Bold Insight privacy policy
For all users in the United States
PRIVACY POLICY
Bold Insight, Inc. (“Bold Insight”) is a United States based company that provides user experience and human factors research and consulting services. The nature of our business involves recruitment of human participants for studies with new and existing technologies.
This Privacy Policy covers the collection, use, and disclosure of personal information that may be collected by Bold Insight Inc., a Delaware corporation (“Bold Insight” or “us” or “we”) anytime you interact with Bold Insight or visit our website at www.boldinsight.com (together with any mobile or app versions of such website, the “website”). Please take a moment to read the following to learn more about our information practices, including what type of information is gathered, how the information is used and for what purposes, to whom we disclose the information, and how we safeguard your personal information. Your privacy is a priority at Bold Insight, and we go to great lengths to protect it.
We reserve the right to change the terms and provisions of this Privacy Policy at any time and for any purpose without notice. You should visit this page regularly and review this Privacy Policy for the current version, since your continued access or use of the website will be deemed as an irrevocable acceptance of any such changes, modifications or alterations.
IMPORTANT: IF YOU MAKE USE OF THE SITE, REGISTER WITH THE SITE, REQUEST INFORMATION THAT WE MAY OFFER, OR SUBMIT INFORMATION IN ANY WAY TO OR THROUGH THE SITE YOU AGREE TO PRIVACY POLICY AS THEN IN PLACE. AS WE UPDATE AND EXPAND OUR SERVICES, THIS POLICY MIGHT CHANGE, SO PLEASE REVIEW IT FROM TIME TO TIME.
SCOPE OF PRIVACY POLICY
This Privacy Policy covers the followings methods with which we may collect personal information:
- personal information collected from your use of the website
- personal information collected from human participants in Bold Insight studies
- human resources personal information
If you use our website:
WHY WE COLLECT PERSONAL INFORMATION
We collect your personal information because it helps us deliver a superior experience and level of customer service. Your personal information also helps us and our third-party advertising partners deliver more relevant ads to you when you visit the website.
WHAT INFORMATION WE COLLECT AND HOW WE MAY USE IT
We will ask for your personal information if you wish to create an account with us for the purpose of receiving company updates, blog posts, related company news. We may at that time require that you provide personally identifiable information, including without limitation your name and email address.
We may also collect certain non-personally identifiable information regarding customer activities on our /website. This helps us to determine how best to provide useful information to users and to understand which parts of our website and Internet services are of most interest to them.
When you submit reviews or comments to the website, you will provide us with the contents of your submission.
We will also collect the information described below under “Cookies, Tracking and Other Technologies” when you use the website.
We may use your personal information to provide services that you have requested, respond to your requests, and send you communications, as well as for auditing, research, and analysis to improve the products offered on our website.
CLOSED CIRCUIT TELEVISION
Bold Insight uses closed circuit television (CCTV) images for the prevention, identification and reduction of crimes and to monitor the office buildings in order to provide a safe and secure environment for researchers, participants, clients and visitors.
The CCTV systems at Bold Insight U.S. is comprised of a number of cameras in the Bold Insight office suites that are controlled and monitored by Bold Insight directly. The remainder of the building utilizes cameras and CCTV maintained and monitored by the entity (entities) who manage the building. Bold Insight does not have access nor any control over these cameras or their recording.
PUBLICLY DISPLAYED INFORMATION IS PUBLIC
If you use the review or comment feature on the website, you should be aware that your user name and any other information you share may be visible to other users. Personally identifiable information you submit in this manner can be read, collected, or used by other individuals to send you unsolicited messages. For example, if you submit a review that includes information that was previously non-public, Bold Insight will collect that information from your interaction and the information may become publicly available. Bold Insight is not responsible for the personally identifiable information you choose to submit in this manner.
WHEN WE DISCLOSE YOUR INFORMATION
To help us provide superior service, your personal information may be shared with actual and prospective assignees and licensees of the website, its content, or any portion thereof, including your submissions and personal information. In addition, the personal and other information you provide to Bold Insight is considered an asset of the company and may be included among transferred assets if the website, Bold Insight or any parent company is acquired by a third party.
There are also times when Bold Insight makes certain personal information about you available to companies or individuals to provide products and services to you on our behalf. These companies may help us process information, manage and enhance customer data, provide customer service, assess your interest in our products and services, or conduct customer research or satisfaction surveys. We call them our “Service Providers.” We may share personally identifiable information with Service Providers solely as appropriate for them to perform their functions, but we prohibit them from using such information for any other purpose unless we inform you otherwise at the time of collection.
At times we may be required by law, litigation, arbitration or similar legal process to disclose your personal information. We may also disclose information about you if you consent to it or if we determine that disclosure is necessary for national security, law enforcement, personal safety, or other issues of public importance.
HOW WE PROTECT YOUR PERSONAL INFORMATION
Bold Insight takes precautions – including administrative, technical, and physical measures – to safeguard your personal information against loss, theft, and misuse, as well as unauthorized access, disclosure, alteration, and destruction. We use reasonable and customary measures to safeguard the security of your personal information. Nonetheless, transmissions made on or through the Internet and information stored by us are vulnerable to attack and cannot be guaranteed to be secure. You hereby acknowledge that we are not responsible for any intercepted information sent via the Internet or data loss caused by “hacks,” malicious attacks or other breaches caused by third parties, and you hereby release us from any and all claims arising out of or related to the use of information obtained by means of an unauthorized interception or breach.
COOKIES, TRACKING AND OTHER TECHNOLOGIES
Like many websites, Bold Insight’s website uses cookies, flash cookies, web beacons, and other technologies to help us understand which parts of our websites are the most popular, where our visitors are going, and how much time they spend there. We may use these technologies to study traffic patterns on our website. This information helps us make the website more rewarding and helps us study the effectiveness of our customer communications. We also use cookies to customize your experience and provide greater convenience each time you interact with us. For example, your account information and information about your computer helps us operate the website efficiently. You may have the ability to decline to permit cookies or other tracking technology, but in that case we cannot promise you that all features of the website will function properly as a result.
As is true of most websites, we gather certain information automatically and store it in log files. This information includes Internet Protocol (IP) addresses, browser type, Internet Service Provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information, which does not identify individual users, to analyze trends, to administer the site, to track users’ movements around the site and to gather demographic information about our user base as a whole. Bold Insight will not use this type of collected information to market directly to that person. We may share aggregated anonymous information with third parties to assist in analyzing, operating, maintaining, and improving the website and placing advertising on it.
We also may use third-party website analytics tools (such as Google Analytics) that collect information about visitor traffic on our website. The information we may collect by these tools is similar to that collected by the technologies described above and includes:
- Information about the devices our visitors use to access the Internet (such as the IP address and the device, browser and operating system type);
- URLs that refer visitors to the website;
- Dates and times of visits to the website;
- Information on actions taken on the website (such as page views and site navigation patterns);
- A general geographic location (such as country and city) from which a visitor accesses our website; and
- Search terms that visitors use to reach the website.
In some of the email messages from us or those whose products are available on our website, we use a “click-through URL” linked to content on Bold Insight website. When customers click one of these URLs, they pass through our web server before arriving at the destination web page. We may track this click-through data to help us determine interest in particular topics and measure the effectiveness of customer communications. If you prefer not to be tracked, simply avoid clicking text or graphic links in the email.]
CLICKSTREAM DATA
As you use the Internet, a trail of electronic information is left at each web site you visit. This information, which is sometimes referred to as “Clickstream Data,” can be collected and stored by a web site’s server. As noted above, we collect Clickstream Data. Clickstream Data can tell us the type of computer and browsing software you use and the address of the web site from which you linked to our website. We may use Clickstream Data as a form of non-personal information to anonymously determine how much time visitors spend on each page of the website, how visitors navigate throughout the website and how we may tailor our web pages to better meet the needs of visitors. This information will only be used to improve the website. Any collection or use of Clickstream Data will be anonymous and aggregate.
HOW WE RESPOND TO DO NOT TRACK (DNT) SIGNALS
The California Business & Professions Code Section 22575(b) (as amended effective January 1, 2014) provides that California residents are entitled to know how the website responds to “Do Not Track” browser settings. The website does not react to or honor any “do not track” technologies that you may choose to utilize because uniform technological and commercial standards have not yet been developed.
THIRD-PARTY SITES
Our website has links to the sites of advertisers and other third parties. Bold Insight is not responsible for their privacy practices. We encourage you to learn about the privacy policies of those companies, which may collect personally identifiable information about you.
CHILDREN AND MINORS
Our website and app are intended for use by adults only and we do not knowingly collect or use any personal information from minors under the age of 18. If we collect personal information from someone we learn to be under 18 years of age, such personal information shall immediately be deleted. If you are a parent or guardian of a child under 18 years of age and you believe your child has provided us with personal information, please contact us at [email protected].
If you are a California resident under the age of 18, and a registered user of our website, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted. To make such a request, please send an email with a detailed description of the specific content or information to [email protected] and include “CA Removal Request” in the subject line. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.
CHANGES
We reserve the right to change this Privacy Policy at any time. You will be notified of changes by updates to this Privacy Policy. The date on which this Privacy Policy was last adopted or changed will be set forth at the top of this Privacy Policy. Therefore, please review this Privacy Policy from time to time so that you are aware when any changes are made to this Privacy Policy. If you have any questions about the changes that were implemented, please contact us at [email protected] and include “Information Regarding Updated Policy” in the subject line. In any event, your continued use of the website after such change constitutes your acceptance of any such change(s), and if you do not accept any changes, you may choose not to use our website.
PERSONAL INFORMATION GATHERED UNDER PREVIOUS VERSIONS OF THIS PRIVACY POLICY
Personal information collected via the website will generally be governed by the version of the Privacy Policy in effect at the time the information was gathered. We will not retroactively make material changes to the way we use personally identifiable information collected under previous versions of this Privacy Policy without obtaining your consent.
YOUR CALIFORNIA PRIVACY RIGHTS
Under certain circumstances, California Civil Code Section 1798.83 states that, upon receipt of a request by a California customer, a business may be required to provide detailed information regarding how that business has shared that customer’s personal information with third parties for direct marking purposes. This requirement does not currently apply to Bold Insight. California users may request further information about their rights under this law and our policy by writing to us at [email protected], using the subject line “CA Request for Information,” and requesting further information.
USERS OUTSIDE THE UNITED STATES
If you are visiting the website from a location outside of the United States, your connection will be through and to servers located in the United States and all information you provide will be processed and securely maintained in our web servers and internal systems located within the United States. IN ADDITION, IF YOU ARE LOCATED OUTSIDE THE UNITED STATES, YOU SHOULD NOTE THAT YOUR INFORMATION WILL BE TRANSFERRED TO THE UNITED STATES, THE LAWS OF WHICH MAY BE DEEMED BY OTHER COUNTRIES TO HAVE INADEQUATE DATA PROTECTION. Users of the website located in countries outside of the United States of America who submit personal information do thereby consent to the general use of such information as provided in this Privacy Policy and to the transfer of that information to and/or storage of the information in the United States of America.
APPLICABLE LAW
This Privacy Policy and our legal obligations are subject to the laws of the State of Delaware and the United States of America, regardless of the location of any user. Any claims or complaints must be filed in the United States of America in the State of Delaware.
UPDATING OR REMOVING YOUR PERSONAL INFORMATION
Please contact us at any time to update or remove your personal information. We may reject requests that are unreasonably repetitive, require disproportionate technical effort or expense (for example, developing a new system or fundamentally changing an existing practice), risk the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup systems). Please be aware that a removal request does not ensure complete or comprehensive removal of the content or information you have provided and that there may be circumstances in which the law does not allow removal even if requested.
DISCLAIMER
Our website and app operate AS-IS, and we do not represent or warrant that they will be available at all times, or that your use of the website will be uninterrupted or error-free. We are not responsible for your ability to access the website, or for matters beyond our control.
If you are a participant in a Bold Insight study:
WHY WE COLLECT PERSONAL INFORMATION
Bold Insight conducts human factors and user experience research studies to help improve products and services for our clients and their customers. Studies may be conducted remotely or in-person. Prior to the study session, we need to collect certain types of personal information to identify you and qualify you for our study. During the session, a typical study may include an interview with you while you interact with the study stimuli, which, for example, might be a website or device. In a remote study, we may ask you to share your computer or phone screen and/or join a meeting via video. Depending on the study, we may collect video and audio recordings of your session so we can analyze the results, which helps to improve the design of products and services for our clients. Your session may also be securely live streamed to other viewers involved in the study. To learn more about how we secure your information, see below under SECURITY. Prior to your participation in any Bold Insight study you will be provided with an Informed Consent Form containing details specific to your study with the option to opt in or opt out.
WHAT INFORMATION WE COLLECT AND HOW WE MAY USE IT
When you participate in a Bold Insight study, Bold Insight may collect any of the following personally identifiable information as applicable for that study. You will always have the choice to opt in or opt out of providing this information.
- Contact details such as name, address, telephone number, and email address
- Social security, driver’s license or passport number for identification purposes
- Identification of workplace and position (title)
- Video and audio recordings of faces and voices
- Profile data such as username and purchasing history
- Information collected from a recruiting firm which recruited you for our study
- Information regarding any relevant experience or subject matter expertise necessary for the study
- Medical condition and any prescribed medications, when applicable for the study
- Relevant professional licensing number (e.g., medical license number)
- Demographic information such as age, household income, race, gender, ethnicity
- Sensitive information such as racial or ethnic information sexual orientation, religious information, personal health information, biometric data, personal identifiable financial information as well as information received from third parties
- Opinions, specifically limited to opinions on the products or services in the study
Information received from third parties:
- We have business relationships with recruitment agencies that help identify appropriate study participants. We may receive your personally identifiable information to help qualify you for the study. We also partner with other User Experience and Human Factors Research agencies from whom we may receive your personal information.
SHARING OF YOUR PERSONAL INFORMATION
In the context of its business and with your consent, Bold Insight may transfer your personal information to our client, which would be the sponsor of the study. In some cases, our client will request data that includes your personal information. Transfer of this data that includes your personal information allows our client to improve the design of the product or service that is being developed.
In many cases, we will simply transfer aggregate reports which do not contain your personal information or any information that can be used to identify you. Aggregate reports are those wherein the information you provide is anonymized and combined with that of other study participants for analysis, where this information cannot be used to identify you.
We do not permit the use of your personal information for any reason other than that for which it was originally provided, which will be described in the Informed Consent Form provided to you prior to your participation in the study.
We may share materials containing your personal information with other third-party processors to assist with analysis. For example, this could include interview transcription, web conferencing tools, diary tools used for data collection. In such cases of transfer of your personal information, Bold Insight remains liable for the protection of personal information under if the third party handles the information in a manner inconsistent with this Privacy Policy. In the event information will be transferred, Bold Insight provides clear and unambiguous advanced notice and a description of the purpose of transfer to the data subject, who will have the opportunity to decline.
CROSS-BORDER TRANSFER
Bold Insight is a global business. As a result, Personal Data can/may be transferred worldwide with recipients of that data residing in any number of countries. As a result, Bold Insight cannot guarantee that participants will maintain the same rights as those rights afforded to them in their country of residence. See below for specific rights pertaining to specific countries. Prior to your participation in any Bold Insight research study, you will be informed of the countries where processing will take place and how your rights over your data may be affected.
RETENTION OF YOUR PERSONAL INFORMATION
Bold Insight will only use your personally identifiable information to the extent necessary to carry out the research as specified in the informed consent form provided to you prior to your participation in our study. Your personal information will be retained within study data for as long as needed to support the research purpose as specified in the Informed Consent Form. Aggregate reports of your personal information may be developed and retained for longer periods. This means that information you provide is anonymized and combined with that of other study participants for analysis, where this information cannot be used to identify you.
SECURITY
To ensure ongoing protection of your personal information, Bold Insight has implemented information security practices consistent with industry standards. This includes technical, physical, administrative, and organizational measures we have implemented to protect the confidentiality, integrity, and availability of your personal information and safeguard your personal information against loss, theft, and misuse, as well as unauthorized access, disclosure, alteration, and destruction.
YOUR RIGHT TO ACCESS YOUR PERSONAL INFORMATION
You have the right to access, amend, correct, access, or transfer your personal information at any time. Additionally, you have the right to request us to limit the use of, block transfer of, or delete your personal information from our records. To make any request regarding your personal information, please contact our Data Privacy Officer at [email protected].
CONTACT US
If you have any questions, concerns, or complaints about Bold Insight or our Privacy Policy, please contact us:
Bold Insight
Attn: Data Privacy Officer
2001 Butterfield Rd., Suite 360
Downers Grove, IL 60515
United States
For participants based in the European Economic Area
Right to Lodge a complaint
You have the right to lodge a complaint with the relevant supervisory authority. You are able to find the appropriate authority at https://edpb.europa.eu/about-edpb/about-edpb/members_en
Right to Access
You have the right to request Bold Insight for copies of personal data. We may charge a you a small fee for this service.
Right to Rectification
You have the right to request that Bold Insight correct any information you believe is inaccurate. You also have the right to request Bold Insight to complete information you believe is incomplete.
Right to Erasure
You have the right to request that Bold Insight erase your personal data, under certain conditions
Right to Restrict Accessing
You have the right to request that Bold Insight restrict the processing of your personal data, under certain conditions.
Right to Object to Processing
You have the right to object to Bold Insight processing your personal data, under certain conditions.
Right to Data Portability
You have the right to request that Bold Insight transfer the data that we have collected to another organization or directly to you under certain conditions.
We utilize the standard contractual clauses for transfer of your information outside of the European Economic Area. In the event the standard contractual clauses are not used as a mechanism of transfer, you will be informed of the risks during informed consent.
For participants based in the United Kingdom
Right to Lodge a Compliant
You are able to file a complaint with the Information Commissioner’s Office
ICO
Telephone: 0303 123 1113
Textphone: 01625 545860
Right to Access
You have the right to request Bold Insight for copies of personal data. We may charge a you a small fee for this service.
Right to Rectification
You have the right to request that Bold Insight correct any information you believe is inaccurate. You also have the right to request Bold Insight to complete information you believe is incomplete.
Right to Erasure
You have the right to request that Bold Insight erase your personal data, under certain conditions
Right to Restrict Accessing
You have the right to request that Bold Insight restrict the processing of your personal data, under certain conditions.
Right to Object to Processing
You have the right to object to Bold Insight processing your personal data, under certain conditions.
Right to Data Portability
You have the right to request that Bold Insight transfer the data that we have collected to another organization or directly to you under certain conditions.
We utilize the International Data Transfer Agreement (IDTA) for transfer of your information outside of the United Kingdom. In the event the IDTA is not used as a mechanism of transfer, you will be informed of the risks during informed consent.
For participants Outside of the U.S., EEA or the UK
Bold Insight is a global business. As a result, studies can/may be conducted worldwide with participants residing in any number of countries. Because of the wide ranging and ever-changing laws globally, not all countries nor governing laws of those countries will be explicitly stated in this Privacy Policy. However, Bold Insight agrees to adhere to and follow all country laws and rights of its citizens when and where applicable. If you would like to inquire further or have any complaints, please contact us:
Bold Insight
Attn: Data Privacy Officer
2001 Butterfield Rd., Suite 360
Downers Grove, IL 60515
United States
For participants within the United States
Some U.S. state privacy laws (e.g., the California Consumer Privacy Act (CCPA) and Virginia Consumer Data Protection Act (VCDPA)) require specific disclosures for state residents. As a result, studies can/may be conducted within a multitude of states with participants residing in any number of states. Because of the wide ranging and ever-changing laws nationally, not all states nor governing laws of those states will be explicitly stated in this Privacy Policy. However, Bold Insight agrees to adhere to and follow all states laws and rights of its citizens when and where applicable. If you would like to inquire further or have any complaints, please contact us:
Bold Insight
Attn: Data Privacy Officer
2001 Butterfield Rd., Suite 360
Downers Grove, IL 60515
United States
CCPA NOTICE TO CALIFORNIA RESIDENTS
Effective January 1, 2020, the California Consumer Privacy Act (CCPA) provides California residents with several rights for control over their data. The terms used in this CCPA Notice but not defined here will have the same meaning as defined under the CCPA:
- Prior to participation in any Bold Insight study, you will be provided with an Informed Consent Form detailing the categories of personal information being collected for your study. The Privacy Policy above details categories of personal information collected by Bold Insight in general.
- Bold Insight does not use your information for any purpose other than the purpose outlined in your Informed Consent Form notice, including the sale of your personal information. Additional information regarding onward transfer and sharing of your personal information is described in the above Privacy Policy.
- Bold Insight does not discriminate against you in any way for exercising your rights under the CCPA.
If you are a California resident and have been a participant in a Bold Insight study or have otherwise submitted your personal information to Bold Insight, you have the right to request Bold Insight to disclose to you what personal information we have collected, used, or shared about you, and why we collected, used, or shared that information. Specifically, you may request that we disclose:
- The categories of personal information collected
- Specific pieces of personal information collected
- The categories of sources from which Bold Insight collected personal information
- The purposes for which Bold Insight uses the personal information
- The categories of third parties with whom Bold Insight shares the personal information
You may also request us to delete your personal information, subject to legal and regulatory exceptions.
For additional information about your rights under the CCPA, or to request disclosure or deletion of your personal information, please contact us at [email protected] or submit a written notice to the address below. Bold Insight is required under the CCPA to respond to your written request within 45 calendar days.
Bold Insight Inc.
Email: [email protected]
Attn: Data Privacy Officer
2001 Butterfield Rd., Suite 360
Downers Grove, IL 60515
United States
Bold Insight UK privacy policy
1. INTRODUCTION
This privacy policy (Policy) relates to your personal information in connection with your use of and access to the Bold Insight website boldinsight.co.uk (the Bold Insight Platform) and any services provided by Bold Insight (the Bold Insight Platform, your participation in a Bold Insight study and services together form the Bold Insight Services).
We are committed to protecting your information and your right to privacy. If you have any questions or concerns about our Policy, or our practices with regards to your personal information, please contact us via [email protected].
When you participate in Bold Insight research you trust us with your information, and we take your privacy very seriously. We seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this Policy that you do not agree with, please discontinue your use of the Bold Insight Services.
2. CHANGES TO THIS POLICY OR YOUR PERSONAL INFORMATION
We review this Policy regularly, and it is your responsibility to check regularly and determine whether you still agree to comply with the Policy. If you do not agree to any changes to this Policy, then you must immediately stop using the Bold Insight Services. If we make any significant changes to this Policy, we will use our reasonable endeavours to inform you of such changes in advance in writing.
It is important that the personal information we hold about you is true, complete, accurate and current. Accordingly, you must notify us of any changes to your personal information (for example, if you change your email address).
3. ABOUT US
The Bold Insight Services are owned and operated by Bold Insight Limited (trading as “Bold Insight”), a company registered in England and Wales with company number 13804835 and whose registered office is situated at 231-232 Strand, Ste 304, London, WC2R 1DA (Bold Insight/we/us/our). Bold Insight is the controller (also known as a data controller) of, and is responsible for, your personal information. The term “you” refers to the user wishing to access and/or use the Bold Insight Services.
Bold Insight UK conducts human factors and user experience research studies to help improve products and services for our clients and their customers. Studies may be conducted remotely or in-person. Prior to the study session, we need to collect certain types of personal information to identify you and qualify you for our study. During the session, a typical study may include an interview with you while you interact with the study stimuli, which, for example, might be a website or device. In a remote study, we may ask you to share your computer or phone screen and/or join a meeting via video. Depending on the study, we may collect video and audio recordings of your session so we can analyse the results, which helps to improve the design of products and services for our clients. Your session may also be securely live streamed to other viewers involved in the study. To learn more about how we secure your information, see below under “How do we keep your information safe”. Prior to your participation in any Bold Insight study, you will be provided with an Informed Consent Form containing details specific to your study with the option to opt in or opt out.
4. INFORMATION WE MAY COLLECT ABOUT YOU
4.1 Personal information you disclose to us
In Short: We collect personal information that you provide to us which may include, but is not limited to your name, address, contact information, proof of identify, date of birth, employer, household income, gender, ethnicity, job title, health information such as medical condition or prescribed medications, as well as video and photographic recordings of your face and audio recordings of your voice.
(a) Where and how we collect personal information
We collect personal information that you voluntarily provide to us when registering to use and actually using the Bold Insight Services, or otherwise contacting us. More particularly, the personal information that we collect depends on the context of your interactions with us, the choices you make and the products and features you use. For example:
- We gather information directly from you face to face if you come to our offices for information or to discuss an agreement and over the telephone if you ring us to make an enquiry.
- We collect personal information via our website, mobile applications and other technical systems.
- We collect personal information when you use our website or mobile applications to sign up to, participate in or receive a service from us, for example where you contact us, request information online, report an issue, provide feedback or enter a live chat.
- We collect personal information when you participate in live or recorded interviews with us or our representatives.
- Our website also uses cookies and collects IP addresses (for more information on this, see our Cookie Policy).
- We may monitor and record communications with you (such as telephone conversations and emails). We may do this for a number of reasons, such as to check the quality of our customer service, for training purposes, to prevent fraud or to make sure we are complying with legal requirements.
- If you visit our offices, some personal data may also be collected from monitoring devices and systems such as closed-circuit TV (CCTV).
- If you apply or are put forward for a role with us, or work for us (either directly or indirectly) for any period of time, we also conduct a background check, collect your personal information, which may include your contact details, financial and payment details, details of your education, qualifications and skills, your marital status, your nationality, your NI (National Insurance) number, your job title and your CV.
If you give us information on behalf of another individual, in providing that information to us you are confirming that you have sought and obtained, from that individual, permission for you to:
- Consent on their behalf to the processing of their personal data;
- Receive on their behalf any data protection notices; and
- If relevant, consent to the transfer of their personal data abroad, and you shall indemnify us and hold us harmless against any claims, actions, proceedings, losses, damages, costs (including reasonable legal costs) and expenses (including taxation), in each case of any nature whatsoever, arising out of or in connection with your failure to obtain these permissions.
(b) The types of personal information we may collect
We may collect the following information about you (the Information):
- Identity Data, which includes your first name, last name, gender, driver’s licence, passport number, professional licensing number (e.g., medical licence number), national insurance number, information, audio recordings of your voice, and video recordings of your face and upper body.
- Contact Data, which means the data we use to contact you including your address, email address and contact number, as well as (where applicable) details of your next of kin, and emergency/alternate contact(s) or referee(s).
- Experience Data, which includes your job title, place of work, employment experience, educational background, subject matter expertise, and household income.
- Profile Data, which includes your username, email address and log-in data, details of any purchases or orders made by you.
- Feedback data, which includes your feedback and opinions on the products and services referenced in the studies in which you participate, as well as any survey or questionnaire responses.
- Usage Data, which includes Information about how you use the Bold Insight Services. This includes your browsing patterns and Information such as how long you might spend on one of our webpages on the Bold Insight Platform and what you look at and for, the page that referred you to the Bold Insight Platform and the click stream during your visit to our website, page response times, and page interaction Information (for example, clicks you make on a page).
- Marketing and Communications Data, which includes your preferences with regards to receiving marketing from us and your other communication preferences.
4.2 Sensitive personal information
In Short: We may collect sensitive personal data due to the nature of the services we provide.
Due to the nature of the services we provide, you may be asked to provide sensitive personal information, or third parties might provide us with sensitive personal information about you. When such information is requested, we will explain why we are requesting it and how we will use it, either in this policy or separately.
Sensitive personal information includes information relating to your ethnic origin, political opinions, religious beliefs, whether you belong to a trade union, your physical or mental health or condition, sexual life, and whether you have committed a criminal offence. Bold Insight and any third party will only collect your sensitive personal information with your explicit consent.
More specifically (and depending on the nature of a study you are participating in), we may collect medical information about you, including information about your medical health and conditions and any medications you have been prescribed. We may also collect information about your ethnicity. This sensitive information is used only to qualify you for the study and to perform data analysis of aggregate data.
4.3 Personal information from third parties
In Short: We may receive information about you from third parties, and we may use this information to provide, improve and personalise the Bold Insight Services.
We might also collect personal information about you from third parties (for example, firms that recruit individuals to participate in our studies), which we will add to the information we already hold about you in order to help us provide, improve and personalise the Bold Insight Services.
If you apply for a job with us, we may also receive information from those who provide references relating to your prospective or actual engagement or employment.
4.4 Information automatically collected
In Short: Some Information – such as IP addresses and/or browser and device characteristics – is collected automatically when you use the Bold Insight Platform.
We automatically collect certain Information when you visit, use or navigate the Bold Insight Platform. This Information does not reveal your specific identity (unless your device name is the same as your name) but may include device and usage Information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, Information about how and when you use the Bold Insight Platform and other technical Information. This Information is primarily needed to maintain the security and operation of the Bold Insight Platform, and for our internal analytics and reporting purposes.
Like many businesses, we also collect Information through cookies and similar technologies. You can find out more about this in our Cookie Policy.
5. HOW DO WE USE YOUR INFORMATION?
In Short: We process your Information for purposes based on legitimate business interests, the fulfilment of our contract with you and our client, compliance with our legal obligations, and/or your consent.
We use your Information collected via the Bold Insight Services for a variety of business purposes described below. We process your Information for these purposes in reliance on our legitimate business interests (Business Purposes), in order to enter into or perform a contract with you (Contractual Reasons), with your consent (Consent), and/or for compliance with our legal obligations (Legal Reasons). We indicate the specific processing grounds we rely on next to each purpose listed below.
We may process your Information for the following purposes:
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- To take steps towards entering into a contract with you, to provide the Bold Insight Services and to claim any right to be paid under our terms and conditions (Contractual Reasons). This includes collecting and using your personal information to:
- Prepare an agreement with you;
- Manage any accounts you hold with us;
- Contact you for reasons related to the Bold Insight Services;
- Enable us to follow up on enquiries made by you in relation to the Bold Insight Services and/or to provide information you have requested;
- Contact your next of kin or your emergency/alternate contact(s) in order to get in touch with you when we have failed to do so using your own contact details;
- Contact your referee(s) or to obtain a reference for a job that you are applying for;
- Deal with payment for the Bold Insight Services;
- Notify you of any changes to our Site or to the Bold Insight Services that may affect you; and
- Resolve disputes or collect overdue payments.
- To take steps towards entering into a contract with you, to provide the Bold Insight Services and to claim any right to be paid under our terms and conditions (Contractual Reasons). This includes collecting and using your personal information to:
- To pass it onto our clients, sister companies and research vendor partners in connection with the provision of the Bold Insight Services (Business Purposes), for example so that such recipients can observe, edit, enhance and/or transcribe video interviews remotely in their home countries.
- To contact you regarding enquiries you have made in relation to the Bold Insight Services.
- To facilitate a recruitment process in which you are involved.
- To follow up on enquiries in accordance with industry guidelines and providing quotes (Business Purposes).
- To send administrative Information to you for Business Purposes, Legal Reasons and/or possibly Contractual Reasons. We may use your Information to send you product, service and new feature information and/or information about changes to our terms, conditions and policies, as may be in place from time to time.
- To administer promotions for our Business Purposes and/or with your Consent.
- To request feedback for our Business Purposes and/or with your Consent. For example, we may use your Information to request feedback and to contact you about your use of the Bold Insight Platform.
- To protect the Bold Insight Services for Business Purposes and/or Legal Reasons. We may use your Information as part of our efforts to keep the Bold Insight Services safe and secure (for example, for the purposes of monitoring and/or preventing fraud).
- To enforce our terms, conditions and policies for Business Purposes, Legal Reasons and/or possibly Contractual Reasons.
- To respond to legal requests and prevent harm for Legal Reasons. For example, if we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
We may use your Information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve the Bold Insight Services, our products and services, our marketing and your experience.
6. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
- In Short: We only share Information for Contractual Reasons, to fulfil our Business Purposes, or with your Consent.
We only share and disclose your Information in the following situations: - Contractual. With your consent, we may share Information with partners to enable any orders for services, or obligations arising out of any such orders, to be fulfilled.
- Compliance with Legal Obligations. We may disclose your Information where we are legally required to do so in order to comply with applicable laws, governmental requests, judicial proceedings, court orders, or legal processes, such as in response to a court order or a subpoena (including in response to requests from public authorities in order to meet national security or law enforcement requirements).
- Vital Interests. We may disclose your Information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, illegal activities or situations involving potential threats to the safety of any person, or where we believe it is necessary for the purpose of providing evidence in connection with litigation proceedings in which we are involved.
- Third Party Service Providers. We may share your Information with third party vendors, service providers, credit reference agencies, trade associations of which we are a member, credit card associations, contractors or agents who perform services and require access to such Information to carry out that work. Examples include: sister companies involved in the research, research vendor partners, or screen sharing applications (such as Zoom or Goto). Such third parties will only have access to your Information to the extent that they need to perform those services. They are required to keep your Information confidential and may not use it other than as we ask them to and always in accordance with this Policy.
- Business Transfers. We may share or transfer your Information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
- Third Party Advertisers. We may use third party advertising companies to serve ads when you visit the Bold Insight Platform. These companies may use Information about your visits to the Bold Insight Platform and other websites that are contained in web cookies and other tracking technologies in order to provide personalised advertisements about goods and services that may be of interest to you. See our Cookie Policy for further Information.
- Business Partners. Provided you have given us Consent to do so, we may share your Information with our business partners to offer you certain products, services or promotions.
- With your Consent. We may disclose your Information for any other purpose with your Consent, including with any person who you have named as a person we can contact to discuss your account and any agent or representative of yours.We may disclose aggregated, anonymous Information (i.e. Information from which you cannot be personally identified), or insights based on such anonymous Information, to selected third parties, including (without limitation) analytics and search engine providers to assist us in the improvement and optimisation of the Bold Insight Services. In such circumstances we will not disclose any Information which can identify you personally.
7. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
In Short: We may transfer, store, and process your Information in countries other than the UK, but will take all reasonable steps to ensure it is protected.
Whenever we transfer your Information outside of the UK, we will take all reasonably practicable measures to protect your Information in accordance with this Policy and applicable laws. To the extent that any transfer requires approved safeguards to be in place we will either: (a) transfer your Information to countries that have been deemed to provide an adequate level of protection for personal data; or (b) transfer your Information where we have an agreement in place in line with relevant requirements set out by the Information Commissioner’s Office; or (c) transfer your Information with your specific consent. Please contact us if you want further information on the specific mechanism(s) used by us when transferring your personal data out of the UK.
8. THIRD PARTY WEBSITES
In Short: We are not responsible for the safety of any Information that you share with third party providers who feature or advertise, but are not affiliated with, the Bold Insight Services.
The Bold Insight Platform may feature links to third party websites or social media channels or contain advertisements from third parties that are not affiliated with us, and which may link to other websites, online services or mobile applications. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this Policy.
We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services or applications that may be linked to or from the Bold Insight Platform. You should review the policies of such third parties and contact them directly if you have any related questions.
9. FOR HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your Information for as long as necessary to fulfil the purposes outlined in this Policy, unless a longer retention period is permitted or required by law.
We will only keep your Information for as long as it is necessary for the purposes set out in this Policy, unless a longer retention period is required or permitted by law (such as tax law, accounting requirements or other legal or regulatory requirements), or as specified at the point of collection with your consent.
When we have no ongoing Business Purpose to justify the processing of your Information, we will either delete or anonymise it, or, if this is not possible (for example, because your Information has been stored in backup archives), then we will securely store your Information and isolate it from any further processing until deletion is possible.
10. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your Information through a system of organisational and technical security measures.
We have implemented appropriate technical and organisational security measures designed to protect the security of any Information we process. For example, we store your personal data in cloud environments which require unique user authentication and have firewalls in place, and all computers used to access the information are encrypted (e.g., BitLocker, FileVault).
We have procedures in place to deal with any suspected data security breach. We will notify you and any applicable supervisory body of a suspected data breach where we are legally required to do so.
We have procedures in place to evaluate the security measures adopted by the third parties to which we transfer data, and mandate that they must have similar or equivalent security measures in place.
However, please also remember that we cannot guarantee that the Internet itself is 100% secure. Although we will use our reasonable endeavours to protect your Information, we cannot guarantee the security or integrity of personal Information that is transferred from you or to you via the Internet. Transmission of personal Information to and from the Bold Insight Platform is therefore at your own risk. You should only access our services within a secure environment.
11. DO WE COLLECT INFORMATION FROM MINORS?
In Short: In occasional circumstances, we may collect and process information relating to minors, but only ever with the informed consent of the minor and their parent or guardian (as applicable).
We do not knowingly market to children under 16 years of age. In exceptional circumstances, we may collect and process information relating to minors, but only ever with the informed consent of the minor and their parent or guardian (as applicable). If we learn that Information from users less than 16 years of age has been collected without such consent, we will take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under 16 years of age without the correct consent, please contact us immediately via [email protected].
12. YOUR CONSENT TO PROCESSING
You will be required to give Consent to certain processing activities before we can process your Information. Where applicable, we will seek Consent from you when you first submit Information to or through the Bold Insight Services.
If you have previously given your Consent, you may freely withdraw such Consent at any time. You can do this by emailing [email protected] or, where applicable, clicking the ‘Unsubscribe’ button that appears in mailing list communications.
If you withdraw your Consent, and if we do not have another legal basis for processing your Information, then we will stop processing your Information. If we do have another legal basis for processing your Information, then we may continue to do so subject to your legal rights.
Please note that if we need to process your Information in order for you to use the Bold Insight Services and you object or do not provide Consent to us processing your Information, you accept that the Bold Insight Services will no longer be available to you.
13. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: You have certain rights in respect of your Information.
You have certain rights in relation to the Information that we hold about you. Details of these rights and how to exercise them are set out below. Please note that we will require evidence of your identity before we are able to respond to any requests. This is a security measure to ensure that your Information is not disclosed to a person who does not have the 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. To exercise or discuss any of your rights, please contact us via [email protected].
- Right of Access. You have the right at any time to ask us for a copy of the Information that we hold about you and to check that we are lawfully processing it. Where we have good reason, and where data protection law permits, we can refuse your request for a copy of your Information, or certain elements of the request. If we refuse your request or any element of it, we will provide you with our reason(s) for doing so.
- Right of Correction or Completion. If Information we hold about you is not accurate or is out of date and requires amendment or correction, you have a right to have the data rectified or completed.
- Right of Erasure. In certain circumstances, you have the right to request that the Information we hold about you is erased (for example, if the Information is no longer necessary for the purposes for which it was collected or processed, or our processing of the Information is based only on your Consent and there are no other legal grounds on which we may process the Information).
- Right to Object to or Restrict Processing. In certain circumstances, you have the right to object to our processing of your Information (for example, if we are processing your Information on the basis of our legitimate interests but there are no longer any compelling legitimate grounds to justify our processing overriding your rights and interests). You may also have the right to restrict our use of your Information, for example during a period in which we are verifying the accuracy of your Information in circumstances where you have challenged the accuracy of that Information.
- Right of Data Portability. In certain instances, you have a right to receive the Information that we hold about you (or a portion thereof) in a structured, commonly used and machine-readable format. In such circumstances, you can ask us to transmit your Information to you or directly to a third-party organisation on your behalf. While we are happy for such requests to be made, we are not able to guarantee technical compatibility with a third-party organisation’s systems. We are also unable to comply with requests that relate to personal Information of others without their consent.
If we are relying on Consent to process your Information, you have the right to withdraw your Consent at any time. Please note however that this will not affect the lawfulness of the processing that occurred before the withdrawal of such Consent.
14. CONTACT US
We welcome your feedback and questions on this Policy. If you wish to contact us about this Policy or have any other questions, please email us via [email protected].
You have the right to make a complaint at any time to the Information Commissioner’s Office (the ICO), the UK supervisory authority for data protection issues (https://ico.org.uk/concerns). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.