Platform Privacy Policy

Updated February 2024

Who are we?

“PureSpectrum” has developed technology and a web portal to help researchers speak to people that are interested in giving their opinion.  This policy sets out how we will use your personal data.  

This Privacy Notice defines how PureSpectrum collects, stores, uses and discloses your Personal Data (as defined below). PureSpectrum will, and will cause its affiliates to, establish and maintain business procedures that are consistent with this Privacy Statement. We are committed to protecting your personal data and take the security of your information very seriously.  We have strict security measures in place to protect your data.  This includes robust security procedures and encrypting all the data on our web-based applications.

If you have any concerns or would like to contact us about any aspect of this policy, please get in touch through the contact details set out below. 

EU-U.S., UK EXTENSION TO THE EU-U.S. DPF, AND SWISS-U.S. DPF

PureSpectrum complies with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, UK Extension and the Swiss – U.S. DPF as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from Switzerland, European Union member countries, and the United Kingdom. PureSpectrum has certified that it adheres to the Data Privacy Framework Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement, and Liability. If there is any conflict between the policies in this privacy policy and the DPF Principles, the DPF Principles shall govern. To learn more about the DPF program, and to view our certification page, please visit https://www.dataprivacyframework.gov/s/

In compliance with the EU-U.S., the UK Extension to the EU-U.S. DPF, and Swiss-U.S. DPF Principles, PureSpectrum commits to resolve complaints about your privacy and our collection or use of your personal information. UK, Swiss, and European Union individuals with inquiries or complaints regarding this privacy policy should first contact PureSpectrum at:

Mail:

PureSpectrum, Inc.
Attn: General Counsel
31416 Agoura Road, #210
Westlake Village, CA 91361

Email:
privacy@PureSpectrum.com

PureSpectrum has further committed to refer unresolved privacy complaints under the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and Swiss-U.S. DPF Principles to the INSIGHTS ASSOCIATION DATA PRIVACY FRAMEWORK SERVICES PROGRAM, a non-profit alternative dispute resolution provider located in the United States and operated by the Insights Association. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.insightsassociation.org/Resources/Data-Privacy-Framework/Information-for-EU-Swiss-Citizens-to-file-a-complaint for more information and to file a complaint. This dispute resolution service is offered at no cost to you.

PureSpectrum is under the enforcement authority of the Federal Trade Commission to adhere to the EU-U.S., the UK Extension to the EU-U.S. DPF, and Swiss-U.S. DPF. It may be possible, under certain limited conditions, for European Union individuals to invoke binding arbitration before the DPF Panel to be created by the U.S. Department of Commerce and the European Commission.

The Information we collect about you and its sources

To find the best match for both you and the researchers, we will ask some demographic information relating to you.  This will include 

• Your age
• Your Gender
• Your income
• Zip or Postal Code
• Race
• Ethnicity
• Marital Status

While we will not ask for any directly identifying data, such as your name, email address, physical address or phone number without your prior explicit consent, we will collect additional information from you that will be project specific.  This data will be dependent on the individual project but may include protected or more sensitive data such as race or ethnicity, health or medical information, biometric information, financial information, educational information, Political or religious beliefs and professional or employment-related information, including occupation trade union membership and sexual orientation.  Please do not participate in such surveys that ask for this information if you do not consent to this data being collected, processed and shared with the Client running that particular project. 

In addition, we will obtain data from the following sources to better understand your compatibility with projects that you may wish to participate in and to protect our business 

• Geo Location
• IP Address
• Device Details which includes collecting Information about your device (e.g., device operating system, the other applications on your device, device network provider, device type, time zone, network status, browser type, browser identifier and other information that alone or in combination may be used to uniquely identify your device)
• Hashed Email Address: We may obtain your Hashed Email Address from a third party to whom you have supplied your email address.  To protect your privacy, we utilize hashed emails. Hashing is a process that converts your email address into a unique, anonymized string of characters, ensuring that your personal information remains confidential. This method allows us to maintain the security and integrity of your data while still enabling necessary communications and services, such as data matching and appending. Your original email address is never stored or shared in its plain form, enhancing your privacy, and safeguarding your information against unauthorized access.

Lastly, we also hold independently generated data to track your participation in projects and monitor accuracy

• Unique user ID
• Accuracy score 

Your obligations

By participating in market research surveys sponsored by our clients and third-party market research companies you agree that:

• You will provide honest, candid and complete answers and will not misrepresent yourself or any of your demographic information
• When you provide written answers to survey questions your answers will not include any content that is obscene, indecent, pornographic, seditious, offensive, defamatory, threatening, liable to incite racial hatred, menacing, blasphemous, or otherwise violates the law, or which infringes on anyone’s intellectual property rights
• You will keep confidential and shall not copy, screenshot, download, transfer, share, store, reproduce, republish or disseminate any materials that are shown to you in any survey, including the Brands and companies sponsoring the surveys, survey questions, images, trademarks, tradenames, slogans, advertising copy, videos or audio files

How we use your personal data

We use the above information for the following reasons 

Processing Your Data using Artificial Intelligence and Automated Decision Making

Some of the decisions that we take about you may be through fully automated means and in some cases using Artificial Intelligence (together “AI”).  Some examples are our accuracy scoring and exposing you to relevant survey opportunities.  We also use AI to help prevent duplicate surveys, prevent fraud, and help us determine what survey opportunity you best qualify for.  We also use AI to analyse your responses to demographic profiling questions together with the responses of other survey participants to predict what other similarly situated individuals would answer to the same or similar questions.  We may sell or transfer these derived survey answers and opinions to third parties, and you agree that we may do so without any compensation accruing to you.   We do not believe that this automated processing has a significant impact on your privacy, but you can always contact us through your affiliated MR partner or at the email address below if you have any concerns or questions. 

Who we may pass your data on to:

If you are eligible for a client survey opportunity offered through a Third-Party MR Company, the Third-Party MR Company will provide your unique identification number and a survey link to us and you will be invited through the Third-Party company from which you were sourced, to participate in the client survey. 

Where appropriate, we may also disclose your data to 

• Member of our the PureSpectrum group
• Our professional advisors, consultants, and auditors
• Where we may have a legal obligation to disclose; or
• As part of the sale of one of more elements of our business 
• Dynata LLC – a partner of ours that can offer you additional survey opportunities.  We will pass certain personal data and social/demographic information to these parties for use in connection with the purposes set forth in their privacy policy. To view the privacy policy for Dynata LLC. (www.Dynata.com/privacy)

We also create anonymized and statistical information generated by your data which may be made available to other organisations and researchers.

We also collect anonymized data you provide us, including sensitive data, and sell licenses to use this data to third-parties for use in training Artificial Intelligence models

In exceptional circumstance Regulators and law enforcement agencies may also request your information from us and we will provide them with your information only when there is a legal basis to do so. 

If we suspect someone has committed fraud or tried to manipulate our systems we’ll note it in our records and may share the information with others that we deem relevant – such as the our affiliate MR partner or Client. 

How we transfer and store your personal data 

Your personal data may be processed, stored, or accessed by our staff, agents, or Clients in all the locations across the world that we operate in, and in particularly the United States.  Some of these locations may not have privacy laws in place that provide the same protections as available to you at home.  In these cases, we will take steps to protect your data, which include legal protections are required by such regimes as the EEA General Data Protection Regulations. 

Your personal information will be retained in line with the instructions that we receive from our MR Affiliate and our Clients.  Where we hold data about you independently of these affiliates, we will retain the data in line with our Retention policy and will fully anonymize data as soon as we no longer need to be back to link your profile back to your submitting MR affiliate or our clients.  

PureSpectrum may collect or obtain personal information such as name, mailing or email address, and phone numbers, but only for the purposes of conducting research. We may share this information with MR Affiliates, our Clients and others to assist with the research process, understanding our potential liability in cases of onward transfer to third parties. We may also be required to disclose personal information in response to a lawful request by public authorities, as well as to meet national security or law enforcement requirements.

Your choices

We respect the rights that individuals are granted through their local Data Protection legislation.  Where these rights exist for you, you may exercise these over the data we hold through your affiliated MR company.  These may include:

• The right to be informed about the processing of your personal information and to know what data we hold 
• The right to correct or rectify the personal information we hold
• The right to access your data and rights of data portability
• The right to be forgotten 
• The right to withdraw any consents you have previously given to us  
• The right to opt out of the sale of your data (pursuant to the California Consumer Protection Act of 2018 “CCPA” and Virginia Consumer Data Protection Act “VCDPA”, the Connecticut Data Privacy Act, The Utah Consumer Privacy Act, The Colorado Privacy Act, The Indiana Consumer Data protection Act, The Iowa Act Relating to Consumer Data Protection, The Nevada Health Privacy Law, the Oregon Consumer Privacy Act, The Tennessee Information Protection Act, The Texas Information Protection Act, The Washington My Health My Data Act
• The right to choose (opt out) of whether your personal information is (i) to be disclosed to a third party or (ii) to be used for a purpose that is materially different from the purpose(s) for which it was originally collected or subsequently authorized by you.  You  can exercise this right by submitting a verifiable consumer request by sending an email to privacy@purespectrum.com.
•  For sensitive information (i.e., personal information specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or information specifying the sex life of the individual), we will obtain affirmative express consent (opt in) from you if such information is to be (i) disclosed to a third party or (ii) used for a purpose other than those for which it was originally collected or subsequently authorized by you through the exercise of opt-in choice.  We will treat as sensitive any personal information received about you from a third party where the third party identifies and treats it as sensitive.
• Right to non-discrimination as a result of exercising your rights, however, if you withdraw consent for us to collect and process your data, you will not be eligible to participate in MR surveys as that is the core function of our service 
• Rights to object or have human intervention in fully automated decisions
• Right to complain to a local Privacy and Data Protection Regulatory body
• Additional rights as described below related to the China Personal Information Protection Law (“PIPL”) described below

If you exercise your rights or opt-out, the company that invited you to this survey opportunity is solely liable and responsible for managing all requests and opt-out requests and will communicate your request to PureSpectrum on your behalf.

Notice to California, Virginia, Connecticut, Utah, Colorado, Iowa,  Oregon, Indiana, Tennessee, Nevada, Washington and Texas Residents

Pursuant to your applicable state’s privacy laws and regulations (the “Applicable Law”), (including the California Consumer Protection Act of 2018 (“CCPA”) for California residents the Virginia Consumer Data Protection Act, the Connecticut Data Privacy Act, The Utah Consumer Privacy Act, The Colorado Privacy Act, The Indiana Consumer Data protection Act, The Iowa Act Relating to Consumer Data Protection, The Nevada Health Privacy Law, the Oregon Consumer Privacy Act, The Tennessee Information Protection Act, The Texas Information Protection Act, The Washington My Health My Data Act, and subject to certain exceptions and limitations, you can contact us to exercise the rights described below with respect to certain personal information that we hold about them. To the extent those rights apply to you, they are described below. We also sometimes collect and process certain personal information on behalf of our customers. You should contact those customers to exercise any rights you may have with respect to that personal information.

Right to Know About Personal Information Collected, Disclosed, or Sold

You have the right to request that we provide you with details about the personal information we collect, use, disclose and sell. You can submit a verifiable consumer request by emailing privacy@purespectrum.com. We reserve the right to verify your identity to our satisfaction, including by asking you to provide certain personal data that will help us identify you and connect you to personal data we have collected. 

You are entitled to receive the following:

• The categories of your personal information that we have collected in the preceding 12 months
• The categories of sources from which that information was collected
• The business/commercial purpose for the collection or selling
• The categories of third parties with whom we share personal information
• The specific pieces of personal information we have collected about you (subject to some exceptions)

Because we have disclosed or sold (as those words are defined in the applicable state law) personal information to third parties in the last 12 months, you are also entitled to receive:

• The categories of personal information that we have disclosed or sold in the past 12 months

Right to Request Deletion of Personal Information

You have the right to request deletion of the personal information we have collected about you (subject to some exceptions). You can submit your request as described above, and we reserve the right to conduct the verification described above.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

You have the right not to receive unlawful discriminatory treatment from us for the exercise of your privacy rights under the applicable state law. 

Right to Opt-Out of Sale of Personal Information

You have the right to opt-out of the sale, sharing or transferring of your personal information by us. You can submit a verifiable consumer request by sending an email to privacy@purespectrum.com. 

Business Transfers

If PureSpectrum or its assets are acquired, or in the unlikely event that we go out of business or enter bankruptcy, we would include data, including your personal information, among the assets transferred to any parties who acquire us. You acknowledge that such transfers may occur, and that any parties who acquire us may, to the extent permitted by applicable law, continue to use your personal information according to this policy, which they will be required to assume as it is the basis for any ownership or use rights we have over such information.

List of Categories of Personal Information to be Collected and May Have Been Sold or Disclosed

Categories of Personal Information Collected

We collect personal information and sensitive data from research participants during participation in a survey and other market research activities.

• Your age
• Your Gender
• Your income
• Zip or Postal Code
• Race
• Ethnicity
• Marital Status

While we will not ask for any directly identifying data, such as your name, email address, physical address or phone number, we will collect additional information from you that will be project specific.  This data will be dependent on the individual project but may include protected or more sensitive data such as:

• Health or medical information including (i) any health condition or status, disease or diagnosis; (ii) social, psychological, behavioural or medical interventions; (iii) surgeries or other health-related procedures; (iv) the use or acquisition of medication; (v) bodily functions, vital signs or symptoms; (vi) reproductive or sexual health care; (vii) gender-affirming care; (viii) biometric data; (ix) Diagnoses or diagnostic testing, treatment, or medication; (x) Data that identifies a consumer seeking health care services;  or (xi) any information that can associate or identify a consumer with the data described in (i) through (xi) of this subsection that is derived or extrapolated from non-health information (such as proxy, derivative, inferred, or emergent data by any means, including algorithms or machine learning).
• Educational information, 
• Political beliefs
• Religious beliefs
• Professional or employment-related information, including occupation trade union membership
• Sexual orientation 
• Other demographic information  

In addition, we will obtain data from the following sources to better understand your compatibility with projects that you may wish to participate in and to protect our business 

• Geo Location
• IP Address
• Device Details which includes collecting Information about your device (e.g., device operating system, the other applications on your device, device network provider, device type, time zone, network status, browser type, browser identifier and other information that alone or in combination may be used to uniquely identify your device)

All of the information above was collected for the purposes described in this Privacy Policy

Categories of Personal Information that May Have Been Sold

We have sold all of the above categories of personal information in the last 12 months.

Categories of Personal Information that Were Disclosed

We have disclosed all of the above categories of personal information in the last 12 months.

Notice to Residents of the Peoples Republic of China

Your Rights Under the China Personal Information Protection Law (“PIPL”)

Pursuant to the China Personal Information Protection Law (“PIPL”), and subject to certain exceptions and limitations, residents of the Peoples Republic of China can contact us to exercise the rights described below with respect to certain personal information that we hold about them. Relatives of deceased persons about whom we hold personal information may, for their own lawful and legitimate interest, exercise these rights.  To the extent those rights apply to you, they are described below. We also sometimes collect and process certain personal information on behalf of our customers. You should contact those customers to exercise any rights you may have with respect to that personal information.

Right to Consent to the Collection of Personal Information and Sensitive Personal Information 

We will obtain your voluntary consent to the collection, processing, storage, and sale of your Personal Information before you begin a survey opportunity.  By providing that consent you are agreeing to the terms of this privacy policy.

Right to Know About Personal Information Collected, Disclosed, or Sold

You have the right to request that we provide you with details about the personal information we collect, use, disclose and sell. You can also request to correct or complete the information we hold about you.  You can submit a verifiable consumer request by emailing privacy@purespectrum.com. We reserve the right to verify your identity to our satisfaction, including by asking you to provide certain personal data that will help us identify you and connect you to personal data we have collected. 

Right to Limit or Object to Processing Your Personal Information 

You are entitled to restrict or object to the processing of your personal information and to withdraw consent to the collection of your personal information, but if you do limit or object to the processing of your personal information, we will not be able to offer you survey opportunities.

Right to Request Deletion of Personal Information

You have the right to request deletion of the personal information we have collected about you (subject to some exceptions). You can submit your request as described above, and we reserve the right to conduct the verification described above.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

You have the right not to receive unlawful discriminatory treatment from us for the exercise of your privacy rights under PIPL.

Right to Opt-Out of Sale of Personal Information

You have the right to opt-out of the sale, sharing or transferring of your personal information by us. You can submit a verifiable consumer request by sending an email to privacy@purespectrum.com. 

WE MAKE UPDATES TO THIS POLICY

We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

How to Contact Us

If you have any questions about the processing of your data, or to exercise any of your rights under your local Data Protection laws or regulations, you can contact your affiliated MR Company or email us at privacy@purespectrum.com

Your participation in any survey opportunities does not entitle you to any benefits offered by, or membership with, the Third-Party MR Companies. If you have any questions or issues regarding this, please contact  respondentsupport@purespectrum.com