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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.
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 includes, 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 will 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 platform, such as Qualtrics or SurveyGizmo.
* 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 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 uses the data from
such third-party sources primarily to provide research services. Hanover 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. 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. 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).
INFORMATION ABOUT CHILDREN 13 YEARS OLD
Although this website is not directed to children under 13 years old, Hanover
Research’s clients, which include school districts and corporate clients, may
ask Hanover Research to use online services to conduct surveys of children under
13 years old.
When clients request that Hanover Research conduct surveys of children under 13
years old, the clients typically provide the children with links to Hanover
Research-created surveys, usually hosted on a third-party site. Hanover Research
collects and processes the children’s responses to the surveys. The information
that Hanover Research collects may include their school, grade, and IP address.
Students who are surveyed on behalf of school districts usually take the surveys
on school computers.
Hanover Research’s surveys typically do not result in the collection of personal
information, as defined by the Children’s Online Privacy Protection Act (COPPA).
Out of an abundance of caution, however, Hanover Research will only conduct
surveys of students under 13 years old upon receiving consent from either the
student’s school, school district, or parent. If the survey of a child under 13
years old is conducted on behalf of a corporate client, Hanover Research will
obtain verifiable consent from the child’s parent.
Hanover Research’s online services do not enable a child under 13 years old to
make personal information publicly available.
Hanover Research only uses information collected from children under 13 years
old to produce research reports for the school districts and corporate clients
that requested the survey be conducted. The information in the report does not
contain personally identifiable information about any children under 13.
For any inquiries concerning Hanover Research’s privacy policies and use of
children’s information, contact: Hanover Research, Attention: Privacy & Data
Protection, 4401 Wilson Boulevard, 4th Floor, Arlington, VA 22203; (202)
559-0050 privacy@hanoverresearch.com. In the rare event that Hanover Research
has collected personal information, as defined by COPPA, from a child under 13
years old, the child’s parent can contact Hanover Research to request a review
or deletion of the child’s personal information, or to refuse to permit further
collection of personal information.
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. 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.
* Hanover Research may use any information that survey respondents voluntarily
provide to Hanover Research, in combination with any other information, to
provide research and insights to clients. Please note that depending on the
specific contractual relationship with the client, Hanover may be acting as
either a data controller or a data processor, or both.
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
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, primarily
through 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 shares 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. 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, your
personal information may be disclosed to third parties as part of the
transaction.
SECURITY
We maintain reasonable 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. 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 for which the
data was collected has ended; the sensitivity of the personal information; and
whether the information could be anonymized or aggregated.
ADDITIONAL INFORMATION FOR INDIVIDUALS LOCATED IN THE EUROPEAN UNION
If you are located in the European Union 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 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 is acting as the 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 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
movementsNoSensory dataAudio, electronic, visual, thermal, olfactory, or similar
informationNoProfessional 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
Some of the personal information that Hanover Research collects is related to
employees. Most of the rights provided under the CCPA do not currently apply to
employment-related personal information collected from California-based
employees, job applicants, contractors, or similar individuals. The CCPA also
currently exempts personal information reflecting a written or verbal
business-to-business communication from many of its requirements.
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.
In the rare instance that 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.
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 and EEA residents, if we provide any personal information about you to
any non-EEA 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:
* in the case of transfers to US based entities, entering into European
Commission approved standard contractual arrangements with them, or ensuring
they have signed up to the EU-US Privacy Shield (see
further https://www.privacyshield.gov/welcome); or
* in the case of transfers to entities based in other countries outside the
EEA, entering into European Commission approved standard contractual
arrangements with them.
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
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.
TRANSPARENCY IN COVERAGE RULE
Access the Cigna Federal Transparency in Coverage Rule machine-readable files
which outline negotiated rates between health plans and providers here.
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 update or correct any information that you have previously
provided to us, please contact us at:
4401 Wilson Boulevard, 4th Floor, Arlington, VA 22203
Phone: (202) 559-0050
Email: privacy@hanoverresearch.com
We will send you a response within 30 days. If you are located in the EU or EEA,
you may also make a complaint to the Information Commissioner’s Office in the
UK, or the data protection regulator in the country where you usually live or
work, or where an alleged infringement of the General Data Protection Regulation
has taken place. Alternatively, you may seek a remedy through the relevant
European courts if you believe your rights have been breached.
Effective Date: This Privacy Policy was updated on May 27, 2020 and is effective
as of that date.
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