Research Participant Privacy Notice

Effective Date:  September 26, 2016
Last Revised:  October 18, 2023

This Privacy Notice defines how NAXION collects, stores, uses, and discloses your Personal Data (as defined below). NAXION will, and will cause its affiliates to, establish and maintain business procedures that are consistent with this Privacy Notice.

We Protect Your Privacy

NAXION is a leading market research company. NAXION is strongly committed to the protection of the confidentiality of Personal Data (“Personal Data”). NAXION strives to conform its privacy practices to applicable laws, codes, regulations, and the codes of standards of applicable market and opinion survey research associations, including, without limitation, the Insights Association.

How Do We Collect Your Personal Data?

We will always collect your Personal Data by fair and lawful means. For example, we may collect your Personal Data when you complete a survey or participate in another research program.

NAXION only collects Personal Data for market research purposes.

NAXION may receive your Personal Data from another research organization, from a client, or from a data provider. This data may originate from a public source, or it may result from a relationship you have with one of these organizations. Regardless, NAXION will process and protect your Personal Data as described in this Privacy Notice.

What Personal Data Do We Collect?

Personal Data is any information that is identifiable with you and may include but is not limited to your name, address, telephone number, email address, date of birth, etc.  From time to time we may also collect Sensitive Personal Data (“Sensitive Personal Data”) that may include but is not limited to health and financial information.

How Do We Use Your Personal Data?

When you participate in one of our surveys or other research programs, we combine the information you provide with the information of all other research participants and report aggregate responses. Additionally, we may use data we collect in statistical modeling to better understand trends in the relevant population. We do not release Personal Data as part of statistical modeling.

We will not make your Personal Data available to any third party without your consent unless it is for research purposes or required by law, as further specified below.

We may use Personal Data for a variety of reasons, including but not limited to:

• Inviting you to participate in a survey or other research program
• Updating our records of your Personal Data
• Managing our incentives programs and fulfilling your requests for such incentives
• Allowing you to participate in sweepstakes (if permitted)
• Responding to any messages or requests you may send to us
• Providing service and support to you
• Using as otherwise authorized by you

Please note that receiving email communications may be a requirement of your participation in our surveys or other research programs. You can opt out of receiving these emails by unsubscribing from the survey or other research program.

We may use a third-party agent to host our surveys or other research programs or perform other market research-related activities. Contractual agreements between NAXION and its 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 disclose your Personal Data and/or survey responses or other research data to third parties as follows:

• In accordance with Insights Association guidelines, we may provide your Personal Data to a third party, including the client who commissioned the survey or program activity you participated in, so long as such third party is contractually bound to keep the information confidential and use it only for research or statistical purposes
• In connection with market research services (including our incentives programs); to our agents, contractors, or partners that facilitate such services; provided, however, such parties are restricted from using your Personal Data in any way other than to provide services to NAXION
• In connection with the request or requirement of any lawful request by public authorities to meet national security or law enforcement requirements
• Pursuant to required legal process, to the related compelling party
• When we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with suspected or actual illegal activity
• In connection with the sale, assignment, or other transfer of NAXION, in which case we will require any such buyer to agree to treat Personal Data in accordance with this Privacy Notice. In the event that a sale, assignment, or other transfer of NAXION is not consummated with a prospective buyer, we will require the third party not to use or disclose your Personal Data in any manner whatsoever and to completely erase the same
• As otherwise authorized by you

NAXION will require others who acquire or provide Personal Data from or to NAXION, including those engaged to provide support services, to adopt and comply with the principles in this Privacy Notice. NAXION acknowledges its potential liability in cases of onward transfers to third parties.

We may maintain Personal Data or machine-identifiable information in order to satisfy your requests and/or NAXION’s business requirements. For instance, we may retain the email address of persons who opted out, or requested to be removed from, our panel to ensure we conform to such wish. We may retain such data until its business need is finished and in accordance with client data retention requirements.

What Information Do We Collect by Automated Technologies?

As further specified below, we may automatically collect a variety of machine-readable information about you, including the date and time you visited our website, the pages you visited, the website you came from, the type of browser you are using (e.g., Internet Explorer, Firefox, Safari, Chrome, etc.), the type of operating system you are using (e.g., Windows, mac OS, etc.), the type of device you are using (e.g., mobile phone, desktop computer), your Internet Protocol address, and the domain name and address of your Internet service provider.

We may also collect the following:

• Website name (full URL of the website homepage)

• Date and time you visited the site

• Number of pages you viewed

• Time in seconds you spend on each page

• Details of any website you visited before and/or after participation in one of our surveys or other research program

Cookies:

Cookies are small text files stored on your computer by a website that assigns a numerical user ID and stores certain information about your online browsing. We may use cookies on our survey site to help us recognize you as a prior user.

Cookies collected:

If you wish, you can adjust your web browser’s privacy settings to delete cookies upon exiting websites or when you close your browser. You may also configure your browser to block cookies; however, doing so may negatively impact your user experience when participating in one of our surveys or other research programs.

Web Beacons:

A web beacon (also known as a tag, clear gif, or 1×1 pixel) consists of a small string of code that is embedded within a web page or email. There may or may not be a visible graphic image associated with the web beacon, and often the image is designed to blend into the background of a web page or email.

We may use web beacons in our email messages to help determine whether our messages are opened and to verify any clicks through to links within the email. We may use this information to determine which of our emails are more interesting to users to improve the quality of the emails that we send and to query users who do not open our emails as to whether they wish to continue receiving them. The web beacon is deleted when you delete the email.

If you would prefer not to have web beacons in the emails that you receive, you should adjust your email program to receive messages in plain text rather than HTML. It is also possible to detect and control web beacons that are present on web pages by downloading a plug-in for your browser.

Log Files:

NAXION may use logging throughout your survey-taking and research program experiences. When you access any of these services, our servers automatically record information that your browser sends whenever you visit a website. These server logs may include information such as your web request, Internet Protocol (IP) address, browser type, browser language, the date and time of your request, and one or more cookies that may uniquely identify your browser. This information is periodically deleted as part of normal maintenance routines.

Digital Fingerprinting:

NAXION may use Digital Fingerprinting technology, also known as “machine identification” technology (“Digital Fingerprinting”), to gather certain data about you and/or your computer. This data may include Personal Data and Internet Protocol (IP) address as well as other data such as a computer operating system or browser version number. This technology creates a unique computer identifier (“ID”) that may be used to identify and track your participation in a survey or other research program and limit participation.

NAXION may utilize Digital Fingerprinting technology to assist our clients in ensuring the integrity of survey results by enabling us to authenticate users and to help ensure users participate in surveys no more than the maximum allowable participation. In furtherance of NAXION’s efforts to assist its clients in protecting and ensuring the integrity of survey results, NAXION may: (a) link or associate an ID to an individual or to Personal Data of an individual; (b) share an ID with NAXION’s clients and/or sample or panel providers; and/or (c) receive or obtain a unique identifier that is linked to an identified or identifiable individual. Any unique identifier(s) received or obtained by NAXION that are linked to an identified or identifiable individual will be protected in accordance with this Privacy Notice.

Do We Collect Information From Children?

If we collect any Personal Data from children under 13 years of age, we only do so with verifiable parental consent. Where regional laws are more restrictive, NAXION complies with the law.

What Safeguards Have We Implemented to Help Ensure the Security of Your Personal Data?

The security of your Personal Data is very important to us. We have put in place reasonable physical, electronic, and administrative procedures to safeguard the information we collect. Only those employees who need access to your information in order to perform their duties are authorized to have access to your Personal Data.

We cannot guarantee that all communications between us or information stored on our servers will be free from unauthorized access by third parties such as hackers, and your use of our services demonstrates your assumption of this risk.

How Can You Review Your Personal Data That We Have Collected, Used, or Disclosed?

We will make available to you your Personal Data in our custody or control that we have collected, used, or disclosed, upon your written request, to the extent required and/or permitted by law.

To request access to Personal Data that we hold about you, we require that you submit your request in writing at the email address or postal address shown below in the Contact section. When we receive an access request from an individual, we will attempt to fulfill the requested information within 30 days, including requests regarding the Personal Data we have in our possession or control about the individual, what it is being used for, and to whom it has been disclosed, if applicable.

How Do You Know That the Personal Data We Have on You is Accurate?

NAXION makes reasonable efforts to keep Personal Data in its possession or control accurate and complete based on the most recent information available to us. If you believe your Personal Data is inaccurate, you can demonstrate in writing the accuracy or completeness of the Personal Data we have on you by emailing privacy@naxionthinking.com. If you successfully demonstrate that the Personal Data we have on you is inaccurate or incomplete, we will amend as required.

How Do I Opt Out of Surveys or Other Research Programs or Restrict Processing?

Your decision to participate in a survey or other research program, respond to any specific survey question, limit processing of your data, or provide Personal Data or Sensitive Personal Data will always be respected. You may choose whether or not to participate in a particular survey or research program or discontinue participation at any time. However, failure to provide certain information or fully participate in a particular survey may preclude you from receiving incentive compensation or participation in future certain research studies.

If you decide not to participate in a survey or other research program, you can click the unsubscribe hyperlink within the email and you will no longer receive survey or other research program invitations. You can also email us at privacy@naxionthinking.com.

Information for Citizens of the EU and Switzerland About Cross-Border Transfers

NAXION relies on Legitimate Interest as its basis for collecting Personal Data in its surveys and other programs. We contact customers and potential customers of our clients to include their perspectives on new and developing products and services, brand performance, and information-sharing methods such as advertising and website evaluation.

As part of this work, we may need to collect or process personal or sensitive information for analysis, validation, to pay incentives, to prevent fraud, or to contact potential future survey participants.

Individuals have the right of access to personal information about them that NAXION holds and are able to correct, amend, or delete that information where it is inaccurate or has been processed in violation of the Principles of the EU-US with UK Extension and/or Swiss-US Data Privacy Framework, 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.

NAXION complies with the EU-US Data Privacy Framework (EU-US DPF), the UK Extension to the EU-US DPF, and the Swiss-US Data Privacy Framework (Swiss-US DPF) as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union, United Kingdom, and Switzerland to the United States. NAXION has certified to the Department of Commerce that it adheres to the Principles of the EU-US DPF, the UK Extension to the EU-US DPF, and the Swiss-US DPF with respect to such information. If there is any conflict between the terms in this privacy policy and the Data Privacy Framework Principles, the Data Privacy Framework Principles shall govern. To learn more about the Data Privacy Frameworks and to view our certification, please visit https://www.dataprivacyframework.gov/s/.

In compliance with the EU-US and Principles of the EU-US DPF, the UK Extension to the EU-US DPF, and the Swiss-US DPF, NAXION 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 NAXION at:

Data Protection Officer
NAXION
1835 Market Street
Philadelphia, PA 19103-2984

NAXION has further committed to refer unresolved privacy complaints under the Principles of the EU-US Data Privacy Framework (EU-US DPF), the UK Extension to the EU-US DPF, and the Swiss-US Data Privacy Framework (Swiss-US DPF) to The Insights Association Data Privacy Framework Services Program, a nonprofit alternative dispute resolution provider located in the United States and operated by Insights Association. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.insightsassociation.org/Resources/Data-Privacy-Framework/Information-for-EU-Swiss-Citizens-to-file-a-complaint for more information and to file a complaint. These dispute resolution services are available at no cost to you.

NAXION is under the enforcement authority of the US Federal Trade Commission. Under certain limited conditions, individuals may be able to invoke binding arbitration before the EU-US Data Privacy Framework Panel to be created by the U.S. Department of Commerce and the European Commission. Swiss individuals may do so through the Federal Data Protection and Information Commissioner (FDPIC).

California Residents

NAXION complies with the California Privacy Rights Act (CPRA).  The types of data we may collect and/or store are:

• Contact information – most commonly to invite participants to surveys, pay incentives, and deduplicate interviews
• Personal Data – typically collected from survey participants for analysis, collected via cookies to prevent fraud, or included in customer files we receive
• Protected classifications – collected from survey participants for analysis purposes
• Commercial data – collected in surveys for analysis or may be included in customer files to determine who to invite to a survey
• Internet activity – on rare occasions, we might receive this data for analysis or to determine who saw an ad
• Geolocation – on rare occasion it might be used for analysis, to prevent fraud, or to invite to a survey
• Inferences – the result of analysis is often to create aggregate inferences. Link models make inferences on the individual level, but we do not target participants as a result of their survey participation without the participant’s permission

We may have collected or stored all of the above types of information from California residents within the past year.

NAXION maintains a written policy for how we will handle requests under the CPRA from California residents. These requests may be sent to privacy@naxionthinking.com or you may call us at 800-342-9102.

While NAXION does not sell consumer information, we may share it with third parties for business purposes related to market research. For example, we might share contact information with a printer who will print and mail survey invitations on our behalf, or we might share Personal Data with a client for analysis. In any case, survey participants are informed of this possibility and may opt not to take the survey without consequence other than not receiving any incentive for completing the survey. We ensure in writing that any third-party receiving such data complies with the CPRA. You may opt out by sending an email request to privacy@naxionthinking.com or by calling us at 800-342-9102; we will not share your information with any third-party if you opt out.

It is infrequent for NAXION to knowingly collect information from or about minors and share it. However, when we do, we gain verifiable permission from a parent/guardian or directly from the minor, consistent with the law.

Under the CPRA, California residents may request to be “forgotten,” limit processing of their data, request the categories of personal information gathered and categories of sources for the personal information, the purpose for having it, categories of third parties with whom it is shared, what specific pieces of personal information we have, categories of personal information that were disclosed for business purposes within the past 12 months, and the category of third parties with whom we share their personal information.

In rare circumstances, NAXION may be unable or unwilling to comply with requests from California residents related to CPRA. Examples include if the data is under subpoena, is needed to detect a security incident, or if there is a legitimate business purpose for not fulfilling the request as permitted under the CPRA.

Links to Third-Party Websites

This Privacy Notice applies solely to surveys and other research programs operated by NAXION and not to any other product or service. This website may contain links to a number of third-party websites that we believe may offer useful information. The policies and procedures we described here do not apply to those websites. We recommend that you carefully read the privacy notices or policies of each site that you visit for information on their privacy, security, data collection, and distribution policies.

Contact Us

We value your opinion. If you have questions, comments, or suggestions, or if you would like to opt out of our surveys or other research programs, please contact us at privacy@naxionthinking.com or via mail at:

NAXION
1835 Market Street
Philadelphia, PA 19103-2984