- Who we are
- What personal information we collect
- When and how we collect your personal information
- How we use your personal information
- How we protect your information
- How long we keep your personal information
- Accessing hyperlinks and other websites
- Use of the C Space mobile application
- Special information for California residents
- Data originating from the European Economic Area (EEA)
- How we collect and use information about children
- Your choices and rights
- Rights for EEA Residents
- Questions or feedback
Who We Are
Promise Corporation Limited t/a C Space is a wholly owned subsidiary of Communispace Corporation d/b/a C Space. Promise Corporation Limited and Communispace Corporation are collectively referred to in this policy as “C Space.” C Space is a leading provider of market research services. Our services include conducting online market research projects (“Communities”) on behalf of our clients (“Sponsor”) as well as providing downloadable market research insights and information through our Site.
What Personal Information We Collect
The information we collect on our Site and through Communities generally falls into the following two categories: Personal Information and Non-Personally Identifiable Information. Personal Information refers to information that lets us know the specifics of who you are. Non-Personally Identifiable Information refers to information that does not by itself identify a specific individual. If we do combine Non-Personally Identifiable Information with Personal Information, the combined information will be treated as Personal Information for as long as it remains combined.
In general, we collect Personal Information about you through our Site related to your identity and contact information such as your name, e-mail address, company name, job title and company address. If you participate in our Communities, we may collect additional Personal Information about you, such as your date of birth, home address, phone number, online user identity (ex. social media accounts), marital status and family details. We may also collect limited amounts of Sensitive Data, such as health information, through certain Communities.
Other data may be collected automatically through the website (such as IP addresses, browser characteristics, device characteristics, operating system, language preferences, referring URLs, information on actions taken on our website, and dates and times of website visits).
When and How We Collect Your Personal Information
In general, we collect your Personal Information when you voluntarily provide it on our Site and through our Communities. When you provide Personal Information to us, we may ask if you want to receive future marketing information and communication from us, such as newsletters, email or other information. You can choose not to receive this communication, if you wish. If you have already chosen to receive such communication, you can ask us to stop by clicking the opt-out link on any email communication, or by emailing a request to firstname.lastname@example.org. C Space may also obtain Personal Information from trusted vendors who have previously obtained information and appropriate permission and consent from you.
We may use the following types of Cookies within our Site and our mobile applications:
1. Strictly necessary cookies – “Strictly Necessary” cookies are required for the operation of the Site. These cookies let you access and navigate the Community and allow you to use essential features and secure areas. Without these cookies, services you have asked for cannot be provided. Please note that we do not use information gathered from these cookies for marketing purposes or for remembering where you’ve been on the internet.
2. Analytics cookies – These cookies allow us to track and analyze page visits and traffic sources so we can measure and improve the performance of our Site using a service provided by Google Analytics. They allow us to collect statistical information about our visitors, such as whether they have visited the Site before and the pages they view. This information is gathered anonymously; it does not enable us to identify who you are and we do not combine any analytic information we collect from these cookies with your personally identifiable information.
3. Preference cookies – These cookies may be used to save your personal preferences so that we can remember your settings and display personalized information to you the next time you visit. Generally, these types of cookies require you to “opt in” to store your preference.
4. Session cookies – These cookies store temporary information to enable Site functionality. They are automatically deleted when you close your browser.
5. Third Party cookies – These cookies may be set on our Site by other companies or “third parties”. These companies may collect data that enables them to display advertisements on other sites that are relevant to your interests or these cookies may be used to allow for functionality of third party applications or devices we offer on our Site. For more information on these cookies, please visit the relevant third-party website.
How We Use Your Personal Information
Information Collected Through our Site: Personal Information you provide through C Space’s Site is used to provide you with email updates and marketing communications from us about our services, such as newsletters or emails. Your information may also be used to help us track the way you use our Site and our products. We may also combine the information you provide with information that we collect separately, including information you have provided to other organizations (with consent that it can be shared) as well as public information. All of this information will help us to better understand your needs and how we can improve our products and services.
Information Collected Through our Communities: Personal Information you provide through C Space’s Communities is used for market research purposes, such as:
a. to determine whether you meet the criteria for a “Community;”
b. to communicate with you regarding C Space’s services and/or your participation in a Community;
c. for market research conducted on behalf of a C Space client;
d. to analyze, evaluate and/or improve C Space’s Site, services and/or market research tools.
We will not use Personal Information collected through Communities for direct marketing purposes (however, if you have provided your information to C Space in other ways, such as through our Site, we may use your information to contact you as set forth above).
In some circumstances, the information you provide may include Sensitive Data (ethnicity, income, education, etc.). C Space collects such Sensitive Data solely for meeting the market research goals of C Space and the Sponsor. Specifically, collecting this Sensitive Data allows C Space and the Sponsor to create a balanced community reflective of a certain consumer population or its segments. Such information is not collected for any discriminatory purposes. You will always retain the right not to answer any question with which you do not feel comfortable.
How We Protect Your Information
We use reasonable and appropriate technological and physical safeguards to protect Personal Information you provide to us from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the Personal Information. We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. In order to ensure that your information is protected when transferred out of the EEA, C Space relies on inter-company agreements between our various affiliates that may process your information on behalf of C Space. If you would like a copy of these agreements, please email us at email@example.com.
How Long We Keep Your Personal Information
In general, we will only retain your information for the time necessary to realize our legitimate business purposes and to comply with the law. However, we may continue to store anonymous or anonymized information, such as Site visits, without identifiers, in order to improve our services.
Accessing Hyperlinks and Other Website
Currently, to help facilitate login to our communities, we may offer in some Communities, at the Sponsor’s discretion, a sign-on service that allows you to sign into your Community using login credentials from your Facebook® account. This allows you to associate your existing Facebook® profile with your C Space account. By linking these accounts, C Space will have access to certain profile information contained within your Facebook® profile such as your full name, email, locale, gender, profile picture, as well as other publicly available profile information. No Community content will ever be shared on Facebook® without your express permission. You can disassociate your Facebook® account from your Community account at any time by clicking “Unlink” on your Member Profile page.
Use of the C Space Mobile Application
In some Communities, members may have the option to participate in Community activities on their mobile device through C Space’s mobile application. Use of the mobile application is voluntary and optional. Members who choose to use the mobile application must provide their Community login and password to access and complete mobile Community activities. The mobile application may request your permission to collect location data and/or may request access to multimedia stored on your mobile device (i.e. photos or videos). Location data is not required for participation in Community activities; if you do not wish for your location data to be submitted, please respond accordingly when prompted on your mobile device. Multimedia will only be collected from your device if you affirmatively select it for submission through the application (i.e. you chose an image or video to submit for a Community activity). You can change your permissions with respect to location data and multimedia sharing through the settings feature on your mobile device. Any information and content collected through the mobile application will be used consistent with this Policy and the policies and agreements applicable to your Community.
Use of the mobile application may not be available in all Communities, at the Sponsor’s discretion.
Special Information for California Residents
Under the California Consumer Privacy Act (CCPA), California Residents are afforded certain rights over their personal information, which are detailed below. To exercise any of these rights, please visit our California Residents’ Landing Page here or email firstname.lastname@example.org.
In order to help you exercise your rights, we require what the CCPA calls a “Verifiable Consumer Request.” When contacting us about your rights, we need to be assured within reason that you are not being impersonated, and so contacting us through an email address that you have previously used to sign up to a community or event run by C Space is preferable. In case this is not possible, we will use alternate methods to verify your identity. You may make up to two requests of any one type within a 12-month period. We require that you provide clear details on what you are looking for, so that we can assist you in the most appropriate way. Please allow up to 45 days for a response.
Your rights pertain to the collection and use of your personal information over a period of the last 12 months. Upon the receipt of a verifiable consumer request from you, you have the right to request to:
• See the categories and the specific pieces of Personal Information that C Space holds on you.
• Deletion of the Personal Information being held on you by C Space.
• Be provided with a breakdown of information collected, the categories of sources from which the information is gathered, the business purpose(s) for processing the information, the categories of third parties with whom C Space shares this information, and the specific personal information gathered regarding you.
• See an itemized list of the categories of Personal Information collected, sold and disclosed about you.
• Opt out of the ‘sale’ of your personal information (‘selling’ defined in the CCPA as including transfer to our partners as part of normal business practices – C Space would never sell your personal information to marketers) and can enforce this right by submitting a request at our California Residents’ Landing Page.
Data Originating from the European Economic Area (EEA)
The Legal Basis for Using European Personal Information
When we collect information about you through our Site, the legal basis on which we process your Personal Information is our legitimate interests, namely, to provide you with information marketing our technology and services.
When we collect information about you through our Communities, the legal basis on which we process your Personal Information is the performance of our contract with you to participate in our Communities. If we collect any information about you through our Communities and process it in a way that is not necessary for our performance of our contract with you, the legal basis on which we will process your Personal Information will be your consent.
Storage and Processing of Personal Information Outside the EEA
If you are located in the EEA, your Personal Information is processed by C Space’s EU based affiliate, Promise. Please note that as part of our service, we may transfer your personal information to other regions, including to the United States.
To learn more about the Privacy Shield Program and to view our certification, please visit: privacyshield.gov.
C Space has mechanisms in place designed to help assure compliance with the Privacy Shield Principles. C Space conducts an annual self-assessment of its Personal Information practices to verify that the attestations and assertions C Space makes about its Privacy Shield privacy practices are true and that C Space’s privacy practices have been implemented as represented and in accordance with the Privacy Shield Principles.
You may file a complaint concerning C Space’s processing of your Personal Information. C Space will take steps to remedy issues arising out of its alleged failure to comply with the Privacy Shield Principles. You may contact C Space as specified below about complaints regarding C Space’s Personal Information practices.
In compliance with the Privacy Shield Principles, C Space commits to resolve complaints about our collection or use of your Personal Information. EU and Swiss individuals with inquiries or complaints regarding our Private Shield policy should first contact C Space at email@example.com.
C Space has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States, under the JAMS EU-US and Swiss-US Privacy Shield. The services of JAMS are provided at no cost to you. For more information and/or to file a complaint, please visit: jamsadr.com/eu-us-privacy-shield. C Space is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC) to ensure compliance with the EU-US and Swiss-US Privacy Shield principles outlined in this policy.
If your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.
Who We Share Your Information With
C Space shares Personal Information with its affiliates and subsidiaries. We may also share your information with companies who carry out work for us. C Space requires these companies to agree to:
a. only process the Personal Information for limited and specified purposes consistent with your consent;
b. provide the same level of protection for Personal Information as is required by the Privacy Shield Principles; and
c. notify C Space and cease processing Personal Information (or take other reasonable and appropriate remedial steps) if the company determines that it cannot meet its obligation to provide the same level of protection for Personal Information as is required by the Privacy Shield Principles.
We do not share the information you provide with third parties for their direct marketing purposes unless you affirmatively agree to such disclosure.
How We May Collect and Use Information About Children
C Space’s Site is not intended for use by children, particularly those under age 16, and we do not knowingly collect information from children. In the event that we learn that we have collected Personal Information on the Site from a child under age 16, we will delete that information as quickly as possible. If you believe that we might have any information from a child under 16, please contact us at firstname.lastname@example.org.
We do, however, collect information about children under the age of 16 from their parents through some of our Communities. We ask that our users do not provide information about a child without first obtaining consent from the child’s parents. Where appropriate, we will always ask for consent from a parent or guardian to collect information about children. In the event that we learn we have collected any Personal Information from a child under the age of 16 without verification of parental consent, we will delete that information from our database as quickly as possible.
Your Choices and Rights
You have several choices regarding the use and disclosure of your information.
Information You Provide: With respect to the collection of your information, if you do not want your Personal Information collected, please do not submit it to us. If you have already submitted information and would like to review, correct or remove it from our records, please contact your community facilitator or email@example.com.
Cookies: If you wish to disable cookies, you can set your browser not to accept cookies. You can find out how to do so here: aboutcookies.org. Please note though that if you turn off cookies, there may be some features and functions of our Site that will not be available to you and some pages may not display properly
Information Shared with Third Parties: You may also choose whether your Personal Information may be disclosed to third-parties or used for a purpose that is materially different from the purposes for which the information was originally collected or subsequently authorised by you. To the extent required by the Privacy Shield Principles, C Space obtains opt-in consent for certain uses and disclosures of Sensitive Data. You may contact C Space as indicated below regarding the company’s use or disclosure of your Personal Information. Unless C Space offers you an appropriate choice, we use Personal Information only for purposes that are materially the same as those indicated in this Policy.
Rights for EEA Residents
In addition, if you are a resident of the EEA, you have the right to:
• Find out if we use your Personal Information, to access your Personal Information, and receive copies of your Personal Information.
• Withdraw your consent to the processing of your Personal Information at any time without penalty.
• Access your Personal Information and have it corrected or amended if it is inaccurate or incomplete.
• Obtain a transferable copy of some of your Personal Information which can be transferred to another provider when the Personal Information was processed based on your consent.
• If you believe your Personal Information is inaccurate, unlawful, no longer necessary for our business purposes, or if you object to our processing of your Personal Information, you also have the right to instruct us to restrict the processing of your data pending our investigation and/or verification of your claim.
• Request your Personal Information be deleted or restricted under certain circumstances. For example, if C Space is using your Personal Information on the basis of your consent and has no other legal basis to use such, you may request your Personal Information be deleted when you withdraw your consent.
If you wish to exercise any of these rights, or raise a complaint on how we have handled your Personal Information, please contact us at firstname.lastname@example.org.
If you are not satisfied with our response, or believe we are processing your Personal Information in violation of the law, you can complain to the Information Commissioner’s Office ico.org.uk
Questions or Feedback
Attn: Tom Finocchio
Bankside 2 90-100 Southwark Street
London, SE1 0SW
%For all others%:
Attn: Tom Finocchio
290 Congress Street
Boston, Massachusetts 02110
Effective Date: January 1, 2020