Privacy Policy
Privacy Policy for Our Web and Mobile Platforms
(Covering our products and services as a whole.)
Last Updated: December 02, 2022
SERGIU RACU
Introduction
We believe in protecting your privacy. This Privacy Policy describes the information we collect, how we use it, and how it is shared.
Your Role and Ours
To fully understand our Privacy Policy it is best for you to understand our role with respect to your personal data. We are a technology system and services provider for companies and individuals that provide client acquisition system, lead generation, social media marketing and digital marketing as a whole.
Our system is used within our company and partners to collect data, store and process it, and report it to the end-clients. Depending on your role in this process you may be using our site, services, and/or products as one of the following types of users below:
1. A general visitor (General User)
2. An employee/agent of one of our clients / providers
3. An independent contractor or respondent who submits data into our platform on behalf of one of our clients / providers (Submitting User)
4. An end-client of one of our clients / providers (End-client User)
5. An Outside Person*(see below)
*Outside Person: If you are not a Provider User, Submitting User, or End-client User, it is also possible that our system still contains personal information about you loaded by one of those users. In this case you are an Outside Person . For example, a provider may have obtained your information and loaded it into our platform and then sent you an email, despite you having no commercial relationship yet with that provider.
Personal Data
Throughout this document we will use the term Personal Data to mean any of the above information that can be used alone or in combination with other sources to uniquely identify, contact, or locate a single person or to identify an individual.
Our providers or their end-clients may also collect your consent for some types of collection and processing of your Personal Data.
We will collect only as much Personal Data as needed to conduct specific, identified activities related to our business. As such, the “Do Not Track” browser setting is not relevant to our products and services.
Categories of Personal Data Collected
Personal Data is collected from you and used differently depending on your role as described above under “Your Role and Ours”. As examples:
If you are a General User of our products or services we may collect the following information about you:
Contact information (such as name, address, phone, email, fax)
Localization data (including geolocation/date/time)
Connection data (such as usage information, device or browser information, IP address, and page visits and navigation data)
If you are a Submitting User, Provider User, or End-client User then our providers or their end-clients may collect the above, and also the following additional categories of information from you using our products or services:
Employment and compensation details
ID data
Work/professional life data
Professional skills information
Personal life data
Personal master data
Contract master data (contractual relationships)
Performance metrics and history
Customer history
Billing and payment data (tax ID numbers, bank account numbers)
Media files and information from media files
Results from online form submission, and other marketing, service evaluation, business audit, and data collection and reporting projects
If necessary in connection with performing the services, our providers or their end-clients may also collect special categories of data such as the following:
Racial or ethnic origin
Political opinions
Religious or philosophical beliefs
Trade union membership
Genetic data
Biometrics data for the purpose of uniquely identifying a natural person
Data concerning health
Data concerning a natural person’s sex life or sexual orientation
If you are an Outside Person, it is possible that any of the above categories of information has been collected about you and entered into our system.
Who We Collect Information From or About (Data Subjects)
With the above roles in mind (see “Your Role and Ours”), we collect the above information from or about the following individuals or entities (data subjects):
Staff, employees, agents, advisors, business partners, vendors, subcontractors
Independent Contractors such as field agents, mystery shoppers, callers, mailers, interviewers
Respondents
Friends & family
Data subjects from end-client (or prospective end-client) sources:
Staff, employees, agents, advisors, business partners, vendors, subcontractors
Customers, prospects, friends & family
Other third-party individuals
How We Use the Information We Collect
We do not sell your Personal Data and only use the information that we collect to provide and improve our products and services. If you provide to us contact information for the purpose of staying informed about our products and services, or for support/troubleshooting operations, we will use the information for those purposes. Your IP address may be used to infer your geographical location. We keep various logs relating to Personal Data for internal purposes.
If you are a Submitting User, Provider User, End-client User, or Outside Person, your Personal Data may be used by us, our providers, and/or their end-clients for such things as contacting you, or for data verification, anti-abuse, and anti-fraud purposes.
For details about how our providers or their end-clients use the information they collect using our products and services, please refer to their specific Privacy Policies, or contact that company directly. If you need any assistance in this regard, please contact us using the contact information below.
Information We Share: Partners and integrations
Generally, we do not share your information except as required by law, or in connection with delivery of our products and services.
We may use third-party vendors to provide storage, hosting, infrastructure, support, and processing in the delivery of our products and services. We may also use third-party vendors for data verification and anti-fraud purposes.
Cookies
Our products use cookies and similar technologies to provide certain features and functionality. These are used only for our legitimate interests of delivering and optimizing services to you. Specifically, we use cookies for:
Security/Authentication: When you log in and we authenticate your identity we use a cookie to confirm that you are logged in.
Functionality: Certain functionality you use in the system may use a cookie to deliver the data or information you request.
Preferences: When you set certain configuration settings in our products we may use a cookie to store that setting.
You may use your browser settings to remove or disable cookies, however our products and services will likely not work correctly for you.
Security
We take the security of your Personal Data very seriously and take reasonable and appropriate measures to protect it from loss, misuse and unauthorized access, disclosure, alteration, and destruction. We have put in place appropriate physical, electronic, and managerial procedures to ensure the protection of your Personal Data.
External Links
We are not responsible for any content in external links. Content on third-party websites, and the related Privacy Policies covering those, are the responsibility of their respective owners.
Data Retention
We keep your Personal Data only as long as needed for the purposes for which it was originally collected, or as permitted by law.
For the data retention policies of our providers or their end-clients, please contact the appropriate company.
Safety of Minors
Our products and services are not intended to be used by anyone under 16 years of age. We do not allow them to register and do not knowingly collect Personal Data from them. If it comes to our attention that we have collected Personal Data from a minor, we may delete this information without notice. If you have reason to believe that this has occurred, please contact customer support.
Changes to Our Privacy Policy
From time to time we may update our privacy policy. Please check back periodically to see any changes. If we make a change to this privacy policy that materially affects your protections under the policy, we will notify you.
Our Mobile Apps
Mobile App
The app syncs survey data with your device and the server so that you can work with surveys offline. If you have entered Personal Data into a survey it is stored on your device until the survey has been submitted and the app has synced with the server. Deleting the app will also remove that data from your device.
Note that submitting a survey does not necessarily remove any information or media (e.g. images, video, recordings) captured outside of the app. This data will need to be manually removed by you.
The app stores account email address(es) and passwords that you provide to it on your device to allow you to quickly sync data from our providers. You may delete this data by removing the account from the app or deleting the app entirely. Note that for certain older or special-market Android phones, after deleting the app you may also need to manually delete the file(s) located at: Android/data/{APP_PACKAGE_NAME}files/11cb952d76c3
EU / EEA / Swiss Residents
For users who reside in the European Union, the European Economic Area (Norway, Liechtenstein, or Iceland), or Switzerland, we have additional privacy-related information for you.
EU / EEA residents are covered under the General Data Protection Regulation (GDPR). Swiss residents are covered under the Swiss Federal Data Protection Act (Swiss DPA). These provide certain protections and rights regarding how Personal Data is collected, processed, and how and when it may be transferred outside of those countries.
GDPR Rights and Your Data Controller
If you are an EU/EEA resident you have certain legal rights, listed below. You exercise these rights by contacting your data controller:
Your Data Controller
In most cases your Personal Data is controlled by one of our providers. This is especially true if you are a Provider User, a Submitting User, or an Outside Person. Please contact the provider that collected the information, as they are the data controller.
If you are an End-Client User, it is also possible that your employer is the data controller that collected and supplied your Personal Data to one of our providers. In that case, please contact the appropriate person at your employer.
If you are a General User visiting our website or using our products, we collect only the limited Personal Data mentioned above, and are the data controller for that limited data. If you have questions about this data, please contact us using the contact information below. We will respond to your request to exercise any of these rights within 30 days of receiving it.
If you need any assistance in determining who your data controller is, or how to contact them, please contact us using the contact information below.
As an EU/EEA resident, your specific rights under the GDPR include:
In addition, you have the right to not be subject to decisions based solely on automated processing, including profiling, which produce legal or other significant effects for you.
If a Personal Data breach occurs and is likely to result in a high risk to your rights and freedoms, we will notify you, the Data Controller and the appropriate supervisory authority in a timely fashion.
EU/EEA residents wishing to lodge a complaint with the supervisory authority should do so with the contact information here:
http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080
We do not disclose Personal Data to non-agent third parties. If the need should arise, prior to disclosing Personal Data to a non-agent third party, we will notify you of such disclosure and allow you the choice to opt out of such disclosure. We will ensure that any third party to which Personal Data may be disclosed subscribes to the same principles for managing Personal Data and agrees in writing to provide an adequate level of privacy protection. We may be liable for the inappropriate transfer of Personal Data to third parties. Also note that we may be required to disclose your Personal Data in response to a lawful request by governmental authorities.
In compliance with the law, we commit to promptly resolve complaints about your privacy and our collection or use of your personal information. EU/EEA or Swiss individuals with inquiries or complaints regarding this Privacy Policy should first contact us using the contact information below.
We are also committed to using “last-resort” binding arbitration at your request to address any Privacy Shield complaint that has not been resolved by other recourse and enforcement mechanisms.