Toluna complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. Toluna 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 Toluna's certification, please visit http://www.export.gov/safeharbor.
The information we gather
Toluna gathers personal information when an individual registers to become a member of our panels. Your participation in any of our panels and surveys is voluntary. After registration we ask panel members to provide us with more personal information so that we may invite them to appropriate surveys. To become a Transamerica Customer Advisory Panel ("Community"), we ask that you fill out a registration survey that gathers some personal and general consumer information. We ask for your email address so that we can send you email invitations to participate in our upcoming surveys and subject to the preferences you expressed when registering, to send you newsletters to make you aware of new features or contests running on the site. The other information we gather, such as your name, address, gender, birthday and employment status is for matching you with the appropriate marketing research projects. Your birthday is used to automatically update your age for us to target age-related marketing groups. We ask you for this information as a means to see if you might qualify for particular projects. All email contact from Community will be sent to your primary email address that you gave to us upon registration. If you become a Community member, your information (name, address, city, state, and zip) is also used for the purposes of incentive fulfillment. When incentive points are deposited in your account and you wish to redeem them or you are determined as the winner of physical gift card in a sweepstakes, this information is required so that we may send your reward to the appropriate recipient address. From time to time, a third party may be used for issuing checks or processing the delivery of rewards; your personal information will not be used for any other reason, but to mail you your reward.
In some circumstances, Toluna may ask you to inform us of your sensitive personal data, unless we are permitted to process such sensitive personal data by law, we will ask for your consent. In general sensitive data that may be collected by Toluna may cover: your racial or ethnic origin; your political opinions; your physical or mental health or condition; and your sexual life. This information is not shared with any third party, except as required by law and as part of a transfer of Toluna's business.
You should be aware that any personal information you choose to make public on the site, in the Community area (as an opinion or topic in a message board or live chat or any other public area or forum) can be read, collected, or used by other users and could be used to send you unsolicited messages. We are not responsible for the personal information you choose to submit or make public. In addition, we are not responsible for the content you publicly post on the site that can be found via web-based search engines. To request removal of your personal information from our blog or community forum, contact us at firstname.lastname@example.org. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
We display personal testimonials of satisfied customers on our site in addition to other endorsements. With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at email@example.com
Use of this information
Toluna does not sell or transfer the personal information collected about the members of its panels or the individuals that take surveys for us. Information which is personally identifiable will only be transferred with your prior permission on a case by case basis, except for the narrow exceptions specified below. If you are a member of the Community, your information is stored in our proprietary database so we may call upon it to determine which people match up with specific research studies. If we think your profile makes you a potential candidate for a study, we will email you an invitation to make you aware of this opportunity. From time to time Toluna may use third-party software for email list management and email distribution, or may use third party list management providers to match the members of our Panel to members of other lists or panels, or to validate accuracy of personal information you provide. We may use third parties to provide us with data they have collected about you, and append this data to your demographic profile. In such cases only a minimum amount of information is transferred to these third parties so as to enable them to perform specific functions on our behalf. We also may share your information with our service providers, such as to provide prizes you have won or other incentives for your participation in our panels.
Your information may be transferred to other countries, including the United States. All such transfers shall solely be made in accordance with applicable law.
Though we make every effort to preserve your privacy, we may need to disclose your personal information when we have a good-faith belief that such action is necessary to comply with a judicial proceeding or a court order or if we believe it is necessary in order to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of the Toluna site terms, or as otherwise required by law. Toluna may also disclose your personal information to third parties where it has your express permission to do so, or where it can reasonably be inferred from the circumstances that you consent to the disclosure to the third parties.
One or more "cookies" will be placed on the hard disk of the computer(s) used by site visitors, panelists and survey takers in order to allow Toluna to recognize the participant when they connect to the Toluna website, in order to facilitate the management of Toluna, for statistical purposes (pages consulted, date and time of consultations etc.), and to enable us to provide the participant with surveys specifically tailored to his / her interests. This will not affect the performance of your computer but simply provide you with additional opportunities to receive more surveys relevant to your interests.
By the use of the site all site users authorize cookies to be put in place and their use by Toluna and Toluna's clients and business partners. The cookies will expire after one year.
Site users may disable the installation of "cookies" or to delete cookies installed by Toluna or its clients. To do so you should modify your browser settings click on the help section of your Internet browser and follow the instructions.
Digital Finger Printing:
Toluna shall use commercially reasonable efforts to ensure that the technology is safe, secure and does not cause undue privacy or data security risks.
In the event that Toluna discovers or learns of any unethical conduct in connection with the use of the technology, or that the technology is being used in a manner that is inconsistent with the statements and/or disclosures made by Toluna to respondents or in violation of applicable Laws and Codes, Toluna will take immediate action to prohibit such unethical conduct and to ensure the proper administration of the technology.
Many browsers including Internet Explorer, Firefox, and Google Chrome contain a "do not track" optional setting. In general, when a "do not track" setting is active, the user's browser notifies websites that the user does not want the user's personally identifiable information about an individual consumer's online activities tracked over time and across different Web sites or online services. Websites are not required to honor a do not track request and as required by amendments to the California Shine the Light law, we are informing you that we do not honor such requests.
Access to Your Information; Member Services Area/Update, Correct, Delete Information
You have the right to gain access to your data and correct it. In order to access this data you may either write to the address below or Contact Us at firstname.lastname@example.org.
We provide you with a Members Area on our site; here you may correct or update your membership information or delete your membership. If you are a panel member and delete your membership, your profile information will be permanently removed, but may be stored in our disaster recovery databases, and in such circumstances will not be used for commercial purposes. Please note that in most cases, it will take two or three business days for your information to be completely removed from our records; but please allow up to fifteen days.
By becoming a Community member, you agree to receive Emails inviting you to participate in surveys that we feel may match your experiences and background. From time to time, we will also email newsletters to you to make you aware of new features or contests running on our site. You may update your registration information at any time. Please see Correct/Update Policy below.
If you need to correct any of your profile information or if you would like to update any of your information, you may automatically do so by clicking on Your Profile after logging in. By following the appropriate directions, your information should be automatically updated in our database.
If you choose to end your membership with Community or to require us to cease processing your personal data, you may automatically discontinue your membership by clicking Unsubscribe in the footer of our Homepage or by contacting us at email@example.com. By following the appropriate directions, your record will be marked as "unsubscribed", and you will no longer receive communications from the Community. In addition, you will forfeit any incentive balance that has not been requested as of the time you opt out. In most cases it will take 2 to 3 days to process this change, but please allow up to two full weeks for your status to be finalized. In the meantime, you may receive emails from us. Email links are provided on the site so that you may contact us directly with any questions or concerns you may have. Each email we receive is read and responded to individually; please allow two to three business days for us to get back to you.
We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Winners policy and privacy guarantee
Community members are randomly selected to win prizes for participation in surveys, polls, and other promotions. All winners are notified by email of their winnings. For more information, please visit our Terms and Conditions page. Toluna shall post the usernames or first name and first initial of last name of winners on the Reward Page or communicate them via newsletter to all panelists.
Notification of changes
We reserve the right to modify this privacy statement at any time, so please review it frequently. If we make material changes to this policy, we will notify you here, by Email, or by means of a notice on our home page prior to the change becoming effective.
Social Media Widgets
You may be able to log in to our site using sign-in services such as Facebook Connect or an Open ID provider. These services will authenticate your identity and provide you the option to share certain personally identifiable information with us such as your name and email address to pre-populate our sign up form. Services like Facebook Connect give you the option to post information about your activities on this Web site to your profile page to share with others within your network.
California Privacy Rights
Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice describing what categories of information we share with third parties or corporate affiliates for those third parties or corporate affiliates' direct marketing purposes. That notice will identify the categories of information shared and will include a list of the third parties and affiliates with which it was shared, along with their names and addresses. If you are a California resident and would like a copy of this notice, please submit a written request to the following email address: firstname.lastname@example.org. Please allow 30 days for a response.
Toluna USA Inc.
21 River Road
Wilton, Connecticut 06897
Last Updated: January 15, 2015