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Strategic Eye and its affiliate (Kids-in-sight) are committed to safeguarding your privacy. We will never share personal information or use it for any reason other than which it was intended. No matter where in the world we engage with you or conduct market research, we strictly adhere to the privacy laws and marketing research codes of conduct for that country. We will not transfer personal information to a country or territory outside the United States or the European Economic Area or United Kingdom (including Gibraltar) unless that territory or county ensures an adequate level of protection for the rights and freedoms of data subjects. The following sets forth our privacy policy for the treatment of Personal Information: Strategic Eye and its affiliate have implemented appropriate technical and organizational measures to meet all applicable laws, regulations and regulatory guidance in relation to the processing or protection of personal information relating to a resident of the European Union and the United Kingdom (and Gibraltar) or otherwise subject to protection under the laws of the European Union and its Member States, as amended from time to time, including, but not limited to, Regulation (EU) 2016/679 of 27 April 2016, General Data Protection Regulation (GDPR) and Data Privacy Framework (DPF) Principles, Executive Order 14086, 28 CFR part 201, and accompanying letters and materials, including the commitments by the U.S. Department of Commerce’s International Trade Administration (ITA) regarding the administration and supervision of the DPF program, the UK Government recognized the adequacy of protection provided by the UK Extension to the EU-U.S.. Personal Information that is Collected When we conduct a study in which you would participate, you would be required to submit some Personal Information and basic contact information. When we interview you about the subject matter, we will retain all information pertaining to that discussion. International Transfer of Personal Information When you submit Personal Information, it is transferred to our base of operations in the United States, and you hereby consent to such transfer which is protected in accordance with GDPR law and US Data Privacy Framework. Your Personal Information may also be stored and processed in any country where we have facilities or in which we engage service providers. Your data will be subject to the data transfer rules of that country and this privacy policy will still apply. How Personal Information is Stored Your information is stored in a central management database in the United States. This leading database provider and its software has been Data Privacy Framework certified. Our project management team will use the information, and is in turn, governed by system security and strict data protection protocols. We may disclose your Personal Information to any member of our group only for project support purposes. Strategic Eye uses robust organizational, technical, and administrative measures to protect personal information within our company. This includes security controls to prevent unauthorized access to our systems. While we take reasonable steps to secure your personal information, please be aware that no transmission or security system is guaranteed to be 100% secure from intrusion or hacking, and there is always some risk assumed by sharing Personal Information. If you have reason to believe that your interaction with us is no longer secure, please notify us immediately at privacy@strategiceye.com. How Personal Information is Used Strategic Eye uses information you provide to communicate with you and help facilitate the research we undertake. We will never share or sell that information for commercial purposes. We will only use that information for the specific reason for which it was provided to us. Individuals Rights to Access Their Personal Data Strategic Eye provides individuals access to their personal information for the sole purpose to be able to correct, amend, or delete that information where it is inaccurate, or has been processed in violation of the Principles, except where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question, or where the rights of persons other than the individual would be violated. Choices and Means Offered to Individuals for Limiting the Use and Disclosure of Personal Data Strategic Eye offers individuals the opportunity to choose (opt out) whether their personal information is (i) to be disclosed to a third party or (ii) to be used for a purpose that is materially different from the purpose(s) for which it was originally collected or subsequently authorized by the individuals. Individuals are provided with clear, conspicuous, and readily available mechanisms to exercise choice. Information Processors We may provide your Personal Information to companies that provide services to help us with our business activities, such as research recruitment. These companies are authorized to use your Personal Information only as necessary to provide these services to us. Changes in Ownership If our company or our assets are acquired by another company, that company would receive all information collected by Strategic Eye companies. In such an event, a prominent notice would appear on our website of any changes of ownership. Compelled Disclosure We reserve the right to disclose your Personal Information if required by law or if we believe use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud or comply with a law, court order or legal process. Market Research Privacy Policy Strategic Eye and its affiliate (Kids-in-sight) are committed to the protection and safeguarding of personal data collected from persons who are (a) consumers, (b) patients relating to health information and (c) business individuals or entities relating to business information. Privacy is an especially important issue for marketing research and opinion research since we are in contact with consumers, patients and business persons on a daily basis. In this regard, we often obtain confidential information from such persons (“Personally Identifiable Information or PII”). In order to protect the company and our Respondents, and comply with legal requirements such as the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), the Child Online Privacy and Protection Act (“COPPA”) and other relevant statutes and regulations, it is important to us that we are aware of and comply with our Privacy Policy and Principles when handling PII. Privacy & Data Protection In order to fulfill our Mission Statement to Protect Consumer, Health Information and Business Information Privacy, Strategic Eye and its affiliate adheres to the following policies: 1. All PII obtained shall be lawfully collected, compiled, stored, allowed access to, processed and utilized by Strategic Eye. 2. Participation in all research projects is voluntary and respondents may opt out of any research project, at any time. In addition, consent will be obtained prior to the collection of PII that will be recorded. 3. All PII obtained shall be treated confidentially, shall be used for research purposes only and shall not be disclosed to any person not employed/contracted by Strategic Eye, except with consent, as required by law or by court order. 4. All PII obtained shall not be disclosed to any client other than for lawful research purposes. In this regard, in general, clients will not receive (a) the last name or contact information of any recruited Respondent for any research study; (b) any original screeners or sign-out sheets containing any last names or contact information. Further, clients are bound by the Strategic Eye Privacy Policy and any such information shared with clients will be used for marketing research and opinion research purposes only. 5. Strategic Eye adheres to the policy laws of all countries in which we conduct research. 6. Strategic Eye will not transfer personal data to a country or territory outside the U.S. or the European Economic Area or the United Kingdom (and Gibraltar) unless that territory or country ensures an adequate level of protection for the rights and freedoms of data subjects. 7. Strategic Eye adheres to research industry Codes and Standards relating to the USA, and additionally, any country in which we conduct research. Data Privacy Framework (DPF) Compliance Strategic Eye Inc and its affiliate (Kids-in-sight) comply with EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF as set forth by the U.S. Department of Commerce. Strategic Eye and its affiliate have certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov website. Strategic Eye is responsible for the processing of personal data it receives, under the Data Privacy Framework, and subsequently transfers to a third party acting as an agent on its behalf. Strategic Eye complies with the DPF Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions. Any employee found to have violated this policy may be subject to disciplinary action, up to and including termination of employment. Strategic Eye is subject to the investigatory and enforcement power of the Federal Trade Commission or any other U.S. authorized statutory body. We are required to disclose personal information in response to lawful requests by public authorities, including meeting national security or law enforcement requirements. Independent Dispute Resolution Mechanism In compliance with the Data Privacy Framework, Strategic Eye commits to resolve complaints about our collection or use of your personal information. Individuals in the European Union and United Kingdom (including Gibraltar) with inquiries or complaints regarding our DPF policy should first contact Strategic Eye, refer to our Contact Information section below. Within the scope of this privacy notice, if a privacy complaint or dispute cannot be resolved through Strategic Eye, Inc.’s internal processes, Strategic Eye, Inc. has agreed to participate in the Data Privacy Framework (DPF) Dispute Resolution Program. Subject to the terms of the VeraSafe Data Privacy Framework Dispute Resolution Procedure, VeraSafe will provide appropriate recourse free of charge to you. To file a complaint with VeraSafe under the DPF Dispute Resolution Procedure, please submit the required information to VeraSafe here: https://www.verasafe.com/public-resources/dispute-resolution/submit-dispute. In the event complaints to Strategic Eye and the VeraSafe Procedure do not result in a satisfactory resolution, a consumer may seek binding arbitration. Additionally, if the consumer has a national security concern, you can contact the Ombudsperson at the Department of State at http://www.state.gov/s/ombudsman/. Contact Information If you have questions about this Privacy Statement, please email Strategic Eye Privacy Administrator at privacy@strategiceye.com, or send a letter to: Privacy Administrator Please refer to our Data Privacy Framework profile on the DPF Website for specific details regarding our direct contact details at Strategic Eye USA’s Privacy Shield profile. |