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PRIVACY POLICY
The following Privacy Policy describes how The Hanover Research Council LLC
(“us” or “we” or “Hanover Research”) collects, uses, discloses, retains, and
protects personal information that we obtain through this website
(www.hanoverresearch.com), from our current and potential clients; from
prospective, existing, and former employees; as well as about research
participants (such as survey respondents and potential research participants,
online and offline); and from third-party list providers (collectively,
“services”). Please read this Privacy Policy carefully.
Hanover Research reserves the right to update this Privacy Policy at any time.
If we change the Privacy Policy, we will post an amended draft
on www.hanoverresearch.com, along with an effective date. If we make material
changes to our Privacy Policy, we will post a revised Privacy Policy at the
bottom of the main page of the website at www.hanoverresearch.com that states
“Privacy Policy,” and a notice of the policy change will appear at the bottom of
the website. We will email you to notify you of any material changes if you are
a client or an employee of ours.
INFORMATION WE COLLECT
Personal information is any information relating to an identified or
identifiable natural person. In other words, it is information through which an
individual can be identified (either directly or indirectly) and it includes
name, identification number, location data, an online identifier, or one or more
factors specific to the physical, physiological, genetic, mental, economic,
cultural, or social identity of a person. Anonymized or aggregated information
that cannot be used to identify a specific natural person is not considered
personal information.
Hanover Research collects personal information through several different online
and offline channels, including, but not limited to the following: via our
website on any form completed, over the phone, via email when communicating with
you, in person, via internal and third-party web-based survey tools, through our
customer portals, and from third-party list providers. The types of personal
information we generally collect include, but are not limited to:
* Client or Potential Client Information: If you use our services, or express
interest in our services, you may provide this information via our website or
other means, in person or remotely. This data includes: name; employer name;
telephone number; email address; mailing address; other contact information;
billing, tax, and payroll information; employee background check information;
inquiries about actual or potential projects; publicly available social media
posts and profiles, and any other information you choose to provide us. We
also may maintain documentation of discussions with current or prospective
clients, either in person or remotely. We also collect any other information
that you choose to provide to us via email, website, phone, in person, or any
other means.
* Survey or Research Information: If you participate in one of our research
projects (e.g. respond to a survey), we may collect your name, email address,
IP address, company name, job title, demographic information (such as race,
ethnicity, gender, and age), educational information, responses to our survey
questions, and any other information that you provide to us, online, over the
phone, or in person. You may provide this information to us via a third-party
research survey platform.
* Recruitment Information: If you applied for a job at Hanover Research, we
will collect employment related information, such as your name, age,
demographics, email address, resume information, job roles, work history,
compensation data, benefits information, performance metrics and reviews,
background checks, assessments, and any other information that you provide to
us or we gather during the course of your candidacy.
* Third-party sources: We also collect data from third-party sources. This
third-party information includes contact lists or unique identifiers of
potential survey respondents provided by our clients or other third party
services such as research panel providers; contact information about
potential clients from directories and databases of companies; and
information that is available on the Internet, for research or business
relations purposes, such as publicly available social media posts. Social
media (e.g., Twitter, LinkedIn, Facebook) is analyzed based on publicly
available posts and engagement (including opens, clicks, shares, etc.)
subject to the individual privacy policies of the respective social media
platforms. Hanover Research uses the data from such third-party sources
primarily to provide research services. Hanover Research is not liable for
any security breaches that may occur on any social media platform.
Automated Information through use of our website or other online services: When
you use our website or other online services, we automatically collect certain
types of information, including IP address, browser type, device ID, referral
URL, date and time of access and the pages you visited and other automated log
information. We use this information to help us understand our website activity
and to monitor and improve our website. Like many websites, Hanover Research
uses website analytics services (e.g., Google Analytics) to collect website
usage data. For more information or to opt-out using the Google Analytics
opt-out browser add-on, see “How Google uses data when you use our partners’
sites or apps” and “Google Analytics and Privacy”. These services may use
cookies, which are small text files placed on your computer, to help us analyze
how visitors use our website. Most Internet browsers automatically accept
cookies by default. You can change your browser settings to reject cookies or to
prompt you before accepting a cookie from the websites that you visit, however,
if you decide not to accept cookies from our website, you may not be able to
take advantage of all of the website features. This website usage data may be
linked to the other personal information that we may hold about you. For further
information about our use of cookies, please refer to our Cookie Policy
(https://www.hanoverresearch.com/cookie-policy).
CHILDREN’S DATA
The collection, processing, use, sharing, and storage of any information
regarding children under 18 years old complies with all applicable
international, federal, state, and provincial laws regarding minor and student
privacy. HANOVER RESEARCH DOES NOT SELL CHILDREN’S DATA, and we do not use
personally identifiable information collected from children or their schools for
commercial purposes.
COPPA: Although Hanover Research’s surveys and website are not intended for
children under the age of 13, as defined by the Children’s Online Privacy
Protection Act (“COPPA”), out of an abundance of caution, Hanover Research will
only conduct surveys of children under 13 years old upon receiving verifiable
consent from either the child’s school or school district pursuant to COPPA, or
directly from the child’s parent. Hanover Research relies upon its school and
school district clients’ representations that they have obtained verifiable
parental consent for the sharing and use of information from any students who
were under the age of 13 when Hanover Research began its contracted services.
In the rare event that Hanover Research has collected information from or about
a child under 13 years old without verifiable parental consent, the child’s
parent may contact Hanover Research to request a description of the types of
personal information collected, request deletion of any personal information
collected, revoke consent for the use and maintenance of already collected data,
and/or revoke consent for any future data collection.
FERPA: If a school or school district client grants Hanover Research access to
Personally Identifiable Information (“PII”) as it is defined by the Family
Educational Rights and Privacy Act of 1974 (“FERPA”), all parties agree to
comply with the requirements imposed by FERPA and its regulations. For purposes
of any PII subject to FERPA, Hanover Research will be considered a “school
official” with a “legitimate educational interest” as these terms are used in
FERPA and are interpreted by the Family Policy Compliance Office. Any PII
subject to FERPA will remain under the direct control of the client and will not
be disclosed to third parties except as expressly provided for by FERPA. If a
parent or student contacts Hanover Research directly to review any PII, Hanover
Research will promptly refer the parent or student to the school or school
district client.
Hanover Research relies upon its school and school district clients to comply
with all Protection of Pupil Rights Amendment (PPRA) notice and inspection
requirements.
For any inquiries concerning Hanover Research’s privacy policies and use of
children’s data, contact: Hanover Research, Attention: Privacy & Data
Protection, 4401 Wilson Boulevard, 4th Floor, Arlington, VA 22203; (202)
559-0050; privacy@hanoverresearch.com.
USES OF PERSONAL INFORMATION
Below is a summary of the ways that we use your personal information, the
purposes for those uses, and the legal bases for the uses:
We will use your personal information if the use is necessary for the
performance of a contract to which you are a party or in order to take steps at
your request prior to entering into a contract. Such uses and purposes include:
* If you provide us with personal information requesting services or products
from us, we will use that information to respond to your request.
* We will use your personal information to provide any services that you have
requested. For example, if you are a client and you provide us with your
phone number, we may call you. If you provided us with payment information,
we may process that information. If you apply for a job, we will use your
information to assess your suitability for current or future job
opportunities with Hanover Research.
* We will use your personal information for purposes identified at the time the
personal information is collected. Depending on the jurisdiction in which you
reside, we may also use your personal information if the use is necessary for
the purposes of our client’s or our legitimate interests, provided that these
interests are not overridden by your interests or fundamental rights and
freedoms.
* We may use any information that data subjects, including any survey
respondents, voluntarily provide to us, in combination with any other
information we have collected from other sources such as third party sites or
publicly available information, to provide research and insights to clients.
Please note that depending on the specific contractual relationship with the
client, Hanover Research may be acting as either a data controller (also
sometimes known as an accountable entity) or a data processor (also sometimes
known as a service provider), or both.
* We may use deidentified, anonymized or aggregate personal information in
accordance with applicable law to create derivative research products.
We may use any information you provide to us to detect, prevent, mitigate, and
investigate any potentially prohibited or illegal activities.
We may use your personal information to comply with a legal obligation.
We may use any data for which you have given consent for the processing, such as
when individuals provide their information when downloading content from our
website. You may withdraw this consent at any time by emailing Hanover Research
at privacy@hanoverresearch.com.
SHARING PERSONAL INFORMATION
We may transfer or disclose your personal information to the following types of
third parties:
* Clients:Hanover Research conducts research on behalf of clients through
primary and secondary research, including the use of surveys. We may share
any information that we collect as part of our research, including responses
to surveys, with our clients in accordance with the notice provided to you at
the outset of the survey.
* Hanover Research Affiliates:Hanover Research may share personal information
with any parent company, subsidiary, or corporate affiliate that is owned or
controlled by the same owner.
* Service Providers:To provide our research services, communicate with new and
prospective clients, maintain our daily operations, provide information about
our services, and improve our services, we provide personal information to
third-party service providers (which may include our parent company,
subsidiaries or corporate affiliates). Such providers include data processing
services, cloud storage, business process outsourcers, transcription
services, and marketing outreach partners. Such third-party service providers
are required to maintain the confidentiality of the information we provide to
them and are prohibited from using the information for their own purposes. A
list of our service providers who may have access to your personal
information, which we may update from time to time, will be provided to you
upon written request to privacy@hanoverresearch.com. We do not share your
personal information with service providers for their own promotional use.
* Law Enforcement and Legal Proceedings:We will provide personal information to
third parties, such as law enforcement or government agencies, if required to
do so by applicable law or valid legal process, or if we determine that such
sharing is necessary to protect the rights and safety of anyone. We will also
provide personal information to parties to a legal proceeding, if we receive
a subpoena or similar valid legal process.
* Corporate Transactions, Mergers, Sales, and Acquisitions:In the event of a
prospective or actual merger, sale or acquisition of our company, or a
partial sale or transfer of assets, or as part of a corporate reorganization
or other change in corporate control, your personal information may be
disclosed to third parties as part of the transaction.
SECURITY
We maintain commercially reasonable administrative, technical and physical
measures and security protocols to help protect and secure your personal
information against loss, misuse and unauthorized access, disclosure, alteration
or destruction while in transmission and storage. A summary of our information
security program can be found here. We restrict access to personal information
on a need-to-know basis to employees and authorized service providers who
require access to fulfill their job requirements. We require our service
providers to adhere to industry best practices to safeguard the personal
information they handle. However, no method of data transmission or storage is
100% secure, therefore, we cannot guarantee its absolute security.
RETENTION
We retain your personal information for as long as necessary to fulfill the
purposes for which the data was collected or to otherwise meet a valid business
or legal requirement. Once the personal information no longer is necessary to
fulfill any of these purposes or retained under our retention policies, we will
securely dispose of it. Among the factors that we consider in determining
whether to retain personal information are: whether the project(s) for which the
data was collected has concluded and retaining the data is no longer necessary;
the sensitivity of the personal information; and whether the information could
be anonymized or aggregated.
ADDITIONAL INFORMATION FOR INDIVIDUALS LOCATED IN THE EU, UK OR EEA
If you are located in the European Union, United Kingdom or European Economic
Area and Hanover Research processes your personal information, you may have the
following rights. To exercise any of the rights, you may contact Hanover
Research via the “Contact Us” section of this privacy policy. Please note that
for research data (such as surveys), Hanover Research may act as either a data
controller or data processor, depending on the contractual relationship with the
particular client. These rights only apply to the extent that Hanover Research
is acting as the data controller. If Hanover Research is acting as a data
processor or service provider, then you will need to address any request to
exercise your rights to the relevant data controller.
* To the extent that any of Hanover Research’s use of your personal information
is based on consent, you may request to withdraw that consent.
* To the extent that the processing of your personal information is based on
the legitimate interests of Hanover Research or a Hanover Research client,
you may object to this processing at any time. We will no longer process this
personal data unless we can demonstrate compelling legitimate grounds for the
processing which override your interests, rights and freedoms or for the
establishment, exercise, or defense of claims.
* You have a right to access your personal data, including: information about
the purposes of processing; the categories of personal data concerned; the
recipients of the personal data; and where possible, the envisaged period for
which the personal data will be stored, or, if not possible, the criteria
used to determine that period. This right of access may be subject to legal
limitations, of which we would advise you.
* You have the right to obtain from us without undue delay the rectification of
inaccurate personal data concerning you. Taking into account the purposes of
the processing, you shall have the right to have incomplete personal data
completed, including by means of providing a supplementary statement.
* You have a right to obtain the erasure of personal data concerning you
without undue delay, if one of the following grounds applies:
* * * The personal data are no longer necessary in relation to the purposes for
which they were collected or otherwise processed;
* If the processing was based on your consent, you withdraw your consent;
* You have a legal right to object to this processing, and there are no
overriding legitimate grounds for the processing;
* The personal data has been unlawfully processed; or
* Erasure is necessary to fulfill a legal obligation of Hanover Research.
The right to erasure does not apply to the extent that processing is necessary
for exercising the right of freedom of expression and information, for
compliance with a legal obligation of Hanover Research or a Hanover Research
client, for archiving purposes in the public interests, or for the
establishment, exercise, or defense of legal claims.
* You may request that we transfer your personal information to another
controller, if technically feasible and the processing is based on your
consent or a contract performance.
YOUR PRIVACY RIGHTS UNDER STATE LAW
YOUR CALIFORNIA PRIVACY RIGHTS
On January 1, 2020, the California Consumer Privacy Act (“CCPA”) went into
effect. The law requires companies to notify California residents about how
their data is collected, used, and shared, and in some cases gives them rights
to access and delete that data. This section provides Hanover Research’s
disclosures as required by the CCPA. These disclosures supplement and
incorporate the statements in the other portions of the Privacy Policy. This
section applies to all visitors, users, and others who reside in the State of
California.
INFORMATION WE MAY COLLECT
Hanover Research collects personal information from individuals in order to
administer and provide services to Hanover Research clients and for the other
purposes identified in this Privacy Policy. We may collect the following
categories of information, as defined in the CCPA. The examples listed are only
illustrative of potential types of data within each category, and Hanover
Research does not necessarily collect that data about every individual.
CategoryExamplesCollectedIdentifiersReal name, alias, postal address, unique
personal identifier, online identifier, internet protocol address, email
address, account name, social security number, driver’s license number, passport
number, or other similar identifiersYesCategories of personal information
described in Cal. Civ. Code 1798.80(e)Name, signature, social security number,
physical characteristics or description, address, telephone number, passport
number, driver’s license or state identification card number, insurance policy
number, education, employment, employment history, bank account number, credit
card number, debit card number, or any other financial information, medical
information, or health insurance informationYesCharacteristics of protected
classifications under California or federal law
Age (40 years or older), race, color, ancestry, national origin, citizenship,
religion or creed, marital status, medical condition, physical or mental
disability, sex
(including gender, gender identity, gender expression,
pregnancy or childbirth and related medical conditions),
sexual orientation, veteran or military status, genetic
information (including familial genetic information).
YesCommercial informationRecords of personal property, products or services
purchased, obtained, or considered, or other purchasing or consuming histories
or tendenciesYesBiometric informationImagery of the iris, retina, fingerprint,
face, hand, palm, vein patterns, and voice recordings, from which an identifier
template, such as a faceprint, a minutiae template, or a voiceprint, can be
extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and
sleep, health, or exercise data that contain identifying informationNoInternet
or other electronic network activity informationBrowsing history, search
history, and information regarding a consumer’s interaction with an internet
website, application, or advertisement.YesGeolocation dataPhysical location or
movementsYesSensory dataAudio, electronic, visual, thermal, olfactory, or
similar informationYesProfessional or employment-related informationCurrent or
past job history or performance evaluationsYesNon-public education information
(per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34
C.F.R. Part 99))Education records directly related to a student maintained by an
educational institution or party acting on its behalf, such as grades,
transcripts, class lists, student schedules, student identification codes,
student financial information, or student disciplinary records.YesInferences
drawn from other personal informationProfile reflecting a person’s preferences,
characteristics, psychological trends, predispositions, behavior, attitudes,
intelligence, abilities, and aptitudes.No
SOURCES OF CALIFORNIA PERSONAL INFORMATION
We obtain the above categories of personal information from the following
categories of sources:
* Directly from you: For instance, you may provide us with information when
signing up for an account
* Indirectly from you: For example, we may observe your interactions on our
website
* From third parties: For example, a school or company with whom you conduct
business may provide us with information related to the services that we
provide.
* From publicly available information.
USE OF CALIFORNIA PERSONAL INFORMATION
We may use any of the above categories of collected User information to provide
requested services, maintain and improve our services, communicate with Clients
about Hanover Research Services and affiliated third-party services, market
Hanover Research services, prevent potentially illegal activities, protect the
rights and property of Hanover Research and third parties, respond to inquiries
of Clients, and for any other purpose to which the individual data subject has
consented. Our use and disclosure of California Personal Information is more
fully described above, in the section entitled “How We Use This Information”.
SHARING CALIFORNIA PERSONAL INFORMATION
We may disclose your personal information to a third party, as more fully
described in the section above entitled “Sharing Personal Information). The vast
majority of data that Hanover Research collects and discloses to its clients is
in its capacity as a service provider, as defined by CCPA. Accordingly, Hanover
Research does not typically “sell” CCPA-covered personal information.
In the past 12 months, Hanover Research has disclosed the following categories
of personal information for a business purpose:
* Identifiers
* Categories of personal information described in Cal. Civ. Code 1798.80(e)
* Characteristics of protected classifications under California or federal law
* Commercial Information
* Internet or other electronic network activity information
In the past 12 months Hanover Research has disclosed personal information to the
following categories of third parties:
* Clients
* Service providers
YOUR RIGHTS UNDER THE CCPA
Moreover, Hanover Research typically acts as a service provider to its Clients.
The Clients solely determine the purposes and means of processing Clients’
personal information. To the extent that Hanover Research collects or processes
CCPA-covered personal information in its capacity as a service provider,
requests for access to CCPA-covered data and deletion must be directed to the
Hanover Research Client.
If the CCPA rights apply to the personal information and Hanover Research does
not collect or process data in its capacity as a service provider, you have the
following rights:
ACCESS TO PERSONAL INFORMATION COLLECTED OR SOLD AND DATA PORTABILITY
You have the right to request that we disclose certain information to you about
our collection and use of your personal information over the past 12 months.
Once we receive and confirm your verifiable consumer request (see “Exercising
Your Rights” section), we will disclose to you:
* The categories of personal information we collected about you;
* The categories of sources for the personal information we collected about
you;
* Our business or commercial purpose for collecting that personal information;
* The categories of third parties with whom we share that personal information;
* The specific pieces of personal information we collected about you (also
called a data portability request;
If we disclosed your personal information for a business purpose, a separate
list disclosing disclosures for a business purpose, identifying the personal
information categories that each category of recipient obtained.
Deletion of Personal Information: You have the right to request deletion of
personal information. If you wish to do so, please contact us at any method
listed below. The right to deletion is subject to certain exceptions, such as if
we need the personal information to provide services or comply with legal
obligation.
No Discrimination: You will not be subject to discrimination for exercising any
of your privacy rights.
To exercise any applicable access, data portability, and deletion rights, please
submit a verifiable consumer request by: sending mail to Hanover Research, 4401
Wilson Boulevard, 4th Floor, Arlington, VA 22203, calling (202) 559-0050, or
emailing privacy@hanoverresearch.com.
Only you, or someone legally authorized to act on your behalf, may make a
verifiable consumer request related to your personal information. You may also
make a verifiable consumer request on behalf of your minor child. You may only
make a verifiable consumer request for access or data portability twice within a
12-month period. The verifiable consumer request must:
* Provide sufficient information that allows us to reasonably verify you are
the person about whom we collected personal information or an authorized
representative, which may include:
* Your name
* Address
* Additional information depending upon the type of request and the
sensitivity of the information.
* Describe your request with sufficient detail that allows us to properly
understand, evaluate, and respond to it.
We use good faith efforts to respond to a verifiable consumer request within
forty-five (45) days after its receipt. If we need more time (up to 90 days), we
will inform you of the reason and the needed extension period in writing. Any
disclosures we provide will only cover the 12-month period preceding the
verifiable consumer request’s receipt. The response we provide will also explain
the reasons we cannot comply with a request, if applicable. For data portability
requests, we will select a format to provide your personal information that is
readily useable and should allow you to transmit the information from one entity
to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request
unless it 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.
You may designate an authorized agent to make a request under the CCPA on your
behalf.
The California Shine the Light Law requires companies to disclose certain
information about information shared with third parties that is used for the
third parties’ direct marketing purposes. If you are a California resident, you
may request information about the disclosure of your personal information to
third parties for the third parties’ direct marketing purposes by
emailing privacy@hanoverresearch.com
YOUR VIRGINIA PRIVACY RIGHTS
If you are a resident of Virginia and we serve as the data controller for your
personal information, you may have the following rights:
* To confirm whether Hanover Research is processing your personal information
and, if so, to access that data
* To delete personal data processed by Hanover Research
* To obtain a portable copy of your personal information
* To correct errors in your personal information, taking into account the
nature of the personal data and the purposes of the processing
* To opt out of targeted advertising (as defined by Virginia law)
To exercise your Virginia Privacy Rights, use any of the methods in the “Contact
Us” section of this Privacy Notice.
If we serve as the data processor for a client, you must contact the client to
exercise your privacy rights.
YOUR COLORADO PRIVACY RIGHTS
If you are a resident of Colorado and we serve as the data controller for your
personal information, you may have the following rights:
* To confirm whether Hanover Research is processing your personal information
and, if so, to access that data
* To delete personal data processed by Hanover Research
* To correct errors in your personal information, taking into account the
nature of the personal data and the purposes of the processing
* To opt out of targeted advertising (as defined by Colorado law)
To exercise your Colorado Privacy Rights, use any of the methods in the “Contact
Us” section of this Privacy Notice.
If we serve as the data processor for a client, you must contact the client to
exercise your privacy rights.
YOUR CONNECTICUT PRIVACY RIGHTS
If you are a resident of Connecticut and we serve as the data controller for
your personal information, you may have the following rights:
* To confirm whether Hanover Research is processing your personal information
and, if so, to access that data
* To delete personal data processed by Hanover Research
* To correct errors in your personal information, taking into account the
nature of the personal data and the purposes of the processing
* To opt out of targeted advertising (as defined by Connecticut law)
To exercise your Connecticut Privacy Rights, use any of the methods in the
“Contact Us” section of this Privacy Notice.
If we serve as the data processor for a client, you must contact the client to
exercise your privacy rights.
YOUR UTAH PRIVACY RIGHTS
If you are a resident of Utah and we serve as the data controller for your
personal information, you may have the following rights:
* To confirm whether Hanover Research is processing your personal information
and, if so, to access that data
* To delete personal data processed by Hanover Research
* To opt out of targeted advertising (as defined by Utah law)
To exercise your Utah Privacy Rights, use any of the methods in the “Contact Us”
section of this Privacy Notice.
If we serve as the data processor for a client, you must contact the client to
exercise your privacy rights.
ADDITIONAL INFORMATION FOR INDIVIDUALS LOCATED IN CANADA
If you are located in Canada, subject to limited exceptions under applicable
law, you have the right to access, update, and correct inaccuracies in your
personal information in our custody and under our control, and to withdraw
consent to our collection, use and disclosure of your personal information. You
may request access, updating and corrections of inaccuracies in your personal
information in our custody or control, or withdraw your consent, by contacting
us at the contact information under “Contact Us” below. We may request certain
personal information for the purpose of verifying the identity of the individual
seeking access to his or her personal information records.
Some of our internal resources, third-party vendors and affiliates are located
in the United States and other foreign jurisdictions. Your personal information
may be transferred, accessed, collected, stored and processed outside of Canada,
or the province in which you reside (which may include transfer outside of
Quebec for Quebec residents). Hanover Research, its affiliates and third-party
vendors may disclose your personal information in response to a search warrant
or other legally valid inquiry or order or as otherwise required or permitted by
United States or other laws (which may include disclosure to United States and
foreign courts, law enforcement or governmental authorities).
LINKS TO THIRD-PARTY WEBSITES
Our site provides links to third-party websites, such as those of our clients.
Hanover Research does not control and is not responsible for the information
policies or practices of these third parties. You should review the privacy
policies governing these third parties and their websites to learn more about
how they collect and use your personal information.
INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
If you are located outside of the United States, please be aware that the
information we collect will be transferred to and processed in the United States
by us and will be subject to the laws of the United States (which may include
access by US law enforcement, courts and governmental authorities).
For EU, UK and EEA residents, if we provide any personal information about you
to any non-EEA or non-UK members of our group or third parties, we will take
appropriate measures to ensure that the recipient protects your personal
information adequately in accordance with this privacy policy. These measures
may include the following permitted in Articles 45 and 46 of the General Data
Protection Regulation:
* ensuring that there is an adequacy decision by the European Commission in the
case of transfers out of the EEA, or by the UK Government in the case of
transfers out of the UK, which means that the recipient country is deemed to
provide adequate protection for such personal data; or
* where we have in place model contractual clauses with the recipient which
have been approved by the European Commission (or the UK Government for
transfers out of the UK). These model contractual clauses include certain
standard safeguards to protect the personal data.
Further details on the steps we take to protect your personal information, in
these cases is available from us on request by contacting us using the details
in the ‘Contact Us’ section below.
HOW TO OPT OUT OF COMMUNICATIONS WITH HANOVER RESEARCH
If you would like to opt out of further marketing communications from us, please
unsubscribe at the following link: https://www.hanoverresearch.com/optout.
Please note that you may continue to receive certain transactional or
account-related communications from us.
ACCESS TO PERSONAL INFORMATION
In accordance with applicable law, you may access, update and correct
inaccuracies in your personal information in our custody or control at any time,
subject to limited exceptions prescribed by law. You can request access,
corrections or updates to all personal information by contacting us as set out
in the Contact Us section below. We may request certain personal information for
the purposes of verifying the identity of the individual seeking access to their
personal information records.
CONTACT US
If you have any questions or concerns about this Privacy Policy or the
information collection and handling practices of us or our service providers, or
you would like to exercise any of your rights and choices over your personal
information, please contact our Privacy Officer at:
4401 Wilson Boulevard, 9th Floor, Arlington, VA 22203
Phone: (202) 559-0050
Email: privacy@hanoverresearch.com
If you are located in the EU, UK, EEA, or certain other jurisdictions, you may
also make a complaint to the data protection regulator in the country where you
usually live or work, or where an alleged infringement of the General Data
Protection Regulation or other applicable privacy laws has taken place.
Alternatively, you may seek a remedy through the relevant courts if you believe
your rights have been breached.
Effective Date: This Privacy Policy was updated on September 6, 2023 and is
effective as of that date.
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