Verto Smart Panel - Privacy Policy

Introduction

Verto Analytics Oy ("we," "us") is a market research company. We are passionate about creating new technologies that match today's market and customer needs, innovating in the areas of data acquisition and partnerships, and driving new inventions by turning data into value-adding insights that help our customers.
Your privacy is a top priority to you, and to us.  This Privacy Policy describes how we collect and use personal data about you and how we protect personal data about you.  By registering for the Service and/or using the Site, as these terms have been defined below, you agree to this Privacy Policy, as it may be amended from time to time as provided below, and to the processing of your personal data in accordance with it.
In all of our business practices, we apply the market research principles and practices set forth by the International Chamber of Commerce and ESOMAR which can be found here: http://www.esomar.org/uploads/public/knowledge-and-standards/codes-and-guidelines/ICCESOMAR_Code_English_.pdf and the standards set forth by CASRO, which can be found here: http://www.casro.org/?page=TheCASROCode.

Definitions

As used in this Privacy Policy, the terms enlisted below have the following meaning:
Personal data means information that relates to an identified or identifiable natural person (for example, corporations are not natural persons).
Research Application means a piece of software that the User installs voluntarily in his/her device, which sends certain user-level data elements (as described in Section 6 of this Privacy Policy to our servers for use as described in this Privacy Policy.
Service means a market research service in which the Research Application that is placed on Users' devices analyses Users' activities, as described in this Privacy Policy and includes the Site and the Verto Smart Panel.
Site means www.vertoanalytics.com and/or https://webassets.ssisurveys.com/vertoopinion/us/home_us.html and any applicable sub-domains thereof.
You or User means a user of the Service and/or the Site.

The Scope of the Privacy Policy

This Privacy Policy pertains to the Service, which is operated by us in collaboration with our partners. Please be reminded that this Privacy Policy applies to personal data that we process when you use the Service. It does not apply to any links to third parties' websites, services, material, content or applications, which you may encounter when you use the Service. We encourage you to carefully familiarize yourself with privacy policies applicable to any websites and/or services operated by third parties.
Reference is also made to the Verto Smart Panel Terms of Service, available at https://webassets.ssisurveys.com/vertoopinion/us/terms_Vertoopinion.html. In the event of any conflict between the Terms of Service and this Privacy Policy, the Terms of Service shall prevail.

Opt-In to the Verto Smart Panel

The User's initial registration to and participation in the Verto Smart Panel shall always be the User's choice ("Opt-in"), subject to the Verto Smart Panel Terms of Service.

Opt-In To Research Application

The User's initial installation and initial activation of the Research Application shall always be the User's choice ("Opt-in"). Following initial installation and initial activation of the Research Application, we may automatically update activated Research Applications from time to time.

Collection and Use of Personal Data

We may collect personal data from Users in a variety of ways, including through online forms, through the Research Application and other software applications, and other instances where Users are invited to volunteer such data.  We also automatically collect information about how Users interact with websites, Internet applications and device features. This information is obtained through analysis of logs generated by Users' activities and through the utilization of the Research Application. We may also automatically generate information such as internal technical identifiers ("IDs") which may be considered personal data. Below, we describe the personal data that we collect in more detail.

Data You May Provide to Us or Which We May Generate

We may collect or otherwise generate the following information from our Users that may, in certain circumstances, alone or in connection with other data, constitute personal data.

Data Collected Automatically

The Service may automatically collect the following information from our Users that may, in certain circumstances, alone or in connection with other data, constitute personal data:

The Purposes for Which We Use the Data

We use the personal data we collect directly from you for the following purposes:

We may use the data collected automatically for the following purposes:

We will not disclose personal data without permission (opt-in) from the relevant User unless the disclosure of such information is permitted by this Privacy Policy. 
The personal data collected in the Service may be disclosed in the following manner:

(i)Personal Data that You Provide to Us:

We may disclose personal data you provide to us with the following categories of third parties:

(ii) Data collected automatically: 
The data collected automatically in the Service may be disclosed to the following categories of third parties: 

Moreover, we may disclose information to third parties in an aggregate format that does not constitute personal data and does not allow the identification of individual users. In conducting our business, we can use, process, analyze, disclose and commercialize aggregated and summary User data in such form that does not enable identification of individual Users, including disclosing such data to our partner companies.  This data is anonymous (meaning that we cannot link your identity to the data points contained therein) and includes, for example, data such as statistics related to User behavior such as device and application usage, data and communication usage and time distribution of Service usage activity. By using the Service, you consent to having the information that is collected from you as a User and as specified in this Privacy Policy disclosed to the above-mentioned third parties.

You have the following rights with respect to the personal data we hold about you:

Data Security

We use commercially reasonable physical and technical safeguards to secure data about you. For example, our data systems use SSL encryption and our servers have denial-of-service attack prevention and virus protection tools. All servers we use have access codes.  Access to personal data is restricted to persons authorized to access the data. Passwords are changed at regular intervals.  Despite these efforts, we cannot guarantee the security of personal data during its transmission or its storage on our systems. Further, while we attempt to ensure the integrity and security of personal data, we cannot guarantee that our security measures will prevent third-parties such as so-called hackers from illegally obtaining access to personal data.  We do not warrant or represent that personal data about you will be protected against, loss, misuse, or alteration by third parties.

International Transfers of Personal Data

By using the Service, you consent to having the personal data collected from you as a User transferred to, and stored in, Finland. The laws applicable to the protection of personal data in Finland may be different from those applicable in your home country.  From time to time, we may transfer personal data to our affiliates in other countries such as the United States. Such transfers are undertaken in accordance with the Commission of the European Union Standard contractual clauses for the transfer of personal data to third countries.  

Children's Privacy

You must be at least eighteen (18) years of age to register to and use the Service independently. If you are under eighteen (18) years old, we will use specific methods to validate that both you and your parents accept the study you are joining. We do not under any circumstances intend to collect personal data from children under 13.

Amendments to this Privacy Policy

This Privacy Policy may be amended at any time. You can tell when changes have been made to the Privacy Policy by referring to the "Last Updated" legend on top of this page.  We encourage you to familiarize yourself with the Privacy Policy regularly for any amendments. If we materially change the ways in which we use and disclose personal data, we will post a notice on the Site. Your continued use of the Service following any changes to this Privacy Policy constitutes your acceptance of any such changes made.   

Communications From Us

We may from time to time send you either email communications or push notifications to computing devices with an installed copy of the Research Application. Such communications will occur solely in order to communicate with you regarding your use of the Service or any part thereof, to activate the installed Research Application, or to invite you to participate in further research projects including but not limited to additional surveys.

Your California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to request from a business, with whom the California resident has an established business relationship, certain information with respect to the types of personal information the business shares with third parties for direct marketing purposes by such third party and the identities of the third parties with whom the business has shared such information during the immediately preceding calendar year.
To request a copy of the information disclosure provided by us pursuant to Section 1798.83 of the California Civil Code, please contact [INSERT].

Questions or Concerns?

Should you have any questions regarding this Privacy Policy, your privacy as it relates to the use of the Service, or the protection of the personal data we hold about you, please contact our Privacy Administrator via e-mail at privacy@vertoanalytics.com, or by mail at Verto Analytics Oy, Tekniikantie 14, 02150 Espoo, Finland. We seek to swiftly resolve any concerns you may have.