’ contractors who provide support services to DIRECTIONS in its execution of Marketing Research Surveys, but only to perform such functions on our behalf and for our purposes under confidentiality agreements or other appropriate confidentiality assurances. In such cases, DIRECTIONS will share only the minimum PI necessary and maintain liability for those data processors. DIRECTIONS and those additional support services are defined as Service Providers under the California Consumers Privacy Act (CCPA). 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 reorganisation of all or parts of DIRECTIONS’ business.
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:
Directions Research, Inc.
401 East Court Street
Cincinnati, OH 45202
DIRECTIONS takes reasonable precautions to protect your personal information from loss, unauthorised access, disclosure, alteration and destruction. Information outlining such security precautions is included on our websites.
10. DATA INTEGRITY AND PURPOSE LIMITATION
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.
12. THIRD PARTY SITES AND EXTERNAL LINKS
13. TO CONTACT US WITH A COMPLAINT OR INQUIRY
Write to DIRECTIONS at:
Directions Research, Inc.
401 East Court Street
Cincinnati, OH 45202
DIRECTIONS has further committed to refer unresolved privacy complaints under the EU-US and Swiss-US Privacy Shield Principles to the INSIGHTS ASSOCIATION PRIVACY SHIELD PROGRAM, a non-profit alternative dispute resolution provider located in the United States and operated by the Insights Association. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.insightsassociation.org/Resources/Privacy-Shield/Information-for-EU-Swiss-Citizens-to-file-a-complaint for more information and to file a complaint.
Effective Date: August, 2020
Last Updated: August, 2020