Privacy Policy

Commitment

Toluna UK Ltd of Power House, Harrison Close, Knowlhill, Milton Keynes, MK5 8PA ("Toluna", "we", "us," "our") takes your privacy seriously and has developed this Privacy Policy to explain what data we collect from our users ("you", "your"), account holders and panelists and how we use and share this information.

Toluna is an online data collection company focused on providing high quality data to the full-service marketing research industry, advertising agencies and consultancies. We build and maintain large online consumer panels. You can be assured your privacy and the confidentiality of your information is our number one priority. All of the data that Toluna collects in our research studies report is aggregate information, that is, information about groups - not individuals. Individual information is never reviewed or published without your consent, as it is irrelevant to the research conducted by our clients. All individual information provided is held confidential in accordance with the terms of this Privacy Policy.

The information we gather

Toluna gathers personal information when an individual registers to become a member of our panels. Your participation in any of our panels and surveys is voluntary. After registration we ask panel members to provide us with more personal information so that we may invite them to appropriate surveys. To become a Macmillan Minds member, we ask that you fill out a registration survey that gathers some personal and general consumer information. We ask for your email address so that we can send you email invitations to participate in our upcoming surveys and subject to the preferences you expressed when registering, to send you newsletters to make you aware of new features or contests running on the site. The other information we gather, such as your name, address, gender, and birthday is for matching you with the appropriate marketing research projects. Your birthday is used to automatically update your age for us to target age-related marketing groups. We ask you for this information as a means to see if you might qualify for particular projects. All email contact from Macmillan Minds will be sent to your primary email address that you gave to us upon registration. If you become a Macmillan Minds member, your information (name, address, city, state, and zip or postcode) is also used for the purposes of incentive fulfillment. When incentive points are deposited in your account and you wish to redeem them or you are determined as the winner of a physical gift card in a sweepstakes, this information is required so that we may send your reward to the appropriate recipient address. From time to time, a third party may be used for issuing cheques or processing the delivery of rewards.

In some circumstances, Toluna may ask you to inform us of your sensitive personal data. If we do so, we will ask for your explicit consent. In general sensitive data that may be collected by Toluna includes: your racial or ethnic origin; your political opinions; your physical or mental health or condition; and your sexual life. This information is not shared with any third party, except as required by law and as part of a transfer of Toluna's business.

You should be aware that any personal information you choose to make public on the site, in the Community area (as an opinion or topic in a message board or live chat or any other public area or forum) can be read, collected, or used by other users and could be used to send you unsolicited messages. We are not responsible for the personal information you choose to submit or make public in this way. In addition, we are not responsible for the content you publicly post on the site that can be found via web-based search engines. To request removal of your personal information from our blog or community forum, contact us at minds@macmillan.org.uk   . In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

We display personal testimonials of satisfied customers on our site in addition to other endorsements. With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at minds@macmillan.org.uk .

  Use of this information

Toluna does not sell or share the personal information collected on this site. . Information which is personally identifiable will only be transferred with your prior permission on a case by case basis, except for the narrow exceptions specified below. If you are a member of the Macmillan Mindspanel, your information is stored in our proprietary database so we may call upon it to determine which people match up with specific research studies. If we think your profile makes you a potential candidate for a study, we will email you an invitation to make you aware of this opportunity. From time to time Toluna may use third-party software for email list management and email distribution, or may use third party list management providers to match the members of our panel to members of other lists or panels, or to validate accuracy of personal information you provide. We may use third parties to provide us with data they have collected about you, and append this data to your demographic profile. In such cases only a minimum amount of information is transferred to these third parties so as to enable them to perform specific functions on our behalf. [the foregoing sentence is unclear as to who these third parties might be, how they might be in a position to legally share with you personal data they hold about your panel member and what functions they will be performing on your behalf. Please note also that under the UK Data Protection Act 1998 ("DPA") if you are sharing personal data about any of your panel members with third parties so that they can perform services for you, this arrangement must be governed by a written contract covering prescribed aspects such as data security. Let us know if you require more assistance with this.] We also may share your information with our service providers, [again any such arrangements with service providers by which personal data is shared with them should be governed by a written agreement conforming to the DPA's requirements in that regard] such as to provide prizes you have won or other incentives for your participation in our panels.

Your information may be transferred to other countries in the European Economic Area [for what purposes and in what circumstances?]. All such transfers shall solely be made in accordance with applicable law.

Sharing

Your information are processed by Toluna UK Ltd acting as a data processor on behalf of Macmillan and on its instructions only. In such context, your information may be transferred to the USA, on servers belonging to Toluna USA for hosting purposes. Toluna USA complies with the Safe Harbor Privacy Principles. In addition, contractual warranties have been implemented on the basis of the Standard Contractual Clauses of the European Commission between Macmillan and Toluna USA in order to secure such transfer.

Though we make every effort to preserve your privacy, we may need to disclose your personal information when we have a good-faith belief that such action is necessary to comply with a judicial proceeding or a court order or if we believe it is necessary in order to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of the Toluna site terms, or as otherwise required by law. Toluna may also disclose your personal information to third parties where it has your express permission to do so, or where it can reasonably be inferred from the circumstances that you consent to the disclosure to the third parties [what might these circumstances be? It may be necessary to give an example in this policy to further aid the user's understanding].

 

The Use of Digital Finger Printing on Our Site


Digital Finger Printing:

In general, Digital Fingerprinting technologies assign a unique identifier or "Machine-ID" to a user's computer to identify and track the computer. Toluna will not use Digital Fingerprinting technology (the "technology") to collect personal information, or track the online activities, of the user of a computer; and will not disrupt or interfere with the use or control of a computer or alter, modify or change the settings or functionality of a computer. Toluna will use the technology to assist Toluna's clients in ensuring the integrity of survey results. The technology will analyse publicly available information and data obtained from the computer's web browser and from other publicly available data points, including without limitation the technical settings of the computer, the characteristics of the computer, and the computer's IP Address, to create a unique identifier assigned to the computer. The unique identifier will be an alpha-numeric ID. After creating the unique identifier, Toluna does not retain the information ID used by the Technology to create the unique identifier.

Toluna (a) may link or associate your unique identifier to you and any of your Personal Information, (b) may share your unique identifier with Toluna's clients and with other sample or panel providers; and (c) may receive or obtain a unique identifier linked to you from a third party, including without limitation a sample or panel provider or a client of Toluna. Any unique identifier(s) received or obtained by Toluna and linked to a specific individual will be protected in accordance with this privacy policy. These steps are taken in furtherance of Toluna's efforts to assist its clients in protecting and ensuring the integrity of survey results, as they allow the identification of fraudulent and duplicate respondents.

Toluna shall use commercially reasonable efforts to ensure that the technology is safe, secure and does not cause undue privacy or data security risks.

Toluna shall use and distribute the technology in a professional and ethical manner and in accordance with (a) Toluna's privacy policy, (b) any statements and/or disclosures made by Toluna to respondents, and (c) applicable Laws and Codes.

In the event that Toluna discovers or learns of any unethical conduct in connection with the use of the technology, or that the technology is being used in a manner that is inconsistent with the statements and/or disclosures made by Toluna to respondents or in violation of applicable Laws and Codes, Toluna will take immediate action to prohibit such unethical conduct and to ensure the proper administration of the technology.

 

Access to Your Information; Member Services Area/Update, Correct, Delete Information

In accordance with the provisions of the Data Protection Act 1998, you have the right to gain access to your data and correct it. In order to access this data you may either write to the address below or Contact Us at minds@macmillan.org.uk .

We provide you with a Members Area on our site; here you may correct or update your membership information or delete your membership. If you are a panel member and delete your membership, your profile information will be permanently removed, but may be stored in our disaster recovery databases, and in such circumstances will not be used for commercial purposes. Please note that in most cases, it will take two or three business days for your information to be completely removed from our records; but please allow up to fifteen days.

Opt-Out Policy

By becoming a Macmillan Minds panel member, you agree to receive Emails inviting you to participate in surveys that we feel may match your experiences and background. From time to time, subject to any preferences you express at or after signing up to be a panel member we will also email newsletters to you to make you aware of new features or contests running on our site. You may update your registration information at any time. Please see Correct/Update Policy below.

Correct/Update policy

If you need to correct any of your profile information or if you would like to update any of your information, you may automatically do so by clicking on Your Profile after logging in. By following the appropriate directions, your information should be automatically updated in our database.

Delete/Deactivate policy

If you choose to end your membership with Macmillan Minds or to require us to cease processing your personal data, you may automatically discontinue your membership by clicking Unsubscribe in the footer of our Homepage or by contacting us at minds@macmillan.org.uk . By following the appropriate directions, your record will be marked as "unsubscribed", and you will no longer receive communications from Macmillan Minds. In addition, you will forfeit any incentive balance that has not been requested as of the time you opt out. In most cases it will take 2 to 3 days to process this change, but please allow up to two full weeks for your status to be finalised. In the meantime, you may receive emails from us. Email links are provided on the site so that you may contact us directly with any questions or concerns you may have. Each email we receive is read and responded to individually; please allow two to three business days for us to get back to you.

We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Winners policy and privacy guarantee

Macmillan Minds members are randomly selected to win prizes for participation in surveys, polls, and other promotions. All winners are notified by email of their winnings. For more information, please visit our Terms and Conditions page. Toluna shall post the usernames or full name and county of winners on the Reward Page or communicate them via newsletter to all panelists.

Notification of changes

If we decide to change our privacy policy, we will post those changes to this privacy statement, the home page, and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.
We reserve the right to modify this privacy statement at any time, so please review it frequently. If we make material changes to this policy, we will notify you here, by Email, or by means of a notice on our home page prior to the change becoming effective.

Security

Toluna takes strict measures to ensure every aspect of your information is kept secure. Access to all personal information is restricted and limited to few key personnel. Our website security is reviewed periodically and can only be accessed via a strict password policy. Toluna will never ask you for private information such as your credit card or social security numbers as a part of our research. We use SSL encryption when collecting or transmitting sensitive information. Your profile information is highly confidential and will be used only by Toluna to Email you concerning our studies, newsletters, winner notifications, and incentive redemptions, or as otherwise provided for in this privacy policy.


Social Media Widgets

Macmillan Minds Web site may include Social Media Features, such as the Facebook Like button (and Widgets, such as the Share this button or interactive mini-programs that run on our site). These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing them.

Single Sign-On

You may be able to log in to our site using sign-in services such as Facebook Connect or an Open ID provider. These services will authenticate your identity and provide you the option to share certain personally identifiable information with us such as your name and email address to pre-populate our sign up form. Services like Facebook Connect give you the option to post information about your activities on this Web site to your profile page to share with others within your network.


Legal disclaimer

We may disclose personal information when required by law or in the good-faith belief that such action is necessary to conform to the edicts of the law or to comply with a legal process served on our website.

Children's privacy

Toluna will not knowingly collect any information from any child without permission from his/her parents or legal guardian.

Privacy contact:
Privacy Officer
Toluna UK Ltd.

Ealing Cross, 85 Uxbridge Road, W5 5TH
E-Mail: minds@macmillan.org.uk