Effective Date: August 17, 2017
We will not make your Personal Information available to anyone without your knowledge unless it is for research purposes only or if required by law (as described in this policy). This includes your name, address, phone number and e-mail address. We will never try to sell you anything and we will never sell your name to anyone. That is not our business. We are not telemarketers or direct marketers. We are market researchers interested only in your opinions. Occasionally, we may re-contact you to validate your responses. We will never misrepresent ourselves or what we are doing.
Your decisions about participating in a study, responding to specific questions, or discontinuing participation will be respected without question.
We are also demonstrating our commitment to your privacy, by complying with the laws and regulations under applicable privacy laws in Canada, including the Personal Information Protection and Electronic Documents Act (“PIPEDA”).
If you have any privacy questions or concerns, please contact our Privacy Officer (firstname.lastname@example.org).
The Federal Trade Commission (FTC) has jurisdiction over Leger’s compliance with the Privacy Shield.
2.0 SCOPE AND APPLICATION
- non-personally identifiable information;
- your name, business title, business address and telephone number and fax in your capacity as an employee of an organization;
- depending on the jurisdiction, publicly available information (e.g. specified by regulation pursuant to the Personal Information Protection and Electronic Documents Act in Canada).
This Policy applies to the processing of Individual Personal Data that Leger receives in the United States concerning Individual who reside in the European Union and Switzerland.
“Collection”: The act of gathering, acquiring, recording, or obtaining Personal Information from any source, including third parties, by any means.
“Consent”: Voluntary agreement for the collection, use and disclosure of Personal Information for defined purposes. Consent can be either express or implied and can be provided directly by the individual or by an authorized representative. Express consent can be given orally, electronically or in writing, but is always unequivocal and does not require any inference on the part of Leger. Implied consent is consent that can reasonably be inferred from an individual’s action or inaction.
“Disclosure”: Making Personal Information available to a third party.
“Employee”: An employee of or independent contractor to Leger.
“Interviewer”: An employee of Leger who contacts a member of the public for the purpose of conducting survey research.
“Panel”: A panel of households or individuals recruited by Leger whose members have agreed to participate in telephone, mail or Internet-Survey research from time to time.
“Personal Information”: Information that individually or in combination could identify a specific individual.
“Privileged Information”: Information protected by a legally recognized right against disclosure.
“Respondent”: A member of the public who provides Personal Information to Leger in the course of a survey conducted by Leger. For example, a respondent is an individual who discloses Personal Information to Leger in the course of quantitative or qualitative marketing or social research.
“Survey Research” means telephone surveys, mail surveys, Internet surveys, door to door surveys, ad hoc panels, continuous panels, mall intercepts, business-to-business surveys, focus groups, one-on-one executive interviews, media rating services, mystery shopping, employee surveys, and all other types of survey research.
“Third party”: An individual or organization outside of Leger.
“Use”: The treatment, handling, and management of Personal Information by and within Leger or by a third party with the knowledge and approval of Leger.
4.1 The Personal Information We Collect
Personal Information means any information that can specifically identify you during a survey and/or enrollment process. This information may include but is not limited to, your first and last name, mailing address, phone number(s), e-mail address and in, certain circumstances, your opinions and individual preferences. This information is used to contact you regarding market research opportunities, as well as to send incentive rewards.
In most research surveys, we also collect demographic and professional information, some of which may be considered sensitive in nature, such as your age, gender, occupation, income range, racial or ethnic origin, household composition, language preference, employment status, etc. We ask these questions to help ensure that the demographic profiles of individuals who kindly participate in our surveys accurately reflect the target population that we are trying to approximate.
We may also collect sensitive information that may include but is not limited to health-related information (disease, conditions and treatment) or financial information. We will never ask you for sensitive Personal Information that could give rise to economic crimes if it were lost, misused or disclosed to an unauthorized party, such as credit card numbers, social insurance numbers, bank account information, passport numbers or driver’s licence numbers.
Personal Information, however, does not include (i) your name, business title or business address and business telephone number and fax in your capacity as an employee of an organization; and (ii) depending on the jurisdiction, publicly available information. However, if in your capacity as an employee of an organization you participate in one of our surveys, your responses will be treated as Personal Information.
We may collect Personal Information about other members of your household. This information may include but is not limited to the age and gender of the other household members. We use this information to determine if certain surveys are relevant to you based on the composition of your household. Sometimes we use this information to invite other members of your household to participate in our surveys.
We may offer you the opportunity to refer-a-friend on our Legerweb panel, which allows you to invite one or more friends to join the Panel and after joining participating in any type of event on the Panel or in surveys. This process will never ask you to provide the email address or any other personally identifiable information about the individuals you wish to refer. An email message with a registration link may be sent to you, and you may be asked to pass on a link to the membership survey to one or more of your friends. Alternatively we may encourage you to forward a link to the membership survey to one or more of your friends by using the friend feature on the panel homepage.
4.2 How We Collect Personal Information
We will always collect your Personal Information by fair and lawful means. We collect your Personal Information where we have obtained your consent to do so or as otherwise permitted by law.
We may collect Personal information directly from you or we may obtain Personal Information from clients or research firms who commission us to provide research services on their behalf. We may also obtain Personal Information from list providers who have assured us that their lists comprise only individuals who have consented to be listed (“opt-in” lists). Finally, we may collect and use Personal Information obtained from publicly-available sources, such as telephone directories.
We may use a third party agent to host surveys or panel events to collect Personal Information, including email address. That information is delivered to Leger directly. Contractual agreements between Leger and third party vendors ensure that your Personal Information will not be shared with anyone and will not be used for any other purpose without your consent.
Leger will give notice when Personal Information is collected or when any collected information is later to be provided to third parties. All notices will explain the need for the information and describe how the information will be used. Personal Information will not be used to directly market any products or services to identifiable persons unless that possibility has been disclosed in advance and the opportunity not to participate has been given.
4.3 How We Use Personal Information
We identify the purposes for which we use your Personal Information at the time we collect such information from you and obtain your consent, in any case, prior to such use.
We collect your Personal Information for the following purposes:
- to conduct quantitative or qualitative marketing and social research on behalf of our clients who include businesses, non-profit organizations and governmental institutions;
- to understand respondent opinions to establish suitability for further quantitative and qualitative marketing and social research;
- to meet legal and regulatory requirements.
this context, we may use your Personal Information for any of the following reasons:
- To invite you to participate in survey research;
- To conduct a survey research interview with you;
- To validate answers you provided in a recent survey we conducted;
- To manage our incentives programs and fulfill your requests for such incentives.
- To update and to ensure that our records of your Personal Information are correct;
- To provide services and support that you have requested;
- To provide you with general information about Leger and our products and services;
- To send you important information regarding your participation, changes to our Legerweb panel terms, conditions;
- To verify the integrity of submitted information;
- To detect and to prevent violation of our Terms & Conditions.
As otherwise authorized by you.
Data collected from market and social research studies is shared with our clients in aggregate (or group) form, and responses are not attributed to individuals, in other words we combine your survey responses with the responses of all other survey participants and report aggregate responses. Individual level responses are occasionally used, but never associated with any personal identifying information without your explicit permission, except as otherwise stated herein.
4.4 To whom Personal Information is Disclosed
We will not make your Personal Information available to any third party without your knowledge, unless it is for research purposes or required by law, as further specified below.
The only exceptions when we may disclose your Personal Information and/or survey responses to third parties are as follows:
To a client of Leger who commissioned the survey you participated in, who is contractually bound to keep the information confidential and use it only for research or statistical purposes (in accordance with the guidelines of the Insights Association and with MRIA Code of Conduct and Good Practice);
To a third party engaged by Leger to perform functions on its behalf (including our incentives programs), such parties are restricted from using your Personal Information in any way other than to provide services to Leger;
- You consent to sharing your identifying information and individual responses with a third party for a specified purpose;
- In the rare but possible circumstance that the information is subject to disclosure pursuant to judicial or other government subpoenas, warrants, orders or for similar legal or regulatory requirements, except for “Privileged Information”. In that specific case, we will consult with our attorney before responding to any request for the information.
- When we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with suspected or actual illegal activity.
- Leger may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. Leger is liable for appropriate onward transfers of personal data to third parties.
4.5 How and When we obtain Your Consent
We obtain your consent prior to collecting, and in any case, prior to using or disclosing your Personal Information. You may provide your consent to us either orally or in writing. For example, when you respond to a survey, you provide your consent to allow us to use your Personal Information for the purpose of conducting quantitative and qualitative market and social research and, in certain circumstances, to disclose your Personal Information to our clients.
When you agree to participate in survey research, and the method of data collection is by telephone or in-person, a Leger interviewer then conducts an interview with you. When the method of data collection is by mail, via our web panel or email invitation, you complete a questionnaire yourself.
From time to time, we may collect, use or disclose your Personal Information based on your consent and as permitted by law. If you provide us with sensitive Personal Information such as health or financial information, we will obtain your express consent for the collection, use and disclosure of such sensitive Personal Information.
When you participate in market research telephone interviews and discussions with Leger, the interview may be recorded, or there may be others on the call for note taking, training, or research evaluation purposes. To protect your privacy, only your first name will be used during discussions. You may decline to participate in interviews that are monitored by others or recorded.
4.6 Opting-out of Leger Market Research
You are always free to choose whether or not to participate in a survey, free to choose not to answer any specific questions and free to discontinue participation at any time.
As a Legerweb panel member, you will receive our e-mail invitations to complete surveys. If you decide you no longer wish to participate as a member of Legerweb panel, upon receipt of your e-mail invitation, you can reply to it with the word “Unsubscribe” in the body of the reply or, alternatively, you can click on the Unsubscribe link at the bottom of the e-mail and you will no longer receive survey invitations. You can also e-mail our helpdesk at email@example.com with the word “Unsubscribe” in the title. Of course, if you decide you later wish to participate in the community, you are welcome to reactivate your account at any time. However, we are not able to remove your Personal Information from the lists of third parties with whom your information has been shared with your consent or as permitted by this Policy.
4.7 Access to Personal Information
We will make available to you any specific Personal Information on you in our custody or control, that we have collected, used or disclosed, upon your written request, to the extent required and/or permitted by law. We will make such information available to you in a form that is generally understandable, including explaining any abbreviations or codes.
To request access to Personal Information that we hold about you, we require that you submit your request in writing at the e-mail address or postal address shown below in the Contact section. When we receive an access request from an individual, we will attempt to fulfill the requested information within 30 days, including requests regarding the Personal Information we have in our possession or control about the individual, what it is being used for, and to whom it has been disclosed, if applicable.
In certain situations, however, we may not be able to give individual access to all of their Personal Information. This may occur when:
- Providing access to Personal Information would be likely to reveal Personal Information about a third party;
- Disclosing the information would reveal confidential commercial information;
- The information has been collected for the purposes of a legal investigation.
If we deny an individual’s request for access to their Personal Information, we will advise the individual of the reason for the refusal.
4.8 Accuracy of Personal Information
We make reasonable efforts to keep Personal Information in our possession or control accurate, complete, current and relevant, based on the most recent information available to us. We rely on respondents, such as panel members, to keep certain Personal Information relating to them accurate, complete and current. If you register with us, you have the right, and we encourage you, to view and update your registration information at any time.
To update your information, please log-in to your account page on www.legerweb.com or send an e-mail to our Panel Support Team at firstname.lastname@example.org.
In your request, please be specific and make clear what action you would like us to take with your Personal Information. We will try to comply with your request as soon as reasonably practicable.
4.9 Ensuring Third Party Confidentiality
You may set your web browser to notify you of cookie placement requests or to decline cookies completely. You can delete the files that contain cookies; those files are stored as part of your internet browser, however doing so may prevent you from answering our online surveys.
Legerweb.com also makes use of Google Analytics features (Display Advertising, Google Analytics Demographics and Interest Reporting). Legerweb uses this data to identify member interests and improve our contests and promotional campaigns. Using the Google Ads Settings, users can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads. You can also explore Google Analytics’ currently available opt-out options for the web.
4.11 Collecting Information from Children
Occasionally, we conduct surveys with children under 13 but only with parental or legal guardian consent. Depending on the sensitivity of the survey topic, we may seek parental or legal consent for interviewing children between 13 and 17 years of age. If we become aware that Personal Information from a child under 13 has been collected without the consent of such child’s parent or guardian, we will use all reasonable efforts to delete such information from our database.
The security of your Personal Information is very important to us. We have put in place reasonable physical, administrative, electronic, contractual and technological security procedures to protect your Personal Information we collect. Only those employees who need access to your information in order to perform their duties are authorized to have access to your Personal Information. We prevent electronic intrusion by using firewall technology. The employees who are granted access to your Personal Information, including email address, can only access it using secure connections and passwords from within our networks.
4.13 EU-U.S. and Swiss-U.S. Privacy Shield Frameworks
Your Personal Information may be collected, stored, processed, used and transferred by one or more Leger affiliated companies or non-affiliated service providers in one or more countries outside your originating country.
4.14 Questions or Suggestions
USA and Canada Residents:
If you are concerned or have any complaints or questions about our use of your Personal Information, please email our Privacy Officer at: email@example.com with the subject line “Privacy”. You can also write us at the following address:
507, place d’Armes
Montreal, QC., H2Y 2W8
EU Citizens and Swiss citizens:
Leger has further committed to refer unresolved privacy complaints under the EU-U.S. and Swiss-U.S. 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 http://www.insightsassociation.org/get-support/privacy-shield-program/privacy-shield-eu-swiss-citizens-file-complaint for more information and to file a complaint. These dispute resolution services are provided at no cost to you.
Finally, as a last resort and in limited situations, EU individuals may seek redress from the Privacy Shield Panel, a binding arbitration mechanism.
4.15 Renewal / Verification
Leger will renew its EU and Swiss Privacy Shield self-certifications annually, unless it subsequently determines that it no longer needs such self-certification or if it employs a different adequacy mechanism.
Prior to the re-certification, Leger will conduct an in-house verification to ensure that its attestations and assertions with regard to its treatment of Individual Customer Personal Data are accurate and that the company has appropriately implemented these practices. Specifically, as part of the verification process, Leger will undertake the following:
C. Ensure that this Policy continues to comply with the Privacy Shield principles
D. Confirm that Individual Customers are made aware of the process for addressing complaints and any independent dispute resolution process (Leger may do so through its publicly posted website, Individual Customer contract, or both)
E. Review its processes and procedures for training Employees about Leger’s participation in the Privacy Shield programs and the appropriate handling of Individual’s Personal Data
Leger will prepare an internal verification statement on an annual basis.