Our Privacy Policy

1. Civicom Websites

When you visit our website, we collect your IP address and type of browser. Our websites also collect information by using cookies.

1.1 Website Cookies

Our cookies assign a randomly generated number to your computer. The cookies do not extract from your computer any information regarding other Internet sites or your surfing activities.

Our websites contain a notice that we use cookies to collect data. We use different types of cookies for the following reasons:

• To retain your preferences for pop ups and advertisements;
• To obtain details about your device and browser so the display can adapt to your screen size and layout content to fit your browser;
• To improve our services with usage information about our website, such as the number and frequency of visitors and the pages you visit, your geographical location, referral source, and length of visit.

You may disable optional browser cookies at any time. To do so, please refer to your browser’s Help page.

1.2 Website Beacons

Web beacons are used to track the journey of a user navigating through our website or a series of websites to assist us in delivering cookies on our sites and to allow us to count users who have visited those web pages and in turn to deliver Services. Web beacons do not collect nor record personally identifiable information.

We may use web beacons, customized links or similar technologies to determine whether an email we sent has been opened and which links you click on in order to provide you more focused email communications or other information.

1.3 Navigational Information

In selected instances we advertise our services on other websites. These websites likely use cookies and web beacons to collect information about your activities and may provide you with targeted advertising based upon your interests. Information collected by cookies and web beacons do not include personally identifiable information. If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out by clicking here: http://www.aboutads.info/choices/ (or if located in the European Union, by clicking here: http://www.youronlinechoices.eu/).

Please note this does not opt you out of being served advertising. You will continue to receive generic ads.

1.4 Registrations and Forms

We collect Personal Information that is provided during webinar registration, through our sign up and landing pages,contact us forms, and through your subscribing to one or more of our blogs, or through our online chat. This information is used to either assure your registration and/or to provide you with the information or answers you requested.

Our forms require you to identify your country of location. If you are located in an EU country, they require you to check a box indicating your knowledge and permission that we have collected your data, offer you the option to opt out, and provide you with information on how to do so. If you are located in the United States, we ask for you to provide your state of residence. We include information on various state privacy laws here.

Our registrations and forms may ask you only once to authorize the use of your Personal Information in order to eliminate your need to repeatedly enter the same information. If you are an EU/Swiss natural person, you may contact us at dataprotection[at]civi.com to change or request removal of your Personal Information at any time. Requests made under rights available under non-EU legislation may be directed to dataprotection[at]civi.com.

1.5 Buttons and Tools From Other Companies

Civicom websites and mobile apps may include buttons and tools that link to our social media accounts, such as our Company Facebook, LinkedIn, or Twitter accounts. Your interaction with our social networking pages may result in us receiving information about you.

2. Mobile Apps

When you register to use our mobile apps, we receive information sent by your device to our servers to identify you, such as your Device ID and email address . We will also receive any other Personal Information and content you may upload including your name, company, email address, phone number, and text messages, photos, videos and voice recordings.

We use mobile analytics software to allow us to better understand the functionality of our Mobile Apps on your mobile device. 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. When you use our Mobile Apps we also collect your device model and version, and device identifier (or “UDID”).

If you have enabled your GPS, this may send us your latitude/longitude coordinates, cell tower and WiFi-based location information.

We send push notifications from time to time in order to update you. Mobile research study notifications may include new comments or available exercises within the scope of the research. The PleaseDo application may send notifications and promotions. Hey DAN will push announcements related to your use of the service.

We may link information we store within the analytics software to Personal Information you submit within the Mobile App. We do this to improve the services we offer you and improve our analytics and site functionality.

If you sign up for one of our services using Facebook or Google, we do not use your Facebook or Google credentials for any reason other than to enable you to use the service you signed up for, unless you provide your permission for us to use them for other reasons.

3. Operator-Assisted Conference Calls

When you participate in an operator-assisted call our facilitators may request your Personal Information in order to grant you access. By providing this information freely, you have granted us the right to use it to facilitate your call experience and provide it to the call sponsor at their request.

4. Phone Inquiries

If you contact us by phone for information or assistance with our Services, we may ask you to provide your contact information in order to serve you. By providing this information freely, you have granted us the right to use it to facilitate your call experience and provide our Services to you.

5. Trade Events

If you provide your business card to us at a trade event, we consider this your opt-in to receive information about our Services and will use your contact details to send you information and resources that we think may be valuable to you. You can opt out at any time by clicking on the unsubscribe link in an email sent by us, or email us with your request to unsubscribe. If you are an EU/Swiss natural person, you have the additional option to opt out at any time by emailing us your request to unsubscribe at dataprotection[at]civi.com. Requests made under rights available under non-EU legislation may be directed to dataprotection[at]civi.com.

6. Data on Marketing Research Respondents

Through our CiviSelect Website (civiselect.com), social media accounts, and by telephone and email, we collect information for individuals who desire to be included in our CiviSelect respondent database or in an active research study. Individuals who wish to participate must provide their first and last name, phone number, email address, country, and whether or not they have high speed internet in order to be considered for a marketing research study.

Additional information, such as address, ethnicity, birthdate, gender, health information, income, and other demographics may be required for a specific study based on client requirements to participate. These requirements also apply to any individual who replies to any of our respondent recruiting solicitations or by way of a third-party respondent recruiter or panel (“Respondent Information” is incorporated under the definition of “Personal Information”).

Respondent Information shared with us by our clients as a part of a specific study may include similar information as the above. As part of our facilitation role we will contact you based on the information provided to us and in order to include you in the study.

In order to participate in a research study, you may need to provide additional information about yourself that is required by the research study in order to confirm that you are eligible to participate under the project specifications required. This information is collected to determine if you qualify for the study. Anonymized data is in most cases entered into a spreadsheet for disposition reporting. By providing this data you realize it is for the purpose of qualifying you for a research study.

When you are a respondent in a marketing research study, we or our clients may ask your opinions and views on products and services external to our company or theirs. You understand that you are providing this information freely of your own will in order to participate in the research study you have been qualified to participate in.

Researchers who engage with us in our facilitation of a research study may have their own privacy policies which apply to studies involving you. Those privacy policies may detail how they handle your personally identifiable information. We encourage you to become familiar with any such policies.

7. Information About Children

Our websites are not intended for or targeted at children under 13, and we do not knowingly or intentionally collect information about children under 13. If you believe that we have collected information about a child under 13, please contact us at dataprotection[at]civi.com, so that we may delete the information.

An exception may be where a marketing research study requires a child under 13 to become a respondent. In this case, after we have received written consent of the parent or legal guardian, the child’s privacy will be protected as under section 6 on Data on Marketing Research Respondents.

Data Protection

1. EU–U.S. Privacy Shield and Swiss–U.S. Privacy Shield

Civicom participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss–U.S. Privacy Shield Framework. Civicom is committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, in reliance on the Privacy Shield Framework, to 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.

Civicom is responsible for the processing of personal data it receives under the Privacy Shield Framework and subsequent transfers to a third party acting as an agent on its behalf. Civicom complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Civicom is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Civicom may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

You may direct any inquiries or complaints related to our Privacy Shield compliance to dataprotection[at]civi.com. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, you may contact our U.S.-based third party dispute resolution provider (free of charge) at: https://thedma.org/resources/consumer-resources/privacyshield-consumers/

Under certain conditions, more fully described on the Privacy Shield website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

As part of the Privacy Shield Frameworks, the U.S. State Department Senior Coordinator serves as the Ombudsperson to facilitate the processing of requests relating to national security access to data transmitted from the EU and Switzerland to the U.S.

To view Civicom’s certification, please visit https://www.privacyshield.gov/list

2. HIPAA Compliance

The Health Insurance Portability and Accountability Act of 1996 (HIPAA) as amended, including by the Health Information Technology for Economic and Clinical Health Act (HITECH), is a United States federal law regulating the US healthcare system, with its primary purpose to protect the privacy and security of health and medical information, known as Protected Health Information (PHI). For more information about HIPAA, see here: https://www.hhs.gov/hipaa/.

Certain Civicom clients are in the health care sector and as such, Civicom is acting as a Business Associate of Covered Entities as defined under HIPAA. Accordingly, Civicom will readily review and accept Business Associate Agreements with clients and partners to govern and ensure that PHI shared with us will not be compromised.

Civicom is committed to confidentiality and the protection of health information for individuals, clients, customers and partners. We ensure that privacy and security of their health information is protected in all forms, with particular care in controlling the confidentiality, storage and access to electronic Protected Health Information. We have achieved this by implementing security standards, administrative, technical, and physical safeguards, organizational requirements, and requirements for documentation, policies and procedures.

Our standards are maintained and improved by continuous review and audit of internal processes and business agreements, with the aid of external consultants and specialized staff dedicated to data privacy. Any complaints concerning Civicom’s privacy policies and procedures or Civicom’s compliance with such policies and procedures should be made to our Data Protection Officer by contacting dataprotection[at]civi.com.

Civicom provides training to all members of its workforce on policies and procedures with respect to PHI, as necessary and appropriate for them to carry out their job responsibilities. Processing of data is kept to a minimum and will not be excessive in relation to a declared and specified purpose.

3. US State Data Privacy Laws

US State Data Privacy Laws, such as the California Consumer Privacy Under The California Consumer Protection Act (CCPA), California Privacy Rights Act (CPRA), the Virginia Consumer Data Protection Act (VCDPA), the Colorado Privacy Act (CPA), Connecticut Data Privacy Act (CTDPA), and the Utah Consumer Privacy Act (UCPA) requires certain businesses, including Civicom, to provide certain information disclosures and services specifically to US consumers. A consumer has the right to request a copy of their personal information that a business has collected, used, sold or otherwise disclosed.

Under the US State Data Privacy Laws, Civicom has both the right and obligation to properly verify the identity of a consumer requesting to view, modify, delete or opt-out with respect to personal information. Prior to any information disclosure, we will require certain information and processes to be followed to verify the identity of the requestor, including at a minimum your name, a valid email address, a valid phone number, and a valid street address. In order to mitigate fraudulent requests and other misuse of the services provided under these data privacy regulations, if a consumer cannot be reasonably verified, we will be unable to disclose certain information to the requester.

A consumer can request for opt-out of sale of personal data, opt-out of sharing personal data for cross-context ads, and request to limit the use and disclosure of their sensitive personal data by filling out our request form here – link.

4. Choice

We offer individuals the opportunity to opt out (choose) whether their Personal Information is to be disclosed to a third party acting as a controller or processor, as well as to opt out (choose) whether their Personal Information will be used for a purpose that is materially different from the purpose for which it was originally collected or which they subsequently sanctioned for use. We require, or when acting on behalf of a client, or as a facilitator we require, written confirmation (opt in) from individuals that we are able to disclose their Sensitive Personal Information to a third party acting as either a controller or processor.

We will provide individuals reasonable and clear mechanisms for individuals to exercise their choices. For purposes of this understanding Personal Information includes first and last name, phone number, email and/or physical address and phone number. Sensitive Personal Information includes health care, genetic or biometric data, information regarding religious beliefs, race, ethnicity, union memberships, and sexual behavior or orientation.

5. Security of Personal Information

We are committed to protecting your privacy and have implemented reasonable administrative, technical, and physical security controls to secure your Personal Information.

If a password is provided to help protect your projects and Personal Information, it is your responsibility to keep your password confidential.

6. Where Civicom Stores My Personal Information

We use a variety of security technologies and procedures to help protect your Personal Information from unauthorized access, use or disclosure. Your Personal Information and files are stored in our servers and those hosted by our authorized third-party storage providers. We secure the Personal Information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure.

If you have any questions about the security of your Personal Information, you can contact us at dataprotection[at]civi.com.

7. Access to My Personal Information

Civicom recognizes the right of individuals to access their Personal Information. As an account holder, you have the ability to view or edit your Personal Information online or cancel your account.

If you have an online account with Civicom, you can view or edit your Personal Information online or cancel your account at any time.

If you do not have an online account but are our client or customer, you may contact us by way of your Account Manager or by contacting us at dataprotection[at]civi.com in order to edit your information or cancel your account with us.

If you are not a customer or client, but would like to change your mind about receiving information from Civicom you also can contact us at dataprotection[at]civi.com to have your information changed or removed.

As an EU/Swiss natural person, you have the additional option to reach us to modify your information, review the information we have on file about you, or request that your information be removed from our system by emailing us at dataprotection[at]civi.com.

In the case where we are your data processor and not your data controller, you may need to contact your data controller to request to see or change your Personal Information with us.

The above paragraphs on access to your Personal Information are subject to our need to comply with our legal obligations or contractual agreements.

For requests for changes or deletions of personally identifiable information, we reserve the right to validate your identity and/or to charge you an adequate handling fee before providing access to data, except as required by the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks.

8. Third Party Service Providers and Clients

Civicom uses third party service providers to deliver some of our services. We may share your Personal Information with our third-party service providers to fulfill their obligations to us on your behalf. These service providers include:

• Market research partners such as recruiters, transcribers, translators, moderators and end clients;
• Market research technology and/or platform providers; and
• Webinar platform and audio conferencing storage providers.

Customers who utilize our capabilities or otherwise subscribe to our Services are obligated through our agreements with them to comply with our Privacy Policy.

We may disclose the Personal Information you provide to our clients who use our tools and software platforms, and/or to contractors, service providers and other third-parties we use to support our business (and who are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them).

9. Personal Information Across National Borders

We may transfer your Personal Information electronically across borders and around the world, including to or from the United States and/or the EU/Switzerland, to facilitate our global operations. This Privacy Policy shall apply even if we transfer Personal Information to other countries.

As a global company working with a continuous flow of global projects, we operate a highly secure web-enabled infrastructure that assures all of our clients that we have taken the appropriate steps to ensure security as well as to meet the EU-US data protection requirements. Where global projects require data transfer to countries outside the EEA and not deemed as having adequate data protection rules, significant controls are in place to meet the required levels of data protection under the GDPR and other legislation. Where acting as controller or processor transferring personal data, we carry out such transfers using appropriate safeguards as specified under Article 46 of the GDPR. These safeguards are provided by means of: binding corporate rules, an approved code of conduct, and standard data protection clauses required. We maintain strict information security policies, data flow procedures, mapping and security measures, GDPR and HIPAA training, a Compliance team, an Information Security Team, and a Data Protection Manager

Our servers are maintained in the following locations and can be directed to any other country as an additional safeguard:

• Google (Gmail/GSuite): North America: Berkeley County, South Carolina; Council Bluffs, Iowa; The Dalles, Oregon; Douglas County, Georgia; Henderson, Nevada; Jackson County, Alabama; Lenoir, North Carolina; Loudoun County, Virginia; Mayes County, Oklahoma;Midlothian, Texas; Montgomery County, Tennessee; New Albany, Ohio; Papillion, Nebraska; Storey County, Nevada; South America: Quilicura, Chile; Europe: Dublin, Ireland; Eemshaven, Netherlands; Fredericia, Denmark; Hamina, Finland; Middenmeer, Netherlands; St. Ghislain, Belgium; Asia: Changhua County, Taiwan; Singapore.
• Amazon (AWS): Northern Virginia, USA; Ohio, USA; Oregon, USA.
• Adobe Systems (Adobe Connect): Hillsboro, Oregon; Dallas, Texas; London, England; Sydney, Australia.
• CoSo Cloud (Adobe Connect): Hong Kong, United Kingdom, and the United States.

• To respond to demo requests, pricing inquiries, and questions about our Services
• To address reports of technical issues
• To provide you with Services requested
• For billing purposes
• To conform to legal requirements or comply with legal process
• To protect or defend the rights and property of Civicom
• To enforce the Terms of Service Agreement
• To protect the rights of our account holders or others
• For normal business operations
• To improve our Services
• For any other purpose disclosed by us when you provide the information
• For shipping and handling required to deliver our Services to you