Techsumption Ventures Privacy Policy

First Effective: January 1, 2018

This Version: Effective January 12, 2019

The Privacy Policy describes how Techsumption Ventures Pte. Ltd. and their parents, subsidiaries and affiliated companies (collectively “TECHSUMPTION”, “We”, “us, or “our”) processes Personal Data in the context of online panel communities, surveys, reward programs, websites and mobile applications (collectively the “Service”). In particular, it describes the types of Personal Data we collect in connection with the Service, the purposes for which we collect that Personal Data, the other parties with whom we may share it, and the measures we take to protect the security of the data. It also tells you about your rights and choices with respect to your Personal Data, and how you can contact us to update your contact information or ask questions about our privacy practices.

This Privacy Policy does not apply to the processing of your Personal Data in the context of surveys administered by third parties. In these situations, TECHSUMPTION is not the sponsor of the survey and the survey instrument, and the survey results or survey data are and will be controlled by the sponsor of the survey. Please refer to the relevant sponsor’s privacy policy to learn more about that sponsor’s privacy practices.

 

1. Personal Data That May Be Collected About You

We collect Personal Data in various ways described below. For the purpose of this Privacy Policy, “Personal Data” means any information relating to an identified or identifiable individual. Where applicable, we indicate whether and why you must provide us with your Personal Data, as well as the consequences of failing to do so. If you do not provide Personal Data when requested, you may not be able to benefit from the Service if that information is necessary to provide you with the Service or if we are legally required to collect it.

A. Personal Data Provided by You

  • We ask you to provide certain Personal Data when you register an interest to participate by signing up via Google Forms or other forms of online survey platforms, including but is not limited to, your name, address, email address, phone number, date of birth, occupation, education, and gender.
  • In addition, we collect Personal Data you provide in the context of a panel, when you participate in a survey or in connection with the receipt and redemption of rewards and incentives. Such information includes a unique panelist/ respondent identification number we assign to you when you sign up for an account and the responses you provide when completing the survey. In this context, you may choose to provide sensitive Personal Data about you, such as Personal Data that discloses or reveals health and medical conditions, sexual orientation or sexual life, political opinions/views, race/ethnic origin, religious and philosophical beliefs and trade-union membership. Where required by law, we obtain your explicit consent to the processing of your sensitive Personal Data. We may also collect content that you submit, upload or transmit when using the Service, such as photos and videos.

B. Location Data

  • We may request your permission to obtain location information from your mobile device. We may use your location information to offer you the option to participate in location-based surveys and market research, or to share such location data with third party clients to demonstrate certain location traffic patterns of participants, including but not limited to purchasing behavior based on locations visited.
  • We collect your location information for the above purposes with your consent. If you no longer wish to share your geo-location information with us, please change the privacy settings of your device. Where required by law, we obtain your explicit consent to share your location information with third parties.

C. Social Media Accounts

  • You may also have the opportunity to access the Services through third party social media platforms. If you select to access the Services in this manner, we may collect certain profile information stored in your social media platform account, such as name, gender and email address.

D. Personal Data Provided by Third Parties

  • We may obtain Personal Data, behavioral and/or demographic information from third parties, such as data management platforms, ad networks, information service bureaus, and sample suppliers. This collection may include, but is not limited to, age, gender, geography, location, presence of children, mobile ad IDs, purchase history, advertising exposures, look-a-like segments.

 

2. How We May Use Your Personal Data

We may use the Personal Data we obtain from or about you for a variety of purposes, including:

  • To offer you the opportunity to participate in research activities, including to join a panel, participate in surveys administered by TECHSUMPTION or by third parties (whether as a panel member or a non-panel member), or use websites and mobile applications associated with panels or surveys.
  • To administer, manage, fulfill, facilitate entry into, and communicate about TECHSUMPTION’s reward, incentive programs and other promotions, including sweepstakes offered in connection with panel membership and/or the completion of surveys.
  • To communicate with you regarding your membership with a panel owned by TECHSUMPTION, or to send you notifications of your participation in a survey and tailored survey opportunities.
  • To arrange for advertisements to be displayed to you outside the Service for the purposes of facilitating the completion of recall surveys.
  • To provide you with Services and advertisements tailored to you based on criteria such as your interests or location information and to enable TECHSUMPTION and third parties to develop marketing insights, audience/look alike models based on individual and/or aggregated profile data, and segment audiences. For example, we may develop marketing and advertising campaigns designed to target individuals who have a social and demographic profile similar to yours.
  • To assess the effectiveness of online advertising and for website audience measurement, and to assist in the creation, development, and implementation of websites, online advertisements, and other Internet and digital media features, functionality, and campaigns.
  • To send tailored marketing communications about TECHSUMPTION and third party products and services.
  • To update TECHSUMPTION’s records, perform data analyses for TECHSUMPTION purposes or for our clients.
  • To provide a better survey experience, including quality control, validation, tracking of completed surveys or other completed actions.
  • To ensure safety and security and to detect and prevent fraud.
  • To comply with our legal obligations, including, without limitation, tax obligations, or otherwise enforce or protect our rights.
  • For data suppression or exclusion purposes, including, without limitation, preventing the same respondent from taking a survey more than once, complying with opt-out/unsubscribe requests, etc.
  • To share your Personal Data with third parties (e.g., clients, sample suppliers, etc.) for suppression and exclusion purposes, including, without limitation, preventing a respondent from taking the same survey more than once, preventing an individual from being invited to a survey through more than one source, to comply with opt-out and unsubscribe requests for communications from or on behalf of TECHSUMPTION, etc.
  • As otherwise permitted pursuant to this Privacy Policy or as otherwise authorized by you.

If you are located in the European Economic Area, we may collect and use your Personal Data when:

  • You consented to the use of your Personal Data. For example, we may seek to obtain your consent for our uses of cookies or similar technologies, to send you marketing communications, or to process Personal Data deemed sensitive pursuant to applicable law.
  • Necessary to provide you with products and services, or to respond to your inquiries.
  • We are required or authorized by applicable law to use your Personal Data.
  • We, or a third party, have a legitimate interest in using your Personal Data, such as to ensure and improve the safety, security, and performance of our products and services, to anonymize Personal Data and carry out data analyses.

 

3. How We Share Your Personal Data

We may disclose the Personal Data we collect about you as described below or otherwise disclosed to you at the time the data is collected, including with:

  • Our parent, subsidiary, and affiliates for the purposes described in this Privacy Policy.
  • Our service providers who perform services and process Personal Data on our behalf. Examples of our service providers include our cloud storage providers, fraud tool providers, survey data collection platform, and sourcing suppliers. We may also share Personal Data with data brokers and data aggregators acting under our instructions and on our behalf to add to enrich our database for the development of audience insights and/or look-alike models, analytics, and marketing intelligence. We require these service providers by contract to only process Personal Data in accordance with our instructions and as necessary to perform services on our behalf or comply with legal requirements. We also require them to have safeguards designed to protect the security and confidentiality of the Personal Data they process on our behalf. In connection with sharing Personal Data with service providers as set forth above, such service providers may use such Personal Data to improve and enhance their services, in which event they are acting as data controllers and not as data processors engaged by TECHSUMPTION.
  • Program partners who invited you to join the Service and that you have enrolled through.
  • Our clients for market research-related purposes (including for the creation and validation of models, fraud detection and prevention, data market segmentation and database matching, and reward, incentive, or sweepstakes redemption, fulfillment and/or entry), to enable them to develop marketing campaigns, audience insights, look-alike models and/or to market third party’s products/services to you, and for the purposes of identifying respondents for re-contact surveys or communications.
  • With a third party in connection with any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
  • As otherwise permitted pursuant to this Policy or (i) if we are required to disclose Personal Data about you by law or legal process, (ii) in response to a request from a court, law enforcement authorities, or government officials, or (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity.

We may allow a client to collect Personal Data directly from you. You are free to provide them with your Personal Data. In these situations, we enter into a written agreement with our clients to, among other things, limit their use of the Personal Data.

 

4. Your Rights and Choices

Subject to applicable law, you may have the right to:

  • Opt out of certain collection and use of your Personal Data when we provide the Service.
  • Opt out of the collection and use of certain information, which we collect about you by automated means. Your browser may tell you how to be notified of and opt out of having certain types of cookies placed on your device. Note that without certain cookies you may not be able to use all of the features of our websites, apps or online services.
  • Request access to and receive information about the Personal Data we maintain about you, to update and correct inaccuracies in your Personal Data, to restrict or to object to the processing of your Personal Data, to have the information anonymized or deleted, as appropriate, or to exercise your right to data portability to easily transfer information to another company. In addition, you may also have the right to lodge a complaint with a supervisory authority, including in your country of residence, place of work or where an incident took place.
  • Withdraw any consent you previously provided regarding the processing of your Personal Data, at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before your consent withdrawal.

Those rights may be limited in some circumstances by local law requirements.

You can stop all collection of Personal Data and other information by us by contacting us as specified in the “How to Contact Us” section below.

 

5. Data Security and Data Retention

We maintain appropriate technical, administrative, and physical safeguards to protect Personal Data and other information disclosed or collected by us against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. We review, monitor, and evaluate our privacy practices and protection systems on a regular basis. Despite the safeguards we implement, transmissions over the Internet or a mobile network are not totally secure, and therefore we cannot guarantee the security of online transmissions. We are not responsible for any errors by individuals in submitting Personal Data to us.

We also take measures to delete your Personal Data or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it, unless we are required by law to keep this information for a longer period. When determining the retention period, we take into account various criteria, such as the type of products and services requested by or provided to you, the nature and length of our relationship with you, possible re-enrolment with our products or services, the impact on the services we provide to you if we delete some information from or about you, mandatory retention periods provided by law and the statute of limitations.

 

6. Data Transfers

Your Personal Data may be transferred to recipients in countries other than the country where you are located. These countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your Personal Data to other countries, we will protect that information as described in this Privacy Policy or as disclosed to you at the time of the collection.

If you are located in the European Economic Area or Switzerland, we comply with applicable legal requirements providing adequate safeguards for the transfer of Personal Data to third countries.

 

7. No Children

The Service is not designed for, or intended for use by, any individual under the age of 16. We do not knowingly collect Personal Data from children under the age of 16, and if we became aware that we have inadvertently collected Personal Data from a child under the age of 16, we will undertake reasonable commercial efforts to delete such Personal Data.

 

8. Updates to This Privacy Policy

This Global Privacy Notice may be updated periodically to reflect changes in our Personal Data practices. We will post a prominent notice on relevant websites to notify you of any significant changes to our Global Privacy Notice and indicate at the top of the Notice when it was most recently updated. If we update our Global Privacy Notice, in certain circumstances, we may seek your consent.

 

9. How to Contact Us

If you have any questions or comments regarding our privacy practices or this Privacy Policy or if you would like to opt out of certain uses of your Personal Data, exercise your rights in relation to the Personal Data we hold about you or make a complaint about our privacy practice, please feel free to contact Techsumption Ventures Pte. Ltd. as described below.

  • Techsumption Ventures Pte. Ltd.: write to us at info@techsumption.com or to 8 Burn Road, Trivex #15-13, Singapore 369977, Attention: Data Protection Officer.