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PRIVACY POLICY

The purpose of this Privacy Statement is to inform you about the practices and
procedures of IPSOS (as follows, “we” or “us”) in handling Personal Information
and to inform you about the Personal Information we collect about you (for
example, when you participate in one of our surveys). It explains how we use and
disclose that information, the choices you have regarding such use and
disclosure, and how you may correct that information.

If you are a resident of the United States of America and have any questions or
comments regarding this statement, you should first contact our Member Relations
Team at Ipsos, Social Media Exchange, Member Relations, 222 West Adams Street,
Suite 1100, Chicago IL 60606 or by email using the contact us page.

We are proud to demonstrate our commitment to your privacy. From time to time,
we may make changes to this Privacy Statement. The Privacy Statement is current
as of the “last revised” date which appears at the top of this page. We will
treat Personal Information in a manner consistent with the Privacy Statement
under which it was collected and our Privacy Policy, unless we have your consent
to treat it differently. This Privacy Statement applies to any information we
collect or receive about you, from any source.




1. WHAT IS PERSONAL INFORMATION?


Personal Information is any information that is identifiable with you. This
information may include but is not limited to your name, mailing address, phone
numbers, email address, identification numbers and, in certain circumstances,
your opinions and individual preferences. Personal Information, however, does
not include (i) your name, business title or business address and business
telephone number and fax in your capacity as an employee of an organization; and
(ii) depending on the jurisdiction, publicly available information. However, if
in your capacity as an employee of an organization you participate in one of our
surveys, your responses will be treated as Personal Information.

We may collect personal information about other members of your household. This
information may include but is not limited to the age and gender of the other
household members. We use this information to determine if certain surveys are
relevant to you based on the composition of your household. Sometimes we use
this information to invite other members of your household to participate in our
surveys. If one of your household members is selected for one of our surveys we
will always deliver the survey invitation to your email address, and ask you to
personally invite the household member to participate.

We may offer you the opportunity to refer-a-friend on some of our proprietary
Custom Communities, which allows you to invite one or more friends to join the
Panel and after joining participating in any type of event on the Panel or in
surveys. This process will never ask you to provide the email address or any
other personally identifiable information about the individuals you wish to
refer. An email message with a registration link may be sent to you, and you may
be asked to pass on a link to the membership survey to one or more of your
friends. Alternatively we may encourage you to forward a link to the membership
survey to one or more of your friends by using the friend feature on the panel
homepage.




2. HOW DO WE COLLECT YOUR PERSONAL INFORMATION?


We will always collect your Personal Information by fair and lawful means (for
example, when you respond to one of our surveys or participate on our
Interactive Panel). We collect your Personal Information where we have obtained
your consent to do so or as otherwise permitted by law.

We may use a third party agent to host surveys or panel events to collect
personal information, including email address. That information is delivered to
Ipsos directly. Contractual agreements between Ipsos and third party vendors
ensure that your personal information will not be shared with anyone and will
not be used for any other purpose without your consent.

We may receive your email address from a third party through a co-registrations
process. If you indicate that you would like to join our survey Panel through
one of our co-registration partners, your email address may be provided to us
for the purpose of us sending you a link to our registration page. Our
co-registration partners may just direct you to a registration page on one of
our websites, in which case your email address will not be given to us until you
provide it at the appropriate point in our registration process. Contractual
agreements between us and our co-registration partners ensure that your personal
information will not be shared with anyone and will not be used for any other
purpose without your consent.






3. HOW DO WE USE YOUR PERSONAL INFORMATION?


We identify the purposes for which we use your Personal Information at the time
we collect such information from you and obtain your consent, in any case, prior
to such use. One of the primary purposes for which we collect your Personal
Information is to conduct marketing and social research through conducting
surveys. We may also use your Personal Information as otherwise permitted by
law. If you provide us with sensitive personal information such as health or
financial information, we will obtain your expressed consent for the collection,
use and disclosure of sensitive personal information.






4. HOW DO WE USE YOUR EMAIL ADDRESS?


We will use your email address to send you several different types of messages
related to your participation in the Panel you joined. Primarily we will invite
you to participate in any type of exercise or event on the Panel, whether it is
participating in a live chat, bulletin board discussion or other type of
exercise or send you an email invitation to participate in online surveys. Once
you have joined you can also participate by posting comments, providing feedback
and giving likes anywhere on the Panel. We will contact you by inviting you to
participate in events on the Panel or a survey. When you register to participate
in the Panel we will send an email message to the email address you provide us
to confirm that we have received your registration information. We may send you
a weekly email informing you about news, new events and contests on the Panel.
These weekly email communications are a requirement of you participation in this
Panel. You can only opt out from received the weekly emails by unsubscribing
from the Panel.

If you use the “Need help with your login name or password?” link on Panel Login
Page to inquire about your login information, you will receive an automated
email message sending you the information requested to the email address you
provided. Our Member Relations Team may also contact you using the email address
you provided to respond to your questions.






5. HOW CAN YOU OPT-OUT OF RECEIVING OUR EMAIL MESSAGES?


All of our email messages clearly explain how you can opt-out of receiving
future email communications and unsubscribe from the Panel. Our weekly emails,
event or survey invitations and other communications always include an
unsubscribe link that allows you to unsubscribe yourself from the Panel right
away or an email address that you can contact to unsubscribe. We will always
process your opt-out request within 10 business days of receiving it. Note that
you can only opt out of receiving certain emails by unsubscribing from the
Panel.






6. TO WHOM DO WE PROVIDE YOUR PERSONAL INFORMATION?


We identify to whom, and for what purposes, we disclose your Personal
Information at the time we collect such information from you and obtain your
consent to such disclosure. For example, we may disclose your Personal
Information, including email address:



a) to a client of IPSOS for the client’s purposes of conducting further
research; In such rare cases we will explain the reason for the disclosure and
ask for your consent before providing disclosure of your Personal Information;

b) a third party engaged by IPSOS to perform functions on its behalf;

c) such other disclosures of Personal Information to such persons for which you
provide your consent; and

d) as mandated by regulatory requirements

e) as otherwise permitted by law.

We reserve the right to disclose your personal identifiable information as
required by law or regulatory requirements and when we believe that disclosure
is necessary to protect our rights and/or to comply with a judicial proceeding,
court order, or legal process served on our Web site. We reserve the right to
disclose your personal identifiable information as required by law and when we
believe that disclosure is necessary to protect our rights and/or to comply with
a judicial proceeding, court order, or legal process served on our Web site.




7. WHEN AND HOW DO WE OBTAIN YOUR CONSENT?


We obtain your consent prior to collecting, and in any case, prior to using or
disclosing your Personal Information, including email address, for any purpose.
You may provide your consent to us either orally or in writing. For example,
when you participate in an event on the Panel, you provide your consent to allow
us to use your Personal Information for the purposes of conducting market and
social research and, in certain circumstances, to disclose your Personal
Information to our clients. From time to time, we may collect, use or disclose
your Personal Information based on your consent and as permitted by law. If you
provide us with sensitive Personal Information such as health or financial
information, we will obtain your express consent for the collection, use and
disclosure of such sensitive personal information.






8. HOW DO WE ENSURE THE PRIVACY OF YOUR PERSONAL INFORMATION, INCLUDING EMAIL
ADDRESS, WHEN DEALING WITH OUR AFFILIATES AND OTHER THIRD PARTIES?


We ensure that all our affiliates and other third parties which are engaged to
perform services on our behalf and are provided with Personal Information are
required by contract to observe the intent of this Privacy Statement and our
Privacy Policy and practices or are governed by the same Privacy Policy.






9. HOW LONG WILL WE USE, DISCLOSE OR RETAIN YOUR PERSONAL INFORMATION?


We will use, disclose or retain your Personal Information for as long as
necessary to fulfill the purposes for which it was collected and as permitted or
required by law. We have established minimum and maximum retention periods and
procedures for maintaining and destroying your Personal Information. If you have
any questions about the Personal Information, including email address, which we
have on file for you, you can contact our Member Relations Team by using the
contact us page. You can update your Personal Information, including email
address, using the Change of Info form on our website.






10. HOW CAN YOU REVIEW YOUR PERSONAL INFORMATION THAT WE HAVE COLLECTED, USED OR
DISCLOSED?


We will make available to you any specific Personal Information on you in our
custody or control, that we have collected, used or disclosed, upon your written
request, to the extent permitted by law. We will make such information available
to you in a form that is generally understandable, including explaining any
abbreviations or codes.






11. HOW DO YOU KNOW THAT THE PERSONAL INFORMATION WE HAVE ON YOU IS ACCURATE?


We will ensure that your Personal Information is kept as accurate, complete and
up-to-date as possible. When we collect Personal Information from you, we rely
on you for its accuracy.






12. WHAT IF THE PERSONAL INFORMATION WE HAVE ON YOU IS INACCURATE?


You can at any time, demonstrate in writing the accuracy or completeness of the
Personal Information we have on you. If you successfully demonstrate that the
Personal Information we have on you is inaccurate or incomplete, we will amend
the Personal Information as required. Where appropriate, we will transmit the
amended information to third parties having access to your Personal Information.






13. HOW FAST WILL WE RESPOND TO YOUR WRITTEN REQUESTS?


We will attempt to respond to each of your written requests not later than
thirty (30) days after receipt of such requests. We will advise you in writing
if we cannot meet your requests within this time limit.






14. ARE THERE ANY COSTS TO YOU FOR REQUESTING INFORMATION ON YOUR PERSONAL
INFORMATION OR ON OUR PRIVACY POLICY OR PRACTICES?


We will not assess any costs to you for access to your Personal Information or
on our Privacy Policy or practices without first providing you with an estimate
of the approximate costs, if any. You may withdraw your requests for access to
information by notifying us within the thirty-day notice period disclosed on the
estimate.






15. HOW DO WE KNOW THAT IT IS REALLY YOU REQUESTING YOUR PERSONAL INFORMATION?


All comments, questions, concerns or complaints regarding your Personal
Information or our Privacy Policy and practices, should be forwarded to our
Privacy Officer as set forth below. We may request that you provide sufficient
identification to permit access to the existence, use or disclosure of your
Personal Information, including email address. Any such information shall be
used only for this purpose.






16. WHAT SAFEGUARDS HAVE WE IMPLEMENTED TO PROTECT YOUR PERSONAL INFORMATION?


We have implemented physical, organizational, contractual and technological
security measures to protect your Personal Information, including email address,
from loss or theft, unauthorized access, disclosure, copying, use or
modification. The only employees, who are granted access to your Personal
Information, including email address, are those in secure data centers with a
business ‘need-to-know’ or whose duties reasonably require such information.
We prevent electronic intrusion by using firewall technology. The employees who
are granted access to your Personal Information, including email address, can
only access it using secure connections and passwords from within our networks.






17. HOW DO YOU CONTACT US REGARDING ACCESS TO YOUR PERSONAL INFORMATION OR OUR
PRIVACY POLICY AND PRACTICES?


All comments, questions, concerns or complaints regarding your Personal
Information or our Privacy Policy and practices, should be forwarded to our
Privacy Officer as follows.

USA Residents:

In writing:
Attn: Privacy Officer
Ipsos
Bank of America Advisory Panel
Social Media Exchange
222 West Adams Street, Suite 1100
Chicago, IL 60606




By email: Use the contact us page.

If you are a resident of the United States of America you may submit changes to
your Name, Mailing Address, e-Mail Address, Telephone Number by email using the
contact us page or mail to our Member Relations Team at Ipsos, Social Media
Exchange, Member Relations Team, 222 West Adams Street, Suite 1100, Chicago IL
60606.

We will inform you when you make an inquiry or lodge challenges or complaints of
the relevant procedures.
If you are chosen as a winner in one of our sweepstakes or judged contests you
will be given the option to provide a testimonial which we may post on the Panel
Homepage or include in an email communication to Members. Your testimonial,
username, and an electronic picture of yourself, if you provide one, will only
be included in the newsletter or communication, if you provide us with consent.
You can request to have your testimonial and Personal Information removed from
the Homepage or future email communication by sending an email to our Member
Relations Team using the contact us page. You may also submit your request in
writing to:

Ipsos
Social Media Exchange
Member Relations
222 West Adams Street, Suite 1100
Chicago, IL 60606




NOTIFICATION OF CHANGES


If we decide to change our privacy policy, we will post those changes to this
privacy statement and other places we deem appropriate so our Members are always
aware of what information we collect, how we use it, and under what
circumstances, if any, we disclose it. We will use information in accordance
with the privacy policy under which the information was collected.

If, however, we are going to use Members' personally identifiable information,
including email address, in a manner different from that stated at the time of
collection we will notify users via email. Members will have a choice as to
whether or not we use their information in this different manner. However, if
Members have opted out of all communication with the site, or
deleted/deactivated their account, then they will not be contacted, nor will
their personal information be used in this new manner. In addition, if we make
any material changes in our privacy practices that do not affect user
information already stored in our database, we will post a prominent notice on
our web site notifying users of the change. In some cases where we post a notice
we will also email Members, who have opted to receive communications from us,
notifying them of the changes in our privacy practices.






LOG FILES


As is true of most Web sites, we gather certain information automatically and
store it in log files. This information includes internet protocol (IP)
addresses, browser type, internet service provider (ISP), referring/exit pages,
operating system, date/time stamp, and click stream data.
We use this information, which does not identify individual users, to analyze
trends, to administer the site, to track Members’ movements around the site and
to gather demographic information about our user base as a whole.
We do not link this automatically-collected data to personally identifiable
information, including your email address.






COOKIES


Cookies are small data files stored in web browsers to track usage and enable
useful services and features on our Advisory Panel. This document provides
information on the standard cookies set by our Advisory Panel and how to manage
or adjust them should users choose to do so.



How to control cookies

Some cookies are necessary for the proper operation of the Panel and disabling
or removing them may have an adverse impact on the proper functioning and user
experience. However, users may choose to view, block, or remove cookies set by
our site through their web browser settings. Consult the help feature for your
specific browser to find how. Here are some useful links for your convenience.

• Microsoft Internet Explorer Privacy Settings and Information
• Google Chrome Privacy Settings and Information
• Mozilla Firefox Privacy Settings and Information
• Apple Safari Privacy Settings and Information



Cookies used by our site

Our panel website uses the following standard cookies. Disabling or removing
these cookies may have an adverse impact on the proper functioning and user
experience on the site.






STATE LEGISLATIVE REQUIREMENTS


Certain State laws may give you additional rights to limit the sharing of your
personal data or require that you are informed of your specific privacy rights.

California Consumer Privacy Act
There are certain rights that California residents have under the California
Consumer Privacy Act (“CCPA”). For example, the Ipsos Policy explains how
California residents can exercise their rights under the CCPA to request that
we: (1) provide certain personal information that we have collected about them
during the past 12 months, along with related information described below, or
(2) delete certain personal information that we have collected from them.
Under the CCPA, “personal information” is information that identifies, relates
to, or could reasonably be linked with a particular California resident or
household. This information is referred to in this Notice as “Personal Data.”
If you are a California resident, you have the right to request that we disclose
to you the following information covering the 12-month period prior to your
request (“Access Request”):

a) The categories of Personal Data we collected about you and the categories of
sources from which we collected the Personal Data;
b) The business or commercial purpose for collecting or selling Personal Data
about you;
c) The categories of third parties to whom we disclosed Personal Data about you,
and the categories of Personal Data disclosed;
d) The specific pieces of Personal Data we collected about you; and
e) Delete Personal Data we collected from you (“Deletion Request”).

California residents have the right to opt out of the sale of their information
by businesses that sell Personal Data. The CCPA defines a “sale” as the
disclosure of Personal Data for monetary or other valuable consideration. You
can obtain more information regarding CCPA and exercise your right to opt out of
the sale of your personal data by accessing here.
In addition, you have the right to be free from discrimination by a business for
exercising your rights under the CCPA.



Last revised December 2021

   
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