Survey Club Privacy Policy - European Union

Last Updated: December 6, 2024

Thank you for visiting the SurveyClub.com, LLC ("we", "us" or "our") website and services (collectively, the "Website"). With the help of this privacy notice we want to inform you about our processing activities that concern your personal data.

We will only collect, process and use your personal data in compliance with applicable data protection law and as set out in this privacy notice. Below you will find information on how we use your personal data, for which purposes your personal data is used, with whom it is shared and what control and information rights you may have.

1. Summary of our processing activities

The following summary provides you with a quick overview of the processing activities that are undertaken. You will find more detailed information under the indicated sections below:

• We process certain personal data when you visit our Website, such as your IP address (see 3.1). We may also process your personal data when deploying cookies (see 3.2).
• We process your personal data, such as your name or email address when you register for a user account and participate in studies, surveys or research projects (see 3.3). For the purpose of ensuring high-quality data sets for our clients we may also validate your personal data with third-party data (see (b)), draw inferences and aggregate data for research (see (c)) and for providing you with rewards you earned by completing studies (see (d)).
• We may process your personal data when communicating with you (see 3.4).

Further, in this privacy notice you find information on third-party recipients of your personal data (see 5), cross-border data transfers (see 6), data retention periods (see 7), your data protection rights (see 8) and our contact details (see 9).

2. Definitions

• Personal data: means any information relating to a natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, or an online identifier.
• Processing: means any operation which is performed on personal data, such as collection, recording, organization, structuring, storage, adaptation or any kind of disclosure or other use.

3. We process your personal data as follows:

3.1 Visiting our Website

If you visit our Website for informational purposes, we process your IP address, information on the device and browser you are using (operating system, browser type and version, host name of the device), the referrer URL, time and date of your request and clickstream data. We process this data to display to you our website correctly, enable its core functions, and to ensure the stability and security of our site.

The legal basis for this data processing is Art. 6 (1)(1)(b) GDPR, insofar as it serves to provide our website to you, and Art. 6 (1)(1)(f) GDPR, as we have a legitimate interest to ensure the security of our website, a user-friendly, effective and secure experience and smooth access to its key functions.

3.2 Cookies and other web measurement and tracking technologies

To provide our website and its functions (e.g. language settings, cookie settings), we place cookies on your device and use similar technologies (jointly referred to as "cookies" or "cookie"). A cookie is a small piece of data placed on your computer's hard drive that permits it to identify a specific device or browser.

Strictly necessary cookies are cookies without which the service cannot be provided. Therefore, these cookies are always activated and cannot be rejected. Strictly necessary cookies include cookies that are used to track your progress in surveys. The legal basis for the use of the cookies and the respective data processing is Art. 6 (1)(1)(b) GDPR.

We may also use other categories of cookies that are not strictly necessary. These categories may include, for example, analytics cookies or marketing cookies. We will only use these cookies if you have provided your explicit consent via our cookie banner/consent management tool. The legal basis for the use of the cookies and the respective data processing is Art. 6 (1)(1)(a) GDPR.

You may find more information on the cookies, e.g. information on the provider, purpose of the cookie, lifespan of the cookies and the data categories processed as well as the retention period, in our cookie banner.

3.3 Studies, Surveys and Research Projects

1. Participation
    
   You may participate in surveys, studies and research projects (jointly referred to as "studies" or "study").
    
   To do so, you have to register for a user account. As part of your registration, you must provide certain information, such as your name, email address, and a password. The legal basis for this data processing is Article 6 (1)(1)(b) GDPR. We process the aforementioned personal data in order to grant you the desired access to participate in a survey.
    
   In order to identify and verify that you qualify as a panelist for a study, we may process additional data. Such data may be of a general type, such as personal identifiers (like name or postal address), physical characteristics or descriptions, age, marital status, education, employment and employment history. The legal basis for processing of this data is Art. 6 (1)(1)(b) GDPR, as the evaluation of the data provided is necessary to let you participate in studies.
    
   In addition to the general types of data, we may also process data that falls within the scope of the special categories according to Art. 9 GDPR. Such data includes data revealing racial or ethnic origin, religious or philosophical beliefs, sex (including gender and gender expression, pregnancy or childbirth and related medical conditions) and sexual orientation and medical information (including medical conditions, genetic information and familial genetic information).
    
   The provision of this data is completely voluntary and may serve us to better identify you for corresponding studies. The legal basis for processing such data is Art. 9 (2)(a) GDPR, as we only process this data when you explicitly consent to the processing upon entering the information.
    
   To complete a study, you will be provided with a link to the study. This link will take you to a third-party's website and you will leave SurveyClub.com. When you click on the link, personal data may be forwarded to our client and/or the client may infer certain personal data from the fact that you were provided with a link to the study. The legal basis for the transfer is Art. 6 (1)(1)(b) GDPR as transferring the data to our client is necessary to allow you to participate in a survey.
    
   The processing of the data you enter during the study on the third-party website will be subject to this website's terms of use and privacy policies.
2. Validation of personal data with third-party data (fraud prevention)
    
   In order to provide our clients with high-quality data, we validate certain personal data with third party sources. We provide the third party with identifiers, such as your name, postal, email and IP address and phone number. We do not transfer other data than the identifiers to the third party.
    
   The third party will calculate a fraud risk score that helps us to determine whether to accept or reject you as a member. The legal basis is Art. 6 (1)(1)(f) GDPR. We pursue the legitimate interest of validating the data you provided, ensuring a high-quality data set for our clients and to prevent fraudulent set up of user accounts.
3. Inferences and research on user data
    
   We may draw inferences from personal data, such as a profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes in order to identify and validate that you qualify for a study.
    
   The legal basis for drawing these inferences is Art. 6 (1)(1)(f) GDPR. We pursue the legitimate interest to conduct studies, enhance our data sets and provide our clients with high-quality panelists that contribute reliably to the goal of the study.
    
   We may also conduct research on our users' demographics, interests and behavior based on the data provided by you. This research is compiled and analyzed on an aggregated basis. We may share aggregated data that does not include personally identifiable data with others.
    
   The legal basis for the research and data aggregation is Art. 6 (1)(1)(f) GDPR. We pursue the legitimate interest of outlining to our clients what panelists we have available for participation in studies.
4. Earning rewards
    
   You may participate in our rewards program to be rewarded for your participation in surveys. When participating in the rewards program, we will process personal data such as the points you have earned for completed studies or as the case may be, a user ID, your name or email address. We will either process the data ourselves or forward it to service providers that will provide you with your selected reward.
    
   The legal basis for the data processing is Art. 6 (1)(1)(b) GDPR, as the processing of the data is necessary to provide you with the rewards you have earned.

3.4 Communication with you

While in a business relationship with us, we may process your personal data in order to communicate with you.

Communication may be initiated by you. Such communications may include sending information or materials you request, responding to your questions and comments providing user support after you request such support. Data processed during such communications may include your name and contact information, such as your email address. The legal basis for processing this data is Art. 6 (1)(1)(b) GDPR as it is necessary to respond to your request.

To help you to quickly find studies and other new opportunities, we may contact you by direct mailings or by telephone. We will generally only contact you with such promotional communications when you have given your prior consent and have not objected to future communications. You can object at any time by the means provided for in the mailings or by clicking contact us.

In addition to that, if we have obtained your email address in the context of the provision of a product or a service, we may also use the email address for direct marketing of our own similar products or services, i.e. in particular to invite you to participate in other studies. You are given the opportunity to object to such use when we collect your email address or by clicking the opt-out link in the email, you receive from us.

The legal basis for the use of you contact details for promotional communications is Art. 6 (1)(1)(a) GDPR insofar as you have given your consent to the use of the data for such purposes, and Art. 6 (1)(1)(f) GDPR where we use your email address to promote similar products or services as provided to you before. We pursue the legitimate interest of direct marketing.

4. Other data processing purposes

In specific cases, we may process your personal data for the following purposes:

• We may process your personal data to comply with legal obligations that we face (e.g. regarding data retention under commercial or tax law). The legal basis for such data processing is Art. 6 (1)(1)(c) GDPR in connection with the relevant legal provisions.
• We may process your personal data if we sell our company, a part of it or other assets, or in case we buy another company, a part of it or other assets. The legal basis for this data processing is our legitimate interest (Art. 6 (1)(1)(f) GDPR) to further the development of our company through mergers and acquisitions.
• We may have a legal obligation to participate in investigations and proceedings of public authorities and the government. The legal basis for such processing is Art. 6 (1)(1)(c) GDPR in connection with the respective provision establishing our legal obligations.
• We may also process your personal data to protect our rights and safety, our contract and business partners and others, including through assertion of or participation in legal proceedings. The legal basis for this data processing is either a respective legal obligation to this effect (Art. 6 (1)(1)(c) GDPR in connection with the relevant legal provisions) or our legitimate interest or of those affected to assert legal claims (Art. 6 (1)(1)(f) GDPR).
   
  If we use your personal data for other purposes than those stated above, we will provide specific notification at the time of collection.

5. Third party recipients of personal data

For some of the aforementioned purposes we may disclose your personal data to other parties. In addition to any recipients already mentioned in this privacy notice, these categories of recipients include data processors acting on our behalf and bound by our instructions, such as communication service providers (e.g. mail relay providers), newsletter and contact form providers, IT and IT security providers and software providers (including software as a service solutions).

The legal basis for respective data transfers is Art. 28 GDPR in connection with the respective data processing agreement concluded with the recipient. Through these agreements, we have contractually bound these recipients to process your personal data only on our behalf and in accordance with our instructions.

We may also transfer your personal data to other third parties for some of the purposes and according to the legal basis mentioned above in this privacy notice, e.g. to lawyers and tax advisors, notaries, courts, government authorities and agencies.

6. Cross-border transfers

We are a US-based company. Thus, when using our website, e.g. for registering a user account to participate in studies, we will assess transfer your personal data in the US.

When sharing your personal data with external recipients (see 5 above), some of your personal data may be transferred to other companies within the US or other countries, including third countries outside the EU / EEA where laws may not provide the same level of protection for your personal data as the GDPR does. Please note that data processed in a foreign country may be subject to foreign laws and accessible to foreign governments, courts, law enforcement, and regulatory agencies. However, we will endeavor to take the required measures to maintain an adequate level of data protection when sharing your personal data with recipients established in such countries.

In the case of a transfer to a country outside of the EEA, this transfer is either safeguarded by a so-called adequacy decision from the European Commission declaring that such country or recipient provides for an adequate level of data protection, or, if such adequacy decision does not exist, the conclusion of EU Standard contractual clauses (https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en) and additional measures, if necessary.

7. Data retention period

We retain your personal data only for as long as is necessary for the purpose for which it is processed and delete it afterwards, unless we are required by law to retain it for a longer period (e.g. to comply with statutory retention obligations under tax law).

8. Data protection rights

You may have the following data protection rights, depending on the circumstances of the specific case, which you may exercise by contacting us as set out below:

8.1 Access

You have the right to require information as to whether your personal data is retained and request access to your personal data and/or copies of such data, including purposes of processing, the processed data categories, its recipients as well as potential data retention periods.

8.2 Rectification, restriction of processing, deletion

You have a right to request the rectification, deletion or restriction of processing of your personal data, for example if (i) it is incomplete or inaccurate, (ii) it is no longer necessary for the purposes for which it was collected, or, (iii) the consent on which the processing was based has been withdrawn.

8.3 Refusal or withdrawal of your consent to data processing

You have the right to refuse to provide and - without impact to data processing activities that have taken place before such withdrawal - withdraw your consent to processing of your personal data at any time.

8.4 Automated decision-making including profiling

We do not use your personal data for automated decision making which produces legal effects concerning you or similarly significantly affects you.

8.5 Right to data portability

You may have the right to receive the data, which you have provided to us in a structured, commonly used and machine-readable format and have the right to transmit this data to another controller without hindrance from use. You also have the right to transmit this data directly to another controller, where technically feasible.

8.6 Right to object

You have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data where we process your personal data based on our legitimate interests (Art. 6 (1)(1)(f) GDPR). In case we process your personal data for direct marketing purposes, you have the right to object at any time.

8.7 Right to lodge a complaint with the competent supervisory authority

You have a right to take legal action against any potential breach of your rights regarding the processing of your personal data, as well as to lodge a complaint with the competent supervisory authority.

9. Contact

For questions, suggestions and comments on the topic of data protection, please feel free to contact us at:

Site: https://www.surveyclub.com/contact-us
Email: helpdesk@surveyclub.com

Postal Address:
SurveyClub.com, LLC
191 University Blvd
Suite #200
Denver CO 80206 USA

You can reach our Data Protection Officer at dpo@surveyclub.com.

You can also reach the Data Protection Officer under the postal address provided above. Please add "Data Protection Officer" to the address.

Our EU Representative is:
DP-Dock GmbH
Ballindamm 39
20095 Hamburg
Email: info@dp-dock.com

10. Miscellaneous

We reserve the right to change this privacy notice from time to time in accordance with applicable data protection regulations. Please check this website regularly for updates.