Last Updated: April 27, 2023
Please note that other Innovate products or services, including but not limited to the Innovate DIY 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 participating 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.
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.
Your Privacy Rights
Innovate makes efforts to conform 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, IP addresses, and social security numbers. Personal information may also include unique identifiers, 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.
Depending on your location, you may have certain rights under the law of your home jurisdiction with respect to your personal information.
To access, correct, request deletion of your personal information, or to request a copy of your personal information or opt out of the processing of your personal information, please contact us as provided in the “Contact Us” section below. Depending on your location, you may also have the right to appeal any decision we make regarding your personal information by contacting us as provided below.
Individuals in California and Europe have certain special rights as further described in the applicable sections below.
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.
Collection and Use of Personal Information
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, including without limitation your name, company, title, phone number, email address, phone number, mailing address, or other information you provide.
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 verifying your identity, developing new products and services, managing our communications, analyzing our products, and fulfilling incentives.
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.
If you participate in research, we may also collect self-reported demographic, firmographic, and other profile information, such as age, gender, race/ethnicity, education, profession, job title, political affiliation, and consumer preferences and ownership, as well as system metrics inclusive of survey status (e.g., completion of survey, length of time spent in survey). We use this information to make your survey answers more meaningful to us and our clients. We also use this information, along with information derived from cookies, pixels, and other technologies, to determine your interests in particular surveys, advertisements, and other communications.
We also collect certain information automatically when you use our Site, including without limitation Log files, Internet Protocol (IP) address, browser type, ISP, browser language, the date and time of your request, operating system, referring/exiting pages, clickstream data, and plug-in information. We use this information to analyze web traffic and survey usage, to optimize survey platforms for different operating systems and to analyze the authenticity of a respondent; and to communicate insights to our clients.
We also collect other browsing information, such as date and time you visited our Site, number of pages you viewed, time in seconds you spend on each page, and details of any website you visited before and/or after participation in one of our surveys or other research program. We use this information for website optimization for different operating systems; and to optimize user participation.
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.
Selling and Sharing of Personal Information
We will never share your name, email address, mailing address, or phone number without your consent. However, we may share other information described above, such as your IP address, self-reported demographic and firmographic information, and other information provided in your survey or research answers to our clients in order to better communicate research insights to them. Please note that under certain state privacy laws, including CCPA, this may constitute a “sale” of personal information.
In the past 12 months, we’ve “sold” the following categories of information to our clients, and also disclosed the following categories of information to our third-party service providers subject to confidentiality agreements: name, email address, mailing address, and phone number (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.; 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.
Otherwise, 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 information 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 information 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; and (v) upon notice, take reasonable and appropriate steps to stop and remediate unauthorized processing.
Sensitive Personal Information
Please note that some of the personal information described above, such as demographic information about your race or ethnicity, may constitute “sensitive” personal information under applicable laws. We will never use your “sensitive” personal information except for research purposes, or otherwise to verify your identity or prevent fraud. For more information on how to opt out of the processing of your sensitive personal information, please click here.
Notice to California Residents
If you are a California resident, you also have the following special rights, in addition to other rights outlined in this Policy:
Your Right to “Know”, to Request Deletion, and to Correct
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, selling, or sharing 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, subject to certain exceptions. Please note, however, that our deletion of your personal information may negatively affect our ability to provide you with services.
You also have the right to correct any inaccurate personal information that we maintain about you.
To exercise these rights contact us as provided in the “Contact Us” section below. 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 may only apply to the 12-month period preceding the request, depending on how difficult it is for us to retrieve the necessary information, 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
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.
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.
Please note that we will not “share” your personal information for purposes of cross-context behavioral advertising, as that term is defined under CCPA.
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.
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.
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
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.
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 firstname.lastname@example.org. 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 information 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.
European Economic Area (“EEA”)
Information displayed on our Site or sent to us over the Internet may be transferred outside of the EEA to one of our local offices. If you have any concerns in relation to such transfers, you should not use the Internet as a means of communication with Innovate.
The Site and our services may be accessed abroad. All personal data collected by us will be stored and processed in the United States or any other country in which Innovate or its affiliates, contractors or agents maintain facilities. By using the Site or our services, you consent to any such transfer of data outside of your country.
Users in Europe have the right to request access to and rectification or erasure of personal data, to restrict of processing of their personal data, and to object to processing. Users in Europe also have the right to lodge a complaint with a supervisory authority. If you would like to exercise any of your data protection rights, please contact us using the “Contact Us” section below.
We will not process your personal data unless you have given your consent to our processing for a specific purpose, processing is necessary for the performance of a contract with you or to comply with a legal obligation, or processing is necessary for the purposes of the legitimate interests pursued by Innovate or a third-party controller.
In cases where the purpose of our processing is the “legitimate interest” purpose, we will also carefully balance those interests against your fundamental rights and freedoms related to your data. Where processing is based on your consent, we will identify the processing purposes and provide you with relevant information to make the processing fair and transparent.
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.
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.
Innovate commits to resolve complaints about your privacy and our collection or use of your personal information. Individuals with inquiries or complaints regarding this Policy should contact Innovate at:
Innovate MR, LLC
23679 Calabasas Rd #1038
Calabasas CA 91302
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.
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.