Effective Date: May 25, 2018

Absolutdata respects individual privacy and values the confidence of its customers, employees, business partners and others. Hence, Absolutdata strives to collect, use and disclose personal information in a manner consistent with the laws of the countries in which it does business. The firm also has a tradition of upholding the highest ethical standards in its business practices.

We have implemented industry-standard security safeguards designed to protect the personal information that you may provide. We also periodically monitor our system for possible vulnerabilities and attacks, consistent with industry standards.

This Privacy Policy provides a description of how we collect, use, disclose, transfer, and store your information, as well as your choices regarding use, access and correction of your Personal Information. This Privacy Policy does not apply to data that we collect through other means, including data that we collect offline or via web or mobile Sites on which we do not post this Privacy Policy. Please take a moment to familiarize yourself with our privacy practices and let us know if you have any questions.

  1. Introduction & Notice
  1. Introduction

AbsolutData Holdings, Inc. (“Absolutdata”) and its respective successors, subsidiaries, divisions and groups in the United States and other geographies is committed to ensuring the privacy of those customers who use the Absolutdata website (“Clients or Suppliers” or “you”) and to individuals who provide responses to sample, sample panel or survey questions (“Respondents” or “you”)  brokered, accessed by, hosted on or otherwise provided to Clients or Suppliers on or through the websites owned, maintained or licensed by Absolutdata , including but not limited to: absolutdata.com (collectively the “Sites”). This Privacy Policy (“Policy”) describes what information is collected from prospective employees, Clients or Suppliers and Respondents and how that information is used and disclosed. By using the Sites, you consent to the terms of this Policy. This Privacy Policy was created to demonstrate our commitment to fair information practices. Our policies and procedures address applicable U.S. and international privacy requirements concerning the collection, use, and cross-border transfer of personal data.

Our website is also used to source talent for the firm and requires candidates to submit personal data with reference to their candidature. This information is used by Absolutdata strictly for resourcing / hiring purposes.

As described more fully below, Absolutdata participates in and has certified its compliance with the EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Information from European Union member countries and Switzerland, respectively. Absolutdata has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.

To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov.

IF YOU DO NOT AGREE WITH THE TERMS IN THIS PRIVACY POLICY, DO NOT USE THE SERVICES AND SITES. CONTINUED USE OF THE SERVICES AND SITES CONSTITUES YOUR FREELY GIVEN, SPECIFIC AND INFORMED CONSENT AND AGREEMENT TO YOUR PERSONAL DATA BEING PROCESSED PURSUANT TO THIS POLICY.

  1. Definitions
  • “Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
  • “Data Subject” means an identifiable natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • “Joint Controller” means two or more controllers jointly determining the purposes and means of processing Personal Data.
  • “Personal Data” and “Personal Information” means any information relating to an individual that can be used to identify that individual either on its own or in combination with other readily available data.
  • “Pixels” means small, graphic images on web pages, web-based documents, or in email messages that allow us or third parties to monitor who is visiting our Sites (or other third-party sites) or if an email has been read.
  • “Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
  • “Respondent” means individuals who provide responses to sample, sample panel or survey questions.
  • “Panel” is a group of pre-screened respondents who have expressed a willingness to participate in surveys and/or customer feedback sessions.
  • “Special Categories of Data” means Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.
  • “We”, “our”, and “us” in this Privacy Policy refer to Absolutdata and any legally empaneled sub-processor or contractor delivering the services and products herein.
  • “You” means the individual to whom any given Personal Data covered by this Privacy Policy refers.
  1. Regulatory Oversight

For this Privacy Policy and its content, Absolutdata is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). If Absolutdata becomes subject to an FTC or court order based on non-compliance with this policy or EU-U.S. and Swiss-U.S. Privacy Shield frameworks, Absolutdata shall make public any relevant Privacy Shield related sections of any compliance or assessment report submitted to the FTC, to the extent consistent with confidentiality requirements.

  1. Collection of Personal Information
  1. Authorized Users

The Sites are not intended for children under the age of 16. If you are under 16 years old, please do not provide information of any kind whatsoever on the sites. If you are the parent of a child under 16 and believe your child has provided us with personal information, please contact us via Section X below and we will remove that information.

  1. Usage and Browsing Information Your Devices Transmits

You can visit most of our Sites without registering or actively submitting personal data to us. If you do not register, general technical user data, such as your device’s Internet Protocol (IP) address, operating system and browser type, and the date and time of your visit, may be automatically collected through the use of “cookies” (small files that are stored on your computer by a website to give you a unique identification) or other technologies. Cookies also keep track of services you have used, record registration information regarding your login name and password, ensure you do not repeatedly see survey questions, record your preferences and keep you logged into the Absolutdata site.

  1. Information You Actively Submit
  1. Generally

If you visit and / or sign up on our Sites for our blog/newsletter, you may provide contact information such as your name, email address, mailing address and company affiliation.

If you use our/Sub-contractor Sites as a Respondent, you will provide demographic information about yourself and answer questions at your choice which may include political opinion, sexual orientation, health and genetic data. In each such case, you know what information you provide and we collect, because you will actively submit the information.

  1. General Data Protection Regulation (GDPR)

In order to deliver the services, we require opt-in consent from European Union Respondents prior to the collection and processing of your Personal Data. The various modes of collection of data are stated below:

    • Panels
      When you consent to our collection of your Personal Data, we act as a Controller of that data whether collected on our Sites from you or received from our panels. Our customers may receive Personal Data collected pursuant to your opt-in consent on our Sites and as such, our customers are Joint Controllers of that data. In addition, we may share Personal Data collected on our Sites with our customers when performing the Managed Services below; when our customers receive such Personal Data, they are Joint Controllers of that data.
    • Managed Services
      We also offer managed services to our customers. With regard to the control and processing of your Personal Data when we’re performing these managed services, Absolutdata is the Processor and our customers are the Controllers. Our customers provide instructions to us for the processing of your Personal Data, which typically includes using our panels to perform those managed services. In addition, our customers may instruct us to collect your Personal Data from panels to share with our customers; we are relying on the consents given to your panels to allow this processing. You should rely on our customers for obtaining your consent to process your Personal Data as part of the surveys conducted off the panels.
  1. Combination & Synchronization
    We may combine and synchronize information that your device transmits, information that you actively submit and information that we obtain from third party sources (including suppliers of market research sample and data marketing platforms that may direct you to our Sites to answer demographic questions about yourself in preparation for your completion of surveys, and web publishers, advertisers, data brokers and online service providers that may have obtained information from you or your devices via cookies, pixels,  and other tracking technologies).
  1. Business Information
    We do collect employee contact names, addresses, phone numbers and email addresses of our business partners, including buyers, suppliers and vendors, for the administration of our business relationships. If you feel that your personal data or personally identifiable information is being collected inappropriately, please notify us at privacy@absolutdata.com.
  1. Cookie Opt-Out
    On Absolutdata.com, all visitors are given an option to opt-in or opt-out of cookies. If you opt-out, your information won’t be tracked when you visit Absolutdata.com. A single cookie will be used in your browser to remember your preference not to be tracked.
  1. Information Tracking Technologies
    We may use, and allow third parties to use, Pixels (sometimes called web beacons) on our Sites (or other third-party sites) to monitor the effectiveness of survey qualifications. Pixels may be linked to your Personal Information, and they collect the IP address of the device to which the web beacon is sent (for geolocation lookup), the URL of the page the web beacon comes from, the user agent string (for device lookup), and the time it was viewed. We may also use third-party devices, links or electronic mail, to deliver surveys to you during which additional Personal Information may be collected. These third-party surveys or devices may use cookies, web beacons or other technology to collect information about your visits to our Sites (or other third-party sites) in order to present surveys that may be applicable to you. We may collect traffic information and data on and from the use of third-party sites on behalf of our customers. Absolutdata may use a Pixel or cookie to examine what is happening on third-party websites, including programs and sites with marketing and advertising partners, to improve the understanding of site traffic at a granular level, market research effectiveness and other services provided.Respondents that are hosted on, accessed by or routed through the third-party sites should consult the privacy policy and other policies of third parties through whom they are providing information. These third-parties may collect and use data that has been augmented by our services for their own services, which may include marketing and ad targeting, among other uses.
  1. Do Not Track
    Some browsers have a “do not track” feature that lets you tell websites that you do not want to have your online activities tracked. These features are not yet uniform, and our website is not currently set up to respond to those signals for tracking on our website.
  1. Purpose & Use of Collected Personal Information

We use your information to operate, evaluate and improve our business (including developing new products and services; enhancing and improving our services; managing our communications; and analyzing our products).

If you provide us with your name and contact information, we will use this information to answer requests from you, communicate with you regarding any services we are providing to you as well as inform you about new products and services (unless and until you opt-out of marketing information).

If you come to our Sites as a “Respondent” to qualify for or take surveys, we use the demographic information you provide to make your survey answers more meaningful to us and our clients. We may also use information derived from cookies, pixels and other technologies to determine your interests in particular surveys, advertisements and other communications.

  1. Information Retention & Accuracy

We take reasonable steps to ensure that Personal Information we receive, process, or maintain is accurate, complete, and reliable for its intended use. We rely on the accuracy of the information provided directly to us but accept responsibility for the management and confidentiality of the Personal Information collected.

In general, we keep Personal Information only as long as we need it to provide you the services you requested. We may also process data on behalf of third parties who have engaged us. We keep Personal Information processed on behalf of third parties for as long as needed to provide services to third party in question. However, we reserve the right to retain Personal Information for any period required by law or to comply with our legal obligations, resolve disputes, and enforce our agreements.

  1. Data Minimization

We take every reasonable step to ensure that your user Information that we process is limited to the User Information reasonably necessary in connection with the purposes set out in this Policy or as required to provide you services or access to the Services.

  1. Sharing of Personal Information and Accountability for Onward Transfer

Information associated with your name we share only as follows:

  • With your consent.
  • We use affiliated and unaffiliated service providers all over the world that help us deliver our service and run our business subject to confidentiality agreements.
  • We will disclose data as required by law including to meet national security requirements or to protect you, other users, us or third parties from harm, including fraud, data security breaches or where someone’s physical safety seems at risk.
  • In a reorganization or sale of our company or assets, your data may be transferred, subject to the acquirer accepting the commitments made in this Privacy Policy and in compliance with applicable law.

We share aggregated demographic information about our users with third parties. This information is linked to randomly assigned user IDs and survey responses. Your user ID is linked to demographic information about you (excluding your first name and last name) that potentially could include Special Categories of Data. You consent to us collecting and sharing this information with our customers and other third parties.

Additionally, Absolutdata may share your Personal Information, without your prior consent, for the limited purposes noted below:

When Absolutdata does share your Personal Information with third party service providers and/or sub-processors, Absolutdata will:

  1. transfer such data only for limited and specified purposes;
  2. ascertain that the sub-processor is obligated to provide at least the same level of privacy protection as is required by these Principles;
  3. take reasonable and appropriate steps to ensure that the sub-processor effectively processes the Personal Information transferred in a manner consistent with the organization’s obligations under these Principles;
  4. require the sub-processor to notify Absolutdata if it makes a determination that it can no longer meet its obligation to provide the same level of protection as is required by these Principles;
  5. upon notice, including under (iv), take reasonable and appropriate steps to stop and remediate unauthorized processing; and
  6. provide a summary or a representative copy of the relevant privacy provisions of its contract with that sub-processor to the Department of Commerce upon request.

Absolutdata shall remain liable under the EU-US Privacy Shield Principle of Accountability for Onward Transfer if its sub-processors process your Personal Information in a manner inconsistent with the Privacy Shield Principles, unless Absolutdata proves that it is not responsible for the event giving rise to the damage.

If you are visiting this website from a country other than the country in which our servers are located, your communications with us will result in the transfer of information across international boundaries. By visiting this website and communicating electronically with us, you consent to such cross-border transfers.  In the case of data transfers from the EEA and Switzerland, the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks apply.

Absolutdata is responsible for the processing of personal information it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Absolutdata complies with the Privacy Shield Principles for all onward transfers of personal information from the EU and Switzerland, including the onward transfer liability provisions.

With respect to personal information received or transferred pursuant to a Privacy Shield Framework, Absolutdata is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Absolutdata may be required to disclose personal information in response to lawful requests by public authorities, including to satisfy national security or law enforcement requirements.

Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

In compliance with the Privacy Shield Principles, Absolutdata commits to resolve complaints about our collection or use of your personal information. If you have questions or complaints regarding our Privacy Policy or practices, please contact us here.

  1. Protection of Personal Information

Absolutdata uses reasonable security measures in an effort to prevent loss, misuse and alteration of information under our control. However, we cannot guarantee the security of information on or transmitted via the Internet. We rely on various security procedures and systems to ensure the secure storage and transmission of data, including encryption and authentication technology licensed from third parties, to effect secure transmission of confidential information. Additionally, we have absolutely no control over the security of other sites you might visit, interact with or do business with.

If we learn of a security systems breach, then we may attempt to notify you electronically so that you can take appropriate protective steps. Absolutdata may post a notice on the Absolutdata Site if a security breach occurs. We may also send an email to you at the email address you have provided to us in these circumstances. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive a free written notice of a security breach (or to withdraw your consent from receiving electronic notice) you should notify us.

  1. Limits to Your Privacy

Our Sites may contain links to external websites, and areas where you can provide information to third-parties. These are provided for your convenience only, and we do not have control over the content or privacy and security practices and policies of such third parties or third-party sites. Any Personal Information you provide in such areas, and on such linked pages is provided directly to that third party and is subject to that third party’s privacy policy. Please learn about the privacy and security practices and policies of external websites and third-parties before providing them with Personal Information.

  1. Choice Regarding Collection, Use & Distribution of Personal Information

You can choose to opt-out whether your Personal Information is (i) to be disclosed to a third party or (ii) to be used for a purpose that is materially different from the purpose(s) for which it was originally collected or subsequently authorized by the individuals. If you choose to opt-out, please contact us via email at privacy@absolutdata.com. In such an event, you will be only able to access public areas of the Sites and may be limited in the use of Absolutdata’s Sites. In certain cases, limiting the use and disclosure of your personal data may impact functionality or prevent the use of Absolutdata products or services.

  1. Access & Correction

If you are registered as a Buyer or Supplier, you can update, correct, or delete your user information and email subscription preferences by writing to us at privacy@absolutdata.com

You have the right to access the Personal Information we hold about you.

You may also access your information that Absolutdata holds by contacting us at the address below. You have the right to correct, amend, or delete that information where it is inaccurate, or has been processed in violation of the Privacy Shield Principles, except where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question, or where the rights of persons other than the individual would be violated.

We maintain processes or mechanisms to allow you to review, update, correct or delete Personal Information held by us. You may make changes to your account information, access, correct, or delete Personal Information held by Absolutdata by contacting us at:

AbsolutData Holdings, Inc.
1320 Harbor Bay Parkway, Suite #170, Alameda, CA 94502
Fax: +1 510-995-8108
Email: privacy@absolutdata.com

Note: All disputes are routed to the Incident Management Team which is an independent entity within the organization and is responsible for overall compliance.

To protect your privacy and security, Absolutdata may also take reasonable steps to verify your identity before making corrections to or deleting your information. We will respond to your request for access to modify or delete your information within a reasonable timeframe.

  1. Contacting Absolutdata

Absolutdata will address all questions, complaints or requests concerning this Privacy Policy within 72 hours of receipt.

Please see the applicable details below:

  1. EU & Swiss Citizens

In compliance with the EU-U.S. and Swiss-U.S. Privacy Shield Principles, Absolutdata commits to resolve complaints about your privacy and our collection or use of your Personal Information. European Union and Swiss individuals with inquiries or complaints regarding this Privacy Policy should first contact Absolutdata at:

Attn: Privacy Policy
AbsolutData Holdings, Inc.
1320 Harbor Bay Parkway, Suite #170, Alameda, CA 94502
Fax: +1 510-995-8108
Email: privacy@absolutdata.com

Note: All disputes are routed to the Incident Management Team which is an independent entity within the organization and is responsible for overall compliance.

For complaints that cannot be resolved between the Company and the complainant, the Company agrees to participate in the dispute resolution procedures of the panel established by the European Union data protection authorities (DPAs) and Swiss Federal Data Protection and Information Commissioner (FDPIC) to resolve disputes pursuant to the Privacy Shield Principles. The EU DPA panel may be contacted at ec-dppanel-secr@ec.europa.eu and the EU DPAs may be contacted directly via the information provided at http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm

  1. Non-EU/Non-Swiss Citizens

Absolutdata commits to resolve complaints about your privacy and our collection or use of your Personal Information. Non-EU/Non-Switzerland citizens with inquiries or complaints regarding this privacy policy should contact Absolutdata at:

Attn: Privacy Policy
AbsolutData Holdings, Inc.
1320 Harbor Bay Parkway, Suite #170, Alameda, CA 94502, USA
Fax: +1 510-995-8108
Email: privacy@absolutdata.com

Note: All disputes are routed to the Incident Management Team which is an independent entity within the organization and is responsible for overall compliance.

  1. Changes to Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we decide to change our Privacy Policy, we will prominently post those changes here and any other place we deem appropriate, so you are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If we make any material changes, we will notify you by means of a notice on this site prior to the change becoming effective. We will use information in accordance with the privacy policy under which the information was collected.

We use a self-assessment approach to address compliance with this Privacy Policy, verifying periodically that the policy is accurate, comprehensive, and addresses the privacy requirements applicable to the markets we serve. Periodically, our operations and business practices are reviewed for compliance with corporate policies and procedures governing the confidentiality of information.

In addition, Absolutdata boasts of best in class information security practices. The Absolutdata Gurgaon delivery center is certified against the ISO 27001:2013 standard which is globally recognized for information security. This certification is renewed annually, for which Absolutdata is subjected to periodic audits by an authorized third-party certification body.