Effective Date: July 1, 2021
If you have not done so already, please also review our Terms of Service. which sets forth the terms governing your use of the SurveyMini Services.
2. INFORMATION WE COLLECT
“Personal Information” means information associated with or used to identify a specific person. Personal Information includes: (1) contact data (such as e-mail address, telephone number and employer); (2) demographic data (such as gender, date of birth and zip code); and (3) your responses on Surveys to the extent the information identifies you or is linked to you as an individually identifiable person (4) information relating to your use of SMG Services (“Usage Data”)..
“Usage Data” is information about activity while using SurveyMini or obtained while SurveyMini is active on your mobile device, such as (i) IP address; (ii) domain server; (iii) type of device(s) used to access SurveyMini; (iv) statistics and information associated with the interaction between your browser or device and SurveyMini, such as device model, carrier/network, battery life information to optimize location sampling based upon the remaining battery life, and basic usage statistics about your device; (v) real-time GPS or other geolocation data from your mobile device when you allow us to receive that information through the location (or similar) settings on your mobile device; and (vi) referring webpage or other source through which you accessed SurveyMini (collectively “Usage Data”).
Generally, we do not consider Usage Data as Personal Information because, in general, Usage Data by itself does not identify an individual. If we link Usage Data with other information in a way that renders the person individually identifiable, however, we will treat that information as Personal Information.
3. HOW WE COLLECT INFORMATION
We collect information that you provide to us and from your use of SurveyMini. The information that we collect and how we process it depends on how you use and access SurveyMini.
SMG conducts market research to better understand consumer preferences about their goods and services and uses that information to derive consumer insights, such as where, when and how often consumers visit retail locations and their experiences during those visits. We collect this information for SMG as well as research on behalf of our Clients. From You: We collect information from you when you:
4. LEGAL GROUNDS FOR PROCESSING
1.1. We process your contact data, demographic data, and responses on Surveys when you complete a Survey or use SMG Services. We process such Personal Data based on SMG’s and our Clients legitimate interests in obtaining feedback from customers to help improve products and services for the benefit of consumers, and based on SMG’s legitimate interest in enhancing SMG’s products, services and market research and in responding to user’s requests for assistance or information. You may withdraw your consent by contacting our Data Protection Officer by email at firstname.lastname@example.org or by writing to Data Protection Officer, Service Management Group, LLC, 1737 McGee Street, Kansas City, MO 64108.
1.2. We process your Usage Data, which includes Personal Data, when you complete a Survey or use SMG Services. We process Usage Data based on SMG’s legitimate interests, including maintaining the integrity of Surveys, facilitating communications between your device and our systems, fraud detection and prevention, and improvement and enhancement of SMG Services. You may withdraw your consent by contacting our Data Protection Officer by email at email@example.com or by writing to Data Protection Officer, Service Management Group, LLC, 1737 McGee Street, Kansas City, MO 64108.
1.3. We may also process information you have provided to Social Media platforms, depending on your privacy settings, when you use social networking services in conjunction with SMG services. We process such information based on your consent, which you provide in your privacy settings to the social networking service. You may withdraw your consent by changing your privacy settings to no longer allow us access to your Social Media data.
1.4. We process information received from our Clients concerning your interactions with their brands, products and services. We process such information based on SMG’s and SMG’s Clients’ legitimate interests, including improving and enhancing SMG’s and our Clients’ products and services and enhancing SMG’s market research.
5. HOW WE USE, SHARE AND DISCLOSE INFORMATION
How we use and share the information that we collect or that you provide to us depends on the type of information and context for its use or disclosure. Where required by law, SMG will comply with your request that we cease providing personal data to third parties.
6. RETENTION AND DISPOSAL OF PERSONAL DATA
We will retain your Personal Data in our records for no longer than is necessary for the purposes for which it was originally collected. When such information is no longer needed for the purposes for which it was originally collected, we will securely delete all of your electronic Personal Data, and securely shred any hard copy Personal Data, except for what is needed to comply with our legal obligations.
7. YOUR CHOICES ABOUT INFORMATION COLLECTION
You may discontinue participating in Surveys at any time by no longer accessing SurveyMini. You can discontinue any SurveyMini data collection by deleting the application from your mobile device. If you do this, we will no longer collect information from your device (or send you Surveys), but we will retain your Personal Information in our records for as long as is necessary for the purposes for which it is collected.
If you turn off location-based services on your mobile device(s), we will not capture any location information. However, SurveyMini will cease to function properly, since Surveys are delivered through SurveyMini based on your particular location or proximity to a shopping, entertainment or dining establishment. Although participation in SurveyMini is voluntary, you may not qualify for certain incentives, rewards, or benefits if you do turn off location based services on your mobile device. If you reside in a location with laws or regulations granting you rights to request specific actions relating to your Personal Data, you will have the specific rights granted to you by such law[s] or regulation[s], which may include the right to request access to and rectification (e.g., amendment or supplementation) or erasure of your Personal Data, the right to transfer your data (i.e., data portability), restriction of processing of your Personal Data, as well as the right to object to processing of your Personal Data, the right to withdraw your consent, the right to cancel your account, and the right to lodge a complaint with a supervisory authority. All such requests will be handled in accordance with the parameters set forth in applicable laws and regulations. If you reside in the European Union, you have the right under the General Data Protection Regulation to request from SMG access to and rectification or erasure of your personal data, data portability, restriction of processing of your personal data, the right to object to processing of your personal data, the right to withdraw your consent, and the right to lodge a complaint with a supervisory authority. If you reside outside of the European Union, you also may have certain data subject rights under your local laws. To make such a request, contact our Data Protection Officer by email at firstname.lastname@example.org or by writing to Data Protection Officer, Service Management Group, LLC, 1737 McGee Street, Kansas City, MO 64108.
8. ONLINE ADVERTISING AND DATA COLLECTION
Purposes of Data Collection for Online Ads
We permit third-party online advertising networks, Social Media companies and other third-party services to collect information about your use of our online services over time so that they may play or display personalized or interest-based ads on our online services, on other websites, apps or services you may use, and on other devices you may use. Typically, though not always, the information used for interest-based advertising is collected through cookies or similar data collection technologies. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research.
How to Opt Out of Online Advertising in Internet Browser
We support the Self-Regulatory Principles for online behavioral advertising (“Principles”) published by the Digital Advertising Alliance (“DAA”). This means that we allow you to exercise choice regarding the collection of information about your online activities over time and across third-party websites for online interest-based advertising purposes. More information about these Principles can be found at www.aboutads.info. If you want to opt out of receiving online interest-based advertisements on your internet browser from advertisers and third parties that participate in the DAA program and perform advertising-related services for us and our partners, please following the instructions at: www.aboutads.info/choices, or http://www.networkadvertising.org/choices/.
When you elect to opt-out through these sites, they will place an opt-out cookie on your device indicating that you do not want to receive interest-based advertisements. Opt-out cookies only work on the internet browser and device they are downloaded onto. If you want to opt out of interest-based advertisements across all your browsers and devices, you will need to opt out on each browser on each device you actively use. If you delete cookies on your device generally, you will need to opt out again. And some of these opt-outs may not be effective unless your browser is set to accept cookies. If you delete cookies, change your browser settings, switch browsers or computers, or use another operating system, you will need to opt-out again.
By visiting www.privacyrights.info or www.optout.privacyrights.info/?c=1, you can opt out from sales of this type of personal information by businesses that participate in the DAA’s CCPA App-based Opt-Out Tool.
How to Opt Out of Online Advertising in Mobile Applications
If you want to opt out of receiving online interest-based advertisements on mobile apps, please follow the instructions at http://www.aboutads.info/appchoices.
To make opt-out requests related to mobile apps on your device for businesses participating in the DAA’s CCPA App-based Opt-Out Tool, you can download the appropriate app at https://www.privacyrights.info/appchoices.
How to Opt Out of Google Data Collection
We also may use certain forms of display advertising and other advanced features through Google Universal Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the Doubleclick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to the online services.
Effect of Opting Out
9. MANAGING YOUR ACCOUNT INFORMATION
You can visit the account section of SurveyMini to view your account information. If you have any questions about how to access, update or correct your Personal Information, please contact us at email@example.com or by writing to Data Protection Officer, Service Management Group, LLC, 1737 McGee Street, Kansas City, MO 64108.
10. CHILDREN’S PRIVACY
SMG Services are intended for general audiences and are not directed to children who are under the age at which they may provide consent for the processing of their Personal Data in any jurisdiction where we operate. We do not knowingly collect Personal Data from such persons. If you become aware that a child under the age at which [s]he may legally provide consent to the processing of his/her Personal Data has provided us with Personal Data without parental consent, contact our Data Protection Officer by email at firstname.lastname@example.org or by writing to Data Protection Officer, Service Management Group, LLC, 1737 McGee Street, Kansas City, MO 64108. If we become aware that a child under the age at which [s]he may provide consent to Personal Data processing in his or her jurisdiction has provided us with Personal Data without parental consent, we take steps to remove such information and terminate the child’s account as soon as possible.
11. LINKS TO THIRD PARTY SERVICES
12. PERSONNEL PRIVACY DISCLOSURES
13. INFORMATION SECURITY
SMG has an information security program that implements technical, physical, and organizational measures designed to assist in maintaining the security and confidentiality of Personal Data; safeguarding against anticipated threats to the confidentiality, integrity and availability of Personal Data; and protecting your Personal Data against loss, misuse, unauthorized alteration or destruction, and unauthorized access or disclosure.
However, whenever Personal Data is processed, there is a risk that such data could be lost, misused, modified, hacked, breached, and/or otherwise accessed by an unauthorized third party. No system or online transmission of data is completely secure. In addition to the technical, physical, and organizational measures that SMG has in place to protect your Personal Data, you should use appropriate security measures to protect your Personal Data. If you believe that your SMG account or any information you provided to us is no longer secure, notify our Data Protection Officer immediately by email at email@example.com or by calling 1-800-764-0439 and asking to speak with SMG’s Data Protection Officer.
14. GEOGRAPHIC CONSIDERATIONS AND CROSS-BORDER TRANSFERS OF PERSONAL DATA
SMG controls and operates SMG Services from the United States of America. SMG may transfer, store and process your Personal Data in the United States, the United Kingdom, Japan, or another location in Asia or in the European Union. Note that data protection and privacy laws of the country to which your Personal Data is transferred may not be as comprehensive as the laws in your country. For example, Personal Data transferred to the United States may be subject to lawful access requests by federal and state authorities in the United States.
If you are accessing our SMG Services from the European Economic Area (“EEA”), your Personal Data will be processed outside of the EEA. In the event of such a transfer, we ensure that: (i) the Personal Data is transferred to countries recognised as offering an equivalent level of protection; or (ii) the transfer is made pursuant to appropriate safeguards, such as standard contractual clauses adopted by the European Commission.
You may contact our Privacy Lead by email at firstname.lastname@example.org or by writing to Privacy Lead, Service Management Group, LLC, 1737 McGee Street, Kansas City, MO 64108.
This English-language Privacy Notice is SMG’s official statement of its privacy practices relating to SMG Services. In case of any inconsistency between this English-language Privacy Notice and any translation into another language, this English-language document prevails.
15. REGION-SPECIFIC DISCLOSURES
We may choose or be required by law to provide different or additional disclosures relating to the processing of Personal Data about residents of certain countries, regions or states. Please refer below for disclosures that may be applicable to you:
16. HOW TO CONTACT US
If you have questions about privacy, need assistance with accessing or updating your Personal Data or have complaints relating to the processing of your Personal Data, contact our Data Protection Officer by email at email@example.com. You can also write to us at:Service Management Group, LLC Attn: Data Protection Officer1737 McGee Street Kansas City, MO 64108
Service Management Group, Ltd.Attn: Data Protection Officer38-40 The MaltingsSt AlbansHertfordshire AL1 3HL UNITED KINGDOM
17. DATA CONTROLLER AND DATA PROTECTION OFFICER
Personal Data collected by SMG is controlled by Service Management Group, LLC, 1737 McGee Street, Kansas City, MO 64108. You may contact our Data Protection Officer by email at firstname.lastname@example.org or by writing to Data Protection Officer, Service Management Group, LLC, 1737 McGee Street, Kansas City, MO 64108.