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SURVEY PRIVACY POLICY


Last modified: November 15, 2022

 1. WELCOME
    1. 1 This privacy policy sets out how we collect, store, transfer, share and
       use information that identifies or is associated with you (your “personal
       information“) when you access and respond to the questions on the survey
       page on which this privacy policy is displayed (the “Survey“).
    2. 2 The Survey is operated by SMG for the corporate customer brand that
       invited you to complete the Survey and whose name and brand are displayed
       on the Survey (the “Brand Partner“).
    3. 3 When we refer to “Users“, “you” or “your” in this privacy policy, we
       refer to individuals who access and complete all or part of the Survey.
    4. 4 Please read this privacy policy carefully before completing the Survey.
       If you have any questions about this privacy policy or how we use your
       personal information, please contact us using the contact details set out
       in paragraph 5 below.
 2. WHO WE ARE
    1. SMG conducts market research for corporate customer brands to help them
       analyse and measure consumer preferences about their goods and services.
       We have affiliates around the world and so, depending on where the
       relevant Brand Partner is located, a different company may be collecting
       your personal information:
       * If the Brand Partner is located in North America, Central America or
         South America, the Survey is operated by Service Management Group, LLC;
       * If the Brand Partner is located in Europe, the United Kingdom or the
         Middle East, the Survey is operated by Service Management Group
         Limited;
       * If the Brand Partner is located in Asia or Oceania, the Survey is
         operated by Service Management Group GK.
    2. Each of the above companies is referred to in this privacy policy as
       “SMG“, “we“, “us” or “our“.
    3. Each of the SMG companies above will use your personal information as set
       out in this privacy policy. However, if you have any questions about
       which SMG company has collected your personal information, please contact
       us using the details set out in paragraph 5 below.
 3. WHAT THIS PRIVACY POLICY COVERS
    1. The comments, opinions and other feedback that you provide when you
       complete the Survey (your “Survey Responses“) is predominantly collected
       by us on behalf of the Brand Partner as a “processor” or “service
       provider”, and, other than as set out in this privacy policy, we only use
       the Survey Responses as instructed by the Brand Partner. If you would
       like to know more about how the Brand Partner uses the Survey Responses
       that we collect about you on their behalf, please refer to the relevant
       Brand Partner’s privacy notice.
    2. We also use your Survey Responses to improve our products and services as
       detailed further in paragraphs 6.1 and 6.2 below. In addition, we collect
       certain information automatically about how you use the Survey in order
       to operate and provide the Survey, and to identify and prevent fraud by
       detecting multiple attempts to complete the Survey by the same person.
    3. This privacy policy sets out how we use the personal information
       contained in your Survey Responses to improve our products and services
       and how we use personal information about how you use the Survey.
 4. WHO IS RESPONSIBLE FOR YOUR PERSONAL INFORMATION
    1. The Brand Partner will be the controller of any personal information
       contained in the Survey Responses that you provide when you complete the
       Survey, which means that they determine and are responsible for how that
       personal information is used.
    2. When we use the Survey Responses to improve our products and services,
       and when we collect and use personal information about how you use the
       Survey, we will also be an independent controller in respect of those
       uses of your personal information. This means that, when we use your
       personal information in these ways, we determine and are responsible for
       how that personal information is used.
 5. HOW TO CONTACT US AND THE BRAND PARTNER

If you would like to contact us, you can email us at privacyofficer@smg.com.

6. INFORMATION WE COLLECT AND HOW WE USE IT

We will collect your Survey Responses primarily to provide the relevant Brand
Partner with feedback and statistics about customer experiences; however, we
will also use them as follows:

How we use this personal informationLegal basis we rely onWe create aggregated
and anonymized statistics from Survey Responses and use that information for our
own market research and benchmarking across multiple Brand Partners.The
processing is necessary for our legitimate interests, namely developing and
promoting our products and services.

6.2 Comments and feedback you provide when responding to the Survey

When you complete the Survey, in addition to responding to specific questions
you may be asked to provide comments and feedback in free text about your
experience with the Brand Partner. We collect those comments, opinions and other
feedback primarily to pass these on to the Brand Partner; however, we will also
use them as follows:

How we use this personal informationLegal basis we rely onWe use this
information to train our artificial intelligence models to identify sentiment,
such as whether the responses you give are positive, negative or neutral.  The
processing is necessary for our legitimate interests, namely improving our
products and services and developing new features and functionalities of our
products and services.

6.3 Information about how you access and use the Survey

We collect information about how you access and use the Survey and the device
you use to do so. For example, we collect the IP address from which you access
the Survey, the time you access the Survey and how long you use it for. Your IP
address may also indicate your approximate location.

How we use this personal informationLegal basis we rely onWe use this
information to present the Survey to you on your device, such as ensuring that
the Survey recognizes you as you navigate between pages on the Survey so you do
not need to enter your information again.  The processing is necessary for our
legitimate interests, namely to provide the Survey to you.We use this
information to identify multiple attempts to complete the Survey from the same
device in order to detect and prevent fraudulent use of the Survey.The
processing is necessary for our legitimate interests, namely identifying and
preventing fraud.We use this information to ensure that the Survey does not get
overloaded.  The processing is necessary for our legitimate interests, namely
load balancing.

 * How we collect your Personal Information
   * We collect Survey Responses directly from you when you complete the Survey.
   * We collect personal information about how you access and use the Survey
     using cookies and similar technologies. Cookies are pieces of code that we
     transfer to your computer’s hard disk to store or collect information.
   * The cookies we use are necessary to operate the Survey. We use the
     following cookies to operate the Survey:

CookieType of cookieTechnical functionDurationTS017a8bfaFunctionalityAllow the
Survey to remember users as they navigate through the Survey, so they do not
need to enter their information again (“Session
Management“).SessionBIGipServermcdfMonitor Survey traffic to ensure that the
Survey does not get overloaded with too many users or requests at the same
time.SessionSNIdentify the server used to host the Survey, to allow you to
connect to the Survey.24 hoursTS16f02ccc027Session
Management.SessionASP.NET_SessionIdStorage of the session ID, to enable Session
ManagementSessionCCIDIdentify the Survey directory to allow you to connect to
the Survey.24 hoursLIDIdentify and remember Survey language, so that the Survey
is presented to you in your language.24 hoursTSecurityDetect and prevent fraud
by detecting and preventing multiple attempts to complete the Survey.Session

 * How long we keep your personal information
   * Survey Responses

We will keep your Survey Responses only until they have been reviewed for
sentiment (such as positive, negative or neutral) by our team. They will then be
used to generate aggregated and anonymised statistics for the purpose of testing
the effectiveness of our AI model.

 * Information about how you access and use the Survey

We will keep the personal information about how you use and access the Survey
for the duration of the Survey campaign, in order to identify multiple attempts
to complete the Survey from your device. We will delete this information when
the Brand Partner finishes the relevant Survey campaign.

9. HOW WE SHARE YOUR PERSONAL INFORMATION

We may share the personal information we collect and use for our own purposes as
follows:

RecipientsWhy we share your personal information with these recipientsHow these
recipients will use your personal informationOther SMG companies listed in
paragraph 2 above.  We may share the Survey Responses with the SMG companies
that carry out the training of our AI models.   We may share the personal
information we collect about how you use the Survey with other SMG companies to
prevent multiple attempts to complete the Survey from different locations.  The
SMG companies that receive your personal information will use it in same way as
described in this privacy policy.   The lawful basis we rely on for sharing your
personal information with these SMG companies is that it is necessary for our
and these companies’ legitimate interests, namely administering and operating
the Survey and improving our products and services.Data hosting providers.  We
may share the Survey Responses with companies that host data in the cloud on our
behalf.These recipients will use your personal information as processors on our
instructions.Law enforcement, regulators and other parties for legal reasons.We
may share your personal information with third parties as required by law or if
we reasonably believe that such action is necessary to (i) comply with the law
and the reasonable requests of law enforcement; (ii) detect and investigate
illegal activities and breaches of agreements; and/or (iii) exercise or protect
the rights, property, or personal safety of SMG, its users or others.These
recipients will use your personal information in the performance of their
regulatory or law enforcement role.   The lawful basis we rely on for sharing
personal information with these recipients is that the processing is either
necessary to comply with a legal obligation to which we are subject, or is
necessary for our legitimate interests, namely enforcing our rights or complying
with requests from regulatory authorities.  

We may also share your Survey Responses with other recipients on the
instructions of the Brand Partner. Please refer to the Brand Partner’s privacy
notice for further information about how the Brand Partner may share (or may
instruct us to share) your personal information.

10. INTERNATIONAL TRANSFERS OF YOUR PERSONAL INFORMATION

We may transfer personal information as described above in paragraph 9. This may
mean that your personal information may be transferred to and stored in
countries outside the country you are in where we and our third-party service
providers have operations.

If you are in the United Kingdom or the European Economic Area, these
international transfers of your personal information will be made pursuant to
appropriate safeguards in accordance with applicable law:

Where we may transfer your personal informationSafeguards that apply to that
transferUnited States  The transfer is subject to standard contractual clauses
approved by the European Commission or the UK Information Commissioner for the
transfer of personal information.  JapanIf you are in the EEA, the country is
deemed to provide adequate protection for personal information by the European
Commission. If you are in the UK, the country is deemed to provide adequate
protection for personal information under the UK Data Protection Act 2018.
 United Kingdom  The country is deemed by the European Commission to provide
adequate protection for personal information.  

We will take appropriate steps to ensure that your personal information is
treated securely and in accordance with applicable law and this privacy policy
regardless of where it is processed.

If you wish to enquire further about the safeguards we use, please contact us
using the details set out at paragraph 5.

11. YOUR PRIVACY RIGHTS

You have the following rights in respect of your personal information that we
hold:

 * Right of access. You have the right to obtain:
   * confirmation of whether, and where, we are processing your personal
     information;
   * information about the categories of personal information we are processing,
     the purposes for which we process your personal information and information
     as to how we determine applicable retention periods;
   * information about the categories of recipients with whom we may share your
     personal information; and
   * a copy of the personal information we hold about you.
 * Right of portability. You have the right, in certain circumstances, to
   receive a copy of the personal information you have provided to us in a
   structured, commonly used, machine-readable format that supports re-use, or
   to request the transfer of your personal data to another person.
 * Right to rectification. You have the right to obtain rectification of any
   inaccurate or incomplete personal information we hold about you without undue
   delay.
 * Right to erasure. You have the right, in some circumstances, to require us to
   erase your personal information without undue delay if the continued
   processing of that personal information is not justified.
 * Right to restriction. You have the right, in some circumstances, to require
   us to limit the purposes for which we process your personal information if
   the continued processing of the personal information in this way is not
   justified, such as where the accuracy of the personal information is
   contested by you.

You also have the right to object to any processing based on our legitimate
interests where there are grounds relating to your particular situation. There
may be compelling reasons for continuing to process your personal information,
and we will assess and inform you if that is the case. 

If you wish to exercise one of these rights, please contact us using the contact
details in paragraph 5.

If you reside in the UK, you have the right to make a complaint at any time to
the Information Commissioner’s Office (“ICO“), the UK regulator for data
protection issues. You can make a complaint via the ICO’s website
(https://ico.org.uk/make-a-complaint/). This website also provides additional
contact details for the ICO.

If you are resident in the EEA, you have the right to make a complaint at any
time to the regulator in your jurisdiction. To find out how to contact your
local regulator, please visit
https://edpb.europa.eu/about-edpb/about-edpb/members_en.

12. SECURITY

We implement appropriate technical and organisational measures to protect your
personal information against accidental or unlawful destruction, loss, change or
damage. All personal information we collect will be stored on our secure
servers. Unfortunately, however, no security measures will always be completely
effective. We will notify you in accordance with applicable laws if we become
aware that your personal information has been compromised.

13. OUR Policy Towards CHILDREN

Our Service is not directed at persons under 13 and we do not knowingly collect
personal information from or about children. If you become aware that we have
collected information about your child without your consent, then please contact
us using the contact details at paragraph 5 so that we can take steps to remove
such information.

14. CHANGES TO THIS POLICY

We may update this privacy policy from time to time and so you should review
this page periodically. When we change this privacy policy, we will update the
“last modified” date at the top of this privacy policy. Changes to this privacy
policy are effective when they are posted on this page.

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