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Home Legal Privacy notice


FORSTA PRIVACY NOTICE

Effective Date: 09 October 2023

1. Introduction

Your privacy is important to the Forsta group (“Forsta”, “ we,” “us,” or “our”).
Forsta provides our customers with a wide array of tools so they can turn
insight into stories that fuel action. If you would no longer like to be
contacted by one of our customers that use our services, please contact the
customer directly.

This privacy notice discloses the information practices for Forsta web sites
(forsta.com, confirmit.com, dapresy.com, focusvision.com), our recruitment
efforts, our relationships with vendors and partners, and our mobile
applications (including AskMe, CAPI, Mobile Panel, SODA, and Confirmit Go),
including what type of information is gathered and tracked, how the information
is used, and with whom the information is shared.

This notice applies to personal data collected about Forsta customers, vendors,
partners, web-visitors, registered account holders of our products, mobile app
users, and applicants to positions at Forsta.

2. When does Forsta process my data?

There are two types of situations in which we may process your personal data.

2.A. For the first type, Forsta acts as on behalf of its customers, meaning we
do not determine the purpose or means of the processing ourselves and instead
our customers do (usually as a software-as-a-service (“SaaS”) provider for
companies conducting data collection and reporting activities via the Internet
or mobile apps). You may be submitting responses to web surveys or app surveys
via mobile devices, and the template of the survey may state “Powered by
Forsta.” or similar. Surveys launched by Forsta’s customers may be hosted on
Forsta’s SaaS environments, or alternatively they may be hosted on the
customer’s own servers. In this situation, Forsta is sometimes called the ‘data
processor’ or ‘service provider’.

In these cases, please be aware that it is our customers who are initiating or
performing the data collection, who determine from whom to collect personal
data, and who define how to use the collected personal data. Our customers are
often called ‘data controllers’ in such case. For more details about how a
Forsta’s customer intends to use your personal data, please refer to the privacy
notice of the Forsta customer from whom the email or the web survey
originates. If you would no longer like to be contacted by one of our customers
that use our services, please contact the customer directly.

In these cases, Forsta will process any and all personal data uploaded to or
collected via the SaaS by our customers. However, Forsta intends to process such
personal data with appropriate and adequate safeguards to prevent unauthorized
breach or use. For more information related to Forsta’s role as a data
processor, please see Section 3 below, “Forsta as a data processor.”

2.B. The second type of situation where we may process your personal data is
when we interact with our customers, prospective customers, potential recruits,
vendors, and partners, often through the Forsta websites. Forsta usually acts as
the data controller in these instances as described in this notice. See Section
4 below for more information about these situations.

3. Forsta as a data processor

3.A. Our role as a processor

In relation to our roles as SaaS provider and data processor, Forsta processes
information under the instructions of its customers and has no direct
relationship with the individuals whose personal data Forsta collects or
processes on behalf of its customer.

If you seek access to correct, amend, or delete inaccurate personal data, or if
you seek to invoke any other rights in respect to the personal data under
applicable laws, you should direct your query to Forsta’s customer as the data
controller. We will honor and support any instructions our customer provide us
with respect to your personal data. If Forsta is requested by Forsta’s customer
to take actions on personal data (access, update, export, delete or other as
required), we will respond within a reasonable timeframe in accordance with
applicable laws.

If you would no longer like to be contacted by one of our customers that use our
SaaS service, please contact the customer directly.

If you have reached out to our customer and are not getting a reply, you may
approach Forsta in accordance with section 6 below.

3.B. Data storage, data access, data transfers, and data retention

Personal data that our customers collect from you may, subject to adequate
confidentiality undertakings, and for the sole purpose of providing our
customers with the services they have contracted from us , be accessed by
personnel, contractors, and third-party services providers of Forsta and its
affiliates. In any such case, the personnel granted access to your personal data
will have been deemed by their managers to have a reasonable business need to do
so.

Where Forsta transfers personal data to one of our affiliates or sub-processors,
we will have legally compliant transfer mechanisms in place. See more details
in Section 4.F. below.

For purposes of complying with data privacy laws throughout the EEA,
Switzerland, the UK, and other jurisdictions, where Forsta transfers personal
data to an entity which is outside of the EEA and in organized a jurisdiction
which has not received an ‘adequacy decision’ or similar from the jurisdiction
from which the data is being transferred, Forsta makes such transfers only if
subject to an adequate transfer mechanism as described by applicable data
privacy law, e.g., standard data protection clauses.

We will retain personal data our customers have instructed us to process for
them for as long as needed to provide services to our customers in accordance
with the contractual terms in our agreements with them. Our customers can at any
time instruct for such personal data to be updated, exported, deleted, or as
otherwise required. Forsta will retain personal data as necessary to comply with
our legal obligations, resolve disputes, and in accordance with our customer
agreements.

3.C. Security measures

Forsta operates under a strong security and privacy regime. If your personal
data is stored on Forsta’s SaaS environments, you are welcome to read more about
how we protect it by applying the appropriate technical and organizational
measures (TOMS) at the following link.

3.D. Device information

When you download and use mobile apps produced by Forsta, at the instruction of
our customers we automatically collect information on the type of device you
use, operating system version, and where applicable, the device identifier (or
“UDID”).

The mobile apps do not require location permission in order to be used. However,
our customers who are using our mobile apps in order to collect personal data
from you may request that the mobile apps collect your precise geolocation.
Should location be requested, you will be prompted by the operating system of
your device with a message that the mobile app has requested to access the
device location (please note that Android OS 6 or older versions lack of this
feature). You can accept or reject that request. If permission has been granted,
this permission can be later changed at any time under the operating system
settings area.

Depending on our customers’ use of the mobile app, the mobile app may also use
beacons or similar technologies as part of the survey taking.

If you would no longer like this information to be used, please contact our
customer directly.

3.E. Cookies and Tracking Technologies on the SaaS environment

At the instruction of our customers, we and our service providers use cookies,
web beacons, scripts, eTags, local storage (HTML5) or similar tracking
technologies. These technologies are used on the SaaS environment to provide you
with a better user experience, including to authenticate users of, or
personalize the content on the SaaS website or online service. They are also
used to preserve functionality in our SaaS platforms, such as monitoring of
network communications, maintain or analyse the functioning of the SaaS website
or online service, protect the security or integrity of the user, SaaS website
or online service.

You can control the use of cookies at the individual browser level, but if you
choose to disable cookies, it may limit your use of certain features or
functions on the SaaS environment.

We do not use cookies in surveys you are invited to take via an email invitation
with a clickable link or via pop-ups or web intercepts, but our customers using
the SaaS may launch their own cookies, which we may not be aware of. Please
contact the company inviting you to access the surveys or reports delivered via
the SaaS for information about their cookies.

4. Forsta as a data controller

4.A. Our role as a data controller

The security of your personal data is important to us. We follow generally
recognized industry standards and all legally required measures to protect the
personal data submitted to us during transmission and once it is received. In
general, you can visit Forsta on the Internet without telling us who you are and
without giving any personal data about yourself, except that we may log IP
address and geolocation. There are times, however, when Forsta or our partners
may request additional personal data from you to serve legitimate purposes.

Forsta will act as a data controller where, for example, you visit our websites
and provide us with your contact details to obtain access to resources, or where
we store your details as part of our management of accounts you have with us in
your role as a customer. As a user of our Services, Forsta will also act a
controller in relation to how you use our software (e.g., how long used, which
services used, etc.). Further, Forsta also acts as a data controller during
recruitment processes (see section 4.Q below). Where Forsta acts as the data
controller, you may choose to provide us with your personal data in a variety of
situations. For example, you may want to give us information such as your name,
physical address, email address, zip code, resume, phone number, and additional
contact information. We intend to let you know how we will use such information
and seek your consent when required by applicable laws before we collect it from
you.

You may at any time revoke your consent or invoke rights in relation to the
personal data provided to us in accordance with applicable laws. If you tell us
that you do not want us to use this information to make further contact with you
beyond fulfilling your requests, we will respect your wishes. If you give us
personal data about somebody else such as a spouse or work colleague, we will
assume that you have his or her permission to do so.

Forsta will also act as data controller when processing personal data for
administrative and operational purposes related to our provision to customers of
services under agreements we have with them. Processing of such personal data
will serve administrative and operational purposes such as account management,
product improvement, invoicing and financial reporting, data protection and
cybersecurity, and complying with our legal obligations.

Forsta does not request the disclosure of special categories of personal data or
sensitive data.

You may contact Forsta in order to invoke your rights as a data subject under
applicable laws in accordance with section 6 below.

4.B. Information required by applicable data privacy laws

a. If you are located in the European Economic Area, the UK, or Switzerland and
Forsta controls your personal data, Forsta AS is the specific data controller
responsible for your personal data unless otherwise stated in another more
specific privacy notice. The operations of Forsta AS are Forsta’s main
establishment in the EEA for EU GDPR purposes. Forsta AS can be reached at
DataProtectionOfficer@forsta.com. The operations of Forsta Worldwide Ltd. are
Forsta’s establishment in the UK for UK GDPR purposes. It can be reached at
DataProtectionOfficer@forsta.com. The data protection officer for Forsta can be
reached at DataProtectionOfficer@forsta.com

b. Further contact details of our data protection officer are available in
section 6 below.

c. The purposes of the processing are either stated in the consent note we
obtain from you prior to processing your personal data, or alternatively:

· To fulfill your transaction request;

· To provide you with a subscription;

· To provide you with support and consulting services;

· To verify your identity;

· To provide information on products, services, or callback requests;

· To send you specific marketing materials;

· To allow our business partners to contact you for marketing purposes;

· In connection with a job application or inquiry;

· To contact you about employment consideration; and

· To invite you to complete web surveys.

d. The legal basis for these purposes detailed in 4.B.c above is legitimate
interests. 

Marketing Preferences – If you no longer wish to receive communications from us,
you may opt-out by following the unsubscribe instructions located at the bottom
of each communication. You may opt back in by emailing us or completing other
opt-in actions offline or online.

d. The recipients of your personal data will be selected Forsta employees and
third parties such as affiliates, hosting providers, web-based software tool
providers, and contractors working for Forsta. All such recipients will always
be under contract with Forsta ensuring data protection levels equivalent to
those set forth in this privacy notice and required by applicable law. Further
details may be provided upon request.

Where personal data collected in the EEA, UK, or Switzerland is transferred to a
subcontractor in a third country outside of these areas and such country is not
deemed to meet the adequacy standards of the relevant regulatory body, Forsta
shall have ensured adequate safeguards with such subcontractor both technically
and contractually.

e. Data Retention – We will retain your personal data for as long as reasonably
necessary in accordance with the purpose of the processing as communicated to
you as part of the consent or privacy notice.

· We will retain personal data we process about our customers for as long as
needed to provide services to our customers in accordance with the contractual
terms in our agreements with them. Forsta will retain such personal data as
necessary to comply with our legal obligations and to resolve disputes.

· When we have no ongoing legitimate purpose to process your personal
information, we will either delete or anonymize it. In cases where your personal
information has been stored in backup archives, we will securely store your
personal information, isolate it from any further processing and anonymize or
delete it as soon as possible.

· To determine the appropriate retention period for personal data, we consider
the amount, nature and sensitivity of the personal data, the potential risk of
harm from unauthorised use or disclosure of your personal data, the purposes for
which we process your personal data and whether we can achieve those purposes
through other means, and the applicable legal, regulatory, tax, accounting or
other requirements.

f. You have the right to seek access to and rectification or erasure of your
personal data in accordance with applicable laws as set forth in section 5
below.

g. Where our processing of your personal data is based on your consent, you have
the right to withdraw such consent at any time as set forth in section 5 below.

h. Where applicable laws so prescribe, you have the right to lodge a complaint
to a supervisory authority.

4.C. Information for Forsta business partners

If you represent a Forsta business partner, you may visit a Forsta website
intended specifically for Forsta business partners. We may use information
provided on that site to administer and develop our business relationship with
you, the business partner you represent, and Forsta business partners generally.

4.D. Information for Forsta customers

If you work for a Forsta customer, you may visit a Forsta website intended
specifically for Forsta customers. We may use information provided on that site
to administer and develop our business relationship with you, the customer for
which you work, and Forsta customers generally.

We may also collect and process your personal data as necessary for the
performance of the contract in place between the Forsta customer and Forsta in
accordance with applicable data privacy laws.

4.E Other Forsta website notices

In some cases, specific Forsta websites may contain other notices about their
use and the information practices applicable to those sites. Such notices will
supersede this notice if it is not directly referenced.

4.F Cross-border flows of personal data

Forsta is a global organization with legal entities, business processes,
management structures, and technical systems that cross borders.

Our privacy practices are designed to provide protection for your personal data
in accordance with the laws applicable to each respective Forsta affiliate.

We may share your personal data within Forsta, or with service providers and
transfer it to countries in the world where we or our service providers do
business.

Transfers of your personal data between the Forsta group of companies are made
subject to intra-group personal data transfer agreements which include the use
of appropriate transfer mechanisms. Transfers of your personal data from the
Forsta group of companies to their respective service providers will be subject
to adequate contractual terms, including where required, EU/UK Model Clauses.

Some countries may provide less legal protection for your information. In such
countries, Forsta will handle information in the manner we describe in this
privacy notice.

4.G. Sharing with Services Providers and Business Partners

Service Providers

We may share your information with third parties who provide services on our
behalf to help with our business activities under contractual terms providing
adequate protection to your information. These companies are authorized to use
your personal data only under our instructions and only as necessary to provide
the contracted services to us. These services may include:

· Sending marketing communications

· Fulfilling subscription services

· Conducting research and analysis

· Providing data center facilities

Before we share personal information, we enter into written agreements with
recipients which contain data protection terms that safeguard your data.

4.H. Passive collection

As is true of most websites, we gather certain information automatically. This
information may include Internet protocol (IP) addresses, browser type, Internet
service provider (ISP), referring and exit pages, the files viewed on our site
(for example, HTML pages, graphics, or other), operating system, date and time
stamp, and clickstream data to analyze trends in the aggregate and administer
the site .

4.I. Cookies and Tracking technologies

Forsta, our services providers, and our partners use cookies, web beacons,
scripts, eTags, local storage (HTML5) or similar tracking technologies to
analyze trends, administer the website, track users’ movements around the
website, and to keep track of the domains from which people visit. We may
extract some information about your transactions in a non-identifiable format
and combine it with other non-identifiable information such as clickstream data
and gather demographic information about our user base as a whole.

You can control the use of cookies at the individual browser level, but if you
choose to disable cookies, it may limit your use of certain features or
functions on our website or service.

Social Media Features – Our sites and services may include social media
features, such as Facebook “Like” button and Twitter re-tweets, as well as share
buttons or interactive mini-programs. These features collect the user’s IP
address, the pages visited on the site or service, and set cookies to enable the
features to function properly. Social media features are either hosted by a
third party or hosted directly on the Website. Interactions with these features
are governed by the privacy notices of the social media companies that provide
them.

4.J. Mobile analytics

We use mobile analytics software to allow us to better understand the
functionality of our mobile software on your phone. This software may record
information such as how often you use the application, the events that occur
within the application, individual and aggregated usage, performance data, and
from where the application was downloaded. We do not link the information we
store within the analytics software to any personally identifiable information
you submit within the mobile application.

4.K. Service quality monitoring

Certain web transactions may also involve you calling us or our calling you.
Please be aware that it is Forsta’s general practice to monitor and in some
cases record such calls for staff training or quality assurance purposes.

4.L. Personalized URL link

On occasion, we may personalize and customize websites for certain visitors. If
you visit one of these sites, you may find it customized with references to
products and services that we believe may be of interest to you based on your
previous interactions with Forsta and information you have provided to us. While
you are visiting these websites, we may collect information about your visit to
better tailor the site to your interests. An invitation to visit one of these
websites is usually presented as a personalized URL in an email, a notice on a
website registration page, or as a response to you logging on to a certain
website.

4.M. Disclosures required by law or to fulfill a business transition

We may also disclose your personal data as required by law such as to comply
with a subpoena or other legal process when we believe in good faith that
disclosure is necessary to protect our rights, protect your safety or the safety
of others, investigate fraud, or respond to a government request. If Forsta is
involved in a merger, acquisition, or sale of all or a portion of its assets,
you will be notified via email or a prominent notice on our website of any
change in ownership, uses of your personal data, and choices you may have
regarding your personal data. We may also disclose your personal data to any
other third party with your prior consent.

4.N. Links to non-Forsta websites

Forsta websites may contain links to other websites. Forsta is not responsible
for the privacy practices or the content of those other websites.

4.O. Notification of changes

We may update this privacy notice to reflect changes to our information
practices. If we make any material changes we will notify you by email (sent to
the e-mail address specified in your account) or by means of a notice on this
website prior to the change becoming effective. We encourage you to periodically
review this page for the latest information on our privacy practices.

4.P. Information We Acquire from Third Parties

We may receive information about you from other sources including publicly
available databases or third parties from whom we have purchased data and
combine this data with information we already have about you. This helps us to
update, expand, and analyze our records, identify new customers, and provide
products and services that may be of interest to you. If you provide us personal
data about others or if others give us your information, we will only use that
information for the specific reason for which it was provided to us.

Examples of the types of personal data that may be obtained from public sources
or purchased from third parties and combined with information we already have
about you may include purchased marketing data about our customers from third
parties that is combined with information we already have about you to create
more tailored advertising and products.

4.Q. Recruitment

During recruitment processes, we will be in need of processing personal data
about job applicants. Such processing will be in compliance with the laws of the
jurisdiction in which we recruit. Our processes for retention and deletion of
documents and data related to recruitment processes is set forth in “Forsta HR
Data Retention Policy”. For any questions, please see Section 5 below.

4.R Do Not Track Signals

We do not collect or respond to Do Not Track signals and our websites do not
function differently based on any Do Not Track preferences that may be received.
For more information on Do Not Track signals, please visit
https://allaboutdnt.com/

5. Forsta’s notice regarding the California Consumer Privacy Act (“CCPA”) (For
California Residents)

Please note that this section relates to our direct consumers, such as business
contacts who work for our customers. If you are a consumer of one of our
customers (the business which sent you the survey which lead you here, for
example), please contact that company directly, such as through the contact
methods they provide in their privacy notices. We will not be able to carry out
your requests to exercise your rights under the CCPA in relation to personal
information controlled by our customers.

a. Your Rights: Subject to certain exceptions, the CCPA affords you the
following rights:

1. Right to know/access personal information collected, disclosed, or sold.

2. You have the right to request that we disclose the following information for
the 12-month period preceding your request:

i. The categories of personal information that we have collected about that
consumer;

ii. The categories of sources from which the personal information was collected;

iii. The business or commercial purpose for collecting or selling the personal
information;

iv. The categories of third parties with whom we share the personal information;
or,

v. The specific pieces of personal information we have collected about that
consumer.

3. Right to Request Deletion of Personal Information

You have the right to request that we delete any personal information about the
consumer that we have collected or that we maintain. Please note that there are
exceptions to this deletion right, such as the information we need to keep
complying with the CCPA, that is permitted to be retained under the CCPA, or is
required or permitted to be retained under other applicable laws.

4. Right to Not Be Discriminated Against

You have the right not to receive discriminatory treatment from us for the
exercise of the privacy rights conferred by CCPA and listed in this CCPA Privacy
Notice.

If you make a request to us under this section, we are required to verify your
identity before complying with your request. Your request should come from the
same e-mail address that you registered with us. We may need to ask for
additional verification details as applicable from time to time. You may
designate an authorized agent to make a request under the CCPA on your behalf,
but you must verify that you authorize your agent to do so.

b. You are able to opt out of our sale of your personal information to third
parties. You may do so by requesting such via an email to privacy@forsta.com.

c. We collected the following categories of personal information from consumers
over the past twelve months:

Category of personal information collectedCategories of sources from which this
category of personal information was collectedBusiness or commercial purpose for
which this category of personal information was collectedCategories of third
parties with whom Forsta shares this category of personal informationPersonal
identifiersConsumers and our service providersMarketing, sales, SaaS, and
support thereofService providers which assist us with SaaS, marketing and sales,
and support thereofPersonal informationConsumers and our service
providersMarketing, sales, SaaS, and support thereofService providers which
assist us with SaaS, marketing and sales, and support thereofInternet or other
electronic network activity informationConsumers and our service
providersMarketing, sales, SaaS, and support thereofService providers which
assist us with SaaS, marketing and sales, and support thereofProfessional or
employment-related informationConsumers and our service providersMarketing,
sales, SaaS, and support thereofService providers which assist us with SaaS,
marketing, sales, and support thereofConsumer profilesConsumers and our service
providersMarketing, sales, and support thereofService providers which assist us
with support

d. We have not sold personal information of consumers in the past twelve months.

e. We have disclosed personal information to service providers for a business
purpose in the past twelve months. The categories of personal information we
disclosed are stated in the table above.

f. We have contractual requirements in place with our service providers so that
they will not further collect, sell, or use personal information except as
necessary to perform our business purpose.

g. We do not sell personal information of minors under 16 years of age without
affirmative authorization.

To make any requests pursuant to this section, or if you have any questions or
comments for us in regards to this section, please contact
us privacy@forsta.com. See also Section 6 below.

6. Privacy questions, access rights, incident reporting

If you have any questions about how we use your personal data or about this
privacy notice, you can send an email to privacy@confirmit.com. You can also
contact us by mail at 300 Seventh Ave., 3rd Floor, New York, NY 10001, or you
may contact us at the physical addresses of the office closest to you, see our
list here.

If you would like to reach Forsta’s Data Protection Officer (as defined under
the GDPR) you can contact DataProtectionOfficer@confirmit.com .

If you have an unresolved privacy or personal data use concern that we have not
addressed satisfactorily, please contact your local data protection authority.

Upon request, Forsta will provide you with information about whether we control
any of your personal data on our own behalf. If you wish to obtain a copy of
particular information you provided to Forsta, if you become aware that the
information is incorrect and you would like us to correct it, update it, or
delete it, if you would like to exercise any of your legal rights such as those
in relation to updating your preferences regarding how we use your personal
data, or to withdraw consent, contact us at privacy@confirmit.com . We will
respond to your access request within a reasonable timeframe within the
timelines prescribed by applicable law.

If you are enquiring or exercising any of your legal rights or want to withdraw
your consent on behalf of personal data we collect and process under the
instructions of our customers (see section 3 above), please direct your query to
our customer, which is the data controller. If you contact our company in
relation to this, we are under obligation to refer your enquiry to the data
controller. We will honor and support any lawful instructions they provide us
with respect to your personal information.

Before Forsta can assist you, provide you with any information, or correct any
inaccuracies, we may ask you to verify your identity and to provide other
details to help us to respond to your request. We will endeavor to respond
within an appropriate timeframe.

Should you want to report an incident relating to Forsta’s security,
confidentiality, or privacy, you are welcome to file a report by entering
required data at http://securityincident.forsta.com . Alternatively,
contact privacy@confirmit.com.

7. International Transfers

For purposes of complying with data privacy laws throughout the EEA,
Switzerland, and the UK, where Forsta transfers personal data to an entity which
is outside of these areas and in organized a jurisdiction which has not received
an ‘adequacy decision’ or similar from the relevant regulatory body, Forsta
makes such transfers only if subject to an adequate transfer mechanism as
described by the relevant data privacy law, e.g., standard data protection
clauses, model clauses, standard contractual clauses, etc. However, Forsta will
remain liable for its obligations as a controller of your personal data
regardless of any transfer.

As related to some transfers from the EEA/UK/Switzerland to entities organized
in the USA, two of Forsta’s US-based affiliates (Forsta, Inc. and Forsta
Worldwide, Inc.) comply with the EU-U.S. Data Privacy Framework (EU-U.S. DPF)
and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy
Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. 
Forsta Worldwide Inc. and Forsta Inc. have certified to the U.S. Department of
Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles
(EU-U.S. DPF Principles) with regard to the processing of personal data received
from the European Union and the United Kingdom in reliance on the EU-U.S. DPF
and the UK Extension to the EU-U.S. DPF.  Forsta Worldwide Inc. and Forsta Inc.
have certified to the U.S. Department of Commerce that it adheres to the
Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with
regard to the processing of personal data received from Switzerland in reliance
on the Swiss-U.S. DPF.  If there is any conflict between the terms in this
privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF
Principles, the Principles shall govern.  To learn more about the Data Privacy
Framework (DPF) program, and to view our certification, please visit
https://www.dataprivacyframework.gov/

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and
the Swiss-U.S. DPF, Forsta Worldwide Inc. and Forsta Inc. commit to resolve DPF
Principles-related complaints about our collection and use of your personal
information.  EU and UK individuals and Swiss individuals with inquiries or
complaints regarding our handling of personal data received in reliance on the
EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF
should first contact us at:

 privacy@forsta.com.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and
the Swiss-U.S. DPF, Forsta Worldwide Inc. and Forsta Inc. commit to cooperate
and comply respectively with the advice of the panel established by the EU data
protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO)
and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with
regard to unresolved complaints concerning our handling of personal data
received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF
and the Swiss-U.S. DPF. Individuals may have the right, under certain
conditions, to invoke binding arbitration related to their complaints. Further,
Forsta Worldwide Inc. and Forsta Inc. are subject to the investigatory and
enforcement powers of the Federal Trade Commission (FTC).

8. Disclaimer

Note that Forsta as a provider of online survey software enables its customers
to send emails to individuals asking them to participate in market research
surveys or to provide customer and employee feedback. Forsta does not authorize,
approve, or in any other way bear responsibility for emails sent out by
customers.

9. Minors and Children under the Age of 13

Forsta does not allow children under the age of 13 or children considered
“Minors” as designated by the laws under which they fall, to use any of our
services without proper consent from a parent or legal guardian. If you believe
we might have any information from or about a Minor that was collected without
proper consent, please contact us at the address provided below.

10. Definitions

In this privacy notice, the term “personal data” includes:

· Under the laws of the United States, personal data shall include any
“non-public personal information” as that term is defined in the
Gramm-Leach-Bliley Act found at 15 USC Subchapter 1 §6809(4), and “protected
health information” as defined in the Health Insurance Portability and
Accountability Act found at 45 CFR §160.103.

· Under the laws of the countries in the European Economic Area (“ EEA”),
personal data shall have the meaning given to it in Directive 95/46/EC (the “EU
Directive”) and in the General Data Protection Regulation (“GDPR”).

· Under the laws of Australia, personal data shall include information or an
opinion about an identified individual or an individual who is reasonably
identifiable: (a) whether the information is true or not; and (b) whether the
information or opinion is recorded in a material form or not.

· Under the laws of California, personal data shall include any “personal
information” as that term is defined in the California Consumer Privacy Act
(“CCPA”) §1798.140(o).

“Data controller” means the party that determines the purposes or means of the
processing of the personal data.

“Data processor” means the party that processes the personal data on behalf of
the data controller.

“Personal information” generally means information that identifies, relates to,
describes, is reasonably capable of being associated with, or could reasonably
be linked, directly or indirectly, with a particular consumer or household.

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Also of Interest
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