Privacy Policy

Last Updated: February 11, 2020

This privacy policy (“Policy”) is posted by Innovate MR, LLC (“we,” “us,” or “Innovate”), and governs uses of Innovate’s main website, located at innovatemr.com and including all individual pages or links under that domain (the “Site”). This Policy also governs our collection and use of personal information via the Site or other communications or survey research under the Innovate or “Survey Surfing” brand names. We’ve developed this Policy to describe (1) how we collect, use, transfer, and store information of individuals (“you” or “your”); (2) your choices regarding your personal information; and (3) how we ensure your privacy.

Please note that other Innovate products or services, including but not limited to Innovate’s Insights platform and the PointClub website, may be governed by separate privacy policies. This Policy only applies to the Site, and to the data that we collect through the Site or other Innovate- or Survey Surfing-branded communications or surveys. It does not apply to any data that we collect via other websites where this Policy is not posted.

We make the Site, including this Policy, accessible to individuals with disabilities. If you are having trouble accessing the Site or this Policy, please contact us as provided below.

By using the Site or participate in Innovate-branded– or Survey Surfing-branded research, you consent to the terms of this Policy, and this Policy forms a binding agreement between you and Innovate. If you do not agree with the terms of this Policy, do not use the Site or participate in such research. Continued use of the Site or participation in such research constitutes your freely given, specific, and informed consent and agreement to the terms herein.

Notice to Survey Respondents

You acknowledge and agree that your participation in a survey or other market research program is completely voluntary, and that Innovate’s use of your personal information is carried out with your consent. Innovate may collect personal information directly from you when you voluntarily provide it to Innovate, or Innovate may obtain personal information from unrelated parties we collaborate with, including third-party panels who have obtained your consent.

You may also provide personal information to Innovate via the Survey Surfing website, which respondents may access directly, or via invitations or advertisements on third-party websites. Information provided via Survey Surfing will be used by Innovate to direct respondents to third-party surveys, and may in some cases be used to recruit members for PointClub, Innovate’s proprietary panel.

We also collect personal information from you when you use Innovate’s Channel Watcher feature (“Channel Watcher”), which may be presented to you on the PointClub website or on third-party websites. In those cases, we collect your IP address and information about your interaction with those videos to share with our clients.

Innovate also serves as a platform for panelists who originate from third-party panels with the purpose of sharing consumer opinions and data with Innovate’s clients. You acknowledge and agree that in such cases your direct relationship is with the third-party panel, which determines the purposes and means for processing your personal information. In such cases, Innovate will only process your personal information at the request of the third-party panel.

Any surveys and other market research programs administered by Innovate clients, partners or other third parties and the data collected in connection with those surveys and other market research programs are not subject to this Policy. You are strongly encouraged to review and understand the privacy policies of such third parties.

By participating in any of our surveys or other market research programs or any of our websites following any notice of a change to this Policy, you freely and specifically give us your consent to collect, use, transfer and disclose your personal information in the manner specified in the then-current Privacy Policy.

Your Personal Information

Innovate conforms its privacy and security practices to applicable laws, codes, and regulations, including, without limitation, the General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act (“CCPA”).

As used in this Policy, “personal data” and “personal information” mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked with a particular data subject, consumer, or household. Personal information includes information such as real names, postal addresses, email addresses, and social security numbers.

Under CCPA’s broad definition, “personal information” may also include unique identifiers, IP addresses, biometric information, internet or other network activity (such as browsing history,search history, etc.), geolocation data, audio/visual data, and even inferences which may be drawn from any of the above to create a profile about a consumer.

Innovate may collect personal information when you voluntarily provide it, or when we receive it from third parties who have secured your consent to share it. Your participation in a survey or other research is voluntary. Surveys and other research administered by Innovate’s clients, partners or other third parties and the information collected therein are not subject to this Policy; provided, however, that if Innovate collects personal information in connection with a third party’s survey or research, such personal information collection is subject to this Policy.

We use your information to operate, evaluate, and improve our business, including for such purposes as developing new products and services, managing our communications, and analyzing our products. If you provide us with your name and contact information, we will use this information to answer requests from you, communicate with you regarding any services we are providing to you, inform you about new products and services (unless and until you opt-out of marketing information), and deliver email updates, newsletters, or other communications to which you’ve subscribed. We may also use information derived from cookies, pixels, and other technologies to determine your interests in particular surveys, advertisements, and other communications.

Any e-mail communications to you regarding new products and services, or any email updates, newsletters, or other communications to which you’ve subscribed, will contain a link with instructions for how to opt out of future communications of that type.

In the previous 12 months, we’ve collected, used, and shared personal information as described below:

Info CollectedSources of InfoBusiness PurposesShared With
Names, email addresses, phone numbersProvided directly via the Site, or direct communications with InnovateIncentive fulfillment, communicating with you; newsletters; advertising new offerings; to communicate insights to our clientsThird-party service providers, Innovate Clients (with your consent)
Log files, including Internet Protocol (IP) address, browser type, ISP, browser language, the date and time of your request, operating system, referring/exiting pages, clickstream data, plug-in etc.Collected directly from online usersAnalyzing web traffic and survey usage, optimizing survey platforms for different operating systems and analyzing authenticity of respondent; to communicate insights to our clients; to support and optimize Channel Watcher videosThird-party service providers, Innovate Clients
Browsing information, such as date and time you visited our website, number of pages you viewed, time in seconds you spend on each page, and details of the any website you visited before and/or after participation in one of our surveys or other research programCollected from internet cookies attached to users while visiting website.Site optimization for different operating systems. User optimization for survey participation and future research; to support and optimize Channel Watcher videosThird-party service providers, Innovate Clients
Self-reported demographics (i.e. age, gender, education, etc.)Provided directly via the Site, or direct communications with InnovateCommunicating with you for new offerings and opportunities; to communicate insights to our clientsThird- party service providers, Innovate Clients
Self-reported firmographics (i.e. employment-related information such as title and profession etc.)Provided directly via the Site, or direct communications with InnovateCommunicating with you for new offerings and opportunities; to communicate insights to our clientsThird- party service providers, Innovate Clients
Self-reported profile information (i.e. political affiliation, technology usage, consumer preferences and ownership etc.)Provided directly via the Site, or direct communications with InnovateCommunicating with you for new offerings and opportunities; to communicate insights to our clientsThird- party service providers, Innovate Clients
System Metrics inclusive of survey status (completed survey, terminated etc.) Length of time spent in a survey.Collected via internet survey redirectionAnalyzing survey usage and tracking successful completion of a survey; to communicate insights to our clientsThird-party service providers, Innovate Clients

Notice to California Residents

CCPA defines the term “sell” broadly. Its meaning includes “renting, releasing, disclosing, disseminating, making available, [and] transferring…for monetary or other valuable consideration.”

Under this definition, and the CCPA’s broad definition of “personal information,” we may “sell personal information” about you to our vendors or other partners, such as your contact information or certain combinations of anonymized or pseudonymized demographic and other information.

Categories of information we’ve “sold” in the previous 12 months include:

Categories
Name, email address, mailing address, phone number
Log files, including Internet Protocol (IP) address, browser type, ISP, browser language, the date and time of your request, operating system, referring/exiting pages, clickstream data, plug-in etc.
Browsing information, such as date and time you visited our website, number of pages you viewed, time in seconds you spend on each page, and details of the any website you visited before and/or after participation in one of our surveys or other research program
Self-reported demographics (i.e. age, gender, education, etc.)
Self-reported firmographics (i.e. employment-related information such as title and profession etc.)
Self-reported profile information (i.e. political affiliation, technology usage, consumer preferences and ownership etc.)
System Metrics inclusive of survey status (completed survey, terminated etc.) Length of time spent in a survey.

Categories of information we’ve otherwise disclosed for a business or commercial purpose (for example, for confidential use by our service providers) in the previous 12 months include:

Categories
Name, email address, mailing address, phone number
Log files, including Internet Protocol (IP) address, browser type, ISP, browser language, the date and time of your request, operating system, referring/exiting pages, clickstream data, plug-in etc.
Browsing information, such as date and time you visited our website, number of pages you viewed, time in seconds you spend on each page, and details of the any website you visited before and/or after participation in one of our surveys or other research program
Self-reported demographics (i.e. age, gender, education, etc.)
Self-reported firmographics (i.e. employment-related information such as title and profession etc.)
Self-reported profile information (i.e. political affiliation, technology usage, consumer preferences and ownership etc.)
System Metrics inclusive of survey status (completed survey, terminated etc.) Length of time spent in a survey.

If you are a California resident, you also have the following special rights:

Your Right to “Know” and to Request Deletion

You have the right to know the categories and specific pieces of personal information we have collected about you. You have the right to know the categories of sources from which the personal information has been collected, the business or commercial purpose for collecting or selling personal information, and the categories of third parties with whom we share personal information.

You have the right to request deletion of personal information we’ve collected or maintain.

To exercise these rights contact us at (+1) 888-229-6664 or by filling out the following webform. We may ask you to provide additional information, such as first and last name and email in order to verify who is making the request.

Please note that any requested disclosures will only apply to the 12-month period preceding the request, and you are entitled to request disclosure regarding your personal information twice in any 12-month period.

Your Right to Opt Out of the “Sale” of Your Information

You have the right to opt out of the sale of your personal information. For more information on how to opt out, please click here.

Your Right to Non-Discrimination

You have the right not to receive discriminatory treatment by Innovate for the exercise of the privacy rights conferred by the CCPA, including but not limited to by denying you services, charging different prices or rates, or providing you with a different level or quality of services. Please understand, however, that certain exercises of your rights may render it impossible for us to render services to you.

Your Right to Use an Authorized Agent

You have the right to designate an authorized agent to make a request under the CCPA on your behalf. To designate an authorized agent, please contact us as provided below. In order to verify you have authorized an agent we will require a signed, written authorization from you.

Verification Process

If you make a request to access or delete your information, or to opt out of the sale of your personal information, we may ask you for additional information to verify your identity. This information may include: your full name, birth date, phone number, email address, or other basic personal information about you that we already have on file.

Combination

We may combine information that your device transmits, information that you actively submit, and information that we obtain from third party sources, including suppliers of market research sample and data marketing platforms that may direct you to our Site, as well as web publishers, advertisers, and online service providers that may have obtained information from you or your devices via cookies, pixels, and other tracking technologies.

Information Tracking Technologies

We may use or allow third parties to use web beacons on our Site to monitor the effectiveness of survey qualification. Web beacons are small, graphic images on web pages, web-based documents, or in email messages that allow us or third parties to monitor who is visiting our Site or if an email has been read. Web beacons collect the IP address of the device where the web beacon is sent, the URL of the page where the web beacon originates, and the time it was viewed. Web beacons may be linked to your personal information. We may also use third-party devices, services, links, or electronic mail to deliver surveys to you, which may use cookies, web beacons, or other technology to collect information about your visits to our Site (or other sites) in order to present surveys that may be of interest to you.

We may use a pixel or cookie to examine what is happening on third-party websites, including programs and sites with marketing and advertising partners, to improve the understanding of site traffic and market research effectiveness. Respondents or participants in survey or survey panels that are hosted on, accessed by, or routed through the Site should consult the privacy and other policies of third parties through whom they are providing information.

You can opt out of receiving interest-based ads and tracking from third parties who are members of the Network Advertising Initiative (“NAI”) or who follow the Digital Advertising Alliance’s (“DAA”) Self-Regulatory Principles for Online Behavioral Advertising by visiting the opt-out pages on the NAI website and DAA website.

Do Not Track

Some browsers have a “do not track” feature that lets you tell websites you do not want to have your online activities tracked. Because these features are not yet uniform, we do not presently respond to “do not track” signals. We will treat any “do not sell” or similar signals as opt-out requests under CCPA.

Use of Cookies

For more information on our use of cookies, read Innovate’s Cookie Policy, which is incorporated herein by this reference.

Other Communications from Innovate

In addition to contacting individuals who have given us their information, Innovate may also contact individuals who have visited the Site or may otherwise have interest in our products and services. All such communications from Innovate will include a link allowing you to opt out of future communications. You may also opt out by following the instructions in the “Contacting Innovate” section below.

Information Retention and Accuracy

We make efforts to ensure that personal information we receive, process, or maintain is accurate, complete, and reliable. We rely on the accuracy of the information provided directly to us but accept responsibility for the management and confidentiality of the personal information collected. In general, we keep personal information only as long as we need it to provide you the services you requested. We may also process data on behalf of third parties who have engaged us. We keep personal information processed on behalf of third parties for as long as needed to provide services to third party in question. However, we reserve the right to retain personal information for any period required by law or to comply with our legal obligations, resolve disputes, and enforce our agreements.

Protection of Personal Information

Innovate uses reasonable security measures in an effort to prevent loss, misuse, and alteration of information under our control. However, we cannot guarantee the security of information on or transmitted via the Internet. We rely on various security procedures and systems to ensure the secure storage and transmission of data, including encryption and authentication technology licensed from third parties, to effect secure transmission of confidential information. Additionally, we have absolutely no control over the security of other sites you might visit, interact with, or do business with.

If we learn of a security systems breach, we may attempt to notify you electronically so that you can take appropriate protective steps, by posting a notice on the Site if a security and/or sending an email to you at the email address you have previously provided to us. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive a free written notice of a security breach, or to withdraw your consent from receiving electronic notice, you should notify us.

Choice Regarding Collection, Use & Distribution

You can choose whether your personal information is (i) disclosed to a third party or (ii) used for a purpose that is materially different from the purpose(s) for which it was originally collected or subsequently authorized by the individuals. If you choose to opt out, please contact us via email at privacy@innovatemr.com. In such an event, you will be only able to access public areas of the Site and may be limited in the use of the Site. In certain cases, limiting the use and disclosure of your personal data may impact functionality or prevent the use of Innovate products or services.

Third Party Websites and Content

This Policy applies solely to the Site and to Innovate’s surveys and research, and not to any other product, service, content, surveys or research of third parties.

You may be directed to the websites, video, and other content of third parties via Channel Watcher. As with third-party surveys, any data collected by such third parties (e.g., third party websites serving content on Channel Watcher) is subject to the privacy policies of such third parties.

The Site may also contain other links to external websites, and areas where you can provide information to third parties. These are provided for your convenience only, and we do not have control over the content or privacy and security practices and policies of such third parties or third-party sites. Any personal information you provide in such areas, and on such linked pages, is provided directly to that third party and is subject to that third party’s privacy policy. Please learn about the privacy and security practices and policies of external websites and third-parties before providing them with personal information.

Contacting Innovate

Innovate will address all questions, complaints or requests concerning this Policy within 45 days of receipt. Please see the applicable details below:

EU & Swiss Citizens

Innovate complies with the EU-U.S. and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce, under the enforcement authority of the Federal Trade Commission, regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. Innovate has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit www.privacyshield.gov.

Innovate commits to resolve complaints about your privacy and our collection or use of your personal information in compliance with the EU-U.S. and Swiss-U.S. Privacy Shield Principles. European Union and Swiss individuals with inquiries or complaints regarding this Privacy Policy should first contact Innovate at:

Innovate MR, LLC
Attn: Platform Privacy Policy Support
23975 Park Sorrento, Unit 210
Calabasas CA 91302
Email: privacy@innovatemr.com.

Innovate has further committed to refer unresolved privacy complaints under the EU-U.S. and Swiss-U.S. Privacy Shield Principles to the INSIGHTS ASSOCIATION PRIVACY SHIELD PROGRAM, a non-profit alternative dispute resolution provider located in the United States and operated by the Insights Association. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.insightsassociation.org/get-support/privacy-shield-program/privacy-shield-eu-swiss-citizens-file-complaint for more information and to file a complaint. These dispute resolution services are provided at no cost to you. Under certain limited conditions, individuals may invoke binding arbitration before the Privacy Shield Panel.

Class Action Waiver

Any arbitration or court trial, whether before a judge or jury or pursuant to judicial reference, related to any claim under this Policy will take place on an individual basis, without resort to any form of class or representative action (“Class Action Waiver”). THIS CLASS ACTION WAIVER PRECLUDES ANY PARTY FROM PARTICIPATING IN OR BEING REPRESENTED IN ANY CLASS OR REPRESENTATIVE ACTION REGARDING A CLAIM UNDER THIS POLICY. Regardless of anything else herein, the validity and effect of the Class Action Waiver may be determined only by a court and not by an arbitrator.

Sharing with Third Parties, Onward Transfer

We may share information about you with third parties as follows: (i) with your consent; (ii) with service providers who help deliver our services and run our business, subject to confidentiality agreements; (iii) as required by law, or in response to lawful requests by public authorities, including to meet national security or law enforcement requirements; (iv) to protect you, our business, or third parties from harm, including but not limited to fraud and data security breaches; (v) in a reorganization or sale of our company or assets, subject to the acquirer accepting the commitments made in this Policy and in compliance with applicable law.

If we share your personal data with third party service providers and/or sub-processors, we will: (i) transfer such data only for limited and specified purposes; (ii) require the sub-processor to provide at least the same level of privacy protection as is required by this Policy; (iii) take reasonable and appropriate steps to ensure that the sub-processor effectively processes the personal data transferred in a manner consistent with the organization’s obligations under this Policy; (iv) require the sub-processor to notify us if it determines it can no longer meet its obligation to provide the same level of protection as is required by this Policy; (v) upon notice, take reasonable and appropriate steps to stop and remediate unauthorized processing; and (vi) provide a summary or a copy of the relevant privacy provisions of its contract with that sub-processor to the Department of Commerce upon request.

Innovate shall remain liable under the Privacy Shield Principle of Accountability for Onward Transfer if its sub-processors process your personal information in a manner inconsistent with the Privacy Shield Principles, unless we prove we are not responsible for the event giving rise to the damage.

If you are visiting this website from a country other than the country in which our servers are located, your communications with us will result in the transfer of information across international boundaries. By visiting this website and communicating electronically with us, you consent to such cross-border transfers. In the case of data transfers from the EEA and Switzerland, the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks apply.

Access and Correction

You may access your information by contacting us at the address below. You have the right to correct, amend, or delete that information where it is inaccurate, or has been processed in violation of the Privacy Shield 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.

We maintain processes or mechanisms to allow you to review, update, correct or delete personal information held by us. You may make changes to your account information, access, correct, or delete personal information held by Innovate by contacting us at:

Innovate MR, LLC
Attn: Platform Privacy Policy Support
23975 Park Sorrento, Unit 210
Calabasas CA 91302
Email: privacy@innovatemr.com.

To protect your privacy and security, Innovate may also take reasonable steps to verify your identity before making corrections to or deleting your information. We will respond to your request for access to modify or delete your information within a reasonable timeframe.

Non-EU/Non-Swiss Citizens, Non-California Residents

Innovate commits to resolve complaints about your privacy and our collection or use of your personal information. Non-EU/Non-Swiss citizens and U.S. citizens not in California with inquiries or complaints regarding this Policy should contact Innovate at:

Innovate MR, LLC
Attn: Platform Privacy Policy Support
23975 Park Sorrento, Unit 210
Calabasas CA 91302
Email: privacy@innovatemr.com.

Dispute Resolution

All disputes arising under this Policy shall be governed by and interpreted in accordance with the laws of California, without regard to principles of conflict of laws. The parties to this Policy will submit all disputes arising under this agreement to arbitration in Los Angeles, California, before a single arbitrator of the American Arbitration Association (“AAA”). The arbitrator shall be selected by application of the rules of the AAA, or by mutual agreement of the parties, except that such arbitrator shall be an attorney admitted to practice law California. No party to this Policy will challenge the jurisdiction or venue provisions as provided in this section. No party to this Policy will challenge the jurisdiction or venue provisions as provided in this section. Nothing contained herein shall prevent the party from obtaining an injunction.

Changes to this Privacy Policy

We reserve the right to modify this Policy at any time. If we decide to change our Policy, we will prominently post those changes here and any other place we deem appropriate, so you are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If we make any material changes, we will notify you either by way of an email or by a notice on this Site. We will use information in accordance with the Policy as it was in effect at the time information was collected.