Privacy Policy

WELCOME

ComEngage, LLC is a full-service marketing research company located in the United States, with headquarters in Edmonds, WA. As a marketing research company, ComEngage collects data from research study participants so that our clients can understand their customers’ needs and recognize how their products and/or services are received in the general marketplace. This data is collected through online surveys, mobile surveys, phone interviews, focus groups and other research methodologies.

To protect confidentiality and respect your privacy, ComEngage will in no way make your personal information available to any party outside the scope of the research project. Personal information is only utilized to group responses which will provide feedback to our clients. Individual responses or specific information will only be used for research purposes with your consent. You always have the option to opt-out of or terminate your participation in research.

Information We Gather

Any research conducted by ComEngage will be entirely communicated to its research participants with full transparency prior to beginning the study. The information we receive, that you voluntarily provide as part of our research studies, generally includes certain demographic information (age, gender, and/or income level) that is only used to analyze data, information regarding your personal preferences and attitudes, as well as your specific purchase activities or hobbies. Please note, the information we collect is always strictly for use in research studies and ComEngage will never ask for financial account numbers or personal passwords.

ComEngage may receive personally identifiable information from a third-party (e.g., our client) and/or from third-party providers of phone and address lists. The third-party (client) provides this information so that we can contact you to participate in research projects. In this case, we may be provided, from the third-party, with basic personal information (including name, age, etc.), your contact information (such as email address, phone number), your interests and/or product association, and your connection with the third-party.

ComEngage or our third-party sample provider(s) may assign unique identifiers to a participant’s computer to identify and track the computer. ComEngage works primarily with third-party providers to arrange this technology, or to track the online activities of the user of a computer. This technology will not disrupt or interfere with the regular use or control of a computer. Nor will it modify or alter the settings or functionality of a computer.

ComEngage uses the unique identifier to assist our clients in safeguarding the integrity of survey results (to ensure that one person does not complete a survey multiple times). The third-party provider may use and analyze publicly available information and data obtained from the computer’s web browser and from other publicly available data points, including, without limitation, the technical settings of the computer, the characteristics of the computer or web browser to create a unique identifier assigned to the computer. This technology may utilize both cookies as well as locally shared objects known as “flash cookies”. The unique identifier is an alpha-numeric ID. Additionally, to assist our clients in protecting and ensuring the integrity of survey results, we (a) may link or associate your unique identifier to you and any of your personally identifiable information; (b) may share your unique identifier with sample or panel providers; and (c) may receive or obtain a unique identifier linked to you from a third-party, including, without limitation, a sample or panel provider or a client of ComEngage. Any unique identifier(s) received or obtained by ComEngage and linked to a specific individual will be protected in accordance with this Privacy Policy.

How We Use Your Information

Research project participant information is used exclusively for research purposes. ComEngage will never attempt to sell our participants anything; we are only interested in gathering opinions. When you complete a research project, your personal responses are analyzed collectively with all other respondents’ information and may be reported individually to the client. We support the rights of our survey participants by limiting the use of personally identifiable information for legitimate marketing research purposes and actively support industry organizations created to uphold ethical survey research (this support includes making every effort to conform to the organizations’ ethical standards). We will never share our survey participants’ email addresses or personally identifiable information with anyone except our clients. Access to this data is strictly for purposes related to carrying out the research study, including hosting a survey or processing data. ComEngage will obtain guarantees from our vendors that they will safeguard personal information in consistency with this policy. All vendors, clients, and sub-contractors must sign an NDA, confidentiality or “chain of trust” agreement.

Clients who hire ComEngage to conduct market research are typically provided with participant level survey data that includes data such as demographic information needed to analyze data (e.g., gender, income level); the participant level data does not include anything that could personally link this data with you or members of your household (e.g., address, phone number, email address, name). On some occasions our clients request contact information or customer IDs of survey participants for record keeping, authentication or other business purposes.

In certain instances, such as to protect someone’s safety, to protect our rights or property, or when required to do so by law (including to meet national security or law enforcement requirements), ComEngage may disclose your personal information to a third-party.

Notice

ComEngage believes you have the right to be informed about personal information collected and provides transparent notice to online visitors and consumers with clear and accurate information about our policies, and our compliance with privacy and data protection. When we collect your personal information, we will give you timely and appropriate notice describing what personal information we are collecting, how we will use it, and the types of third parties with whom we may share it.

Choice

Research participants in the EU, the United Kingdom, and Switzerland will be given the opportunity to choose whether the personal information they share is to be disclosed to a third party (e.g., our client) or to opt out of the research study. This option is not given when the third party is acting as an agent to perform a specific task on behalf of and under the instructions of Quester (e.g., survey hosting or tabulating data).

If there is ever a need for Quester to collect more sensitive information than the information previously described, such as your name or contact information, or other data that may be considered sensitive per the regulations in your country, we will inform you at the start of the research study that we will be asking for this type of information. We will then provide the option for you to opt-out, either from participating in the study and/or providing that information. Research study participants will also be given the opportunity to choose, or opt out of, whether the personal information they provide can be utilized for a substantially different purpose for which it was originally collected or authorized by the individual.

Security

ComEngage takes the security of your personal information seriously. Access to research participant personal information is restricted and limited to ComEngage staff members and authorized third parties who have an explicit need to access such information for a legitimate business purpose, such as sending email invitations, hosting an online survey or processing data. We take precautions to protect personally identifiable information in our possession from loss, disclosure, alteration and destruction, misuse, and unauthorized access.

Data Integrity and Purpose Limitation

It is ComEngage’s goal to maintain accurate data and provide mechanisms for you to access, correct or delete your personal data. We’ll keep your personal information only if we need it for the purposes for which we collected it, or as permitted by law. Privacy Shield data will only be used to provide the service(s) or carry out the transaction(s) you have requested or authorized. We may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

Access

ComEngage will make available to you your personal information in our custody or control that we have collected, upon your written request, to the extent required and/or permitted by applicable law. Availability will be provided so that you can correct, amend, or delete information where it is inaccurate. Personal information will not be provided in the case 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.

To request access to your personal information, please contact us in writing at the physical mailing address or the email address provided below. ComEngage will fulfill your request within 30 days or give notice of extension (up to 60 additional days).

Recourse, Enforcement and Liability

ComEngage periodically completes a privacy compliance assessment and will make improvements to our controls and processes based on those results. In the event of any privacy or collection complaints, ComEngage provides recourse mechanisms for dispute resolution, to allow expedient resolution of such matters. We regularly review how we are meeting these privacy promises and provide an independent way to resolve complaints about our privacy practices through the Insights Association.

Exceptions to our Privacy Policy

Any exceptions to this Privacy Policy in terms of what data is collected, how it is collected or how it is used will be explicitly disclosed before the data is collected. Additional consent will always be asked, and respondents can always opt-out if they choose.

Changes to Our Privacy Policy

ComEngage will review and update this Privacy Policy periodically to respond to changing legal, technical and business developments. We will note the date of its most recent revision herein. Please review this Privacy Policy frequently to be informed of your rights and how ComEngage is protecting your Personal Data.

California Consumer Privacy Act (CCPA)

Click here for our California Consumers Privacy Notice.

Contact

If you have questions or concerns regarding this privacy policy, please contact ComEngage at:

ComEngage, LLC
Attention: Privacy Officer
144 Railroad Avenue
Suite 222
Edmonds, WA  98020
engagewithus@comengage.us

Last modified September 15, 2020

California Consumer Privacy Act Notice

PRIVACY NOTICE

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Policy of ComEngage, LLC and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.

1.   Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“Personal Information”). This information is used for market research purposes.
In particular, we have collected the following categories of Personal Information from consumers within the last twelve (12) months:

 

Category Examples Collected
A.    Identifiers A name, alias, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers. YES
B.    Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A 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 information. Some Personal Information included in this category may overlap with other categories. YES
C.    Protected classification characteristics 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). YES
D.    Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. YES
E.     Biometric Information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. NO
F.     Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. NO
G.    Geolocation data. Physical location or movements. YES
H.    Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. NO
I.      Professional or employment-related information. Current or past job history or performance evaluations. YES
J.      Non-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. NO
K.    Inferences drawn from any of the information. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. YES

 

Personal Information does not include:

  • Personal Information that California consumers directly shared with ComEngage’s business partners in connection with the services.
  • Publicly available information from government records.
  • De-identified or aggregated consumer information.
  • Information excluded from the CCPA’s scope, like:
  • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
  • Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

We obtain the categories of Personal Information listed above from the following categories of sources:

  • Directly from you as a respondent to surveys.
  • Directly from our clients or their agents. For example, from documents that our clients provide to us related to the services for which they engage us.
  • Indirectly from our clients or their agents. For example, through information we collect from our clients in the course of providing services to them.
  • Directly and indirectly from activity on our websites. For example, from submissions through our website portal or website usage details collected automatically.

2.   Use of Personal Information

We may use or disclose the Personal Information we collect for one or more of the following business purposes:

  • Users:
  • We use your Personal 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 data 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).
  • Respondents:
  • 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. In addition, we use this information as more specifically detailed in our Privacy Policy.
  • In addition, ComEngage may use personal information about you for other purposes that are disclosed to you at the time we collect the information and/or with your consent.

3.   Sharing Personal Information

We may disclose your Personal Information to a third party for a business purpose. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed the following categories of Personal Information to our customers who act as brands, market research companies, advertisers, and strategy consulting firms for a business purpose:

Category A Unique personal identifier.
Category B Physical characteristics, employment, employment history.
Category C Age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, sex, sexual orientation, veteran or military status
Category D Products or services purchases, obtained, or considered or other purchasing or consuming histories or tendencies
Category G Physical location
Category I Employment history
Category K Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We disclose your Personal Information for a business purpose to the following categories of third parties:

  • Our affiliates.
  • Service providers.
  • Third parties to whom you or your agents authorize us to disclose your Personal Information in connection with products or services we provide to you.

4.   Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

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, 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 or selling 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 sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:
  • sales, identifying the Personal Information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your Personal Information that we collect from you and retain, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

  1. Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
  6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  8. Comply with a legal obligation.
  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Do Not Sell Rights

You or a person registered with the California Secretary of State that you authorize to act on your behalf may opt-out of the sale of your Personal Information. If you exercise this right:

  • This will result in providing the same answers within multiple surveys and could change your survey experience; and
  • You are directing us to share only your unique identifier to calculate the completed surveys, so you are remunerated from your panel company for your participation in surveys.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

Writing us at engagewithus@comengage.us. If you are a survey respondent, please keep in mind that the only way we have to identify you is via the survey link which you clicked to start the survey. This link may have been included in an email you received or a website you visited. If you cannot supply the survey link you clicked, we will be unable to verify your identity to process your request.

Only you or a person registered with the California Secretary of State that you authorize 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; and
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response electronically via our Data Rights Portal. 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.

5.   Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

6.   Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify through a notice on our website homepage.

7.   Contact Information

If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your Personal Information, your choices and rights regarding such use, please do not hesitate to contact us at:

ComEngage, LLC
Attention: Privacy Officer
144 Railroad Avenue
Suite 222
Edmonds, WA  98020
engagewithus@comengage.us

Last modified September 15, 2020