Privacy Policy

Terms of Use & Privacy Policy

Lieberman Research Worldwide, together with its subsidiaries LRWTonic, LRWMotiveQuest, and Kelton Global (collectively, “LRW”), is committed to protecting the privacy of all information we collect from our clients, research participants and visitors to our corporate and survey websites (the “Website”). This policy applies to all client and personal data that we collect or use in the course of conducting our business, and covers all client information and research participant data housed at any LRW facility or stored on the LRW network.

By accessing or browsing our Websites, participating in any of our surveys, contacting us on social media, or otherwise providing your data to us, you confirm that you have read and understood the entirety of this privacy policy.

Information We Collect From or About You

We are in the market research business. Most of the information we collect about you (only a small subset of which may be “personal data” or “personally identifiable information” as defined under applicable law) is information you voluntarily disclose to us in connection with our research studies. Consistent with industry practice, online survey activity is typically conducted on an anonymized basis through the use of randomly assigned identifier codes, so the identity of research participants is not known to us or to the client commissioning the study. Some of our studies take the form of “communities,” which involve repeated interaction over a defined period of time; in those cases, we would typically have personal data about you (including a means to contact you), but other participants in the study would not have access to this information. Data collected as part of our studies may include respondent demographic data and respondent-supplied opinions on products or brands. As to some studies, we may also collect video or audio responses. Research participation is voluntary and participants always have the opportunity to decline involvement or to “opt out” of the research after agreeing to participate, as clearly identified in each survey. If the survey involves an incentive or a contest, we may ask for your name and telephone number or email address to notify you if you are a winner. There is never an obligation to provide this information to participate in the survey but if you don’t provide it, you may not be able to participate in the incentive program. Our legal basis for collection and processing of respondent-supplied personal data is consent; we do not collect personal data without the affirmative consent of the research participant. Consent can be withdrawn at any time.

In a few cases in connection with surveys, we may use JavaScript, a commonly used, lightweight browser programming language, to place a cookie on your personal computer or to read a cookie that has been placed on the personal computer by a previous shopping experience. This allows us to correlate your customer survey responses with previous shopping experiences. Additionally, in connection with our online survey activities, we employ software to identify certain systems-related information about respondents, including IP address, device and browser type, and geographic location, in order to detect fraudulent activity (e.g., bots), to protect the integrity of the research, and to optimize the survey experience.

As to certain studies, we may obtain information about you (which in some cases may be “personal data” or “personally identifiable information” as defined under applicable law) from our clients, third party vendors, or partners for use in connection with the studies. In those cases, our legal basis for the processing of the information is our legitimate interest to perform our obligations under our contract with the client commissioning the research study in question.

If you are a client or work for a client, we likely have collected various contact, business, and in some cases financial information about you in the course of administering our relationship with you or your employer. In those cases, our legal basis for the collection and processing of the information is our legitimate interest to perform our obligations under our contract with you or the company for which you work.

If you choose to use social media (for example, Facebook, Instagram, Twitter, LinkedIn, or our blog) in order to contact us or find out about our services, we may collect your public-facing profile data, data relating to your interactions with us, and any data you post on message boards which are relevant to our business.

We may collect certain information regarding visitors to our Websites, including IP address, device and browser type, and behavior while on the Websites (e.g., which links were clicked on). We may do so using cookies, which are small files placed on your internet browser when you visit our Websites, in order to offer you a more tailored experience in the future by, for example, understanding and remembering your particular browsing preferences. If you prefer not to receive cookies from our Websites you can disable their use in your browser settings. By doing so you may reduce the functionality of the web pages you view. Currently, our systems do not respond to browser do-not-track signals. Also, when visiting certain of our Websites, you are provided the option to sign up for our newsletter and mailing list, and if you do, we collect the information you supply. If you wish to be removed from LRW’s email list, please email us at info@LRWonline.com.

What We Do With Information We Collect

Depending on how we obtain your personal data (as described above), we may either be considered a “controller” or a “processor” under applicable law as to that data. If we are the processor, we will process the data in accordance with the instructions provided to us by the controller of that data.

Regarding data collected as part of our research activities, we collect data in, and in connection with, our studies for research purposes only, and our use of that information is limited to that purpose. Research participant information and answers are not used by any entity as an aid for sales. In many cases, this information (which is typically anonymized) is shared with the client commissioning the study pursuant to our contract with that client. In some cases we may need to share personal data with third parties for ancillary services in support of a research project. In these cases, we require the third party to follow all of the same privacy protection regulations as followed by LRW.

As to client data we collect, we do not use the information for any purpose other than to fulfill our obligations to clients. We keep client information secure at all times, and prevent the use and disclosure of it by our employees or any third parties.

Insofar as we have operations in the United States and in Europe and conduct research globally, any data we collect and process in connection with our business activity may be transferred between or among two or more countries (including from the EU to the US), either within LRW or between LRW and a client or other third party described above. In all cases, we will take appropriate measures to ensure that the recipient protects any personal data so transferred adequately in accordance with this privacy policy. These measures include, in the case of transfers from the EU and Switzerland to the US, adherence to the Privacy Principles described in the EU-US and Swiss-US Privacy Shield Frameworks (please see below for further details).

Information we collect regarding visitors to our Websites, as well as visitors to our social media pages, is used for improvement and maintenance of our Websites and the preparation of reports or compilation of statistics in order to improve our Websites and the general suite of services we offer. Information supplied on LRW Websites in connection with newsletters and mailing lists will remain confidential and will be used solely by LRW for its own marketing activities.

We do not rent, sell or give personal data to any third party for the purpose of directly marketing any products or services.

Under certain circumstances, we may be required to release personal data in response to a legal request from public authorities including to meet national security or law enforcement requirements.

In all cases, LRW will take reasonable steps to ensure the personal data is accurate, complete, current and relevant and being used only for the intended purposes. We will not process personal data in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by the individual.

Retention of Personal Data

We keep personal data for no longer than necessary for the purposes for which the personal data is collected or processed. The length of time we retain personal data for depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights.

Information Security

We maintain physical, electronic and procedural security measures to help safeguard client and personal data which are consistent with industry standards and practice and in compliance with applicable law. Third parties that provide us with support or services and that may also receive client or personal data are required by us to maintain security measures similar to ours with respect to such information. We will take reasonable precaution, consistent with industry standards and practice, to protect personal data from loss, misuse, unauthorized access, disclosure, alteration, and destruction.

Your Rights As to Your Personal Data

You have the right to request the following as to any personal data we have about you: that we provide access to any personal data we hold about you; that we update any of your personal data which is out of date or incorrect; where our basis for processing your personal data is consent, that your consent to further processing be withdrawn; where we received your personal data from a third party, inquire where the data originated; that we delete any personal data which we are holding about you; restrict the way that we process your personal data; prevent the processing of your personal data for direct-marketing purposes; that we provide, or not provide, your personal data to a third party provider of services; that we provide you with a copy of any personal data which we hold about you; or that we consider any valid objections which you have to our use of your personal data. Under applicable law, certain personal data may be exempt from such requests in certain circumstances. If you would like further information about these rights or would like to exercise any of them, please email us at legal@LRWonline.com.

Privacy Shield

LRW complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework established by the US Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. LRW has certified to the Department of Commerce 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 https://www.privacyshield.gov. We will not disclose information to a third party without applying the Notice and Choice Principles, as indicated by the Privacy Shield Principles and the EU-US and Swiss-US Privacy Shield frameworks. We may be liable for inappropriate onward transfer of personal information to third parties.

Careers

Any personal data which may be collected in the Careers sections of our Websites will be used solely for purposes of the consideration of possible employment. This information will not be used towards research and is not human resources data within the context of the working relationship.

Children

We operate in compliance with the Children’s Online Privacy Protection Act (“COPPA”), governed by the US Federal Trade Commission (“FTC”). We do not collect, use or disclose information from children under the age of 13 online without a statement of permission from a parent or guardian. For more information on COPPA, please visit http://www.ftc.gov/ogc/coppa1.htm.

Compliance and Enforcement

LRW is subject to the investigatory and enforcement authority of the FTC. Also, as members of the Insights Association and ESOMAR, we strive to model our policies according to guidelines promulgated by those organizations. Our internal Privacy Officer is available if you have questions about our Privacy Policy, or for processing a complaint. We also comply with the EU-US and Swiss-US Privacy Shield frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of data from the European Union and Switzerland. If you are concerned about our use of personal or client information, please contact us by mail at 1900 Avenue of the Stars, 16th Floor, Los Angeles, California 90067 USA, by email at legal@LRWonline.com or by telephone at (310) 553-0550, and request to speak with our Privacy Officer.

In compliance with the EU-US Privacy Shield and Swiss-US Privacy Shield Principles, LRW commits to resolve complaints about your privacy and our collection or use of your personal data. European Union and Swiss individuals with inquiries or complaints regarding this privacy policy should first contact LRW at the contact information listed above.

LRW has further committed to refer unresolved privacy complaints under the EU-US and Swiss-US Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.

Under limited circumstances, if your complaint is not resolved through these channels, a binding arbitration option may be available before a Privacy Shield Panel.

Finally, if required or permitted by law, you may also make a complaint to the data protection authority in the EU country where we may have operations or where we process personal data that relates to offering goods or service to you in the EU.

Changes to the Privacy Policy

We may update this Privacy Policy from time to time by posting an amended version of the statement on one or more of our Websites. Please refer to this policy regularly.

 

Last update: April 30, 2018