Last modified - August 10, 2022

Introduction

Questionlab Inc. (“Company” or ”We”) respects your privacy and is committed to protecting it by complying with this policy.
This policy describes:

• How we collect, use, disclose, and protect the personal information of our customers and website users (“you”).
• Describes the types of information we may collect from you or that you may provide when you visit the website https://questionlab.com/ (our “Website”).
• Our practices for collecting, using, maintaining, protecting, and disclosing that information.

We will only use your personal information in accordance with this policy unless otherwise required by applicable law. We take steps to ensure that the personal information that we collect about you is adequate, relevant, not excessive, and used for limited purposes.

Privacy laws generally define “personal information” as any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person. Personal information does not include business contact information, including your name, title, or business contact information.
This policy applies to information we collect, use, or disclose about you:

• On this Website and any website which our surveys may be hosted.
• In email, text, and other electronic messages between you and this Website.

Please read this policy carefully to understand our policies and practices for collecting, processing, and storing your information. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you indicate that you understand, accept, and consent to the practices described in this policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes indicates that you accept and consent to those changes, so please check the policy periodically for updates. We will notify you in advance of any material changes to this policy and obtain your consent to any new ways that we collect, use, and disclose your personal information.

Information We Collect About You

We collect and use several types of information from and about you, including:

• Personal information, that we can reasonably use to directly or indirectly identify you, relate to you, or could reasonably be linked with you or your household, such as your name, mailing address, e-mail address, records of products purchased, telephone number, gender, fingerprints, date of birth, Internet protocol (IP) address used to connect your computer to the Internet, internet browsing history, geolocation data, username or other similar identifier, inferences from other personal information that could create a profile about your preferences and characteristics, and any other identifier we may use to contact you (“personal information”).
• Non-personal information, that does not directly or indirectly reveal your identity or directly relate to an identifiable individual, such as, demographic information, or statistical or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal information.
• Technical information, including your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, or information about your internet connection, the equipment you use to access our Website, and usage details.
• Non-personal details about your website interactions, including the full Uniform Resource Locators (URLs), clickstream to, through and from our Website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, or any phone number used to call our customer service number.

How We Collect Information About You

We use different methods to collect your information, including through:

• Direct interactions with you when you provide it to us, for example, by filling in surveys, forms or corresponding with us by phone, email, or otherwise.
• Automated technologies or interactions, as you navigate through our Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies, and other tracking technologies.

Information You Provide to Us
The information we collect directly from you on or through our Website may include:

• Information that you provide by filling in forms on our Website. This includes information provided at the time of subscribing to our service or using our Website. We may also ask you for information when you report a problem with our Website.
• Records and copies of your correspondence (including email addresses), if you contact us.
• Copies of your job application, including resume and curriculum vitae.

Information We Collect Through Cookies and Other Automatic Data Collection Technologies
As you navigate through and interact with our Website, we may use cookies or other automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Website, including, location data, logs, and other communication data and the resources that you access and use on the Website.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically is statistical information that includes personal information, and we may maintain it or associate it with personal information we collect in other ways, that you provide to us. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to provide surveys according to your individual interests.
• Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

• To present our Website and its contents to you.
• To notify you if you are entitled to an incentive.
• To match you against the survey you are taking.
• To provide you with information, products, or services that you request from us.
• To fulfill the purposes for which you provided the information or that were described when it was collected, or any other purpose for which you provide it, including for survey data collection.
• To provide you with notices about your account.
• To carry out our obligations and enforce our rights arising from any contracts with you or to comply with legal requirements.
• To notify you about changes to our Website or any products or services we offer or provide though it.
• To improve our Website, products or services, marketing, or customer relationships and experiences.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

Disclosure of Your Information

We may disclose personal information that we collect or you provide as described in this privacy policy:

• In accordance with applicable law, to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Questionlab’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Questionlab about our customers and users is among the assets transferred.
• To contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Website improvement and optimization) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law.
• To enforce or apply our terms of use and other agreements, including for billing and collection purposes, where applicable.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Questionlab, our customers, or others.

Transferring Your Personal Information

We may transfer personal information that we collect or that you provide as described in this policy to contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Website improvement and optimization) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy.

You are welcome to contact us to obtain further information about Company policies regarding service providers outside of Canada. See Contact Information and Challenging Compliance. By submitting your personal information or engaging with the Website, you consent to this transfer, storage, or processing.

Data Security

The security of your personal information is very important to us. We use physical, electronic, and administrative measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. We store all information you provide to us behind firewalls on our secure servers and use data encryption to the extent possible.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Data Retention

Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including to fulfill the services requested, as well as for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.

Children Under the Age of 16

Our Website is not intended for children under 16 years of age. No one under age 16 may provide any information to or on the Website. We do not knowingly collect personal information from children under 16, and we do not knowingly sell any personal information of any minor children under the age of 16. If you are under 16, do not use or provide any information on this Website or on or through any of its features/register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact our Privacy Officer.

Accessing and Correcting Your Personal Information

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes. By law you have the right to request access to and to correct the personal information that we hold about you.

If you want to review, verify, correct, or withdraw consent to the use of your personal information you may also send us an email at privacy@questionlab.com to request access to, correct, or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. We may charge you a fee to access your personal information, however, we will notify you of any fee in advance.

We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

We will provide access to your personal information, subject to exceptions set out in applicable privacy legislation. Examples of such exceptions include:

• Information protected by solicitor-client privilege.
• Information that is part of a formal dispute resolution process.
• Information that is about another individual that would reveal their personal information or confidential commercial information.
• Information that is prohibitively expensive to provide.

If you are concerned about our response or would like to correct the information provided, you may contact our Privacy Officer.

Withdrawing Your Consent

Where you have provided your consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact our Privacy Officer. Please note that if you withdraw your consent we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision.

California State And Eea Privacy Law Compliance

Rights of EEA and California Residents

Under the European Economic Area’s (“EEA”) General Data Protection Regulation (the “GDPR”) and the California Consumer Privacy Act (the “CCPA”), there are certain requests you can make related to personal data which we will respond to as much as we can under applicable laws. See the below for other legal rights you, as the data subject, may have with respect to your personal data:

• The right to be informed. If we are processing your data, we will make clear what we are processing, why, and who else the data may be passed to. Right to know requests include, but are not limited to, requests relating to: (i) the categories of personal information collected; (ii) specific pieces of personal information collected; (iii) the categories of sources from which we have collected personal information; (iv) the purposes for which we use the personal information; (v) the categories of third parties with whom we share the personal information; and (vi) the categories of information that we sell or disclose to third parties. We will provide this information to you for the twelve month period preceding your request.
• The right of access. This is your right to see what data is held about you by a data controller.
• The right to rectification.The right to have your data corrected or amended if what is held is incorrect in some way.
• The right to erasure. Under certain circumstances you can ask for your personal data to be deleted. This is also called ‘the Right to be Forgotten’. This would apply if the personal data is no longer required for the purposes it was collected for, or your consent for the processing of that data has been withdrawn, or the personal data has been unlawfully processed.
• The right to restrict processing. This gives the data subject the right to ask for a temporary halt to processing of personal data, such as in the case where a dispute or legal case has to be concluded, or the data is being corrected.
• The right to data portability. A data subject has the right to ask for any data supplied directly to the data controller by him or her, to be provided in a structured, commonly used, and machine-readable format.
• The right to object.The data subject has the right to object to further processing of their data which is inconsistent with the primary purpose for which it was collected, including profiling, automation, and direct marketing.
• The right not to be discriminated against for exercising rights. The data subject has the right not to be discriminated against for having exercised their rights.
• Rights in relation to automated decision making and profiling. We may use automated decision-making in processing your personal information. Data subjectshave the right not to be subject to a decision based solely on automated processing. You can request a manual review of the accuracy of an automated decision if you are unhappy with it.

Sometimes we will not be able to fulfill your request: if it prevents us from complying with our regulatory obligations or impacts other legal matters, if we cannot verify your identity, or if it requires extraordinary cost or effort, we will tell you in a reasonable time and give you an explanation.

To make a request relating to any of the aforementioned rights, please contact privacy@questionlab.com, or by contacting us at the address in the “Contact Us” section below.

California Privacy Rights

California State consumer privacy laws may provide residents with additional rights regarding our use of their personal information. To learn more about California residents’ privacy rights, visit the CCPA.
If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal data by Questionlab to third parties for the third parties’ direct marketing purposes. To make such a request, please send an email to privacy@questionlab.com,or by contacting us at the address in the “Contact Us” section below.

Personal Information of California Residents We Collect

Subject to certain limitations and exceptions, you have the right to know what personal information is being collected, disclosed, used, or sold by Questionlab. We may collect certain types of personal information from you as described in the “Information We Collect About You” section above in connection with services and marketing that we provide. Specifically, within the last twelve months, we have collected the following categories of personal information from consumers or data subjects:

• Identifiers such as your real name, alias, postal address, online identifier, IP address, and email address.
• Personal information categories listed in the California Customer Records statute (California Civil Code Section 1798.80(e)) including name, signature, address, telephone number, employment, or employment history (some personal information included in this category may overlap with other categories).
• Characteristics of protected classifications under California or federal law, such as age, gender, and disability.
• Commercial information such as records of products or services purchased or considered.
• Internet or other electronic network activity information, such as search history and interaction with our websites, applications, or advertisements.
• Geolocation data, such as the physical location of you or your device.
• Electronic, visual, or other similar information, such as photos, videos, or webcasts from events.
• Professional or employment related information, such as current or past employment status and job role.
• Inferences drawn from the personal information above reflecting your preferences, characteristics, and behavior.

To learn more about the sources from which we collect those categories of personal information and the business purposes for which we collect them, see the “Information We Collect About You” and “How We Use Your Information” sections above. We 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.

Personal Information of California Residents We Disclose and Sell

We may share your personal information with a third party for a business purpose. Specifically, in the past twelve months, we have shared or disclosed each of the categories of personal information set out above.

We may share the personal information set out in the section “Personal Information of California Residents We Collect” with the following third parties for a business purpose:

• Our affiliates;
• Service providers, including for data analytics, marketing, and advertising our services to you;
• Third parties integrated into our services;
• Third parties as required by law;
• Third parties in connection with a merger, sale, or asset transfer; and
• Other third parties to whom you or your agents authorize us to disclose your personal information in connection with services we provide to you.

In the past twelve months, we have shared identifiers, commercial information, internet activity information, and geolocation data to third party companies such as data enrichment services and analytics providers, using advertising technology or cookies which may be considered a “sale” under the CCPA for the purposes of delivering advertising and content targeted to your interests and enhancing your online experience. Except for the foregoing, Questionlab otherwise does not sell any personal information, including any personal information of any minor children under the age of 16.

Do Not Sell My Personal Information (California Civil Code)

The California Civil Code Section 1798.120 requires that we maintain a separate webpage that allows you to opt out of the sales of your personal information. You have the right to opt out of the sale of your personal information and may do so by clicking “Do Not Sell My Personal Information” on the Questionlab website.

Questionlab uses cookies to enhance your user experience and improve the quality of the Website. Some jurisdictions’ privacy laws offer their residents specific privacy rights, which we respect as described in our privacy policy. To exercise rights that you may have related to cookies, including opt-out of sharing information with third parties for advertising purposes, you may disable “advertising cookies” in this interactive web form. Alternatively, you may disable cookies in your browser or opt out by visiting http://optout.aboutads.info/.

Do Not Track (“DNT”) for California Residents

DNT is the concept that has been promoted by regulatory authorities, in particular the U.S. Federal Trade Commission (“FTC”), for the internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.

Currently, various browsers (including Internet Explorer, Firefox, and Safari) offer a DNT option that relies on a technology known as a DNT header that sends a signal to websites visited by the browser user about the user’s DNT preference. You can usually access your browser’s DNT option in your browser’s preferences.

The World Wide Web Consortium (“W3C”) has been working with industry groups, internet browsers, technology companies, and regulators to develop a DNT technology standard. While some progress has been made on this issue, it has been slow, and to date no standard has been adopted. Without an industry standard for DNT, users cannot know how any given company abides by a DNT signal they receive from browser headers. Questionlab is committed to remaining apprised of the W3C efforts to develop a DNT standard.

Questionlab takes privacy and security very seriously and strives to put our data subjects and users first in all aspects of our business. With regard to DNT, Questionlab currently doesn't respond to DNT signals in browsers because no DNT standard has been adopted, as noted above.

Our third party partners may collect information about you and your online activities from time to time. These third parties may not change their tracking practices in response to DNT settings in your web browser, and we do not obligate these parties to honour DNT settings.

Data Retention Under the CCPA

Because the need for data retention can vary for different data types in the context of different services, actual retention periods can vary significantly based on criteria such as user expectations or consent, the sensitivity of the data, the availability of automated controls that enable users to delete data, and our legal or contractual obligations. For example, we may retain your personal data for longer periods, where necessary, subject to applicable law, for security purposes.

Your Consumer Rights Under the CCPA

Subject to certain limitations and exceptions, you have the right to request that Questionlab disclose information to you regarding our collection and use of your personal information at present and in the past twelve months, including the categories and specific pieces of personal information we collected, used, sold or disclosed. You may have the right to request that we delete your personal information that we have collected, subject to certain exceptions. You have the right to opt out of the sale of your personal information and may do so by clicking “Do Not Sell My Personal Information” on the Questionlab website.

Submitting a Request as a California Resident

If you are a California resident and you would like more information or would like to submit a privacy-related request, you may do so by emailing us at privacy@questionlab.com describing the nature of your request, or by contacting us at the address in the “Contact Us” section below.

GDPR Overall Guiding Principles

Questionlab complies with the principles of GDPR. The six overall guiding principles by which all personal data must be processed, as set out in Article 5 of the GDPR, are as follows:

• Lawfulness, fairness, and transparency;
• Purpose limitation;
• Data minimization;
• Accuracy;
• Storage limitation; and
• Integrity and confidentiality.

GDPR Legal Basis for Processing

When we process personal data, we will only do so in the following situations, in accordance with Article 6 of the GDPR:

• We need to use your personal data to perform our responsibilities under our contract with you (e.g., processing payments for and providing our services you have requested).
• We have a legitimate interest in processing your personal data. For example, we process the personal data we collect from you to send you marketing communications, to communicate with you about changes to our services, to enhance the safety and security of our facilities, and to provide, secure, and improve our services.
• If we request your consent to a specific processing activity, and you provide your consent in the manner indicated.
• In some cases, processing will be necessary for compliance with a legal obligation, such as response to legal process requests.

Data Subject Requests for EEA Residents

If you are in the EEA, you have the right to access personal data we hold about you and to ask that your personal data be corrected. In certain cases, you may also have the right to request that we erase data we are processing or to restrict or object to certain of our processing activities. You may also have the right to request that we provide the personal data you have provided us in a portable form for transmission to another controller’s service. If you would like to exercise any of these rights, you may contact us as indicated in the “Contact Us” section below.

Questions or Complaints from EEA Residents

If you are in the EEA and have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the data protection authority where you reside. If you would like to exercise this right, you may contact us at privacy@questionlab.com, or by contacting us at the address in the “Contact Us” section below.

Miscellaneous

Changes To Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the Website home page. If we make material changes to how we treat our users’ personal information, we will notify you by email to the email address specified in your account or through a notice on the Website home page.

We include the date the privacy policy was last revised at the top of the page. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

Contact Information and Challenging Compliance

We welcome your questions, comments, and requests regarding this privacy policy and our privacy practices. Please contact our Privacy Officer at:
Ashwani Marwah
privacy@questionlab.com
(647) 281-0173
We have procedures in place to receive and respond to complaints or inquiries about our handling of personal information, our compliance with this policy, and with applicable privacy laws. To discuss our compliance with this policy please contact our Privacy Officer using the contact information listed above, or by contacting us at the address in the “Contact Us” section below.

Verification of Your Request

Once you submit a request using one of the methods above, we will verify your personal identity based on the information we receive from you. Typically, we may ask business contacts for full name, email address, physical address or phone number. If you are contacting us from an email address not on file, we may ask for at least one other data point we already hold. Depending on data we have on file or other circumstances, we may ask for more or different information. You can also designate an authorized agent to exercise these rights on your behalf, who may do so through the methods described in Contact Information and Challenging Compliance above, but we will require proof that the person is authorized to act on your behalf and may also still ask you to verify your identity with us directly. You may also make a privacy request on behalf of your minor child.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or that you have the authority to request the personal information. We will use personal information provided in a request only to verify the requestor’s identity or authority to make the request.