Privacy

LAST UPDATED: August 10, 2022

1. Introduction

These privacy policies apply to all products, services, websites and apps offered by the Provider and the Provider's other affiliates (collectively, the "Provider"), except when otherwise stated. We refer to these products, services, websites and apps collectively as the "Services" in this statement. Unless otherwise stated in your contract, our services are offered by the Supplier as described in the Applicable Service Agreement.

References to "data" in this privacy policy will refer to any data you use our services to collect, whether it is survey or questionnaire responses, data collected from a form or application, or data entered on a website managed by us . References to personal information or simply information, means information about you personally that we collect or that we act as manager of.

If you wish to identify your data controller, please see the section "Who is my data controller?" below.

For a brief overview of how the Provider processes data and personal information, you can see the basics of privacy.

2. Information we collect

2.1 Who are "you"?

We often refer to "you" and "thee" in these privacy rules. See the following useful definitions to better understand which information is most relevant to you.

Customers : You have an account in a service provided by the Provider and either create surveys, forms, applications or questionnaires directly, or you collaborate on, comment on or review surveys, forms, applications or questionnaires in an account.

Respondents : You have received a survey, a form, an application or a questionnaire from a service provided by the Provider.

Panelists : You have registered and agreed to take surveys sent by the Supplier on behalf of Customers.

Visitors : You only visit one of our sites because you are curious, or have heard about us from our marketing or sales channels.

2.2 Information we collect about you.

Contact information (for example, name or email address).
You may provide us with your contact information either through use of our services, a form on our website, an interaction with our sales or customer support team, or through a response to one of the Supplier's own surveys or forms.
Usage information.
We collect usage information about you when you interact with our websites and services. This includes what websites you visit, what you click on, when you perform those actions, what language preference you have, what you buy and so on.
Device and browser data
We collect information from the device and application you use to access our services. Device Data mainly means your IP address, operating system version, device type, device ID/MAC address, system and performance information and browser type. If you use a mobile device, we also collect the UUID for that device.
Information about page tags.
We use first and third party cookies and tracking services that use cookies and page tags (also known as web beacons) to collect data about visitors to our websites. This data includes usage and user statistics. E-mails sent by the Provider or by users through our services also contain page markings that allow the sender to obtain information about who has opened the e-mails and clicked on links in them. We provide more information about cookies below and in our cookie notice.
Log data.
Like most websites today, our web servers maintain log files that record data every time a device sends a request to the servers. The log files contain data about the background of each access, including originating IP address, Internet service providers, the files displayed on the website (eg HTML pages, graphics, etc.), operating system versions, device type and timestamps.
Referral information.
If you arrive at one of the Provider's websites from an external source (for example, a link on another website or in an email), we record information about the source that referred you to us.
Information from third parties and integration partners.
We collect your personal data from third parties where you, for example, give these third parties permission to share your data with us, where such data is publicly available on the internet, or through your device/browser data.

If you are a creator, we may also collect:

Account information

Registration Information.
You need a user account before you can use services provided by the Provider. When you register for an account, we collect your first and last name, username, password, mobile number and email address. If you choose to register using a third-party account (such as a Google or Facebook account), please see "Information from Third Parties" below.
Billing Information.
If you make a payment to the Supplier, we require you to provide your billing details, a name, an address, email address and financial information about your chosen payment method (eg a credit card number and expiry date or a bank account number). If you provide a billing address, we will consider it as the account holder's location in order to determine which Supplier you have a contract with and which sales taxes apply to the purchase, if applicable.
Account settings.
You can configure various settings and personal information on pages such as your account settings page (or on the account settings page for our other products where applicable). This can be, for example, the default language, time zone and communication settings (e.g. choosing to receive or not receive marketing communications from the Provider).

When you use our services, we may also collect the following data on your behalf for certain services:

Address book information.
We can allow you to import email addresses and other contact information into an address book so you can easily invite people to take your surveys or fill out your form through our entry points. We do not use this data for our own purposes or to contact anyone, unless you ask us to.
Data in connection with surveys/forms/applications.
We store data in connection with surveys/forms/applications (questions and answers) for you, and offer analysis tools that you can use with this data.
Profile information.
When you register for our services, you will be asked to provide information about yourself to us and to provide us with more detailed insight into who you are. This may include providing a photo so that your administrator(s) and colleagues can identify you.

3. How we use the information we collect

3.1 Creator

We process personal data about you there:

- You have given your consent;
- We must fulfill our contractual obligations to deliver the Services to you; or
- We have legitimate interests to
  - improve the service experience and
  - develop new products and service functions.

In each of the cases where we describe how we use your data in these privacy policies, we have identified which basis we use for processing the data.

You have consented to us using certain types of tracking and third-party cookies on our websites. Specifically:

- Cookies and similar technology.

We or third-party data and advertising platforms we work with may use or combine multiple technologies, such as cookies, page tags, mobile identifiers and IP addresses, to suggest users' common identities across different services and multiple devices, such as tablets, browsers and mobile phones. We may do this, for example, to tailor advertising to users, to find out how successful our advertising campaigns are and to improve them. This data and third-party advertising platforms may sometimes use data we provide to them to improve their technology and their ability to match common devices with users. We may also use this technology to allow a developer to measure the performance of email messages and to learn how to improve email deliverability and open rates.

More details: The above data and techniques are used for personalized marketing, analytics and related purposes. If you want to find out more about interest-based advertising and how you can opt out, see section 6 of the cookie notice. We use this data to tailor online marketing campaigns so that they are relevant to you and your interest in our services. By removing the cookies in your browser settings, you will no longer see personalized messages in this way, but you will still see advertisements via the Internet that are not based on the information you provide to the Provider. Depending on your geographic location, you can also withdraw your consent with our in-product cookie management tool.

We process the personal data in the following data categories for our legitimate business purposes, which are described in detail in this privacy policy. We have taken steps to ensure that we set clear limits for each of these uses, so that your privacy is respected and that only the information necessary to achieve these legitimate goals is used. Our main goal is to improve and ensure that our services and messages are relevant to all of our users, while ensuring that the personal information of all users is respected and protected.

- Contact information.

We use contact information to respond to inquiries, send information as part of the services and to send marketing information (as long as you do not opt out).

More details: We use your email address to send you marketing (newsletters), unless you indicate a preference to opt out, and for general updates about your account. You can opt-out of marketing messages at any time by clicking the 'unsubscribe' link in them and by changing the relevant settings on the My Account page.

- How to use our services.

We use information about how you use our services to improve our services for you and all users, and to make recommendations to you and your organization about our other services.

More information: We collect information about the types of surveys/forms/applications you create (eg, HR surveys), the type of subscriptions you purchase, and transaction behavior for your account to build a profile about you so we can assist with to make you and your organization aware of other relevant features and services we offer, and to optimize the user experience, for example by making recommendations to you and your organization.

We may also use usage information such as the levels and type of activity in your account and the number of responses you receive to personalize the features and services we highlight for you and your organization on our Sites, improve your user experience, and to make recommendations to you and your organization about our services through our sales and marketing initiatives.

- Device and browser data.

We use device information to both troubleshoot problems with the Services and to improve them. We also suggest your geographic location based on your IP address.

More details: We collect this to help us improve your service experience through a specific browser/device, by optimizing how the website looks in a specific browser, how the brightness of the screen affects the user experience and to ensure that the service works optimally and as it should on different devices and browsers.

- Log data.

We use log data for many different business purposes, including:

- - To monitor abuse and to debug,
  - to create new services, features, content or to make recommendations,
  - to track behavior on an aggregate/anonymous level to identify and understand trends in the various interactions with our services,
  - to fix errors and troubleshoot product functionality,
  - to investigate security issues.

More details: Your IP address is used to determine where an unknown/unauthorized access may have occurred in your account (abuse monitoring).

· Referral information.

We use referral information to track the effectiveness of our integration and referral processes.

· Third parties and integrations.

We collect and use information from third parties and integration partners, where appropriate for one of our services, to:

- ensure that you can register for our services from third party integrations such as Facebook/LinkedIn/Microsoft/Google/SSO,
- to personalize our services for you, and
- ensure that you can use our service in conjunction with other services.

See more information about our API partners - see below or on the service website for other services the Provider provides.

- Service and marketing use:
- Profiling. We combine information about you from third-party sources with information we have about you to create a user profile, which helps us make our sales and marketing efforts more relevant to you, and to personalize and improve your experience of the Service.
- Machine learning. We use machine learning techniques on certain types of data to provide users with useful statistics and more relevant insights from the information they collect through our services, to optimize our marketing campaigns and to detect fraud. For example, if you have used free text questions in a survey, our machine learning can provide you with useful insight into the response trends to this question through our survey tools.
- To administer our services, we also use your information and data internally, for the following limited purposes:
- To enforce our agreements where applicable,
- to prevent or deal with potentially illegal activities,
- to filter and prevent unwanted or abusive activity. For example, we have automated systems that filter content for phishing, spam and fraud.
- Legal use.

To respond to legal requests or to prevent fraud, we may need to use and disclose information or data we have about you. If we receive a subpoena or other legal request, we may need to inspect the data we hold about you to determine how to respond.

We collect and use the following on the basis that we need to use this information to fulfill our contract with you:

Your account information.

We need to use your account information to operate your account, offer you services, bill you for our services, offer you user support and contact you or your organization about your service or account. From time to time, we will send you communications of a transactional nature (eg, service-related announcements, billing questions, changes to services or policies, a welcome email when you sign up). You cannot opt out of this type of communication, as it is necessary to deliver our services to you.

Your profile.

We process other aspects of your account information (such as the personal information you provide about your job, job title and marketing preferences) as well as information obtained from public sources, for legitimate interests, such as providing you with a personalized service and relevant and useful marketing information, in addition to to make other recommendations about products, features and services to you and your organization in order to optimize the use of the services we offer. If you are part of a business account, we also give you the option to upload a photo so that your administrator(s) and colleagues can identify you.

You can object to our use of your information as described above, but in some cases our ability to provide the Services may be affected if you do not want us to collect the above information. Furthermore, if you have a business account, your organization controls some of the information you include in your profile, and they can also change or remove the information through the main administrator(s) of the account.

In connection with survey data

Your data.

We also use questions and answers from surveys on an aggregated and anonymized basis as described in these privacy rules. We never sell individual response data or identify / contact individual respondents, except at your request or where required by law. Function descriptions will state where this function is connected. In some cases, you can avoid using your questions/answers in this way by choosing not to use a feature, or by indicating your preferences in your account. See our "Respondent" section.

If you are part of a business subscription, the subscription administrator(s) may transfer questions and answers from your surveys to, or share them with, other members of your team, including the subscription administrator(s). The administrator(s) for the subscription can also delete questions and answers in surveys. The subscription administrator(s) may also have the ability to make changes to all parts of survey questions and analysis. See the internal guidelines for your organization if you have any questions about this.

If you use the survey tool, depending on your subscription and the settings you've chosen, respondents may reach the default survey exit page when they complete a survey. The closing page is part of the Supplier's website. We may include our own polls and surveys for research on this landing page. These surveys are optional and respondents can answer or skip them.

3.2 Respondent

We process the personal data in the following data categories for our legitimate business purposes, which are described in detail in this privacy policy. We have tried to ensure that we set clear limits for each of these uses, so that your privacy is respected and that only the information necessary to achieve these legitimate goals is used. Our main goal is to improve and ensure that our services and messages are relevant to all of our users, while ensuring that the personal information of all users is respected and protected.

Cookies (includes page markers).

We collect information using cookies when you take a survey. These cookies are used to ensure full functionality of our survey service, to ensure that the survey works optimally and correctly. For more information, please read the Cookies section below and our Cookie Notice for Respondents. When you have completed a survey, you will, in most cases, be redirected to our website and treated as a visitor to the website where other cookies may be used, so you should read the section Visitors to the website for more information about this.

Examples

We use page markers to give the email sender (for example, a survey or a form) the ability to measure the effectiveness of email messages and find out how email deliverability and open rates can be improved. We also use cookies to ensure that a respondent can only take a survey once (in cases where the Customer has set this feature) and to track survey completion rates.

Contact information.

We only use contact information to answer a question you, as a respondent, submit to us.

Examples

Our customer support team will use your email address to communicate with you if you have contacted us about a survey, application, form or questionnaire you have received, but we will not send you marketing unless you have opted in to receive marketing.

This is how you use our services (applies only to respondents who answer surveys).

We use information about how you use our services to improve our services for you and users in general.

Examples

We collect information about the types of questions you answer. This data will be aggregated and anonymized so that we can examine patterns regarding respondents' preferences when submitting responses (see further down in the Information for respondents section). We collect and use all of this data for our legitimate interests, such as to help us improve the user experience for respondents (so that questions are easier to answer), for training purposes and to understand industry trends and to help improve completion rates for surveys/forms.

We also use usage information such as the type of survey, form, questionnaire or application you have answered to personalize the products we show you when you complete a survey when you are redirected to our website, or to provide our customers with recommendations about the use of our services.

Device and browser data.

We use device information to both troubleshoot problems with the Services and to improve them. We also suggest your geographic location based on your IP address.

Other examples

We collect this to ensure that the service works well on all possible devices and to draw conclusions about geographic location to produce aggregate data around trends related to respondents' locations. We also want to use this information to provide an additional data layer for Customers, allowing them to filter responses based on, for example, inferences about geographic location. However, please note that we do not obtain exact GPS coordinates. We only draw a conclusion about location based on IP address. Finally, we use this information to compare and look at trends and how our service works and how you interact with surveys on different browsers and devices.

Log data.

We use log data for many different business purposes, including:

- To monitor abuse and to debug,
- to create new services, features, content or to make recommendations,
- to track behavior at an aggregate/anonymous level to identify and understand trends in the various interactions with our services, and
- to fix bugs and troubleshoot product functionality.

Examples

Your IP address is used to ensure that you do not complete the same survey/form, application or questionnaire twice, if the Customer has included settings to avoid this (completion of multiple items under the same name), for purposes related to abuse monitoring (so that we can identify a respondent who misused their participation in the survey in a way that is contrary to our policies for use, or to make it easier for the Customer to comply with their own legal obligations). We also collect log data to coordinate aggregate data and calculations about activity on a non-identifying level, and so that we can identify trends in surveys over time.

Third parties and integrations.

We will collect and use information from third parties and integration partners to make it easier for Customers to send surveys/forms/applications/questionnaires to you.

Machine learning.

We will use machine learning methods on response data, metadata (as described above) and cookie data to provide Customers with useful and relevant insights from the data they have obtained using our Services, to build features, improve our Services, to detect fraud and to develop products with aggregated data. You can read more about this in connection with the Supplier's surveys below.

To administer our services, we will also use your information and data internally for the following limited purposes:

- To enforce our agreements where applicable,
- to prevent potentially illegal activities
- and to filter and prevent unwanted or abusive activity. For example, we have automated systems that filter content for phishing, spam and fraud.
Legal use.

To respond to legal requests or to prevent fraud, we may need to disclose information we hold about you. If we receive a subpoena or other legal request, we may need to inspect the data we hold about you to determine how to respond.

Use of survey data

Generally speaking, survey responses are controlled by the Customer (the person who sent or distributed the survey). In such cases, the Supplier only processes the responses on behalf of the Customer.

Trust between creator and respondent is critical to everything we do, and therefore we put customers and respondents first when we use information about respondents. When we analyze response data, we only do so when we have combined and anonymised or pseudo-anonymised the information.

We go into more detail below about how the Provider uses survey data. A creator has some control over how we use their responses in their account settings, and may have turned off our ability to use machine learning for responses where it is connected to a specific product feature in some cases.

The provider uses data in the ways described below, for our legitimate interests as described in this section:

The data affected by this section include:

- Survey type, question type and answer (only at aggregated and anonymised level)
- Device data
- Log data

The provider uses automated processes and machine learning to analyze survey responses, which in turn help us to:

Collect response data and activity:

We do this so that we can identify trends, build product features that optimize responses, provide product recommendations and provide guidance on which products and services work best in different situations.

Retrieve and analyze usage patterns:

By understanding response data and respondents' interaction with different types of surveys, we can:

- improve our services and user-friendliness: for example, we can identify where respondents prefer multiple-choice to free-text questions, and provide predictive answer suggestions where certain question types are selected. We may also use this data to help improve response analyses,
- carry out personalization for Customers and survey respondents (for example, by customizing the page on our website that the respondent sees after completing the survey. If a respondent does not wish to be included in this personalization, they can remove cookies in their browser settings after completing a survey,
- improve the user experience (for example, by collecting and using device and browser information from respondents to improve how our survey service works on those devices and browsers), and
- identify insightful data trends (which never identify any individuals).

3.3 Visitors

We process personal data about you there:

- You have given consent to, or
- we have legitimate interests to:
  - improve the service experience, and
  - develop new products and service functions.

In each of the cases where we describe how we use your data in these privacy policies, we have identified which basis we use for processing the data.

When you have consented to it or we have a legitimate basis to do so, we collect and use the following information about you:

Contact information.

We use contact information to respond to inquiries from you or send you information about our services, either where you have agreed to this when you provided your information, or where you run a business that may be interested in our services and as long as you do not choose it away.

Examples

We will share your email address with a member of our sales team who will contact you if you have sent an inquiry through one of the online forms on our website. You will also receive marketing communications from us if you have consented to this when you provided your information, or alternatively where your company may otherwise find information about related services of interest. We will always give you the opportunity to opt out of this type of marketing at any time.

Cookies and similar technology.

We or third-party data and advertising platforms with whom we work may use or combine multiple technologies, such as cookies, page tags, mobile identifiers and IP addresses to suggest users' common identities across different services and multiple devices, such as tablets, browsers and mobile phones. We may do this, for example, to tailor advertising to users, to find out how successful our advertising campaigns are and to improve them. This data and third-party advertising platforms may sometimes use data we provide to them to improve their technology and their ability to match common devices to users.

Examples

To customize marketing campaigns conducted through third-party advertisers and to help the Provider measure the effectiveness of online advertising and deliver ads for our services based on user preferences. See the section on cookies. If you do not want the Provider to use this information to display customized advertisements about our services, you can choose this in the settings at https://www.aboutads.info , https://preferences-mgr.truste.com or, if you are located in the EU, at https://www.youronlinechoices.eu . You may still receive advertisements on the internet that are not based on information you have provided to the Supplier.

As a result of the above-mentioned information we collect, we also carry out the following processing for legitimate business interests that we pursue:

User profiles.

We combine information about you from third-party sources with information we hold about you to create a user profile. This makes it easier to make sales and marketing activities more relevant to you and allows us to customize and improve sales and marketing campaigns and website experiences.

Machine learning.

We use machine learning techniques on some data to optimize marketing campaigns.

Device data.

We use device information to both troubleshoot problems with the Services and to improve them. We also suggest your geographic location based on your IP address. Some examples that are relevant to you:

Examples

We collect device and browser information to troubleshoot issues with website functionality and to fix bugs.

How to use our services.

We use information about the way you interact with our websites to improve online services for you and users in general. Some examples that are relevant to you:

Examples

We collect information about the websites you have visited and your activity on our websites on an aggregate level. We collect this information to track which parts of the website are most visited and most useful, to identify which services are most popular.

Log data.

We use log data for many different business purposes, including:

- To monitor abuse and to debug,
- to track your preferences and create new services, features, content or to make recommendations tailored to you;
- to track behavior on an aggregate/anonymous level to identify and understand trends in the various interactions with our services
- and to fix errors and troubleshoot product functionality.

Examples

The browser type determines how we can represent the website in the best possible way in the relevant browser.

Referral information.

We use referral information to track the effectiveness of our integration and referral processes.

Examples

If you have clicked on an ad for one of our brands displayed online by one of our partners and which has taken you to one of our websites, we record this information to help us measure the effectiveness of marketing campaigns.

In order to administer our services, we will also use your information and data internally, for the following limited purposes:
- To enforce our agreements where applicable,
- to prevent potentially illegal activities
- and to filter and prevent unwanted or abusive activity. For example, we have automated systems that filter content for phishing, spam and fraud.
Legal use.

In some cases, as a previous visitor to the website, we may not have any personal information about you (for example, if you have not interacted with our website or have deleted cookies).

4. Information You Share

Many of our services allow you to share information with others. Remember that information you share publicly can be retrieved by search engines. Our services give you another option regarding sharing and deleting content, but we cannot delete content from search engines and you must therefore be careful about what information you make public.

5. Information we share

We do not share information or data with third parties outside the Supplier, except in the following limited cases:

If you are a creator who is part of a business subscription, your account information and data is shared with the main administrator(s), and the survey data may also be visible to other members of the team with whom you share surveys or with whom you collaborate. The administrator(s) can view your account information, change your password, suspend, transfer or terminate your account or limit your settings. See your organization's internal policies if you have any questions about this.
To help us deliver certain parts of our services, we use collaborators and key partners we trust - more specifically, we use third parties to:
- to make it possible for the collectors to send surveys to the respondents via e-mail or text message. We share the relevant contact information of the respondents (email address or telephone number) with these third parties.
- to make it possible for customers to make payments.
- to detect fraud (which includes, for example, performing identity checks or verifying malicious IP addresses).
- to deliver and help us track marketing and advertising content.
- to help us track website conversion rates.
- to administer sales and customer support to you, including resolving any disputes.

We enter into confidentiality and data processing terms with partners to ensure that they adhere to high levels of confidentiality and best practice privacy and security standards, and we regularly review such standards and practices.

Following instructions from you, we share information or data about you if you choose to use integration in connection with services provided by the Supplier, to the extent necessary to make use of the services easier. See more information about our API partners here.
We may also need to share information or data in order to:
- comply with applicable legislation, regulation, legal process or comply with government requests;
- comply with applicable guidelines, including investigation of potential violations,
- detect, prevent or otherwise deal with problems related to fraud, security or technology;
- protect against infringement of the rights, property or safety of the users, the public or the Supplier, and/or if this is required or permitted by law, and
- facilitate a sale, merger, or change of control of all or part of your company or business or in preparation for any of these events.

Where we use third parties (sub-processors) to assist us with the delivery of services to you (the Customer), and they process your data as part of this service, we maintain a list of these third parties, which is available here . This contains a list of all sub-processors used across all services covered by this privacy policy, so please note that your service may only be affected by some of these sub-processors.

6. Cookies

We and our partners use cookies and similar technologies on our websites. For more information, see the cookie notice. For information about cookies used in our surveys, see Cookies used on survey pages. If you are a customer of the Supplier and use separate cookies or similar technologies in connection with any of our products and services, you yourself are responsible for following all legislation relating to the use of these technologies, and these privacy rules do not apply to such use by you.

We use certain cookies, as described in our cookie notice and here in this privacy policy, which you accept when you use our websites and, in the case of certain cookies, for legitimate interests regarding the provision and optimization of our services (where cookies facilitate important functionality). Cookies are small pieces of data that are stored on the device from which you use the Services so that we can recognize returning users. Each cookie expires after a certain period of time, depending on what it is used for. We use cookies and similar technology for several reasons:

To collect metrics.

For example, we collect information about the number of clicks respondents used to complete a survey, whether they left and returned to a survey, whether they skipped parts of the survey and how long it took to complete it, and other information about participation in the survey. We also track the number of clicks in the process of creating the survey, to assess whether the product is intuitive enough and improve the overall experience. This information is collected and stored on an aggregate and pseudo-anonymized level.

Make the website easier to use.

Customers: If you use the "Remember me" function when logging in, your username is stored in a cookie, so that you can log in faster the next time you visit our website.

Security reasons.

We use cookies to verify your identity and confirm whether you are currently logged in to our website, or determine whether an event is affecting you.

Customize the content.

We store information about user settings, default language, device, browser and profile information, which involves use of the service and which web pages you visit on the website, so that we can identify you across devices and customize the content you see.

To improve services and track promotions.

We use cookies to analyze and measure visits to our websites and how they were explored, and to track referral data. This information helps us develop and improve our services (they allow us to focus on the parts of the service you seem most interested in), to optimize the content we display online and to track the success of marketing campaigns.

Advertise for you.

We or the service providers and other third parties we work with store cookies when you visit the Site and other websites, or when you access online marketing content or emails we have sent, in order to provide you with better tailored marketing content (about our services or other services ) and to assess whether the content is useful or effective. We assess, for example, which advertisements are most often clicked on, and whether these clicks lead to users making better use of the tools, functions and services. If you do not wish to receive advertisements that are tailored to you and based on your activity on the internet, you can opt out of several of the companies involved in such customization by going to https://www.aboutads.info , https://preferences-mgr.truste.comor if you are located in the EU, by going to https://www.youronlinechoices.eu . Opting out in this way does not mean that you will not see ads. It just means that you won't see ads that have been tailored to you, based on your activity and settings.

Google Analytics.

We use Google Analytics as a tool to measure the success of marketing campaigns and referrals through third-party advertising partners. The Google Analytics data collected for this purpose is aggregated and anonymous.

When you have given your express consent or have not disabled third-party advertising cookies (depending on the region), we also use Google Analytics data to support ad serving, including re-targeting. In addition to customizing your preferences for these behaviors through the steps we've outlined in the Banners and Privacy Policy, you can also customize Google Display Network ads by using Google's tools to manage ad preferences and learn more about how Google handles ads by viewing the Help Center for Customer Ads.

You can also choose to remove or disable cookies through your browser settings and, depending on your geographic location, you can withdraw your consent to non-essential cookies with the cookie settings tool in the product.

7. Security

We have a security statement relating to our self-service businesses, which you can read about here . For information about security related to other business areas, you can speak to a sales representative via support@retailx.no.

8. Data storage

If you are a creator, we generally do not delete any data from your account as long as it is active - you are responsible for and control the time periods for how long you can keep the information. You can read more about this here for using the account.

We also encourage Customers to actively review their account data storage practices and to only store data for as long as necessary.

We also state the expiry periods for cookies on the websites in our cookie notice.

9. The safety of minors

Our services are not intended for and should not be used by minors. "Minors" are persons under the age of 13 (or under a higher age if the law where they live allows it). The provider does not knowingly collect personal data from minors or allow them to register. If we are made aware that we have collected personal information from a minor, we can delete this information without prior notice. If you have reason to believe that this has occurred, please contact customer service.

10. Data transfers and certification of privacy protection

Your information and data may be processed in and transferred or shared in the United States and countries where our business partners are located, and where our service providers are located or have servers. You can see where our partners are located on the page for office locations. We ensure that the recipient of your personal data offers a similar level of security, for example by entering into appropriate "back to back" agreements. We use our standard Data Processing Agreement for all customer agreements, and we use standard contractual terms for the transfer of data, as approved by the European Commission.

Privacy for the EU and the US (Privacy Shield) and privacy for Switzerland and the US (Privacy Shield).

The supplier is committed to subjecting all personal data received from member states of the European Union (EU), Great Britain and Switzerland in accordance with the Privacy Shield Framework, to the applicable principles in the framework. To learn more about the Privacy Shield Framework, please visit the US Department of Commerce's Privacy Shield List at https://www.privacyshield.gov.

The supplier also complies with the provisions on onward transfer liability in the Privacy Shield principles.

When the Provider receives personal data under the Privacy Shield and transfers it to a third-party provider acting as an agent on the Provider's behalf, the Provider has some liability under the Privacy Shield if both (i) the agent processes the information in a manner that does not comply with the Privacy Shield, and (ii) The supplier is responsible for the event that led to the damage. In certain situations, the Provider may need to share personal data in response to lawful requests from public authorities, including to meet national security or legal requirements.

The supplier is subject to the investigative and enforcement authority of the US Competition Authority (Federal Trade Commission). Contact the Supplier as described in section 14 below if you have any questions or complaints of any kind. If you have unanswered questions about privacy or data use that we have not satisfactorily explained, you can contact the US third-party dispute resolution provider (toll-free) at https://www.jamsadr.com/file-an-eu-us -privacy-shield-claim.

Under certain circumstances detailed on the Privacy Shield website, https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

11. Changes to the privacy rules

From time to time we may make changes to the Privacy Basics and this Privacy Policy. In cases where changes will significantly change the way we collect or use personal information or data, we will send notice of this change to all account holders.

12. Customized marketing

You can opt out of direct marketing in the account and we offer options for unsubscribing in all e-mails related to marketing. Finally, if you do not want to see personalized online marketing related to our services, you can delete the cookies in your browser settings.

13. Who is my data controller?

As mentioned above, all response data is checked on an individual level by the Customer. The supplier can only be a data controller for data about respondents in the very limited ways described in the section here called "How we use the information we collect - respondent ".

For business account holders, the organization controls some basic account information that you enter when you set up your account (such as your name, mobile number, email address, and profile picture). You can contact the main administrator(s) for the account if you want to delete, receive a copy of, change or update this information.

14. Your rights

It may be that you wish to exercise a right to obtain information about yourself or to correct, update or delete this information. Some of these rights may be subject to exceptions or limitations in local law. Note that your rights and choices vary depending on your location. We will take reasonable steps to verify your identity and we will respond to your request to exercise these rights within a reasonable time (and in any case within 30 days of receiving a request) subject to the below for specific categories of persons.

This section describes the rights you may generally have as a customer of any service provided by the Supplier.

Creator

If you have an account associated with any service provided by the Provider, you have the right to obtain a copy of any personal data we store relating to you. You may also have the right to request that we limit how we use information about you or to object to any aspect of processing the information. You can see most of the information about you in your account when you log in. If you wish to exercise your rights, you can contact us here.

Depending on your subscription type, the Provider also allows you to export your own response data from our system in various formats, so that you can back them up or use them with other programs. You can also get in touch for help with exporting.

Respondent

If you have completed a survey, form, questionnaire or application sent to you by a creator using a service provided by the provider, you must contact that person or organization directly to discuss handling, deletion, access, restriction of access or other withdrawal of consent to the use of the information you provided in the answers. The supplier does not control response data and is therefore unable to directly handle such requests associated with the data. If you have trouble locating the Customer or have any other questions after reading this Privacy Policy, please contact us through our Customer Support team and we will do our best to assist you.

Visitor

If you have visited the website and wish to exercise any of the above rights, you can contact customer support here. If the request concerns the right to be forgotten, you can possibly achieve this by deleting cookies in the browser settings, as this is only related to the use of cookies.

Third Party Agents

If you are a third party organization acting on behalf of a data subject (or a class of data subjects) to exercise the data subject's rights, we may work with you. In that case:

- We ask you to follow the process described in this privacy policy for security reasons, so that we can independently verify the Customer (if there is a creator) who requested to exercise their rights.
- Where applicable, we interact directly with a creator's registered email address because we verify users with usernames and unique passwords, and not with other identifying information (eg photo ID or similar).

Do not share other types of personal data about the data subject with us when you submit the request.

15. Exercising rights

Except where explicitly stated, please use the following contact information for privacy-related inquiries

RetailX AS

Østensjøveien 14 A

0661 Oslo

Norway

Or contact us at privacy@retailx.no.

Data controller: The data controller at the Supplier can be reached at privacy@retailx.no.

Complaints

If you are an EU citizen and are unhappy with how we have handled a complaint you have sent to us, you have the right to contact your local data protection authorities. Because the Supplier operates in Norway, we operate under the authority of the Norwegian Data Protection Authority .

16. Specific information for other services

ALTHOUGH THESE RULES APPLY TO ALL OF OUR SERVICES, SERVICE-SPECIFIC INFORMATION WILL TAKE PRIORITY IF IT EXISTS FOR THE CURRENT SERVICE.