Effective Date: July, 2019
If you have not done so already, please also review our Terms of Service which sets forth the terms governing your use of our websites, applications, services and mobile applications (“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 email@example.com 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 firstname.lastname@example.org 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 DATAWe 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 email@example.com or by writing to Data Protection Officer, Service Management Group, LLC, 1737 McGee Street, Kansas City, MO 64108.
8. 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 firstname.lastname@example.org or by writing to Data Protection Officer, Service Management Group, LLC, 1737 McGee Street, Kansas City, MO 64108.
9. 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 email@example.com 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.
10. LINKS TO THIRD PARTY SERVICES
11. 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 firstname.lastname@example.org or by calling 1-800-764-0439 and asking to speak with SMG’s Data Protection Officer.
12. INFORMATION FOR CALIFORNIA RESIDENTSA business subject to California Civil Code section 1798.83 is required to disclose to its California customers, upon request, the identity of any third parties to whom the business has disclosed Personal Information within the previous calendar year, along with the type of Personal Information disclosed, for the third parties’ direct marketing purposes. If you are a California resident and would like to make such a request, please submit your request in writing to Service Management Group, Inc., 1737 McGee Street, Kansas City, MO 64108, or by email to email@example.com. Please note that, under California law, businesses are only required to respond to a customer request once during any calendar year.Under California Civil Code Section 1789.3, we are required to provide California residents with the following specific consumer rights information: i. SurveyMini is owned and/or operated by Service Management Group, Inc., 1737 McGee Street, Kansas City, MO 64108. ii. Unless otherwise expressly stated, SurveyMini is provided without charge. iii. To file a complaint regarding SurveyMini or to receive further information regarding use of SurveyMini, please send a letter to Service Management Group, Inc., 1737 McGee Street, Kansas City, MO 64108 or contact us via email at firstname.lastname@example.org (with “California Resident Request” as the Subject Line). You also may contact the Complaint Assistance Unit of the Division of Consumer Services of California’s Department of Consumer Affairs in writing at 400 R Street, Suite 1080, Sacramento, California 95814 or by telephone at 916.445.1254 or 800.952.5210.
13. GEOGRAPHIC CONSIDERATIONS AND CROSS-BORDER TRANSFERS OF PERSONAL DATA
14. 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
15. 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.