DATA PROTECTION NOTICE
Last updated: 15th March 2021
Data Protection Officer: firstname.lastname@example.org
This Data Protection Notice (“Notice”) sets out the basis on which InnoProbe Insight Pte. Ltd. (UEN No. 201821787E) (“IPI”, “we”, “us”, or “our”) will handle the personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or otherwise process personal data of our customers for our purposes, in accordance with the Personal Data Protection Act of Singapore 2012 (“PDPA”).
- As used in this Notice:
- “Customer” means an individual who
- has contacted us through any means to find out more about any goods or services we provide, or
- may, or has, entered into a contract with us for the supply of any goods or services by us; and
- visitors and users of IPI’s ApiaryBuzz websites and mobile apps (collectively defined as “ApiaryBuzz”)
- “Personal Data” means data, whether true or not, about a customer who can be identified:
- from that data; or
- from that data and other information to which we have or are likely to have access.
- For the purpose of this Notice, “Personal Data” means any information which relates to an identifiable living individual.
- “Customer” means an individual who
2. Depending on the nature of your interaction with us, some examples of Personal Data which we may collect from you include your name and identification information such as your contact information, including your address, email address or telephone number, nationality, gender, date of birth, marital status, photographs and other audio-visual information, employment information and financial information such as credit card numbers, debit card numbers or bank account information.
3. Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).
4. The ApiaryBuzz is operated by IPI which is the data controller.
5. The purpose of this Notice is to inform you of how IPI manages Personal Data which complies with the PDPA. Please spend some time to read this Notice so that you know and understand the purposes for which we collect, use and disclose your Personal Data.
6. It also sets out the commitment of IPI, towards the privacy of our Customers, and governs our Customers’ rights regarding privacy and data protection.
7. By any interaction with us, submitting of information to us, or signing up for any products and services offered by us, you agree and consent to IPI in collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to relevant third parties as per listed in this Notice.
LEGAL BASES FOR USING YOUR PERSONAL DATA
8. The PDPA sets out a number of different reasons for which IPI may collect, use and disclose such Personal Data, including:
- Consent – In certain cases, we collect and process your Personal Data with your consent e.g. when you participate in surveys, we will ask you if you wish to participate.
- Contractual obligations – In some circumstances, we need to process your Personal Data to comply with a contractual obligation e.g. when we use your Personal Data to send you your rewards.
- Legal compliance – If the law requires us to, we may need to collect and process your Personal Data in response to lawful requests by public authorities or if e.g. we believe in good faith that disclosure is necessary to protect our rights, to protect your safety or the safety of others, to investigate fraud or breaches of our site terms, or to respond to a government request.
- Protection of interest – we need to process your data in order to protect your vital interests or someone else.
- Public Interest – the processing is necessary to perform a task in the public interest.
- Legitimate interest – means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
- The research activities carried out by IPI ApiaryBuzz require the collection, use or disclosure of personal data, under the PDPA. You will be informed of the purposes for which your personal data is collected, used, and disclosed by us, and we will seek your consent for these purposes, unless any exception under the PDPA applies. Usually these are mentioned at the beginning of each survey.
- Unless otherwise stated in a market survey or poll, all data and opinion provided by you is anonymised later for market research, statistical and historical research purposes. Anonymised data is not personal data and thus would not be governed by the PDPA.
9. IPI complies with the privacy and data protection requirements as set forth by Singapore Personal Data Protection Commission (“PDPC”) regarding the collection, use, disclose and retention of Personal Data. IPI ensures adherence to the principles listed below.
- Personal Data is collected for specified, explicit and legitimate purpose and not further processed in a manner that is incompatible with those purpose.
- Personal Data is adequate, relevant and limited to what is necessary in relation to the purpose for which it is processed.
- Personal Data is processed lawfully, fairly and in a transparent manner in relation to the data subjects.
- Information is processed in a manner that ensures appropriate security of the Personal Data, including protection against the unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organization measures.
- Information is accurate and where necessary, kept up to date every reasonable step is taken to provide that personal which is inaccurate, having regard to the purpose for which it is processed, is erased or rectified without delay.
- Information is kept in a form which permits identification of data subjects for no longer that is necessary for the purpose for which Personal Data is processed.
COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
10. We generally do not collect your Personal Data unless:
- It is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your Personal Data to us (your “Authorised Representative”) after
- you (or your Authorised Representative) have been notified of the purposes for which the data is collected, and
- you (or your Authorised Representative) have provided written consent to the collection and usage of your Personal Data for those purposes, or
- Collection and use of Personal Data without consent is permitted or required by the PDPA or other applicable laws. We shall seek your consent before collecting any additional Personal Data and before using your Personal Data for a purpose which has not been notified to you (except where permitted or authorised by law), for reasonable purposes (e.g. to respond to an emergency that is life threatening or to assist in an investigation).
- It is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your Personal Data to us (your “Authorised Representative”) after
11. We may collect and use your Personal Data for any or all of the following purposes:
- performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;
- managing your relationship with us;
- processing payment or credit transactions;
- verifying your identity;
- responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
- sending your marketing information about our surveys and services including notifying you of our marketing events, initiatives and promotions, lucky draws, membership and rewards schemes and other promotions;
- informing you of, and inviting you to participate in surveys held by us;
- transmitting to any unaffiliated third parties including our third-party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes;
- complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
- any other purposes for which you have provided the information; and
- any other incidental business purposes related to or in connection with the above.
12.We may disclose your Personal Data:
- where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods or services requested by you; or
- to third party service providers, agents and other organisations we have engaged to perform any of the functions listed in clause 11above for us; or
- for announcements of contest winners on our social media, limited to your first name and image
13. The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).
If you provide any other’s individual personal data other than your own personal data to us, you should obtain the consent for collection, use and disclosure from the individual before providing the such individual personal data to us.
HOW WILL WE CONTACT YOU?
14. By becoming an ApiaryBuzz member, you agree to allow us to communicate with you via email or sms or app notifications in relation to your membership of the ApiaryBuzz panel and opportunities to participate in ApiaryBuzz activities. These include but are not limited to communications relating to:
- ApiaryBuzz polls;
- ApiaryBuzz surveys;
- ApiaryBuzz iBuzz online forum;
- Other forms of ApiaryBuzz research;
- ApiaryBuzz research results;
- ApiaryBuzz newsletters;
- ApiaryBuzz notices; and
- ApiaryBuzz rewards and redemption;
WHAT DOES PERSONAL DATA COMPRISE?
15. As set out in clause 1(b) above, personal data, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
16. We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together as follows:
- Identity data – name (includes first, last, maiden and married names), date of birth, marital status, gender, and username.
- Contact data – postal address, email address and telephone number.
- Sensitive Personal Data – ethnic/racial origin, health, political opinion, religion, sexual orientation and sex life, trade union membership, and/or criminal convictions.
WHAT OTHER DATA DO WE COLLECT ABOUT YOU?
- We may collect and process the following data about you:
- Information you provide when participating in specific ApiaryBuzz polls, panels or other forms of ApiaryBuzz research. Participation in such panels, activities and polls is completely voluntary and some such activities may involve you providing sensitive Personal Data;
- information you provide relating to your opinions, attitudes, experiences and use of certain products or services; and
- your bank account details (if you win a prize draw or are entitled to receive an incentive from us).
- Demographic/Profile data – interests, preferences, feedback and survey responses and including, but not limited to age, marital status, gender, birthday, household size, income, education and employment status.
- “Pseudonym data” is identifiable data as unique identifiers such as panelist ID’s are used, however direct identifiers, such as name and Contact data are removed.
- Technical data includes internet protocol (IP) addresses, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
PROTECTION OF PERSONAL DATA
18. To safeguard your Personal Data, ApiaryBuzz will take reasonable efforts to protect Personal Data (in our care or our control), from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures.
- Some of the measure are up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of Personal Data by us, and disclosing Personal Data both internally and to our authorised third party service providers and agents only on a need-to-know basis.
- You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure.
- Hence, we cannot fully guarantee the security of any Personal Data we may have collected from or about you, or that for example no harmful code will enter our websites (for example Trojan horses, adware, viruses, bugs or spyware).
- While security cannot be guaranteed, we strive to protect the security of your information. We will apply our normal procedures and comply with legal requirements to protect your information, so once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
19. All your information is stored on secure servers that are owned or leased by us.
21. We highly recommend that you change your passwords often, use a combination of letters and numbers and symbols, and ensure that you use a secure broswer.
- If applicable, you commit to keep your username and password secure and confidential and shall not disclose or permit it to be disclosed to any unauthorised person.
- If you believe or suspect that someone else knows your login details you must contact us as soon as possible.
22. We have put in place procedures to deal with any suspected privacy breach and will notify you and any applicable regulator of a breach where we are legally required to do so, no later than 72 hours after establishing that the data breach has happened.
ACCURACY OF DATA
23. We generally rely on Personal Data provided by you (or your Authorised Representative), by answering our questions honestly. In order to ensure that your Personal Data is current, complete and accurate, please update us if there are changes to your Personal Data by informing our Data Protection Officer in writing or via email at the contact details provided below.
Data Protection Officer: email@example.com
24. We take reasonable steps to keep Personal Data in our possession or control accurate, complete and current, based on the most recent information made available to us by you and/or by our client.
RETENTION OF PERSONAL DATA
25.We may retain your Personal Data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.
- ApiaryBuzz will retain your Personal Data for as long as you have not unsubscribed / deleted your account from our database.
- In case you unsubscribe / delete your account from our database, we shall retain data for no longer than is necessary for our business or legal purposes to do so after you unsubscribe, unless otherwise required by law.
- Personal Data that is no longer required will be disposed of in ways that ensure their confidential nature is not compromised.
26. We will cease to retain your Personal Data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the Persoanl Data was collected, and is no longer necessary for legal or business purposes.
27. As the results of the surveys and other aggregated or Pseudonym data are used for research and/or statistical purposes, we and our clients or other third parties may use this information in accordance with the terms indefinitely without further notice to you.
28. As part of the ApiaryBuzz business continuity plan, and as required in certain instances the law, our electronic systems are backed up and archived. These archives are retained for a defined period of time in a strictly controlled environment. Once expired, the data is deleted and destroyed to ensure the data is erased completely.
29. You have the right to access, correct or withdraw consent for processing your Personal Data and should direct any request for access, correction of your Personal Data, or to withdraw consent for our use, collection, and/or disclosure of your Personal Data to us, at firstname.lastname@example.org.
30. You have the following rights in relation to your Personal Data:
a. Right to access your Personal Data;
b. Right to rectify omissions or errors in your Personal Data;
c. Right to withdraw your consent; and
d. Right to know IPI’s data protection practices, procedures and complaints processes upon your request.
31. Due to the nature of our activities and i) our need to take a snapshot of views and opinions at a particular moment in time, or ii) due to anonymization of your data it is not possible to access, amend, rectify inaccurate data, restrict processing or withdraw your consent of processing or delete any responses provided to polls, surveys, focus groups, interviews, online forum, ApiaryBuzz activities (where you have provided your username).
32. For the sake of your security and to prevent fraud, we prevent the changing of certain fields in your Personal Data using our app or online, however it can be changed by writing to us with valid proof and we will make the changes from our end after verification.
33. We will respond to your correction request as soon as reasonably possible. Should we not be able to correct the correction request within ten (10) days after receiving your request, we will inform you in writing via email on the time by which we will be able to correct your correction request. If we are unable to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).
34. Correction request will not be approve in respect of:
- opinion data kept solely for an evaluative purpose;
- any examination conducted by an education institution, examination scripts and, prior to the release of examination results, examination results;
- the personal data of the beneficiaries of a private trust kept solely for the purpose of administering the trust;
- personal data kept by an arbitral institution or a mediation centre solely for the purposes of arbitration or mediation proceedings administered by the arbitral institution or mediation centre; or
- a document related to a prosecution if all proceedings related to the prosecution have not been completed.
35. We shall also notify third parties to whom we have transferred your Personal Data of any changes that we make on your request. Note that while ApiaryBuzz communicates to these third parties, ApiaryBuzz is not responsible for the actions taken by these third parties to answer your request. You may be able to access your Personal Data held by these third parties and correct, amend or delete it where it is inaccurate.
36. Please note that a fee may be payable to meet our costs in providing you with details of the information we hold about you upon receiving an access request. We will inform you of the fee before processing your request. It is also important to note that, while you can request your information at any time, you can also do so by logging in to your panel account and proceeding to your personal profile page. We continuously ask our panelists to update information about themselves and our records of your information will be as per the information you provide during registration or update on that page, whichever is later.
37. We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).
38. We will not provide information under the access requirement for:-
(a)opinion data kept solely for an evaluative purpose;
(b)any examination, examination scripts and, prior to the release of examination results, examination results;
(c)the personal data of the beneficiaries of a private trust kept solely for the purpose of administering the trust;
(d)personal data kept by an arbitral institution or a mediation centre solely for the purposes of arbitration or mediation proceedings administered by the arbitral institution or mediation centre;
(e)documents related to a prosecution if all proceedings related to the prosecution have not been completed;
(f)personal Data subject to legal privilege;
(g)personal Data which, if disclosed, would reveal confidential commercial information that could, in the opinion of a reasonable person, harm the competitive position of the organisation;
(h)personal Data collected, used or disclosed without consent pursuant to the exemptions in the PDPA, for the purposes of an investigation if the investigation and associated proceedings and appeals have not been completed;
(i)the personal data was collected or created by a mediator or arbitrator in the conduct of a mediation or arbitration for which he was appointed to act —
- under a collective agreement under the Industrial Relations Act (Cap. 136) or by agreement between the parties to the mediation or arbitration;
- under any written law; or
- by a court, arbitral institution or mediation centre.
- That would unreasonably interfere with the operations of the organisation because of the repetitious or systematic nature of the requests;
- If the burden or expense of providing access would be unreasonable to the organisation or disproportionate to the individual’s interests;
- For information that does not exist or cannot be found;
- For information that is trivial; and
- That is otherwise frivolous or vexatious.
(k)personal Data or other information shall not be provided to an individual if the provision of that Personal Data or information could reasonably be expected to:
- Threaten the safety or physical or mental health of an individual other than the individual who made the request;
- Cause immediate or grave harm to the safety or to the physical or mental health of the individual who made the request;
- Reveal Personal Data about another individual;
- Reveal the identity of an individual who has provided Personal Data about another individual and the individual providing the Personal Data does not consent to the disclosure of his/her identity; or be contrary to national interest.
(l)If Personal Data has been disclosed to a prescribed law enforcement agency without the consent of the individual or pursuant to the exemptions in the PDPA, we shall not be required to inform the individual of such disclosure.
39. If you wish to make (a) an access request for access to a copy of the Personal Data which we hold about you or information about the ways in which we use or disclose your Personal Data, or (b) a correction request to correct or update any of your Personal Data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided herein.
Data Protection Officer: email@example.com
WITHDRAWING YOUR CONSENT
40. The consent that you provide for the collection, use and disclosure of your Personal Data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop using and/or disclosing your Personal Data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.
41. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us.In general, we shall seek to process your request within ten (10) business days of receiving it. However if we are unable to complete your request within the timeline we will inform you within the ten (10) business days.
42. Whilst we respect your decision to withdraw your consent, please note that because of the nature and scope of your request, we may not be in a position allow you to use ApiaryBuzz, and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing or via email to our Data Protection Officer at the contact details provided below.
43. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose Personal Data where such collection, use and disclose without consent is permitted or required under applicable laws.
WHY DO WE NEED TO COLLECT YOUR INFORMATION?
44. The legal bases for us to collect information has already been mentioned earlier. To elaborate further, here are some of the main purposes for which we may collect your Personal Data:
- to ensure that our site’s content is presented as effectively as possible for you;
- Contact you in relation to our Services via email, through mobile notifications or texts or any other proposed communication options you have consented to;
- Contacting you to invite you to take part in surveys, polls and activities and when permitted by you provide you with information, research products or services that you request from us, or which we feel may interest you;
- Evaluating which individuals registered with ApiaryBuzz are best suited for and therefore should be approached for specific surveys;
- Undertaking research surveys on behalf of third parties;
- Processing the answers to surveys to analyse the data for research purposes and to incorporate it into our databases for general research and analysis purposes;
- Providing you with information about rewards/gifts given to you by ApiaryBuzz as a result of your responding to survey requests;
- to enable us to issue prizes, payments or rewards to you;
- to notify you if you win one of our prize draws (this information will also be published on our site);
- to notify you about changes to our services or changes which may affect your participation in ApiaryBuzz activities;
- Update, enrich and clean your data to better understand your needs and obtain your views of ApiaryBuzz products, services and activities;
- The administration of your membership of ApiaryBuzz (if you have registered as a member);
- Help you when you contact us with any complaints, queries or technical problems you experience and processing any enquiries raised by you and other communications initiated by you in relation to your dealings with ApiaryBuzz;
- for our internal purposes, such as quality control, site performance, system administration and to evaluate use of our site and its efficiency, so that we can provide you with enhanced services and a better experience;
- Protect ApiaryBuzz from fraudulent behaviour; and
- Statutory and regulatory compliance.
- To post contest winners’ images and first name on our social media (example Facebook & Instagram) for publicity purposes which individuals can withdraw consent anytime.
WHAT METHODS DO WE USE TO COLLECT YOUR INFORMATION?
45. ApiaryBuzz may collect information in several ways from different parts of our ApiaryBuzz and other activities such as social media, apps and surveys. Examples of these activities may include:
- Information that you submit online via our site by registering with the ApiaryBuzz Panel or participating in ApiaryBuzz activities or polls;
- Research Activities: Personal Data may also be collected from you when you participate in a survey or in a research activity proposed by ApiaryBuzz to the Customers;
- Information you post on our site;
- Some Personal Data is gathered when you register for our Services, including when you fill out request forms on ApiaryBuzz, such as name, email address, postal address, job title and mobile device ID;
- Any correspondence you send to us;
- Details of your visits to our site (and third party websites which link to our site) and the resources that you access (which may include, amongst other things: traffic data and communication data);
- Details of transactions you carry out or orders you place through our site; and
- Information you provide to us via social media or through your social media feed.
WHERE DO WE TRANSFER YOUR INFORMATION TO?
46. We generally try to not transfer your Personal Data to countries outside of Singapore.
47. From time to time your Personal Data may be transferred to, stored, used, and processed in a country other than Singapore, to our partners in other countries. You understand and consent to the transfer of your Personal Data to our partners in other countries.
48. We will take steps to ensure that your Personal Data continues to receive a standard of protection that is at least comparable to that provided under the Singapore law.
WHO DO WE SHARE YOUR INFORMATION WITH?
49. All of the responses we collect from you via our surveys are provided to our clients in aggregate or pseudonym form. This means that information is provided about groups of individuals and not on an individual level but may include Pseudonym data.
50. Identity data or Contact data about you would only be provided to our clients in specific surveys for the purposes of research and we would never provide such data to our clients unless we have first received your consent and confirmed with them that their use is in accordance with applicable law.
51. We may share your information with any companies in our InnoBay group and other branches of ApiaryBuzz for internal reporting purposes. We may share your information with other organisations:
- who provide services to us so that they can provide the services we request. This might include IT service providers who support our IT systems, for example
- who we provide services to so that they can benefit from the services we provide. Whilst we will, where possible, take steps to ensure that you cannot be identified from that information, as we cannot ever fully understand what information our clients may already hold about you, it may be that they can link the anonymous information that we provide, to other information which then enables them to identify you. By way of example:
- we may exchange what we consider to be anonymous or pseudonym information about our panelists with third parties who will use it for analysis purposes, to enhance their own databases, to model audiences and track the efficiency of campaigns, and to gain an insight into behaviours so that they can develop strategies which add value to their, or their clients’ businesses.
- For this purpose, we may also collect anonymised information from third parties which we can use to identify you.
- As our clients and, in turn their clients, will have their own databases and other sources of information, it may be that they could link the anonymous information we provide with information they already have and therefore identify you or
- we may provide limited personal details to trusted third party data processors for the purposes of combining our data with other third-party data sources. The final combined data set will be anonymised and non-attributable.
- if we sell or buy any business or assets, (as we may share your data with the prospective seller or buyer)
- if we or substantially all of our company assets are acquired by another party, in which case your information will be one of the transferred assets or
52. From time to time we may engage third parties to issue you with cash or cheques or processing the delivery of your rewards and they will need to use your Identity data and Contact data for those purposes.
53. We may automatically disclose your first name and image when you win a contest, to be disclosed on our social media(example Facebook & Instagram) and website for publicity purposes.
54. We may also transfer your Personal Data to third parties for the purposes of those parties providing us or our clients with services such as data processing or analytics services or to append data they previously collected about you. Such third parties are not allowed to use your Personal Data for any other reason and we enter into contracts with those third parties to ensure your Personal Data is kept secure and erased in accordance with our data retention and destruction policies.
55. From time to time, we may use third-party software for email list management and email distribution or may use third-party list management providers to match our members to members of other lists or panels or to validate the accuracy of Personal Data you provide.
56. Though we make every effort to preserve your privacy and protect your data, we may be required to disclose your Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements or to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, to protect your safety or the safety of others, to investigate fraud or breaches of our site terms, or to respond to a government request.
57. We will not make your Personal Data available to anyone else without your agreement unless it is for research purposes or if required by law and/or by regulators or authorities. In these cases, the legal basis of our disclosure of your Personal Data is it is necessary to comply with a legal obligation. The data that we disclose may include your name and e-mail address.
58. Our third party partners are all contractually bound to keep any information they collect and disclose to us, or that we collect and disclose to them, confidential and must protect it with security standards and practices that are equivalent to our own.
59. Other than as listed above, we will not rent, sell or otherwise disclose your information without your consent.
60. However, please bear in mind that whenever you voluntarily disclose Personal Data online – for example on message boards, on a blog or chat area – that information will be viewed by others.
61. IPI recognizes the need to provide further privacy and data protection with respect to Personal Data collected from children.
- ApiaryBuzz is not intended or designed to attract children under the age of 16. We do not knowingly collect Personal Data from or about any person under the age of 16, without permission from his/her parents, legal guardian or an adult responsible for the care of the child.
- If children under the age of 16 years join our panel we will notify them within 1 month about their account being invalid and their account and information will be deleted.
- If you are under 16 years old and wish to ask a question or use this Site in any way which requires you to submit your Personal Data, please ask your parent or guardian to do so on your behalf.
- If we need to survey children under 16 years old, we approach his/her parents, legal guardian or an adult responsible for the care of the child, and not the child directly. We also request them adult to monitor their children while they take the survey.
- Eligible ‘young people’ (individuals aged between 16 and 17) may be invited to participate in our Teens panel from time to time.
- We comply the ESOMAR guidelines in relation to surveys concerning children and young people.
OUR MOBILE APP
62. You may choose to use ApiaryBuzz by using our mobile app.
- When you download and use our mobile app, we may automatically collect system and performance information on the type of device you use, operating system version, device identifier and hardware usage statistics such as CPU, RAM, storage, and app version.
- We will use the information we collect via our mobile app in accordance with the terms of this Notice and the provisions set out below.
- We may send you push notifications from time-to-time in order to notify you about surveys and ask you if you would like to participate in certain marketing research studies in accordance with this Notice.
- If you no longer wish to receive these types of communications, you may turn them off at the device level.
- To ensure you receive proper notifications, we may need to collect certain information about your device such as operating system and user identification information.
- The mobile app allows panelists to take surveys they are eligible for and also provides information regarding points earned and their redemption.
- Also in some cases, only after obtaining Customer opt-in, in partnership with our third party, the app also may have the capability of passively capturing mobile behavioural data through its meter installed on your device and sending it across to cloud based servers. The installation and collection of behavioural data through the third-party meter is restricted in various jurisdictions and is applicable for information that you choose to disclose over our mobile app in a constricted manner.
63. We may use “cookies” to collect the information referred to and track your use of our site.
- A cookie is a text file containing a small amount of information that is sent to your browser when you visit a website. The cookie is then sent back to the originating website on each subsequent visit, or to another website that recognises it. Cookies are an extremely useful technology and do lots of different jobs.
- IPI defines cookies within 3 categories: a) Required to use ApiaryBuzz b) Security-specific, and c) Behavioural or advertising research cookies.
- This helps us to provide you with a good experience when you browse ApiaryBuzz and also allows us to improve ApiaryBuzz.
- We may use various types of cookies (including some that we place and others which we permit third parties to place on ApiaryBuzz) for a number of purposes.
- These cookies may expire when your browsing session ends.
- We may gather certain information automatically and store it. This information may include things like Internet Protocol addresses (IP address), browser type, Internet service provider (“ISP”) referring/exit pages, operating system and date/time stamp.
- We use this automatically collected information to analyse trends such as browser usage and to administer the site, e.g. to optimise the Sites experience depending on your browser type. We may also use your IP address to identify your country and also to protect our business against fraudulent behaviour.
- As you use the Internet, a trail of electronic information is left at each website you visit. This information, which is sometimes referred to as ‘clickstream data’, may be collected and stored by a website’s server. Clickstream data can tell us the type of computer and browsing software you use and the address of the website from which you linked to the Site. We may collect and use clickstream data as aggregated information to anonymously determine how much time visitors spend on each page of ApiaryBuzz, how visitors navigate throughout the Sites and how we may tailor our web pages to better meet the needs of visitors. This information will be used to improve ApiaryBuzz and our Services. Any collection or use of clickstream data will be anonymous and will not intentionally contain any Personal Data.
- If for any reason you do not want us to track your use of ApiaryBuzz using cookies, you can opt out of this using your browser settings and can also select the option “Do Not Track” (for more information please refer to your browser).
64. As is true of most websites, we may gather certain information automatically and store it in log files.
- This information may include Internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.
- We may combine this automatically collected log information with other information we collect about you.
- We do this to improve services we offer you, to improve analytics, marketing, and site functionality.
65. We may partner with third parties to either display advertising on ApiaryBuzz or to manage our advertising on other sites.
- Our third-party partners may use technologies such as cookies to gather information about your activities on their site and other sites in order to provide you advertising based on your browsing activities and interests.
- If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by contacting us.
- Please note this does not opt you out of being served ads. You will continue to receive generic ads.
66. We will generally not use digital fingerprinting technology (the “Technology”) to collect your Personal Data or track your online activities and will not disrupt or interfere with the use or control of your computer or alter, modify or change its settings or functionality.
- In general, digital Fingerprinting technologies assign a unique identifier or “Machine-ID” to a user’s computer to identify and track your computer.
- The unique identifier will be an alpha-numeric ID In order to assist our clients in protecting and ensuring the integrity of survey results, we may
- link or associate your unique identifier to you and any of your Personal Data;
- share your unique identifier with our clients and with other sample or panel providers; and
- receive or obtain a unique identifier linked to you from a third party, including without limitation a sample or panel provider or our client, however we will only provide such information to any third parties (including our clients) on an aggregated and anonymised or pseudonym basis.
- In addition, any unique identifier(s) received or obtained by us and linked to you will be protected in accordance with this Notice and if required by law, we will ask for your consent in advance.
67. Occasionally, in specific market research programs, we may use the Technology to assist our clients in ensuring the integrity of survey results.
- The Technology will analyse publicly available information and data obtained from your computer’s web browser and from other publicly available data points, including the technical settings of your computer, the characteristics of your computer, and its IP Address, to create a unique identifier, which will be assigned to your computer.
68. We shall do everything we can to ensure that the Technology is safe, secure and does not cause undue privacy or data security risks and we shall use and distribute the Technology in a professional and ethical manner and in accordance with
- this Notice;
- any other statements and/or disclosures made by us to you and
- applicable laws and market research codes of practice.
69. In the event that we discover or learn of any unethical conduct in connection with the use of the Technology, or that the Technology is being used in a manner that is inconsistent with the statements and/or disclosures made by us to you or is in breach of applicable laws and the market research codes of conduct, we will take immediate action to prohibit such unethical conduct and to ensure the proper administration of the Technology.
SOCIAL MEDIA WIDGETS
70. ApiaryBuzz may include social media features, such as the Facebook Like button (and Widgets, such as the Share This Button or interactive mini-programs that run on ApiaryBuzz).
- These Features may collect your IP address which page you are visiting on ApiaryBuzz and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on ApiaryBuzz.
- Your interactions with these Features are governed by the Notice of the company providing it.
PUBLIC FORUMS AND BLOGS
71. Our website may offer publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them.
- We may display personal testimonials of satisfied customers on ApiaryBuzz in addition to other endorsements. With your consent, we may post your testimonial along with your username. If you wish to update or delete your testimonial, you can contact us here at [firstname.lastname@example.org].
- You should be aware that any Personal Data you choose to make public on ApiaryBuzz, in the public area can be read, collected, stored and/or used by other Customers and could be used to send you unsolicited messages.
- We strongly discourage you from disclosing any of your Personal Data in any public forum or community area that you may find on ApiaryBuzz and/or providing your Personal Data as we cannot guarantee that third parties who may collect and process your Personal Data from those public forums or community areas will keep them secure.
- Please be aware that we are not responsible for the Personal Data you choose to submit or make public. In addition, we are not responsible for the content you publicly post on ApiaryBuzz that can be found via web-based search engines.
72. We may use mobile analytics software to allow us to better understand the functionality of our mobile application on your phone.
- This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from.
- We do not link the information we store within the analytics software to any personally identifiable information you submit within the mobile application.
73. We may collect your location-based information for the purpose of calculating user country, so we can route a visitor to the correct country site. We may share this information with our third-party service providers and clients for the sole purpose of market research services for our clients and for fraud and quality purposes.
74. We may make available a service either directly or through third parties by which you can receive messages on your wireless device via short message service (“SMS Service”).
- Personal Data obtained from you in connection with this SMS Service may include your Identity data and Contact data, your provider’s name, and the date, time, and content of your messages. The use of this information will be in accordance with this Notice.
- You represent that you are the owner or authorised user of the wireless device on which messages will be received and that you are authorised to approve the applicable charges.
- Your provider’s standard data and messaging rates apply to all SMS correspondence.
- All charges are billed by and payable to your mobile service provider.
- If fees are charged to your wireless account invoice, we may be required to provide your carrier with your Identity data and Contact data in connection therewith. Your wireless carrier and other service providers may also collect data about your wireless device usage, and their practices are governed by their own policies.
- You acknowledge and agree that the SMS Service is provided via wireless systems which use radios (and other means) to transmit communications over complex networks. We will not be liable for any delays in the receipt of any SMS messages, as delivery is subject to effective transmission from your network operator.
- SMS message services are provided on an as-is basis.
- We do not guarantee that your use of the SMS Service will be private or secure, and we are not liable to you for any lack of privacy or security you may experience. You are fully responsible for taking precautions and providing security measures best suited for your situation and intended use of the SMS Service.
- You can opt-out from this service at any time by going to your account page and unticking the option “SMS” in the Settings. If available in your country, you may also be able opt out by text by following the instructions given to you in the SMS we send you.
MONITORING OF TELEPHONE CALLS AND E-MAILS
75. Your telephone calls and e-mails to us may be recorded and monitored for quality control purposes. We may also intercept communications made to individual members of staff at IPI when this is required for business purposes.
76. You can log in to ApiaryBuzz using sign-in services such as Google Account or Facebook Connect or an Open ID provider. These services will authenticate your identity and provide you the option to become a member. Services like Facebook Connect give you the option to post information about your activities on this site to your profile page to share with others within your network.
77. From time to time we may offer visitors the ability to voluntarily link to other sites. IPI & ApiaryBuzz does not review, and is not responsible for, the content or effect of the data protection or privacy policies of these sites.
78. Technologies besides cookies, web beacons/web bugs, scripts, and tags may be used by ApiaryBuzz and its clients, partners, affiliates, or analytics and service providers.
- These technologies are used in analysing trends, administering ApiaryBuzz, tracking Customers’ movements around ApiaryBuzz and the Internet, and to gather demographic information about our user base as a whole.
- Our clients may combine your survey responses, demographic information, and web surfing behaviour with those of others to produce “aggregated” reports.
- They may also create scientific reports based upon modelled information. “Modelled information” is data developed based upon demographic and behavioural characteristics (like your gender, age, and websites visited) to predict what people with similar or matching characteristics would watch or buy.
- We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.
- We may use Local Shared Objects, such as HTML5, to store content information and preferences. We partner with third parties to provide certain features on ApiaryBuzz or to display advertising based upon your web browsing activity and we also use HTML5 to collect and store information. Various browsers may offer their own management tools for removing HTML5.
79. As we continue to develop our business, we might sell or buy additional assets. In such transactions, our right to contact you as a member and the information you have voluntarily provided in your user profile would generally be one of the transferred business assets.
- Any sale or transfer of ApiaryBuzz or substantially all of its business assets, which included our panel, would be to an entity that agreed to comply with all of the material terms of our Privacy and Data Protection Policy notice.
- You will be notified via email and/or a prominent notice on ApiaryBuzz of any change in ownership.
DATA PROTECTION OFFICER
80. IPI is the controller and responsible for your Personal Data.
- We are constantly reviewing and enhancing our information security measures.
- If you:
- have any questions or feedback relating to your Personal Data or our Notice
- would like to withdraw your consent to any use of your Personal Data as set out in this Notice or
- would like to obtain access and make corrections to your Personal Data records,
- you may contact our
Data Protection Officer: email@example.com
81. This Notice been drafted in the English language. In the event of any inconsistency between the English version of this Privacy and Data Protection Policy and any translation thereof, the English version shall prevail.
EFFECT OF NOTICE
82. This Notice applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
84. This Notice supplements, but does not supersede nor replace any other consents you may have previously provided to InnoProbe Insight in respect of your personal data, and your consents herein are additional to any rights which InnoProbe Insight may have at law to collect, use or disclose your Personal Data.
CHANGES TO NOTICE
85. InnoProbe Insight may update this Notice to ensure that this Notice is consistent with any future developments, industry trends and/or any changes in legal or regulatory requirements.
- We reserve the right to change, add to, or remove portions from this Notice at any time, so please review it frequently. You should read this page regularly to ensure you are updated as to any changes.
- However, if any material change is made to this Notice, we will notify you of that change, by email, on the homepage, or other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.
- Non-material changes to this Notice will be announced through ApiaryBuzz only. Your continued access to ApiaryBuzz and Services after such changes conclusively demonstrates your consent to any changes.
- It is important that the contact details we hold about you is accurate and current. Please keep your Account details updated if your Personal Data changes during your relationship with us.
- We will always display the most up-to-date Privacy and Data Protection Policy on this web page. This version was last updated on the date at the top of this Privacy and Data Protection Policy.
86. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.