Effective Date: June 5, 2019
Privacy Shield Framework
UserZoom Technologies, Inc. (including its parent/subsidiary company(ies), such as User Zoom, Inc., UserZoom Limited, and UserZoom GmbH) participates in and has certified its compliance with the EU-U.S. and Swiss-US Privacy Shield Framework (“Privacy Shield Framework”). We are committed to processing all personal data received from European Union (EU) member countries and Switzerland, in reliance upon the Privacy Shield Framework, in accordance with the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List at https://www.privacyshield.gov/list.
We are responsible for the processing of personal data we receive under the Privacy Shield Framework, and may subsequently transfer such data to a third party acting as an agent on our behalf. We comply with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions thereunder.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, we are subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including meeting national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described on the Privacy Shield website at https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.
Information we collect
When you use our services, we collect information relating to you and your participation in our studies from a variety of sources:
- Usage data. We collect usage data about you whenever you interact with our Survey Tool (defined below). This may include which webpages (i.e., URLs) you visit, what you click on, when you performed those actions, and so on. Additionally, like most websites today, our web servers keep log files that record data each time a device accesses those servers. The log files contain data about the nature of each access, including originating IP addresses.
- Device data. We collect data from the device and application you use to access our Survey Tool, such as your IP address and browser type. In addition to geolocation information collected as described below, we may also infer your geographic location based on your IP address. When you download and use our Survey Tool, we automatically collect information on the type of device you use and operating system version. We use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not, however, link the information we store within the analytics software to any personally identifiable information you submit within the mobile application. As mentioned above, our mobile application may also request access to your device’s camera and microphone sensor in connection with your participation in certain survey(s), which record the survey participants’ voice, face, and/or computer screen.
- Referral data. If you arrive at a UserZoom website from an external source (such as a link on another website or in an email), we record information about the source that referred you to us, as well as whatever information that website chose to encode in the URL.
- Information from page tags. We use third party tracking services that employ cookies and page tags (also known as web beacons) to collect data about visitors to our websites. This data includes usage and user statistics.
- Name and contact details. We collect your name and contact details you may provide when registering, downloading and/or using our survey platform (“Survey Tool”) or you contact us to request support, ask questions, make a request or complaint.
- Geolocation information. If you respond affirmatively when our Survey Tool asks for permission to collect and use geolocation information on mobile devices, we will infer your geographic location based on your IP address. We collect your location-based information for purposes of the applicable study, providing usage data to the Survey Creator, and/or providing you with the services hereunder.
Providing survey responses is voluntary
Remember, you can always choose not to provide an answer to any given study question (especially those requesting your personal information or data). However, sometimes this will prevent you from completing a study if the Survey Creator has marked that question as requiring an answer.
How we use your personal information
UserZoom will use your study responses for the sole purpose of carrying out the research our Clients have commissioned. Your participation in this research, together with your individual responses to the study questions will be kept strictly confidential by us.
We may use your personal information to send you service-related announcements or to respond to any communication you send to us. We may also use the information we collect from you (including usage data, device data, referral data and information from page tags) to manage and improve our services.
To whom we may disclose your personal information
Access to your information will be limited to only those UserZoom staff involved in the applicable study, or who need access in order to directly support our systems, such as our operations and IT staff. This may include staff of:
- Other UserZoom affiliated companies who provide processing services for and on behalf of, and under the control of UserZoom Technologies, Inc.
- Our sub-contractors who carry out data processing; including the service providers who host or provide technical support for our systems.
- The Survey Creator.
The sub-contractors described above are authorized to use your personal information only as necessary to provide the relevant services to us. This may involve transferring your personal information to and/or from countries located outside of the EU (e.g., USA). However we can reassure you that our data hosting service providers take great care to ensure that any such transfers are carried out securely and in compliance with all applicable data protection and data privacy legal requirements. We can also assure you that any other sub-contractors involved are also required to abide by similar data privacy legal requirements and security arrangements.
Privacy for minors 12 years old and under
UserZoom – Child Participant Solution (owned and operated by User Zoom, Inc.) is a Member of the PRIVO-Cert™ Safe Harbor Certification Program (“the Program”). As a participating member in the Program, UserZoom – Child Participant Solution (owned and operated by User Zoom, Inc.) adheres to the strict information collection, use and disclosure requirements set forth by the Program. PRIVO is an independent, third-party organization committed to safeguarding children’s personal information collected online. PRIVO aims to help parents and their children exercise control over personal information while exploring the Internet. The PRIVO certification seal posted on UserZoom’s Website at www.userzoom.com (“Website”) indicates that UserZoom – Child Participant Solution (owned and operated by User Zoom, Inc.) has established COPPA compliant privacy practices and has agreed to submit to PRIVO’s oversight and consumer dispute resolution process. If you have questions or concerns about our privacy practices, please contact us at (866) 599-1550 or firstname.lastname@example.org. If you have further concerns after you have contacted us, you can contact PRIVO directly at email@example.com.
Privacy for minors 13 and older
UserZoom firmly believes in maintaining the security and confidentiality of all visitors to its Web site or taking surveys using the UserZoom Survey Tool, regardless of age. UserZoom’s customers may, from time to time, request that a parent or legal guardian allow one or more of their minors ages 13 – 17 to respond to surveys administered through the Survey Tool, which surveys are specifically designed for minors ages 13 – 17, by providing a URL to the applicable survey. Minors ages 13 – 17 may only respond to such surveys by using the URL provided, with the prior consent of a parent or legal guardian. Surveys specifically designed for minors ages 13 – 17 to respond to, shall relate to products and services that are age appropriate and shall collect general demographic information about the study participant, which for example, may include the following: the minor’s age, gender and zip code (or larger geographic area) where the minor resides. Such surveys shall not collect more information about the minor (ages 13 – 17) than is reasonably necessary for the purpose of the survey, or otherwise for marketing research purposes. The minor’s (ages 13 – 17) survey responses shall be used for the same purposes and shall be subject to the same obligations, restrictions and conditions as any other similarly-situated survey response. By providing a URL to the applicable survey to any minor (ages 13 – 17), the parent or legal guardian (as applicable) has consented to such minor’s participation in and response to surveys through the Survey Tool. In the event a parent has a reason to believe that their minor is participating in a survey administered via the Survey Tool without authorization, has provided false information through a survey, or wishes to exercise any of the parental rights set forth in this section, such parent may contact UserZoom at 10 Almaden Boulevard, Suite 250, San Jose, CA 95113 (866) 599-1550 or by email at firstname.lastname@example.org.
Moderated studies – Specific provisions
In the event that you participate in a moderated study, you are hereby informed that, besides the presence of the moderator of the applicable study (the “Moderator”), there may be other individuals participating in the study as observers (“Observers”) who have been invited by the Moderator. Their presence may be transparent to you. However, at the Moderator’s election, they may also be permitted to interact with you.
You hereby acknowledge that by participating in a moderated study, you are accepting and agreeing to the conditions described above.
Communications you may receive - service-related announcements
We may make strictly service-related announcements available to you on occasion when it is necessary to do so. For instance, if our services are temporarily suspended for maintenance, we might send you an email. Generally, you may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, you have the option of not using our services (i.e., by not participating in studies).
We may use third parties such as an email service provider to send out emails, provide audio and/or recording capabilities, and provide cloud-computing infrastructure (i.e., datacenter services) on our behalf. When you sign up for our services, we will share your personal information only as necessary for such third parties to provide the relevant services.
The third parties we currently rely on (as of the “effective date” set forth above) in our provision of the services, are:
|Provider name||Service description|
|Amazon Web Services||Datacenter service provider|
|Rackspace||Datacenter service provider|
|Zoom||Video conferencing tool used in moderated studies|
|Use of tracking technologies to improve the website user’s experience (Google Analytics)|
Legal disclosures and business transfers
If UserZoom is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or via a prominent notice on our Website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
Access to your personal information and choice
UserZoom acknowledges that you have the right to access your personal information and choose what to do with it. UserZoom has no direct relationship with the individual study participants whose personal data it processes. UserZoom works with its Clients to help them provide notice to their study participants concerning the purpose for which personal information is collected. A study participant who seeks access to, or who seeks to correct, amend, restrict processing, object to or delete inaccurate data should direct his query to the Client (who is the data controller). UserZoom, as a data processor, is not authorized to take further action without the Client’s authorization. If the Client requests that UserZoom update, remove or delete the data, we will respond to their request within 30 days.
Data Protection Officer (DPO)
In compliance with 2016/679 of the European Parliament (General Data Protection Regulation - GDPR), we have appointed a Data Protection Officer (DPO) who is responsible for any privacy and data protection concerns related to UserZoom, and who can be reached at email@example.com.
The security of your personal information is important to us. We follow industry best practices to protect the personal information submitted to us, both during transmission and once we receive it. We also comply with the security requirements of 2016/679 of the European Parliament (General Data Protection Regulation - GDPR), that regulates our processing of personal data. These security measures include:
- Data encryption both at rest and in transit
- Continuous infrastructure monitoring
- Periodic internal vulnerability scans
- Secure backup policy and Disaster Recovery Plan
- Internal risk assessments
- SOC2 certification
No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about how we ensure the security of your personal information, please contact us at firstname.lastname@example.org.
In particular, we use Google Analytics in order to perform the aforementioned. In the event you do not wish to be tracked by the Google Analytics Tool, you can use the following link in order to install a browser extension that prevents this data collection: https://tools.google.com/dlpage/gaoptout/
As is true of most websites, we use a third party tracking-utility partner to gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data.
Links to other websites