Privacy Policy
Effective Date: 7/1/2020
We at Hannah Marketing, Inc. d/b/a Guest Research, Inc., (“Guest Research”) are concerned about your privacy and are
committed to protecting your personal information. We know you share our concerns, and in the interest of letting you
know how we protect the privacy and security of the personal information you provide to us, we provide the information below.
I.ACCEPTANCE OF THIS PRIVACY POLICY
In order to produce Guest Research surveys and responses to our customers and provide them with materials relevant to the
surveys (“Services”) we require certain personal information (your “personal information”) that includes information that
identifies guests of our clients, employees of our clients and website visitors (collectively “you” or “your”), with
regard to the need to meet certain legal requirements, the location from which they send us your personal information.
We will take commercially reasonable measures to protect the privacy and security of your information, but if you do not
agree with this Privacy Policy or the additional descriptions of how we process your personal information (how we use, share,
disclose, store and delete it), you should not use our Services.
II.PERSONAL INFORMATION WE COLLECT OR RECEIVE
In the course of providing our Services, and as required for us to provide our services to you, we receive, collect, store and use your personal information, as described below. This information may include your name, address, telephone number, email address and the IP address of the device you used to contact us. The ways in which we obtain your information may include:
- Information you share with us through our website, post on the site or send to us by email or text.
- Participation in surveys and questionnaires.
- Data obtained through use of “cookies” is described in Section V, below.
- Apps or other software created or developed for use in connection with Guest Research satisfaction and other Guest Research surveys.
- The legal bases for our uses, sharing and disclosures (“processing”) of your personal information include, as pertinent, where:
- Necessary to perform the contractual obligations in agreements with you to provide access to our services as stated in the preceding paragraph.
- You have consented to the processing as set out in this Policy, which consent you can revoke at any time;
- Necessary to comply with a legal obligation, a court order or to exercise or defend a legal claim;
- Necessary for the purposes of our or a third-party’s legitimate business interests (so long as those interests do not override personal rights as indicated by law);
- You have expressly made your personal information public; and
- Necessary to protect your vital interests or other of others.
III.CHILDREN'S ONLINE PRIVACY PROTECTION
Guest Research complies with the Children's Online Privacy Protection Act, which requires the consent of a parent or guardian for the collection of personally identifiable information from children under 13 years of age. Guest Research does not knowingly collect, use or disclose personal information from children under 13, or equivalent minimum age in the relevant jurisdiction, without verifiable parental consent. However, it is possible that we may inadvertently receive information pertaining to children under 13. If you believe that we have received information about your child that is under the age of 13, please do not hesitate to notify us at
. When we receive your notification, we will obtain your consent to retain the information or will delete it permanently.
IV.USES OF PERSONAL INFORMATION BY GUEST RESEARCH FOR GUEST RESEARCH'S BUSINESS PURPOSES
If you elect to provide us personal information, we may use it as needed to deliver the Services to you. Guest Research may use personal information in a variety of ways to meet our obligations to you to provide you access to the Services. These uses are based in our legitimate business interests in providing services to you and/or fulfillment of our contractual obligation to deliver services you have requested. We have balanced these business needs carefully with your privacy rights and these uses do not improperly infringe on your privacy and confidentiality rights. These business uses for your personal information include the following:
- Guest Research may combine information about you that we have with information we obtain from business partners or other companies in order to better deliver services that may be of interest and benefit to you.
- We may use your personal information for maintenance and enhancement of the security of the digital information we collect and use, including analysis of the personal information to pursue the legitimate business interest in protecting our customers and website visitors against malware, cyber-attack and other crime and security risks.
- Guest Research may use personal information to contact users regarding newsletters and Guest Research services, and to send announcements or special edition e-letters to online registrants.
- We may aggregate and anonymize personal information provided under this Privacy Policy to create anonymized data sets which will then be used to improve our and our affiliates’ services. We may also share aggregated anonymized personal information with clients, prospective clients and customers or business partners in order to demonstrate usage of the services, or to identify industry and advertising trends. We do not share information that identifies individual visitors to our website with third parties.
- We may share personal information where we have a good faith belief that such action is necessary to comply with a judicial proceeding, a court order, or legal process served on Guest Research or to establish or exercise our legal rights or defend against legal claims.
- We may share such information where we have a good faith belief that it is necessary in order to investigate (or assist in the investigation of), prevent, or take action regarding illegal activities, suspected fraud, cyber attack, situations involving potential threats to the physical safety of any person, violations of Guest Research’s terms of use, or as otherwise required by law.
- If Guest Research is acquired by or merged with another company, we will transfer information about you to this other company in connection with the acquisition or merger.
- Guest Research provides a variety of research surveys to its clients. Users may decline to answer any question they wish. Email promotions and/or mass emails sent by Guest Research provide an opt-out link at the bottom of the email pursuant to which users can opt-out of specific services and promotions. If you receive one of these emails and wish to object to this processing of your information or unsubscribe please follow the instructions given in each email or contact . Opt-out requests will be complied within 15 business days.
From time to time we may use customer information for new, unanticipated uses not previously disclosed in our Privacy Policy. If our information practices change at some time in the future, we will post the policy changes to our website.
Right to object. If you are located within the European Union or a country that has adopted the relevant provisions of the GDPR or are located within the state of California that has adopted the relevant provisions of the CCPA (California Consumer Privacy Act), you may object to Guest Research using your personal information for the above purposes at any time by contacting
. If you do so, Guest Research will cease using your personal information for the above purposes (i.e., under a legitimate interest set out above) and remove it from its systems unless such personal information is permitted to be used by Guest Research for another purpose set out in this Privacy Policy or Guest Research determines and demonstrates a compelling legitimate interest to continue in processing your personal information.
V.SHARING OF PERSONAL INFORMATION WITH THIRD PARTIES
Guest Research does not rent, sell, or share personal information about you with other people or nonaffiliated companies except to provide the Services you have requested, when we have your consent as indicated in Section I of this Policy, as follows:
- Guest Research may from time to time share limited personal information such as email addresses, company name, job title and state of business or residence with trusted third parties such as our clients and their vendors so they may deliver content that is likely to be of interest to you.
VI.COOKIES
We may automatically collect certain information when you visit our website. This information may include information about your Internet service provider, your operating system, browser type, domain name, Internet protocol (IP) address, your access times, the website that referred you to us, the Web pages you request, and the date and time of those requests. Our collection of website use information may involve the use of cookies and Web beacons. Cookies are small data files stored on your hard drive by a website. Among other things, cookies help us improve our Sites and your experience. We do not share this information with anyone. On our website, Guest Research may use this passively collected data to:
- remember your information so that you will not have to re-enter it during you visit or the next time you visit our website.
- monitor your participation in various sections of our website.
- customize services to you.
- monitor website usage metrics such as total visitors and pages viewed administer, operate and improve our website.
VII.CHOICE AND CONTROL
You may, if you are located within the European Union or a country that has adopted the European Union’s General Data Protection Regulation, or in the state of California’s (in the United States) California Consumer Privacy Act, or if laws otherwise require, withdraw your consent or otherwise object to uses of your information as described above by contacting
. You may also withdraw your consent to email marketing by unsubscribing, using the unsubscribe link in such communications. If you do so, Guest Research will cease using your personal information for the above purposes and remove it from its systems unless such personal information is permitted to be used by Guest Research for another purpose set out in this Privacy Policy or Guest Research determines and demonstrates a compelling legitimate interest to continue in processing your personal information. In case of withdrawal of consent, Guest Research will not process your personal information subject to this consent any longer unless legally required to do so. In case Guest Research is required to retain your personal information for legal reasons your personal information will be restricted from further processing and only retained for the term required by law. However, any withdrawal has no effect on past processing of personal information by Guest Research up to the point in time of your withdrawal. Furthermore, if your use of a Guest Research offering requires your prior consent, Guest Research will not be (any longer) able to provide the relevant product or service to you after your withdrawal. Please direct any such request for withdrawal to, or write to Guest Research at
.
You can request from Guest Research, at any time, information about which personal information Guest Research processes about you and the correction or deletion of such personal information. If Guest Research uses your personal information to perform a contract with you, you may further request a copy of the personal data that you have provided to Guest Research. To make such a request, please contact us at the email address set forth below and specify in detail the information or the activity to which your request relates, the format in which you would like the personal data returned and the recipient (you or your designee). Furthermore, you may contact Guest Research if you believe that the personal information that Guest Research has is incorrect.
If you are located within the European Union or a country that has adopted the European Union’s General Data Protection Regulation (“GDPR”) or in the United States in the state of California (California Consumer Privacy Act), you may benefit from a number of rights with regard to your personal information that we process. These rights are defined and, in some cases limited, by the laws of your jurisdiction. These rights include (a) data portability, including the right to obtain a copy of the personal information you have provided to Guest Research; (b) data correction (also known as rectification, including the ability to request correction or amendment of your personal information and (c) data deletion, including the right to have Guest Research delete your personal information except for information that we are required to retain. Your right to have your personal information deleted does not apply, however, where the information is necessary:
The identity of those requesting to access or delete their personal information will be verified by Guest Research through a process of comparing the information collected to that provided by the requester. If verification cannot be completed within 45 days, Guest Research may deny the request.
Your right to have Guest Research cease processing your personal information is dependent upon the following events: (i) you state that the personal information Guest Research has about you is incorrect; but Guest Research may retain the information for as long as it requires to check the accuracy of the relevant personal information; (ii) there is no legal basis for Guest Research’s processing of your personal information and you demand that Guest Research restrict your personal information from further processing, (iii) Guest Research no longer requires your personal information but you claim that you require such data in order to claim or exercise legal rights or to defend against third party claims; or (iv) in case you object to the processing of your personal information by Guest Research it may retain and process the information for as long as it is required to review as to whether Guest Research has a prevailing interest or legal obligation in continuing to process your personal information.
You may inquire about the exercise of these rights and, if the laws of your jurisdiction permit, exercise them as permitted by law by contacting .
You can request from Guest Research, at any time, information about which personal information Guest Research processes about you and the correction or deletion of such personal information. If Guest Research uses your personal information to perform a contract with you, you may further request a copy of the personal data that you have provided to Guest Research. To make such a request, please contact us at the email address set forth below and specify in detail the information or the activity to which your request relates, the format in which you would like the personal data returned and the recipient (you or your designee). Furthermore, you may contact Guest Research if you believe that the personal information that Guest Research has is incorrect.
If you are located within the European Union or a country that has adopted the European Union’s General Data Protection Regulation (“GDPR”) or in the United States in the state of California (California Consumer Privacy Act), you may benefit from a number of rights with regard to your personal information that we process. These rights are defined and, in some cases limited, by the laws of your jurisdiction. These rights include (a) data portability, including the right to obtain a copy of the personal information you have provided to Guest Research; (b) data correction (also known as rectification, including the ability to request correction or amendment of your personal information and (c) data deletion, including the right to have Guest Research delete your personal information except for information that we are required to retain. Your right to have your personal information deleted does not apply, however, where the information is necessary:
- for exercising the right of freedom of expression and information;
- for compliance with a legal obligation which requires processing by European Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
- for reasons of public interest in the area of public health in accordance with points (h) and (i) of Article 9(2) as well as Article 9(3);
- for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
- for the establishment, exercise or defense of legal claims.
The identity of those requesting to access or delete their personal information will be verified by Guest Research through a process of comparing the information collected to that provided by the requester. If verification cannot be completed within 45 days, Guest Research may deny the request.
Your right to have Guest Research cease processing your personal information is dependent upon the following events: (i) you state that the personal information Guest Research has about you is incorrect; but Guest Research may retain the information for as long as it requires to check the accuracy of the relevant personal information; (ii) there is no legal basis for Guest Research’s processing of your personal information and you demand that Guest Research restrict your personal information from further processing, (iii) Guest Research no longer requires your personal information but you claim that you require such data in order to claim or exercise legal rights or to defend against third party claims; or (iv) in case you object to the processing of your personal information by Guest Research it may retain and process the information for as long as it is required to review as to whether Guest Research has a prevailing interest or legal obligation in continuing to process your personal information.
You may inquire about the exercise of these rights and, if the laws of your jurisdiction permit, exercise them as permitted by law by contacting .
VIII.SECURITY
The security of your personal information is very important to us. We utilize commercially reasonable information security standards to protect your personal information from unauthorized access, use or disclosure. Guest Research supports online security using appropriately secure technology because we want your data to be safe. We bind our employees and data processors to written agreements to observe your privacy and confidentiality rights. Unfortunately, no method of internet transmission is one hundred percent secure. While we strive to protect your personal information, we cannot guarantee its security.
IX.DURATION AND RETENTION
Guest Research will retain your personal information only for as long as is necessary for the purposes set out in this Policy, or as required or permitted by law, and then will delete it as required by law. For example, Guest Research will retain your information as long as required to comply with applicable tax/revenue laws, cybersecurity and privacy laws, laws and regulations that affect the conduct of our business; to resolve disputes, enforce our agreements, cooperate with law enforcement requests or to meet other legal obligations. We may also retain log files for internal analysis purposes, though we would retain them for only a brief period except in cases where we are legally required to retain them for longer periods, and in cases where they are used for site safety and security or to improve website functionality.
X.INTERNATIONAL TRANSFERS
Guest Research operates on a global basis. By using our Services you understand and agree that your personal information may be transferred from the European Economic Area (EEA, which comprises the European Union countries plus Norway, Iceland, Liechtenstein) to a country that does not have an equivalent level of data protection, such as the United States. When your personal information is transferred from your home country to another country, the laws and regulations that protect your personal information may be different than those in your home country. In particular, if your information is in the US, it may be accessed by government authorities in accordance with US law.
To the extent that Guest Research is deemed to transfer your personal information outside the EEA, Guest Research relies upon data transfer agreements with Model (Standard) Contract Clauses, which the European Commission has adopted to provide safeguards for personal information that is transferred outside the EEA. You may obtain a copy of the Model Clauses by contacting
.
XI.CONTACT
If you have questions regarding this Privacy Policy, wish to lodge a complaint or wish to exercise the rights in the Choice and Control section of the Policy, you may contact
.
XII.UPDATES TO THIS PRIVACY POLICY
We may occasionally update this Privacy Policy. If we do, we will change the “effective date” at the top of the Privacy Policy. Before making any update that would make this Privacy Policy materially less restrictive in our use or disclosure of personal information collected prior to the update we will, where it is practicable to do so, provide prior notice of the update by posting the fact that we plan to update the notice on our Website at the top of the then-current Privacy Policy within a reasonable time before the effective date of the update. We encourage you to periodically review this Privacy Policy to stay informed about our collection, use, and disclosure of personal information.