INTRODUCTION

This privacy notice provides you with details of how we collect and process your personal data.

Philomath Research, a market research company based in India with offices in US and UK (hereinafter “Philomath“, “We“, or the “Company“) is a fieldwork expert who offers a web platform which provides solutions and flawless supporting services to market researchers across the globe.

By registering on our platform you become a member and will provide some personal data to us. The membership with our platforms makes you eligible for participating in opinion surveys at the request of our clients and if you desire so.

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at contactus@philomathresearch.com

We require your explicit consent for processing sensitive data.

WHAT PERSONAL DATA WE COLLECT ABOUT YOU?

Information you give us: This is the information that you give us by filling in forms when signing up to our panel. It includes information you provide when you register to use our sites or services, correspond with us with email or when you report a problem with our site.

Information we collect about you: Our site may automatically collect the following information:

Technical Data: including the internet protocol (IP) address used to connect to the internet, browser type and version, time zone setting, operating system and platforms.

Information about the visit: including the full uniform resource locators (URL), pages you viewed, page response times, errors you might have faced and method used to browse away from the site.

Where we need to collect personal data by law or under other terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for e.g. your email for sending you survey invitations)

Personal Data: means any information about an individual from which that person can be identified. It does not include data which has been anonymized.

Identity Data: name (includes first and last names), date of birth, marital status, gender, panelist id and username.

Contact Data: email address and zip code.

Profile Data: includes your username and password, your interests, feedbacks and survey responses (if answered on a survey deployed by Philomath research)

Technical Data: includes internet protocol, login data, browser type and version, time zone, operating system and platforms

HOW WE COLLECT YOUR PERSONAL DATA

Direct Interactions: You may give us your identity data and contact data by filling out in forms or by corresponding with us through phone, email or otherwise. This includes personal data you provide when you:

• Apply for our services or products
• Enter your contact or identity data
• Create an account on our site
• Request information to be sent to you
• Enter a survey
• Give us feedback

Automated technology data: As you interact with our site, we may automatically collect Technical Data about your equipment, browsing actions and platforms. This data is collected by use of cookies or other similar technologies.

Third Parties or Publically Available Sources: We may receive personal data about you from various third party sources and public sources as below:

• Analytics providers like Google, based outside and inside the EU
• Contact Data, Financial Data and Transaction Data from providers of technical payment and delivery outside the EU
• Identity and Contact Data from data brokers and aggregators based inside or outside the EU (such as Zoon Info)
• Publically available identity and contact data

HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when legally permitted. The most common uses of your personal data are:

• Where we need to perform the relation between us (becoming a member of our platform, participating with the opinion surveys and sharing you data with beneficiaries of the opinion surveys)
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Generally, we don’t rely on consent as a legal ground for processing your personal data when you sign up and subscribe tour panel. It is of the essence of our collaboration that by subscribing to our panel we should be allowed to process your Data. It is possible that sometimes you provide us with Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and bio-metric data (e.g. eye tracking, facial coding). The reason you may choose proving us with any of the above information is your consent to include you in a wider range of opinion surveys and in order for you to generate higher incomes. We do not collect any information about criminal convictions and offences. When processing your sensitive Data, we will ask for your consent to process that data.

You have the right to opt-out any time from our collaboration or only to withdraw you consent for processing you sensitive Data by emailing us at contactus@philomathresearch.com

Purposes for processing your personal data

The set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant.

We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data as set out below:

• Performance of the Relation with you registering as a member of our platform
• Necessary for our legitimate interests to recover payments performed to you in the lack of a grounded reason
• Necessary to comply with a legal obligation.
• Necessary for our legitimate interests to keep our records updated and to study how customers use our products/services
• Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise
• Necessary for our legitimate interests to define types of customers for our products and services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy
• Necessary for our legitimate interests to develop our products/services and grow our business
• Necessary for your participation in polls with our contractors directly

1.Email communication

You will receive email communications from us:

I. When we invite you to participate in a survey;
II. When we provide you relevant information regarding the functioning of our platform (e.g. public holidays, changes without terms and conditions, payments related information etc.).

We will get your express opt-in consent before we start sending you marketing emails (other than info relevant and based on our collaborations) or before share your personal data with any third party for market research purposes. Where you opt out of receiving these messages, this will not apply to personal data provided to us a result of transactions other than marketing messages or an ongoing contract.

We will only use your personal data for the purposes for which it is collected, unless we reasonably consider that we need to use for another reason and that reason is compatible with the original purpose. If we need to use your personal data for unrelated purposes, we will notify you and explain the legal basis which allows us to do so.

We may also be required to process your personal data without your knowledge or consent, in compliance with the above rules, where this required or permitted by law.

2. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 2 above:

I. Service providers who provide IT and system administration services.
II. Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, insurance and accounting services.
III. Revenue & Customs, regulators and other authorities based in India and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
IV. Third parties to whom we sell, transfer, or merge parts of our business or our assets, or to contractors for your participation in detailed surveys.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

When participating to certain surveys, you may be asked if you want your email address is shared with the beneficiaries of the surveys in order for you to participate to next stages of the surveys. We will share your email address only if you consent to such actions.

3. INTERNATIONAL TRANSFERS

We share your personal data within a group of companies which involves transferring your data outside the European Economic Area (EEA).

Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.

Many of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:

I. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
II. Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
III. Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield, which requires them to provide similar protection to personal data shared between the Europe and the US.

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

4. COOKIES

We use site cookies to distinguish you from other users when you are taking a survey. Cookies also help us to provide you with a good experience when you browse our sites and they also help to improve our sites. We may also gather certain information about your computer, hardware and software, for example, your IP address, the display settings of your monitor, the type of browser used, the type of operating system, etc. The data collected in this process are not tied to any of your personal information, is stored on secured servers, and is only used for quality control and fraud prevention purposes and to help prevent Panelists from completing the same survey more than once, and for no other purpose.

5. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

6. DATA RETENTION

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for 10 years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see below for further information.

In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

7. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

1. Request access to your personal data - (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
2. Request correction of your personal data - This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
3. Request erasure of your personal data - This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
4. Object to processing of your personal data - where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms.
5. Request restriction of processing your personal data - This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
6. Request transfer of your personal data - We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
7. Right to withdraw consent - where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please email us at contactus@philomathresearch.com

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.