Effective Date: January 1, 2020
Last Reviewed on: January 1, 2020
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device ("personal information"). In particular, where provided, we have collected the following categories of personal information from consumers within the last twelve (12) months:
Personal information does not include:
· Publicly available information from government records.
· Deidentified or aggregated consumer information.
· Information excluded from the CCPA's scope, like:
· health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
· personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
Branded obtains the categories of personal information listed above from the following categories of sources:
· Directly from you. For example, from forms you fill out when you register on our site and from surveys in which you participate.
· Indirectly from you. For example, from observing your actions on our Website.
· Third parties such as survey generators, researchers, service providers, data aggregators and app developers
For each category of personal information above, Branded collects the information for the following business or commercial purpose(s):
· Performance of a contract. For example, to match you with the appropriate survey opportunities.
· For our necessary legitimate business interests. For example:
o To assess and generate survey data for use with the Services and our third party customers;
o Develop new features and functionality
o Enhance the survey experience and overall survey delivers through the Services;
o To minimize instances of fraud and other illegal activities;
o To communicate with you about the various Services;
o To furnish, uphold, and improve the Services and our business;
o Provision of administration and IT services, network security, and to prevent fraud
o To grow our business and to inform our marketing strategy; and
o To keep our website updated and relevant.
We may use or disclose the personal information we collect for one or more of the following business purposes:
· To fulfill or meet the reason you provided the information. For example, when you subscribe or opt-in to a third party offer or survey, Branded may share your personal information with the third party in order to facilitate the relationship. If you provide your personal information to us, we will use that information in order to match you with the appropriate survey opportunities, including surveys relevant to your interests, targeted surveys, offers and ads through our Website, third-party sites, and via email (with your consent, where required by law).
· To provide, support, personalize, and develop our Website and services.
· To create, maintain, customize, and secure your account with us.
· To process your requests and transactions to prevent transactional fraud.
· To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
· To personalize your Website experience and to deliver content, offers, and surveys relevant to your interests, including surveys relevant to your interests, targeted surveys, offers and ads through our Website, third-party sites, or via text or email message (with your consent, where required by law).
· To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
· For testing, research, analysis, and service development, including to develop and improve our Website, offerings, and services.
· To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
· As described to you when collecting your personal information or as otherwise set forth in the CCPA.
· To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Branded's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Branded about our users is among the assets transferred.
Branded will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Branded may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
We share your personal information with the following categories of third parties:
· Service providers.
· Data aggregators.
· Survey generators.
· App developers.
In the preceding twelve (12) months, Branded has disclosed the following categories of personal information for a business purpose:
Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category C: Protected classification characteristics under California or federal law.
Category D: Commercial information.
Category E: Biometric information.
Category F: Internet or other similar network activity.
Category G: Geolocation data.
Category I: Professional or employment-related information.
Category K: Inferences drawn from other personal information.
We disclose your personal information for a business purpose to the following categories of third parties:
· Service providers.
· Data aggregators.
· Survey generators.
· App developers.
In the preceding twelve (12) months, Branded has not sold personal information.
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
You have the right to request that Branded disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:
· The categories of personal information we collected about you.
· The categories of sources for the personal information we collected about you.
· Our business or commercial purpose for collecting or selling that personal information.
· The categories of third parties with whom we share that personal information.
· The specific pieces of personal information we collected about you (also called a data portability request).
· If we disclosed your personal information for a business purpose, we will identify the personal information categories that each category of recipient obtained.
You have the right to request that Branded delete any of your personal information that we collected from you and retained, subject to certain exceptions. You have access to your personal information and you may delete your member information and email preferences at any time. You may also email us at email@example.com. Once we receive your request via email and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
· Emailing us at firstname.lastname@example.org.
· Logging on to your password-protected account with us.
· Writing to us at: Attn: Data Protection Officer, 343 4th Ave, Suite 201, San Diego, CA 92101.
Only you, an authorized agent, 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 also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability 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, usually by sending us an email from the account in our records or by submitting a request through your password-protected account. If you submit a written request through the mail, please provide your name, email, phone number, account name, and specify your request. We may need to further verify your written request before we can respond.
· 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.
Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password-protected account sufficiently verified when the request relates to personal information associated with that specific account.
We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, up to 45 additional days, we will inform you of the reason and extension period in writing.
We will deliver our written response electronically via the email address you provided to us.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
· Deny you goods or services.
· Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
· Provide you a different level or quality of goods or services.
· Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to email@example.com or write us at: Attn: Data Protection Officer, 343 4th Ave, Suite 201, San Diego, CA 92101.
Branded reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice's effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.
If you have any questions or comments about this notice, the ways in which Branded collects and uses your information described, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
Branded Research, Inc.
Attn: Data Protection Officer
343 4th Ave, Suite 201
San Diego, CA 92101