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TGM Panel Participant Privacy Notice

Effective Date: [ 04.09.2023]

This Privacy Notice defines how TGM Group (“TGM”/TGM Group) uses (collects, stores, uses and discloses and otherwise uses) your Personal Data (“Personal Data” which may also be referred to as Personally Identifiable Information or "PII") and other information described in this Privacy Notice whether you are a member of a panel (“Panel Member”) owned by one of our Panel Owners (“Panel Owners”) or a participant (“Participant”) directed to a survey or other market research program by one of our clients (“Clients”) or Partners (“Partners”). Please notice that Your participation may also be governed by a privacy notice of one of our Panel Owners.

TGM fully respects the right to privacy of people whose personal data we store, particularly by using appropriate technological solutions and legislative measures that prevent unauthorized entities from intruding on their privacy.

We collect and process data on the basis of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (GDPR), which provides the highest standard with respect to the protection of Personal Data. However, depending on where you live (outside the EU), other privacy laws and regulations may apply as well. This Privacy Notice applies to all residents throughout the world.

TGM will and will cause its affiliates to establish and maintain business procedures that are consistent with this Privacy Notice.

By reading the following content, you will find out:

  • Why do we process your Personal Data
  • Why do we do it
  • Whether the provision of data is required
  • How long do we keep the Personal Data
  • If there are other recipients of your Personal Data
  • What rights do You have

WHO IS TGM?

TGM provides a global online and mobile platform for market and opinion research and insights that connects Panel Owners with market researchers, brands, Panel Members, and research Participants to share consumer opinions and data. TGM Group operates globally with entities in Poland and Singapore, among others.

Within the TGM Group, there are also local-associated entities that are authorized to perform specific obligations of TGM related to the TGM platform, which are included to fulfill your rights.

Thereupon, individuals participate in market research on the TGM platform either via membership in our panel, in a panel of one of our Panel Owners or via one of our Partners who direct Participants to a survey or other market research program. TGM’s Panel Owners and Partners who direct participants to surveys or other market research programs, are different Data Controllers who determine the purposes and means for processing Personal Data. TGM will only process your Personal Data, acting as a Data Processor at the request of a Data Controller.

Your Personal Data may be used for a number of purposes that are explained below, along with examples of categories of Personal information for each purpose. Specific details on the use of Personal information might also be described further within a survey or other market research program. If you would like to get more information please verify the content below or contact us as described in the “CONTACT US” section below.

TGM PROTECTS YOUR PRIVACY

The security of your Personal Data is very important to us. Accordingly, TGM has put in place reasonable technical, physical, and administrative safeguards to protect the information TGM collects. Only those employees who need information in order to perform their duties are authorized to have access to your Personal Data.

TGM has also implemented the highest standards to support the maintenance of a reliable information security management system; in particular, TGM strives to conform its privacy practices to binding laws, codes, and regulations, and the codes of standards of applicable market and opinion survey research associations, including, without limitation ESOMAR (www.esomar.org) and the Insights Association (www.insightsassociation.org).

Despite the safeguards that TGM implements, transmissions over the Internet and/or a mobile network are not totally secure, and TGM does not guarantee the security of online transmissions. TGM is not responsible for any errors by individuals in submitting Personal Data to TGM.

WHAT IS THE PURPOSE OF COLLECTING YOUR PERSONAL DATA?

We collect or process Personal Data only to the extent necessary to achieve the purposes for which they were collected and the purposes of the law or the conditions of the service provided. The scope of data will be various and depend on the purpose of the processing. Most of the Personal Data is processed directly for one of the following reasons:

  • enable your use of the TGM platform in accordance with the Terms
  • enable your participation in our Panel;
  • enable your participation in a panel of one of our Panel Owners;
  • gather profiling information about you so TGM can better target specific surveys and other market research programs to you;
  • contact you to invite you to participate in surveys or other market research programs;
  • update our records of your Personal Data;
  • manage our incentives programs and fulfill your requests for such incentives;
  • allow you to participate in sweepstakes (if permitted);
  • to respond to any messages or requests you may send to us;
  • validate your profiling information or answers you provided to a survey or other market research program;
  • provide service and support to you;
  • detect and prevent violation of our Terms & Conditions;
  • to investigate suspected fraudulent activity or violation of another party’s rights;
  • to respond to duly authorized information requests of governmental authorities or where required by law;
  • as otherwise authorized by you.

WHAT ARE THE LEGITIMATE GROUNDS FOR THE PROCESSING?

Your Personal Data will always be collected in a fair and lawful manner for the specific purposes mentioned above. Whenever we process your Personal Data, we must have so- called "Legal ground". The legal bases come directly from the law (in particular from Article 6 and Article 9 of the GDPR), below are the grounds on which we most often base:

  • Consent: You have indicated to us that you consent to the processing of data for a defind purpose, e.g. to participate in a specific panel
  • TGM's legitimate interests: only if the processing is necessary for our business and it does not interfere with the right to respect your privacy, e.g. to adapt the panel offer to your individual criteria or to verify and prevent violations of the Terms of Use of the TGM platform;
  • Performance of the contract: we must process your personal data to enable you to use the TGM platform in accordance with the Terms
  • Legal claims: when data processing is necessary to establish, execute or defend legal claims of TGM;
  • Legal obligation: when, under the provisions of the law, TGM is obliged to process personal data, e.g. to settle any remuneration for completed panels

IS THERE AN OBLIGATION TO PROVIDE PERSONAL DATA?

Registration and participation in our panel or a panel owned by one of our Panel Owners is subject to TGM’s Terms and Conditions. You can find TGM’s Terms and Conditions here. Providing the data specified when registering an account on the platform is voluntary, however, necessary to register and use the TGM platform. Further completion of data within the account is completely voluntary - however, without completing individual information, it may not be possible to use individual services including panels.

Your participation in a survey or other market research program is completely voluntary and TGM use of your Personal Data is carried out with your consent. Surveys and other market research programs administered by TGM’s Clients, Partners or other third parties and the data collected in connection with those surveys and other market research programs are not subject to this Privacy Notice - that is why each time you agree to a specific panel, We recommend you read the information about the processing of personal data beforehand.

Please note that You have the right to withdraw your consent at any time - the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

If the law allows TGM to process Your Personal Data and you withdraw your consent to processing, this will not necessarily mean that TGM will complete the processing of your data, because TGM may have a legal obligation to process Personal Data for a specific purpose eg. to preserve copies of commercial transactions.

WHAT PERSONAL DATA IS COLLECTED AND PROCESSED?

The Personal Data that is processed may include eg. your name, address, telephone number, e-mail address, date of birth, and other similar information on the TGM user account. TGM may collect Personal Data directly from you when you voluntarily provide it to TGM or TGM may obtain Personal Data from our Panel Owners, Clients or market

research firms who have obtained a Participant’s consent. For Panel Members of a panel of one our Panel Owners, TGM will collect data in accordance with their instructions.

TGM may also obtain Personal Data from database owners who have assured us that their databases comprise only individuals who have consented to be included and have their Personal Data shared. Finally, TGM may collect and use Personal Data obtained from publicly available sources, such as telephone directories.

From time to time TGM may collect Sensitive Personal Data which depending on the country in which you live may include, racial or ethnic origin, health records, financial information, political opinions and religious or philosophical beliefs. If TGM collect your Sensitive Personal Data, TGM will always obtain your explicit consent.

You may also submit, upload or transmit content or material, including photos, videos, and/or any other similar or related content or material which may include your Personal Data, for example, when participating in surveys or other market research programs. Such Personal data may be used and disclosed as described in this Privacy Notice and should not include audio, video, images, or the likeness of anyone other than you.

WHAT INFORMATION IS COLLECTED BY AUTOMATED TECHNOLOGIES?

TGM may collect certain information automatically. Depending on the country in which you live, such information may be considered Personal Data. Such information includes, but is not limited to information about your device and device capabilities including, but without limitation, the device operating system, the other applications on your device, cookie information, IP address, device network provider, device type, time zone, network status, browser type, browser identifier, unique device identification number (such as Identifiers for analytics or advertising), network provider user ID (a number uniquely allocated to you by your network provider), Media Access Control (MAC) address, mobile advertising identifier, location and other information that alone or in combination may be used to uniquely identify your device. Specific technology is specified below.

Automatic data collection is associated with the specificity of the TGM platform services provided. As part of automatic mechanisms, TGM can also perform profiling. This means that TGM will use the automated decision-making process to select matching surveys. To ensure greater security of services, we also verify the use of the TGM platform by automatic mechanisms (bots) to prevent fraud or abuse

Based on the information provided, the TGM platform assesses which survey you are potentially interested in. Profiling is necessary to provide you with survey proposals that personalize and fit your expectations.

The decision to use automatic mechanisms and profiling was based on a balance study in which we concluded that these processes will not excessively interfere with your privacy or be onerous.

You always have the right not to be subject to a decision based solely on automatic processing, including profiling which may appeal to legal effect or another which is significant to you. Therefore, you can object to the processing of personal data for profiling purposes at any time, to the extent that the processing is related to such profiling. On how to enforce the rights in "Your rights".

Cookies:

A cookie is simply a small text file containing information about the user that is placed by a website on a user’s computer or device. TGM places cookies on your computer or device for survey and other market research program control and fraud prevention purposes.

TGM may also use tracking cookies, tags, and scripts to track certain information about you based on your activity on our site or third party sites. TGM may use this information to determine whether you have seen, clicked on, or otherwise interacted with an online ad or promotion that TGM is working on to help evaluate for one of our research Clients. Subject to your consent, TGM may also select you for a survey or other market research program where cookies will be used to expose you to specific advertising or promotions before the survey or other market research program activity for the evaluation of such specific advertising or promotions.

With your consent, TGM’s Clients or Partners may also place cookies on your computer or device and use those cookies, tags and scripts to track certain information about your activity on certain websites. TGM’s Clients or Partners may use this information for various market research activities.

If you wish, you can choose not to consent to cookies or choose not to accept cookies by adjusting your web browser’s privacy settings to delete cookies upon exiting websites or when you close your browser. You may also configure your browser to block cookies. Not providing consent, deleting cookies or blocking cookies may exclude you from participating in surveys or other market research programs or negatively impact your user experience. For information on how to opt-out of cookies please refer to the section titled ”HOW DO I OPT-OUT?”

TGM’s use of cookies is always with your consent. If you want to learn more about cookies used by TGM, please click here.

Mobile Advertising Identifiers:

A mobile advertising identifier is a sequence of numbers and letters that identifies an individual smartphone or tablet. On iOS, a mobile advertising identifier is called the “Identity For Advertisers” (IDFA, or IFA for short). On Android, the mobile advertising identifier is the GPS ADID (or Google Play Services ID for Android). TGM may collect mobile advertising identifiers or obtain them from a Partner. TGM may use mobile advertising identifiers in our market research programs or to share your data with Clients or Partners. Subject to your consent, TGM may also select you for a survey or other market research program where mobile advertising identifiers will be used to expose you to specific advertising or promotions before the survey or other market research program activity for the evaluation of such specific advertising or promotions.

TGM will only collect or obtain mobile advertising identifiers with your consent.

Web Beacons:

A web beacon (also known as a tag, clear gif or 1 x1 pixel) consists of a small string of code that is embedded within a web page or email. They may or may not be a visible graphic image associated with the web beacon, and often the image is designed to blend into the background of a web page or email.

TGM may use web beacons in our email messages to help determine whether our messages are opened and to verify any clicks through to links within the email or in advertising or website research to determine if a Participant has viewed ads or other online content that TGM is measuring. TGM and our authorized agents may link Personal Data to web beacons for operational and research purposes.

Geo-Location Data:

TGM may collect geo-location information from your computer or device. TGM may use your geo-location data for fraud prevention or for market research purposes, including but not limited to advertising research or other tracking-based market research activities. TGM will obtain your consent if TGM collects or uses your geo-location information.

Digital Fingerprinting:

TGM may use digital fingerprinting technology to gather certain data about you and/or your computer or device. This data may include Personal Data such as an IP address, as well as non-Personal Data such as a computer operating system or browser version number. This technology creates a unique computer identifier that may be used for fraud prevention or to identify and track your participation in a survey or other market research program and limit participation in accordance with the requirements of a specific survey or other market research program.

Social Media Information:

You may also be offered the opportunity to participate in surveys and other market research programs through or with social media platforms. If you choose to participate in surveys or other market research programs through or with social media platforms, TGM may, with your consent, collect certain profile information stored in your social media platform account.

Log Files:

TGM automatically gathers and stores certain information during survey and other market research program participation. Our servers automatically record information that your browser sends whenever you visit a website. These server logs may include information such as your web request, Internet Protocol (IP) address, browser type, browser language, the date and time of your request and one or more cookies that may uniquely identify your browser. This information is periodically deleted as part of normal maintenance routines.

Information TGM Collects from Third Parties:

TGM may obtain Personal Data, behavioral and/or demographic information from third parties, including, without limitation, data management platforms, ad networks, information service bureaus, other market research suppliers and/or social media platforms. TGM may use the Personal Data, behavioral and/or demographic data received from these third parties for various purposes, including, but without limitation, data validation, data append, development of marketing insights, fraud detection purposes.

WITH WHO DOES TGM SHARE PERSONAL DATA?

The data collected is generally processed within the TGM Group. TGM will not make your Personal Data available to any third party without your consent unless it is required by law, as further specified below.

If a survey or other market research program or other activity includes making Personal Data available to a third party, TGM will only share your Personal Data with your consent. If data collected is used for statistical modeling to better understand trends and preferences amongst specific groups or audiences within the general population, only limited Personal Data shared will be used only for market research purposes and again only with your consent.

TGM may disclose your Personal Data, profiling data, or other research data to third parties as follows:

  • in connection with market research services (including our incentives programs), to our agents, contractors or Partners that facilitate such services; provided, however, such parties are restricted from using your Personal Data in any way other than to provide services to TGM;
  • with agents, contractors or Partners of TGM in connection with services that these individuals or entities perform for, or with, TGM. These agents, contractors or Partners are restricted from using this information in any way other than to provide services for TGM. TGM may, for example, provide Personal Data to agents, contractors or Partners for hosting our survey websites, for data collection or processing services, or for sending you information that you requested, but those parties cannot use your Personal Data for their own purposes unrelated to the work they are doing for us;
  • with Clients of TGM, but in these cases your Personal Data will only be shared with Clients:
  • i) with your consent, or ii) for permitted research purposes in accordance with the codes of the Insights Association and ESOMAR.
  • in connection with the request or requirement of any lawful request by public authorities, to meet national security or law enforcement requirements;
  • pursuant to required legal process, to the related compelling party;
  • when TGM believes that disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with suspected or actual illegal activity;
  • In connection with the sale, assignment, or other transfer of TGM, in which case TGM will require any such buyer to agree to treat Personal Data in accordance with this Privacy Notice. In the event that a sale, assignment, or other transfer of TGM is not consummated with a prospective buyer, TGM will require the third party not to use or disclose your Personal Data in any manner whatsoever and to completely erase the same; or
  • with payment processors, whose services we use to process any payments on the TGM platform
  • as otherwise authorized by you.

TGM may license certain limited Personal Data to third parties (e.g., data brokers, data aggregators, etc.) for market research purposes, including, but without limitation, the licensing of individual-level and/or aggregated-level data (e.g., product and/or service purchasing or usage activity, website visitation data, internet search history, etc.) for the development of audience insights and/or look-alike models, for the purpose of sale of such data to the third party’s customers for the purpose of performing analytics and providing marketing intelligence. This information may be shared via a cookie (cookie ID), a mobile advertising identifier, an email address or other method. After look-alike modeling or aggregation have been performed, Personal Data is deleted or anonymized - in this way the recipient will not be able to know your identity.

Additionally, identifying information and information collected by automated means may be provided to third parties, including, without limitation, Clients, Partners, agents and/or vendors for the purposes of identifying respondents for re-contact surveys or communications, fraud detection and/or prevention, database matching, data validation,

data append, coding, data segmentation, and reward, incentive, and/or sweepstakes or promotion-related services.

TGM may maintain Personal Data or machine-identifiable information in order to satisfy your requests and/or TGM’s business requirements. For instance, TGM may retain the email addresses of Participants who opted out to ensure TGM conforms to any such wish. Any retention of Personal Data is done in compliance with applicable laws and regulations.

DOES TGM COLLECT INFORMATION FROM CHILDREN?

TGM does not knowingly collect Personal Data from children below the age where parental consent is required in accordance with the relevant legal provisions. If TGM becomes aware that TGM has inadvertently collected Personal Data from a child below the age where parental consent is required, TGM will delete such Personal Data from our database.

RETENTION OF PERSONAL DATA

TGM will store Personal Data no longer than necessary for the purpose of the processing activity or as authorized by you. This period may also be based on TGM’s or one of our Panel Owner’s or Partner’s contractual commitments to you, applicable periods of limitation (to bring claims) or according to applicable law.

YOUR RIGHTS

According to the EU provisions of the personal data protection law (GDPR), you have specific rights depending on the basis for data processing, in particular:

  • Right of access — You have the right to obtain confirmation and information about the processing of your Personal Data
  • Right to rectification — You have the right to have any inaccuracies about your Personal Data corrected
  • Right to erasure — You have the right to have your Personal Data deleted (this right is limited to data which according to law and regulation may only be processed with your consent, if you withdraw your consent for processing or are no longer necessary in relation to the purposes for which they were collected)
  • Right to restriction of data processing — You have the right to require that the processing of your Personal Data be restricted (during the course of any investigation into honoring your request, TGM’s access your Personal Data will be limited)
  • Right to object to processing - You have the right to object at any time to processing of personal data for a specific purpose related to your consent or the legitimate interest of TGM
  • Right to data portability — You have the right to have your Personal Data transferred to another party (this right is limited to data provided by you)

If you want to exercise any of your rights, you may contact us with such a request using the contact details provided in the “CONTACT US” section below.

Upon receiving a request from an individual, TGM will attempt to provide the requested information within 30 days, providing that the request is such that it can be reasonably be responded to in that time frame. If more time is required, TGM will notify you within thirty days.

In certain situations, however, TGM may not be able to provide access to some Personal Data. This may occur when:

  • providing access to Personal Data would be likely to reveal Personal Data about a third party;
  • disclosing the information would reveal confidential commercial information; or
  • the information has been collected for the purposes of a legal investigation.

If TGM denies an individual’s request for access to their Personal Data, TGM will advise the individual of the reason for the refusal.

In cases where you find violations of the rules for the processing or protection of your Personal Data, you can lodge a complaint to the supervisory authority - i.e. the public authority that controls the processing of data in individual countries. In the case of resident in the EU, a complaint may be lodge to the supervisory authority of your place of residence.

HOW DO I OPT-OUT?

Your decision to participate in a survey or other market research program, respond to any specific survey question or provide Personal Data, including Sensitive Personal Data, will always be respected.

You may choose any time you want to participate or not in a particular survey or other market research program, refuse to answer certain questions or discontinue participation at any time. However, failure to provide certain information or fully participate in a particular survey may preclude you from receiving incentive compensation or participation in future certain research studies.

Panel Members of a panel of one of our Panel Owners that no longer want to participate in surveys, other market research programs or be subject to the use of automated technologies or other activities, including cookies, can opt-out by visiting the Privacy Settings page of the member portal for the panel you belong. The Privacy Settings page can also be reached by clicking on the opt-out links on survey invitations. Finally, Panel Members and Participants can contact us by using the contact details provided in the “CONTACT US” section below.

TRANSBORDER POLICY

TGM stores data in the European Union (EU) and the European Economic Area (EEA). However as a global organization, a TGM affiliated company or non-affiliated service provider may collect, process, store or transfer your Personal Data outside your originating country or outside of EEA country.

The (EU) and the European Economic Area (EEA):

TGM’s legal entities outside the EU and EEA have entered into intra-company data protection agreements using standard contractual clauses prepared by the European Commission. TGM has contracts in place with service providers and other business providers that require the contracting parties to respect the confidentiality of your Personal Data and to handle European Personal Data in accordance with applicable European data protection laws.

LINKS TO THIRD PARTY WEBSITES

This Privacy Notice applies solely to our surveys and other market research programs, and not to any other product or service. Our surveys or other market research programs may contain links to a number of third party websites that TGM believes may offer useful information. The policies and procedures TGM describes here do not apply to those websites. TGM recommends reading carefully the privacy notices or policies of each site that you visit for information on their privacy, security, data collection and distribution policies. By participating in any of our surveys or other market research programs or any of our websites following any Privacy Notice change, you freely and specifically give us your consent to collect, use, transfer and disclose your Personal Information in the manner specified in such then-current Privacy Notice.

CONTACT US

TGM very much values your opinion and feedback. If you want to review, correct, or delete your Personal Data or have questions, comments or suggestions, or if you would like to opt-out of our surveys or other market research programs or have questions about your Personal Data, please contact us:

Via email at: privacy@tgmpanel.com

Or via postal mail at:

POLAND
ul. Długa 29/226
00-238 Warszawa

SINGAPORE
A68 Circular Road #02-01,
049422, Singapore

Data Protection Officer

Considering the security and transparency of the processing of Personal Data and the need for their constant control, we have appointed a Data Protection Officer (“DPO”) - Marcin Kaleta.

With the DPO, you can contact by using privacy@tgmpanel.com  or via our postal address (with the notation “Data Protection Officer” or "Privacy Compliance Officer”)