Privacy Policy

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Last Modified: June 14, 2023

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Thank you for your interest in the US Panel Project Opt-In Survey Panel (the “Panel”). This privacy policy (the “Privacy Policy”) describes how US Panel Project. (“US Panel Project,” “we,” or “us”), located at 101 State Street, Springfield, Massachusetts 01103, collects, uses, and discloses information from and about you when you visit and use surveys via their Survey (the “Survey”), as well as your ability to control certain uses of that information. It also describes certain data protection rights which apply, subject to applicable law, including a right to object to some of the processing which US Panel Project carries out. More information about your rights, and how to exercise them, is set out in Accessing and Managing Your Personal Information below. If you are a California resident, please see our Notice to California Consumers for information regarding rights of California residents.

 

US Panel Project respects your privacy and is committed to protecting it through our compliance with this Privacy Policy. By accessing or otherwise using the Survey, you agree to the terms and conditions of this Privacy Policy, which is incorporated into the Terms of Use, and to US Panel Project collection, use, and disclosure of your information in accordance with this Privacy Policy, where such agreement is permitted by applicable law. If you choose to apply or enroll in the Panel, use of your personal information, if applicable, will be governed by the privacy policies shown on the application Survey and Website, respectively.

 

We regularly review our compliance with this Privacy Policy. Whenever we receive a formal complaint, we make best efforts to contact the person who made the complaint to attempt to resolve their concerns. If you have any questions about the use of your information, or the contents of this Privacy Policy, please contact us at privacy@uspanelproject.org

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Collection of Information

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Information You Provide

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US Panel Project collects information from you when you choose to provide it to us. For example, we collect your information when you submit a webform requesting information about US Panel Project Opt-in Panel, or otherwise contact us or provide information to us through the Survey. The information we collect includes personal information – such as your name, address, e-mail address, telephone number, and the content of any communications that we exchange – as well as non-personal information when you:

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·       indicate an interest in the Panel (you may unsubscribe from promotional communication by clicking “opt out” on the communication you receive from us);

·       create an account;

·       register or apply for the Panel, either directly with us, through your employer, or through some other means;

·       participate in our surveys, promotions, and competitions;

·       communicate with us, for example to submit queries regarding the Survey; and

·       use the Survey. 

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Information Automatically Collected

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When you visit the Survey or interact with emails that we send to you, we passively collect information from you, including your internet protocol address (“IP address”), browser type, operating system, device identifier, device model, software version, or mobile or ISP carrier information. We and our third-party partners use cookies and other technologies to collect information about your visit to the Survey, such as the date and time of your visit, the information you searched to find the Survey, your activity on the Survey, and your clicks on our ads. “Cookies” are small files which may be stored on your computer during your use of the Survey and contain data about your use of the Survey. We use session cookies (which expire when you close your browser) and persistent cookies (which stay on your computer until you delete them or after a specified expiry date) to understand more about your activity on the Survey. 

Please see US Panel Project Cookie Policy for details about how we use cookies and other tracking technologies and how you can control the cookies set on your browser. 

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Tracking Options and Do Not Track Disclosures 

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You may adjust your browser or operating system settings to limit tracking or to decline cookies. If you choose to limit tracking or decline cookies, however, you may be unable to access certain areas of the Survey. Check the “Help” or “Settings” menu of your browser or operating system to learn how to change your tracking settings or Cookie preferences. Learn more about the use of cookies or other tracking technologies and your choices regarding the use of information collected this way by certain Service Providers (as defined below). On your mobile device, you can adjust your privacy and advertising settings to limit tracking for advertising or to control whether you receive more relevant advertising. Note that our systems may not recognize Do Not Track headers or requests from some or all browsers. Please see our Cookie Policy for more information or click the Data Request Form or email privacy@uspanelproject.org to opt out.

 

Information Collected from Other Sources

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Where permitted by law, we collect or receive information about you from the School, your employer, companies to which you indicate that you would like to learn more about the Program, or other entities within the US Panel Project family of companies (collectively “Other Sources”) in order to update or supplement the information that you provide or that we collect automatically, as described above in Information Automatically Collected. We use this information to help us maintain the accuracy of the information we collect, to target our communications so that we can inform you of products, services or other offers that may be of interest to you, and for internal business analysis or other business purposes.

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Our Combination of Your Information

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We combine the information we receive from and about you via the Survey and from Other Sources to help us tailor our communications to you and to improve the Survey.

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Failure to Provide Personal Information

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Failure to provide certain information may make it difficult or impossible for you to access some services through the Survey. You should ensure that personal information submitted to us is accurate and up-to-date. For example, we need a current mobile (cellphone) number to communicate with you about the Survey.

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Children’s Privacy

We do not direct the Survey to, nor do we knowingly collect any personal information from, children under the age of 18.

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How We Use Your Information

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Purposes for Collecting and Processing Personal Information

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We process personal information under the following legal bases:

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·       To fulfill a contract or take steps linked to a contract, including:

o   providing our services;

o   verifying your identity;

o   communicating with you.

·       To conduct US Panel Project business and pursue our legitimate interests in marketing our business, ensuring that we conduct our business in line with our objectives, improving and developing our products and services, and keeping our records accurate and up to date. This includes: 

o   using your information to provide products and services you have requested and responding to any comments or complaints you may send us;

o   personalizing your experience with the Survey and helping us to better respond to your individual needs;

o   targeting advertising to individuals with similar interests or characteristics through services offered by third parties; 

o   developing new products or services or conducting analyses to enhance current products and services;

o   reviewing the usage and operations of the Survey and analyzing and improving the Survey (we continually strive to improve the Survey based on the information and feedback we receive from you);

o   contacting you for legitimate business purposes; 

o   using personal information to invite individuals to take part in market research;

o   where consent is not required by applicable law, for direct marketing purposes; 

o   protecting the security and functionality of the Survey, including using personal information you provide to investigate any complaints received from you or from others about the Survey or our products and services.

We conduct balancing tests for the data processing we carry out on the basis of our legitimate interests described above. For more details on the balancing tests we have carried out, please contact us at privacy@uspanelproject.org. You may also have the right to object to our use of your personal data on the basis of our legitimate interests as described at the outset of this policy.

·       Where you give us consent. This includes: 

o   where consent is required by applicable law, sending you direct marketing in relation to our relevant products and services, or other products and services provided by US Panel Project.

o   on other occasions where we ask you for consent, using the data for the purpose which we explain at that time.

·       For purposes which are required by law. This includes: 

o   in response to requests by government or law enforcement authorities conducting an investigation;

o   using personal information in connection with legal claims, compliance, regulatory and investigative purposes as necessary, including disclosure of such information in connection with legal process or litigation.

·       For reasons not described in this Privacy Policy where the reason is compatible with the purpose for which we originally collected your information and where such use is lawful.

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Use of De-identified, Aggregate or Anonymized Information

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We use de-identified, aggregate or anonymized information to help us analyze the use of the Survey. Where permitted by law, this Privacy Policy does not limit our use or disclosure of de-identified, aggregate, pseudonymous or anonymous information, and we reserve the right to use and disclose such information to our partners, advertisers, and other third parties at our discretion. 

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How We Disclose Your Information

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US Panel Project shares your information with other entities or individuals in the following limited circumstances: 

 

1.    Service Providers: We share your information with third parties that provide business, professional, or technical support functions for us. In particular, we use third-party providers for Survey hosting, maintenance, marketing services, courier services, certification services, business operations, payment services, and identity verification services (“Service Providers”). These Service Providers are only given access to your information to the extent necessary to process your information and/or provide services to US Panel Project, and they are prohibited from using or sharing your information for any other purposes. Where permitted by law, US Panel Project discloses limited information about you to Service Providers to serve relevant advertising on third party platforms to you or to other audiences.

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2.    Legal Matters; Safety: We access or share your information to satisfy any applicable law, regulation, legal process, or governmental request; in connection with an investigation on matters related to public safety; as permitted by law; or otherwise as required by law. We disclose your information to protect the security of the Program, the Survey, servers, network systems, and databases. We also disclose your information, as necessary, if we believe that there has been a violation of our Terms of Use (including investigation of potential violations thereof), any other legal document or contract related to the Survey, or the rights of any third party.

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3.    Fraud; Security: We access and disclose your information to detect, prevent, or otherwise address fraud, security or other technical issues.

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4.    Consent; Other: We share information with third parties when we have your consent or otherwise as described to you at the point of collection.

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5.    Sale or Transfer of Business or Assets: US Panel Project may sell or purchase assets during the normal course of our business. If another entity acquires us or any of our assets, information we have collected about you may be transferred to such entity. In addition, if any bankruptcy or reorganization proceeding is brought by or against us, such information may be considered an asset of ours and may be sold or transferred to third parties. Should such a sale or transfer occur, we will use reasonable efforts to try to require that the transferee use your information in a manner that is consistent with this Privacy Policy.

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6.    International Transfers: We transfer personal information from the European Economic Area (“EEA”) to other countries, including the United Kingdom, United States and South Africa. Where information is transferred outside the EEA to a third party in a country that is not subject to an adequacy decision by the EU Commission, data is adequately protected by Standard Contractual Clauses or a Service Provider’s Binding Corporate Rules. A copy of the relevant mechanism can be provided for your review on request to privacy@uspanelproject.org. 

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Information Security and Data Retention

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We are committed to protecting the security of your information. We maintain what we believe to be appropriate physical, electronic, and managerial procedures to safeguard and secure your information and to prevent unauthorized access, maintain accuracy, and ensure appropriate use of your information. The accuracy, safety, and security of your information also depend on you. Where we have given you – or where you have chosen – a password for access to any parts of the Survey, you are responsible for keeping this password confidential. We ask that you not share your password with anyone. Even though we do our best to protect your information, the transmission of information via the internet is not completely secure, and we cannot guarantee our security measures. We are not responsible for any unauthorized access to or acquisition of your information. 

 

We retain your personal information for as long as we have a relationship with you. We also may retain your personal information for longer period of time which enables us to: 

·       Maintain business records for analysis and/or audit purposes; 

·       Comply with record retention requirements under the law;

·       Defend or bring any existing or potential legal claims;

·       Address any complaints regarding the services;

·       Enforce our commercial agreements; and

·       Support our legitimate interests, as described in this Privacy Policy. 

 

Accessing and Managing Your Personal Information

 

If you have created a profile after applying to or enrolling in a Program, you may access your personal information through your user profile. 

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In some instances, you may be eligible to (a) ask us for a copy of your personal information; (b) correct, delete, or restrict processing of your personal information; and/or (c) obtain the personal information you provide to us in a structured, machine readable format. In addition, you may have the right under applicable law to object to the processing of your personal information in some circumstances. 

 

Your rights regarding your personal information may be limited, for example, if fulfilling your request would reveal personal information about another person or would infringe the rights of a third party (including our rights), or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. We will inform you of the relevant exemption upon which we rely when responding to any request you make. 

 

Our use of certain personal information is necessary for us to provide information to you about the Program or to provide services to you through the Survey or otherwise. If you choose not to provide this personal information or request that US Panel Project delete or restrict the processing of this personal information, you may not be able to participate in the Program, and we may not be able to provide you with other services, including those provided through the Survey or advertised about the Program. 

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If you wish to access or delete your information as described in this section, please fill out US Panel Project Data Request Form.  If you believe your rights regarding your personal information have been infringed upon, please contact us privacy@uspanelproject.org. For individuals located in the United Kingdom, EEA or Switzerland who have unresolved concerns, you also have a right to lodge a complaint with your applicable Data Protection Authority.

 

Additional Information

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NOTICE FOR CALIFORNIA CONSUMERS

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Categories of Personal Information that We Collect and Disclose

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As required by the California Consumer Privacy Act (“CCPA”), below are the categories of personal information about California consumers that US Panel Project collects and discloses for a business purpose.   

 

We collect and disclose for a business purpose the following categories of personal information:

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·       Contact Information and Identifiers, including real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, phone number, account name, or other similar identifiers.

·       Customer Records, including paper and electronic customer records containing personal information, such as name, signature, address, telephone number, education, employment, employment history, or medical information relevant to your participation in the Program.

·       Usage Data, including internet or other electronic network activity information, such as information about how you interact with our services or advertisements.

·       Audio, electronic, visual, thermal, olfactory or similar information, including voice recordings when you call us. 

·       Employment History, including professional or employment-related information.

·       Education Information, including information about education history or background.

·       Protected Classifications, characteristics of protected classifications under California or federal law such as race, color, sex, age, religion, national origin, disability and citizenship status.

 

Categories of Sources of Personal Information 

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The categories of sources of personal information we collect are described in the section Collection of Information above.

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Purposes for Collecting Personal Information

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We collect the personal information identified above to communicate with you, for advertising and marketing purposes, to provide and improve our services, and other purposes set forth in How We Use Your Information above.

 

Categories of Third Parties with Which Personal Information is Shared 

 

We share the categories of personal information identified above with the following categories of third parties:

 

·       Third-party providers that serve business, professional or technical support functions (all categories of personal information),

·       The US Panel Project family of companies (all categories of personal information),

·       Third parties for legal matters or safety purposes (all categories of personal information). 

In some cases, we share Identifiers and Usage Data with business partners in order to deliver ads that are more relevant to you and to measure and report on the effectiveness of our advertising campaigns. Under the CCPA, some of this data sharing may be broadly considered a “sale” of information, even though these activities do not fit what most people would understand “sale” to mean.  To opt out of the sale of your personal information, please visit US Panel Project Do Not Sell My Information page.

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California Consumer Rights

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California law gives California consumers the right to make the following requests:

·       The right to opt-out of sale of your personal information. 

·       The right to request a copy of the personal information that we have collected about you in the prior 12 months.  

·       The right to request deletion of the personal information that we have collected from you, subject to certain exemptions (for example, where the information is used by us to detect security incidents, debugging or to comply with a legal obligation).

·       The right to request more details about the personal information we collect and how and why we use and share it, including the categories of personal information we have collected about you, the categories of sources for personal information we collect, the business or commercial purposes for collecting personal information, and the categories of third parties with which we share personal information.

You can submit a copy, deletion, or right-to-know request online by filling out US Panel Project Data Request Form or by contacting us at 1-202-567-7241.  To opt out of the sale of your personal information, please visit US Panel Project Do Not Sell My Information page.

 

You have the right not to receive discriminatory treatment for the exercise of your CCPA privacy rights, subject to certain limitations. We do not discriminate if you exercise your rights under the CCPA.

 

California’s Shine the Light Law. If you are a California resident and do not want US Panel Project to disclose your information to third parties (including to affiliates within the US Panel Project family of companies or US Panel Project partner universities) for their direct market marketing purposes, you may opt out here.

 

Questions or Concerns About this Privacy Policy 

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You may direct any questions or concerns regarding this Privacy Policy to us at privacy@uspanelproject.org. We review this Privacy Policy from time to time and reserve the right to make changes to this Privacy Policy at any time. If we do make material changes, we will give notice via the Survey or by otherwise notifying you.

 

To make a request to delete or access personal data, or for more information about the personal data US Panel Project has about you, use US Panel Project Data Request Form