Effective Date: April 27, 2021
Last Revised: April 27, 2021
This notice supplements the information contained in the main m360 Research Privacy Policy and applies solely to residents of the State of California ("California Privacy Policy"). We have adopted our California Privacy Policy in order to comply with the California Consumer Privacy Act of 2018 ("CCPA")1.
Our California Privacy Policy is intended to fulfill CCPA's objectives of providing California consumers with a comprehensive disclosure of the collection, sharing, disclosure, and sale of their personal information by particular businesses (as CCPA defines those terms), and of the rights that California consumers have regarding their personal information ("California Privacy Rights").
I. California Privacy Rights Under CCPA
Right to Know About Personal Information Collected, Disclosed or Sold ("Right to Know")
Scope of Applicable Personal Information
CCPA provides you the right to request that we disclose to you any or all of the following about your personal information for the 12-month period preceding your request:
CCPA also provides you the right to receive information about any financial incentives (i.e., compensation payments) that we may offer in connection with use of your personal information for participating in certain of our Activities (as that term is defined in "About M360 Research" in our Main Privacy Policy ).
For detailed information about the personal information that we collect and the purposes for which we collect it, please see Part II ("Information We Collect and What We May Do With It") below.
If you exercise your Right To Know, after we confirm your identity, as explained more fully in Part III ("Exercising Your California Privacy Rights"), we will: (a) disclose to you the information we have collected about you during the preceding 12 months that corresponds to your request; and (b) deliver, free of charge to you, by mail, or electronically, the personal information that you have requested, in the manner required by CCPA and as further described below in Part III ("Exercising Your California Privacy Rights").
Exclusions from Scope of Personal Information
CCPA excludes the following from its definition of "personal information":
Right to Have Personal Information Deleted ("Right to Delete")
You have the right to request the deletion of your personal information that we collect or maintain.
If you exercise your Right to Delete, after we confirm your identity, as explained more fully below in Part III ("Exercising Your California Privacy Rights"), we will, in the manner specified by CCPA, permanently delete your personal information from our records, unless one of the CCPA exceptions applies to your deletion request applies.
Also, to the extent required by CCPA, we will direct deletion of your personal information by third parties with whom we have shared the personal information that you have requested that we delete.
Exceptions to your Right To Delete include, but are not limited to, instances when the personal information is necessary to complete a transaction or provide the service requested by you for which the subject personal information was collected or provided (such as to participate in our market research Activities), detect security incidents or protect against deceptive, fraudulent, or illegal activity, or to comply with a legal obligation under CCPA, the California Electronic Communications Privacy Act, or other California or US federal law.
Right to Opt-Out of the Sale of Personal Information ("Right to Opt-Out")
Under CCPA, you have the right to opt-out of the "sale" (as defined by CCPA) by a CCPA-subject business of your personal information to third parties. CCPA defines a "sale" of personal information as occurring when a business exchanges personal information of California residents to a third party for monetary or other valuable consideration.
M360 Research does not "sell" your personal information, in either the CCPA sense, nor any other sense.
When you consent to participate in one of our market research Activities, we may share your personal information with our clients and carefully selected service providers solely for business purposes and as otherwise required by law.
Except as set forth herein, all data that we share will be deidentified information (meaning, data that has been carefully encrypted so it no longer identifies you or is linkable to you) or aggregate information (which means data from a group of individuals from which all individual identities have been carefully removed so no particular person may be identified). Neither deidentified information nor aggregate consumer information are considered personal information as defined in CCPA.
To the extent we collect personal information of minor children under the age of 18, we similarly limit the disclosure of their personal information to business purposes, or use deidentified or aggregate information about them. We do not sell the personal information of minor children.
Personal information will never be shared in any way, or for any purpose, other than for what has been specifically consented for us to do with it.
Right to Not Be Discriminated Against for Exercising Your California Privacy Rights ("Right to Non-Discrimination")
You have the right to not receive discriminatory treatment if and when you exercise any of your California Privacy Rights under CCPA. This would include, as examples, imposing a penalty fee or denying services to you because you exercised a CCPA right.
We will never penalize or otherwise subject you to discriminatory treatment for exercising any of your California Privacy Rights.
Please note that exercising your right to delete some or all of your personal information may mean that you are not able to participate in certain market research opportunities that we offer.
For example, if we do not have enough information to determine whether you meet the criteria for a study, you will not receive invitations to participate. In addition, certain studies may require that certain aspects of your personal information be shared with the client (such as a focus group opportunity, where your name, contact information, medical background, and practice location are needed in order to convene a desired focus group).
Financial incentives, such as per-survey compensation payments, are made for certain of our market research Activities. Market research compensation payment amounts are set at levels determined by taking into account many variables such as (by way of examples only) the complexity of the subject matter of the research inquiry, the professional education, training, and experience level desired for the respondents, the number of respondents needed, and the number of qualified respondents available.
If you have questions about your Right to Non-Discrimination, please contact us as described in Part III ("Exercising Your California Privacy Rights") below.
II. Information We Collect and What We May Do With It
M360 Research, our subsidiaries, and our affiliates, as well as our third-party business partners with whom we conduct our regular business operations, may collect, share, or disclose personal information solely for business purposes as described in the following sections:
Business Support Consultants (examples include our consultants, advisors, and/or vendors who help us by (as examples only): (a) preventing fraud or violations of our Terms of Service; (b) analyzing site user data and behavior, and tracking page performance; (c) identifying site issues and repair errors that impair intended functionality; (d) providing marketing and survey panel recruitment assistance, such as moderators and translators; (e) providing customer service to our Site users; (f) providing CCPA-required and other verifications of consumers or consumer consent; and/or (g) providing data storage and/or data processing services.
All of our Business Support Consultants have written agreements with us which:
Personal Information We Have Collected Over the Past Twelve Months:
CATEGORY OF PERSONAL INFORMATION | EXAMPLES | COLLECTED IN PAST 12 MONTHS |
---|---|---|
A. Identifiers | Real name, postal address, e-mail address, unique personal or online identifiers, account names, telephone numbers, social security or tax ID numbers, internet protocol address, driver's license number, passport numbers, or similar | YES |
B. Categories of Personal Information from California's Customer Records statute | Information that identifies, is associated with, or capable of being associated with a particular individual, such as signature, physical description, education, employment, employment history, but excluding that from available from public federal, state, or local government records | YES |
C. Protected Classifications Under US or California Law | National origin, age (consumers over 40), race, color, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, gender or sex (and related identifiers/characteristics), sexual orientation, veteran or military status, or genetic information | YES |
D. Commercial Information | Personal property records, products or services purchased, obtained or considered, purchasing or consuming histories or tendencies | YES |
E. Biometric Information | Genetic physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data | NO |
F. Internet or Other Electronic Network Activity Information | Browsing history, search history, and information about interaction with a websites, applications, or advertisements | YES |
G. Geolocation Data | General physical location, precise GPS location or movements | YES |
H. Sensory Information | Audio, electronic, visual, thermal, olfactory or similar information | YES |
I. Professional or Employment-Related Information | Employers, job history, and performance evaluations | YES |
J. Non-Public Information from US Family Educational Rights and Privacy Act (20 U.S.C. ยง 1232) | Grades, transcripts, class lists, student schedules, student ID numbers, student financial information, or student disciplinary records and other education records directly related to a student | NO |
K. Inferences Drawn From Other Personal Information | Profile reflecting preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes | YES |
Categories of Sources From Which Personal Information Has Been Collected During Past 12 Months
Directly from you (such as from forms or profiles that you create on our website or from our Activities) or indirectly from you (as collected automatically through our website)
Personal Information Categories Collected: A, B, C, D,F,G, H, I
Business Support Consultants
Personal Information Categories Collected: A, B, C, D, F, G, H, I, K
Business Partners
Personal Information Categories Collected: A, B, C, D, F, H, I
Public Authorities or Public Records
Personal Information Categories Collected: A, C, D, I
Personal Information Disclosed for a Business Purpose During Past 12 Months
We have disclosed personal information for one or more of these business purposes:
Sales of Personal Information During Past 12 Months
M360 Research does not ever "sell" personal information, as described in more detail above in Part I.C ("Right to Opt-Out of the Sale of Personal Information").
III. Exercising Your California Privacy Rights
Exercising Rights to Opt-Out of Sale of Personal Information: As M360 Research does not "sell" any personal information, as that term is defined in CCPA, we have not provided consumers with a means to "opt-out" of such sales. However, we will be glad to answer any questions you may have about this or any of your California Privacy Rights. Please use one of the contact methods described below to reach us for any questions.
In order to exercise your Right to Know, Right to Delete, or Right To Non-Discrimination, please submit your request to us in any one of the ways listed below.
By E-mail: info@m-panels.com (please put "California Privacy Request" in the subject line)
By Mail or Courier:
m360 Research Data Protection Officer
c/o m360 Research Systems,
41/1, Lavelle Road,
Bangalore - 560 001, Karnataka, India
Only you, or a person (or a business entity registered with the California Secretary of State) whom you have authorized to act on your behalf may make a consumer request about your personal information. Consistent with CCPA's provisions, we may require either (or both) that you provide your authorized agent with written permission to act for you and verify your own identity to us (or provide a power of attorney signed by you stating your authorized agent's power to act for you) 2 .
If you have questions or concerns about your rights under our California Privacy Policy, or any of the provisions or practices described in either our California Privacy Policy or our Main Privacy Policy, please contact us via the telephone number, e-mail address, or mail/courier address provided above.
IV. Responding to Right to Know and Right to Delete Requests
Within ten (10) business days of receipt of your Right to Know or Right to Delete request, we will confirm our receipt, provide you details about the process we will follow to respond to your request, and/or ask questions, or for additional information, that may be required.
We plan to fulfill these requests within 45 calendar days of receiving the request. If we need more time to respond to your request, we will let you know the reason and, within the first 45 calendar days following receipt of your request, estimate how much additional time we will need (in any event, we will complete your request within 90 calendar days in total from receipt of the request).
If we deny your Right to Know or Right to Delete request, in whole or in part, we will provide you with the reason for this, and if our denial is partial, we will disclose to you, or delete (as applicable), the other information you have requested.
We do not charge a fee to process or respond to your Right to Know requests, unless a particular request is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Procedure; Frequency of Submitting Right to Delete Requests: You may make a Right to Delete request to us at any time. Following verification of your request, we will immediately and permanently delete the personal information requested by you, unless one of CCPA's exception to this right applies to your request.
If we cannot verify the identity of the consumer requesting deletion of personal information, we may deny the Right to Delete request, and will inform the requestor of this.
Once we verify the identity of the consumer making the Right to Delete request, we will respond to their request by either:
We will inform you of the manner in which we have deleted your personal information following a Right to Delete request.
V. Updates to this Supplementary Privacy Notice
We may reserve the right to periodically update our California Privacy Policy. Please reference the "LAST UPDATED" legend above for the effective date of the most recent updates. Your continued use of our Site following these changes means that you accept the revised California Privacy Policy.
1 California's full CCPA statute, 1798 Cal. Civ. Code #chr(0167)##chr(0167)# 1978.100 - 1798.199, may be found here: https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=CIV&division=3.&title=1.81.5.&part=4.
2 For information on preparing a Power of Attorney, see Cal. Probate Code #chr(0167)##chr(0167)# 4000-4465 ("Powers of Attorney"), here: http://leginfo.legislature.ca.gov/faces/codes_displayexpandedbranch.xhtml?tocCode=PROB&division=4.5.