Effective: September 12, 2013
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We may collect both non-personally identifiable information and personally identifiable information from you as described below.
The Application collects "clickstream data". Clickstream data is information generated by you and your device while surfing the Internet and interacting with various sites and services.
In greater detail, the Application collects the following types of information:
1. Online browsing: This includes the sites you visit and apps you use, including news sites/apps or social networks, and your interactions with them.
2. Online activities: This includes the search terms you enter and the results of such searches, the videos you view, the products you shop for online, information you enter into forms, the materials you download or upload, the advertisements you see, information and content on sites or apps that you visit or use and with which you interact and may include personal, financial and health information (subject to the process described below in the section entitled "Protecting Personal & Sensitive Information").
3. Information on secure pages/apps: This includes information and content from protected or secure pages or apps that you access, such as online accounts or the content of complete and incomplete consumer transactions when you are checking out through a service's shopping cart, even if the service makes this information unreadable to others.
4. System information: This includes information about the device and browser that you are running on, including the IP address and phone number of the device, how the Application is operating, and which other applications are installed or running.
5. Mobile Usage Information, which refers to information about your use of your mobile device which we are able to collect if you have downloaded and installed one of our Applications on your device. Please note this information is collected and transmitted to us "in the background", and does not require any further activation on your part. We call this 'passive tracking'. This can include the following types of information:
6. Location Information, meaning data which reveals the geographic location of you and your mobile device, where you have given us your consent to collect such information. When you first download the Application, you will be asked if you agree to your location information being disclosed to us. If you consent, then we may collect and transmit this information on a semi-continuous and passive basis, which does not require any further activation on your part. If you wish at any stage to turn off this passive location tracking, you will need to uninstall the Application, by following the instructions set out here.
7. Information you provide. In some cases, we may ask you to send video, audio or image content to us. That content may include personal information, for example in the form of an identifiable image of you.
Protecting Personal & Sensitive Information
We have established certain procedural and technical privacy rules designed to avoid the use of certain types of personally identifiable and sensitive information that can be identified by those processes, such as credit card numbers, social security numbers, email addresses and information from most web-based email accounts. Procedures are executed by Our personnel to ensure that certain types of personally identifiable and sensitive information are not used in our services.
As part of our security program, we conduct regular checks to update and refresh these procedures and technical rules.
When your information is sent over the public Internet by the Application, it is transmitted through either a secure means of encryption, or the same means of transmission used by your device in the absence of the Application. For example, information normally sent by your device in an encrypted fashion is sent by the Application to Us and Our vendor in an encrypted fashion. Similarly, information normally sent by your device in an unencrypted fashion may be sent by the Application in that format, or we may choose to send it in an encrypted fashion. In other words, the Application does not reduce the security procedures that your device uses to transmit information.
Despite our efforts, certain personally identifiable or sensitive information might get through the privacy rules and procedures, such as health and financial details. However, we do not knowingly use any inadvertently retained personally identifiable or sensitive information in our services.
We may collect certain information in part through the use of a technology called a "cookie." A cookie is a small text file that is saved to your device using your browser, which allows sites to recognize you and store preferences and other information if you return to the site using the same device and browser.
We use temporary session cookies during the download and registration process to correctly identify the research panel that you have joined, enable the creation of a unique, anonymous identifier and to trigger the download process.
You may remove cookies and/or control their operation by adjusting your browser settings. Please visit the 'help' section of your browser for more information.
Information Use and Sharing
This section describes how your data - which includes web use, app use, demographic information, survey responses and information we have obtained from third parties - contributes to the kinds of services our clients buy from us. Our typical process is to combine panel members' data into consumer segments and report on the aggregated (or grouped) results. Consumer segments are pools of users who have common interests or characteristics, for example, "women between the ages of 28-34 interested in travel websites." Once aggregated, the results and consumer segments are shared with our clients and other parties. On some occasions, we may share non-aggregated results for limited purposes. The following are examples of the kinds of services we provide, and how your data is used in these services:
Advertising Research - Your data is combined with data from other users into a pool that is then analyzed for exposure to certain advertising. Information about the combined pool, which does not identify any particular user, is shared with clients so they can understand if and how their advertising spending impacts the consumer journey and consumer decisions. For example, by comparing the behaviors of a group of users who saw a particular online advertisement with another group of users who did not see that advertisement, We can help advertisers understand the effectiveness of their ads.
Media Use Analysis - Your data is combined with data from other users to form consumer segments that are shared with clients without identifying any particular user. These segments are typically analyzed on behalf of clients to understand where consumers go online and how consumers interact with digital media, which includes website content, apps and advertising that they see. For example, we help companies understand the effectiveness of their websites or apps by comparing how users are interacting with their websites or apps versus how users are interacting with their competitors' websites or apps.
Consumer Analysis We may use your data, including personally identifiable information we have obtained directly or through a trusted third party vendor, to enhance our or our customer's consumer segments explained above. We use personally identifiable information in this way when our customer already has this information because it is usually the only way to match our profiles with those of our customers. Sometimes we may gather information from your clickstream data, such as a session ID, and share it with a third party in order to match your information with the information possessed by a third party as part of our services. Although in each of these cases we permit these other parties and our customers to use your information to enhance their broader consumer segments, to which they then may target advertising, we prohibit these parties from using your information to target advertising to you individually. So in the normal course of your online activities, you may be a member of a broader consumer segment that sees particular advertising that your data helped create.
Targeted Surveys We may send you invitations to participate in surveys on the basis of your online behaviors collected by the Application. For example, if you visit sites that suggest you enjoy travel, we may send you a survey regarding travel services. We may provide our clients with some or all of the responses to these surveys without directly identifying any particular user, including specific answers and quotes from individual respondents.
We also may use your information for purposes of maintaining the configuration and proper functioning of the Application, for database or Application services (such as customer support, email, or surveys), and for purposes of data quality and data cleansing.
We may provide RealityMine with data collected through the Application for RealityMine's own internal use only to develop and enhance its general offerings, however, RealityMine is not authorized to provide any third party with access to or use of such data in any manner that identifies you
As part of the registration process prior to installation of the Application or in connection with your participation in a survey or other service, we may directly collect information such as your name, telephone number, email address, birth year, household information, income, gender, and ethnicity. This information is part of your consumer profile and used as described above. Of course, the contact information you give also helps us reach you with information related to Application maintenance and upgrades and other service related communications.
When working with a third party to supplement your profile, we protect your privacy by having our partner sign a confidentiality agreement stating that they will not share personally identifiable information with unauthorized parties. We instruct them to maintain the confidentiality, security and integrity of the information we provide and not to use the information for any purpose other than those we explicitly authorize.
We may share information about you with authorized vendors and service providers, such as RealityMine Ltd., in connection with the services that they perform for us. These third parties are prohibited from using your information for other purposes.
Additional Disclosures of your Information
In the event We go through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, your information may be among the assets transferred.
We also reserve the right to disclose your information as required by law, court order, or legal process served on us, when we believe that disclosure is necessary to protect our rights, or to combat suspected fraudulent activities.
You can opt-out of this Program at any time by removing the Application from your device. For instructions on how to do so, please read the Application Removal Instructions here.
If you are not able to quickly and easily opt-out from data collection, we can and will help you if you ask. If you have any questions regarding removal or opting-out, you may contact Compete via email at email@example.com or call us at 1 (888) 744-6028 or (617) 933-5699.
If you have set your browser to "private browsing" or a similar setting, the Application may still continue to operate and collect data to be sent to Us. To completely stop the operation of the Application and the collection of data from your device, you must follow the instructions above to remove or disable the Application.
We have put in place reasonable administrative, technical, and physical safeguards to protect against unauthorized access to the information we collect. However, no security measures are 100% impenetrable and we cannot guarantee against all potential security breaches. Moreover, the transmission of information over the Internet is not inherently secure, and we are not responsible for the transmission of information over networks that we do not control. Your use of our Application demonstrates your assumption of these risks.
We will retain the information described above for as long as the information has value as part of the services we offer to our clients, or as long as is necessary to comply with our legal obligations, resolve disputes, and enforce our agreements, whichever is longer. If you opt out of the Program by following the directions to remove the Application as described above in the Application Removal section, we no longer will collect data from you but we will retain and continue to use your data collected prior to your removal of the Application.
For the majority of our research, our programs consist of users who are of the legal age of majority within their geography. On occasion, we may recruit children for a non-adult panel for custom research. In these cases of non-adult recruitment, we will obtain parental consent and adhere to the appropriate data laws and regulations, including the Children's Online Privacy Protection Act.
Data Stored in the United States
Data from EU residents
Compete complies with the U.S. - E.U. Safe Harbor framework and the U.S. - Swiss Safe Harbor framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from European Union member countries and Switzerland. Compete has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Compete's certification, please visit http://www.export.gov/safeharbor/.
If you have any complaints regarding our compliance with the Safe Harbor you should first contact us (as provided above). If contacting us does not resolve your complaint, you may raise your complaint with TRUSTe using this URL (https://feedback-form.truste.com/watchdog/request/), fax to 415-520-3420, or mail to TRUSTe Safe Harbor Compliance Dept. (use this URL for mailing address http://www.truste.com/about-TRUSTe/contact-us). If you are faxing or mailing TRUSTe to lodge a complaint, you must include the following information: the name of company, the alleged privacy violation, your contact information, and whether you would like the particulars of your complaint shared with the company. For information about TRUSTe or the operation of TRUSTe's dispute resolution process, use this URL(https://feedback-form.truste.com/watchdog/request) or request this information from TRUSTe at any of the addresses listed above. The TRUSTe dispute resolution process shall be conducted in English.
If we have any personally identifiable information about you, you may correct, update or delete your contact information by contacting Compete via email at firstname.lastname@example.org or call us at 1 (888) 744-6028 or (617) 933-5699. We will respond to your access request within 30 days.
If you have questions related to this policy, the data that has been collected by the Application, or other privacy concerns, please contact us via email at email@example.com ) or by writing to us at:
Privacy Officer Compete, Inc. 501 Boylston Avenue, 6th Floor Boston, MA 02116
Copyright © 2013 by Compete, Inc.