Privacy Policy

PRIVACY POLICY (updated January 1, 2020)

Who We Are and Why We Collect Your Information

Consumer Insights, Inc. (“CI,” “Sonar Strategies” “we,” “us,” “our”) conducts market research on behalf of clients using software applications, smartphones, websites, surveys, computers, tablets, and other means of collecting data (collectively, “Research Tools”). Ultimately, this research allows our clients to deliver better products and services to consumers.

Sonar Strategies is committed to protecting the confidentiality, integrity, and security of your personal information. We take this responsibility seriously. This Privacy Policy is intended to help you understand how we collect and safeguard your information. Additionally, prior to interacting with certain Research Tools, we may present you with a participation agreement, confidentiality agreement, instructions, and/or a privacy policy or information specific to the relevant research project (collectively, “Project-Specific Documentation”), which may contain further terms governing how we treat your information, as discussed more thoroughly in Section I below. By accepting the terms of this Privacy Policy, you hereby consent to our collection, use, and sharing of your information in the following ways:

I. What Does This Privacy Policy Cover?

This Privacy Policy covers our treatment of (1) personally identifiable information, as defined by numerous statutes in the United States, including the California Online Privacy Protection Act (such statutes, the “PII Laws”), and (2) personal information, as defined by the California Consumer Privacy Act (the “CCPA”, and collectively the “Privacy Laws”) (collectively, “Personal Information”), which we gather when you are accessing, viewing, completing, or using any of our Research Tools. This policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage.

Although this Privacy Policy is intended to govern our treatment of Personal Information generally, our Research Tools vary depending on the needs of our clients, and some Research Tools have Project-Specific Documentation that provides additional terms and conditions governing our treatment of your Personal Information. When that is the case, we will provide Project-Specific Documentation to you prior to collecting Personal Information via a Research Tool. In the event of a conflict between the terms of Project-Specific Documentation and the terms of this Privacy Policy, the terms in the Project-Specific Documentation will govern.

II. What Information Does Sonar Strategies Collect?

Sonar Strategies does not collect Personal Information indiscriminately. We limit the type of Personal Information and the amount of Personal Information to what is necessary to fulfill the purposes identified in this Privacy Policy and the Project-Specific Documentation. With that in mind, we collect the following types of information:

A. Information You Provide to Us:

We may collect Personal Information from you when (i) you contact us with questions or concerns, and (ii) you visit, interact with, or answer questions from any of our Research Tools. The information we collect depends on the parameters of the research we are conducting. Examples of Personal Information we may collect include the following: your name and contact information; demographic information like gender, age, and household income; home, work, school, and other locations; your buying habits; your opinions and preferences; additional demographic data (which may include race and/or ethnicity); or a user name or e-mail address that would permit access to a Sonar Strategies survey you may establish as part of your participation in any survey or other Research Tool. You can choose not to provide us with certain information, although that may disqualify you from using or participating in a survey or other Research Tool.

B. Information Collected Automatically:

When you use a Research Tool, certain information is passively collected (that is, gathered without your actively providing the information) using various technologies and means, such as Internet Protocol (IP) addresses, cookies, and Global Positioning System (GPS) location data. These are described in more detail below:

  • IP Addresses. Sonar Strategies Research Tools use IP addresses. An IP address is a number assigned to your computer by your internet service provider to access the internet. In most consumer cases an IP address is dynamic (changing each time you connect to the internet), and not static (unique to a particular user's computer).
  • Cookies are small text files that are placed on your computer by websites that you visit. They are widely used to make websites work, or work more efficiently, and to provide information to the owners of the site. Most web browsers allow some control of cookies through browser settings. We collect the following information via cookies: aggregate statistical information, information related to your use of this site (including your password, the links you click on, your movement around the site, the pages you visit, the number of times you open a page, and which information is consulted), your IP address, and your browser type. You may be able to change the preferences on your browser or mobile device to send “do not track” signals or to prevent or limit your computer or device’s acceptance of cookies, but this may change the functionality of this website or prevent you from participating in some Research Tools. If you click on a link to a third party website, such third party may also transmit cookies to you. This Privacy Policy does not cover the use of cookies by any third parties.
  • GPS Location Data. Sonar Strategies uses smartphone Research Tools to obtain GPS location data passively while a person is part of a survey. These data indicate a user’s location, depending on the monitoring identified in the Project-Specific Documentation.

C. E-mail and Other Communications:

We may contact you, by email or other means; for example, we may send you survey participation offers on behalf of Sonar Strategies or other businesses, or communicate with you about the Research Tools. When we do this, we may receive a confirmation when you open an email from us. This confirmation helps us make emails more interesting and improve our service. If you do not want to receive email or other mail from us, please indicate your preference by clicking on the unsubscribe link in any of our emails.

D. Special Categories of Personal Information:

Except as stated otherwise in this Privacy Policy and Project-Specific Documentation, we do not knowingly collect special categories of Personal Information, including (1) Personal Information revealing racial or ethnic origin, political opinion, religious or philosophical beliefs, or trade union membership, and (2) genetic data, biometric data, data concerning health, and data concerning a natural person’s sex life or sexual orientation. Where Project-Specific Documentation states that we collect and use such information, the Project-Specific Documentation will explain the collection of such Personal Information and request your informed consent.

E. Personal Information Sonar Strategies Has Collected in the Last 12 Months

Sonar Strategies has collected the following categories of Personal Information in the 12 months immediately preceding the Effective Date of this Privacy Policy, listed at the top of this document: names; contact information; demographic information; locations where users of Research Tools are; buying habits; opinions and preferences; user names and e-mail addresses needed to access Sonar Strategies surveys; IP addresses; information related to the use of third party websites and the Research Tools; users’ browser types; and confirmation when users have read Sonar Strategies emails.

III. What Does Sonar Strategies Do With Personal Information?

A. Use of Information

Sonar Strategies collects your information to answer questions related to the research we are conducting. These questions and your responses allow us to qualify you for a survey, tailor survey questions to you, and ensure that our survey participants are a representative sample of the population we are researching. We will also use your Personal Information to provide market research and analysis to our clients (as described in Section IV.A below), which will allow our clients to improve the goods and services they provide, including, but not limited to, consumer goods. In certain circumstances, before collecting Personal Information through a survey or software application, we may provide you in Project-Specific Documentation with the name of the client or the category of client, as well as a more detailed description of the purpose for which Sonar Strategies and the client will use your Personal Information. We store Personal Information on our own servers.

We may:

  • Share certain Personal Information with third parties (as described in this Section and in Section IV below);
  • Share with third parties statistics describing aggregate relationships from Personal Information as part of our research; and
  • Retain Personal Information for research purposes, which may include the development of proprietary or open source algorithms, applications, programs, or tools that analyze nonpersonal and Personal Information, assist with market research, or perform consumer modeling, among other functions.

We use your IP address to diagnose problems with our server, report aggregate information, determine the fastest route for your computer to use in connecting to our site, and administer and improve the site. We may use information collected by cookies to retrieve certain information you have previously provided, to help to customize our survey based on your preferences, to tell our website server information such as your IP address and your browser type, to improve navigation on our surveys, to indicate how many times a page is opened and what information is consulted, to improve the content of our surveys, to administer our surveys, and to manage users’ movements around our surveys. We may also use that information for system management and market research purposes.

We may convert Personal Information to nonpersonal information and store and use the nonpersonal information. For example, we may permanently delete the connection between a person’s identifying information and location information and retain the location information and knowledge it pertains to a single (unidentifiable) individual. We may also disclose the nonpersonal information to third parties.

B. Storage of Information

Unless noted otherwise in this Privacy Policy or in Project-Specific Documentation, we store and process all electronic Personal Information that we collect from you on electronic information systems in the United States. Hard copies of personal information remain in the United States.

IV. Will Sonar Strategies Share Any of the Personal Information it Collects?

We share your Personal Information with third parties as described below.

A. Clients that Have Retained Sonar Strategies to Perform Research

We disclose Personal Information, nonpersonal information that has been derived from Personal Information, and aggregate information to our client(s), unless such disclosures are specifically precluded by the Project-Specific Documentation. Our clients include, but are not limited to, manufacturers of consumer goods and providers of consumer services. At times, we may provide you with more information in Project-Specific Documentation about one or more specific clients, the categories of one or more clients, and/or one or more clients’ industry or sector. Our clients are typically based in the United States.

B. Third Party Businesses We Do Not Control

In certain situations, we will share Personal Information with third party businesses that may contact you by email or phone to assist Sonar Strategies to complete surveys and other Research Tools on behalf of our clients. Sonar Strategies may disclose contact information, including your name, phone number, email address, and physical address, to such third party businesses to facilitate your completion of the Research Tools. Depending on the Research Tool, Sonar Strategies may also share your contact information with third party businesses that we partner with to send rewards to individuals who complete certain surveys. The third party businesses described in this section are typically based in the United States.

C. Business Transfers

We may choose to buy or sell assets. In these types of transactions, customer information is typically one of the business assets that is transferred. Also, if we (or substantially all of our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information would be one of the assets transferred to or acquired by a third party.

D. Legal Obligations, Our Protection, and the Protection of Others

We reserve the right to access, read, preserve, and disclose any information that we reasonably believe is necessary to comply with law or court order; enforce or apply our conditions of use and other agreements; or protect the rights, property, or safety of Sonar Strategies, our employees, our users, or others. This includes exchanging information with other companies and organizations for fraud protection.

E. With Your Consent

Except as set forth above, we will obtain your consent before disclosing your Personal Information with third parties, and you will be able to prevent the sharing of this information.

F. Personal Information Sonar Strategies Has Disclosed to Clients in the Last 12 Months

Sonar Strategies has disclosed the following categories of Personal Information to our clients in the 12 months immediately preceding the Effective Date of this Privacy Policy, listed at the top of this document: contact information; demographic information; locations where users of Research Tools are located; buying habits; opinions and preferences; and further Personal Information Sonar Strategies infers based on Personal Information and nonpersonal Sonar Strategies obtains.

G. Personal Information Sonar Strategies Has Disclosed to Third Parties in the Last 12 Months

Sonar Strategies has disclosed the following categories of Personal Information to third parties for business purposes in the 12 months immediately preceding the Effective Date of this Privacy Policy, listed at the top of this document: : contact information; demographic information; locations where users of Research Tools are located; buying habits; opinions and preferences; and further Personal Information Sonar Strategies infers based on Personal Information and nonpersonal Sonar Strategies obtains.

V. Sonar Strategies’s Legal Basis for Collecting and Using Your Personal Information

Sonar Strategies collects and uses your Personal Information pursuant to your informed consent, which you have granted by (a) confirming the prompts produced by each Research Tool, and (b) continuing to use each Research Tool, consistent with this Privacy Policy and any Project-Specific Documentation. Please note that without your consent to collect and use the Personal Information required in any particular survey or other Research Tool, Sonar Strategies may disqualify you from using or participating in a survey or other Research Tool. If you have any questions concerning the terms of this Privacy Policy and the conditions of your consent, please contact us at info@consumerinsights.com

To the extent that you provide Sonar Strategies with the Personal Information of other people, you warrant and represent that each such person who is required under the Privacy Laws to give consent, or the person who is required to give consent, if the Privacy Laws require the consent of another person, has granted his or her consent to you sharing his or her Personal Information with Sonar Strategies for the use described in this Privacy Policy and any Project-Specific Documentation.

VI. How Long Will Sonar Strategies Retain Your Personal Information?

Except upon the request of an individual, as explained in Section VII below, and except as the law permits and requires, Sonar Strategies maintains Personal Information as follows:

a. When our contract with a client requires that we delete all information that we have collected and processed at the end of a project or after a defined period of time, we will do so.
b. Other than that, we will determine the retention period based on the following criteria:

    1. The nature of our relationship with the relevant client;
    2. The existence of other ongoing or expected projects with the relevant client;
    3. The nature of the Personal Information in question; and
    4. Our internal research needs.

VII. What Are Your Rights to Control Your Personal Information?

Except where permitted or required by law (including, but not limited to, compliance with a legal obligation, to further a public interest, and establishing and/or exercising a legal claim or defense), you have the following rights regarding Sonar Strategies’s collection and use of your Personal Information.

A. Requests to Sonar Strategies:

You may request (1) the deletion or restriction of collection, use, sale, and/or transmission of your Personal Information, (2) the categories of Personal Information Sonar Strategies has collected, and (3) the specific pieces of Personal Information Sonar Strategies has collected about you. We will respond to all such requests within 45 days, although there may be a brief delay in processing a request while we verify that the request is valid and originates from you as opposed to an unauthorized third party. If you request that your Personal Information be deleted or that Sonar Strategies otherwise limit its use of your Personal Information, we reserve the right to terminate and/or limit your access to our Research Tools, and any financial incentives we have provided, subject to the terms of Section VII.G below. If we do not have your Personal Information, have not collected your Personal Information, or have not disclosed or transferred your Personal Information to another party, we will inform you in response to a request regarding your Personal Information.

To exercise the access and deletion rights described here, please submit a verifiable consumer request to us by either:

·         Calling us at 1-800-333-0533

·         Emailing us at info@consumerinsights.com

Only you may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. For residents of California, only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information.

You may only make a verifiable consumer request twice within a 12-month period. The verifiable consumer request must:

·         Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

·         Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

When you update information, we may maintain a copy of the unrevised information in our records. Please note that some information may remain in our private records after your deletion of such information from your account. We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally.

B. Withdrawal of Consent

You may withdraw your consent at any time by either

·         Calling us at 1-800-333-0533

·         Emailing us at info@consumerinsights.com

Please be aware that such withdrawal does not affect the lawfulness of Sonar Strategies’s use of your Personal Information before such withdrawal. Withdrawal of consent may affect your ability to participate in surveys and other Research Tools.

C. Non-Discrimination

Sonar Strategies will not discriminate against you because you have exercised any of the rights above or any other rights you retain pursuant to Privacy Laws.

Consistent with Privacy Laws, Sonar Strategies: (i) retains the right to provide a different level or quality of survey services to you, if that difference is reasonably related to the value provided to Sonar Strategies by your Personal Information; (ii) may offer financial incentives, including payments to you as compensation, for the collection or disclosure of your Personal Information; (iii) may enter you into a financial incentive program only if Sonar Strategies clearly describes the material terms of the financial incentive program, so long as you give Sonar Strategies prior opt-in consent, which you may revoke at any time; and (iv) shall not use financial incentive practices that are unjust, unreasonable, coercive, or usurious in nature.

VIII. Is Personal Information About Me Secure?

We use appropriate technical, administrative, and physical safeguards to protect against loss, unauthorized access, destruction, misuse, modification, and improper disclosure of the personal information we collect, in both physical and electronic format. To that end, we use encryption and cloud services that comply with various globally recognized security practices and standards to protect the personal information submitted to us, both during transmission and once we receive it. We take reasonable and appropriate steps to contract for and monitor the services we use to determine that they remain compliant with such practices and standards. We also provide information security awareness training to our staff and conduct periodic quality assurance audits. We endeavor to protect the privacy of your Personal Information that we hold in our records, but we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of information at any time.

Our Research Tools may contain links to other sites. We are not responsible for the privacy policies and/or practices on other sites. When following a link to another site you should read that site’s privacy policy.

IX. Children’s Privacy

Except as stated otherwise in Project-Specific Documentation, we do not knowingly collect or solicit personal information from anyone under the age of 16 or knowingly allow such persons to participate in Research Tools. If you are under 16, please do not attempt to register for Research Tools or send any information about yourself to us, including your name, telephone number, or email address. No one under age 16 may provide any Personal Information to us or through the Research Tools. In the event that we learn that we have collected Personal Information from a child under age 16 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from a child under age 16, please contact us by either:

·         Calling us at 1-800-333-0533

·         Emailing us at info@consumerinsights.com

X. Failure to Provide Personal Information

You can always opt not to disclose information to us, but keep in mind some information may be needed to participate in some surveys or other Research Tools.

 XI. Transfer of Data

When we transfer personal information from a country of origin to the United States, we do so in compliance with all laws of the originating country.

 XII. Changes to this Privacy Policy

We may amend this Privacy Policy from time to time. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used. If we make changes in the way we use Personal Information, we will notify you by posting an announcement on our website or sending you an email. You are bound by any changes to the Privacy Policy when you use this website or any Research Tool after such changes have been first posted.