QualSights Privacy Policy

Georama Inc. d/b/a QualSights (“QualSights”) is a Delaware (USA) corporation, and our principal office is located at 541 N. Fairbanks Ct, Suite 2200, Chicago, IL 60611 USA. If you have any concerns or questions about any of the provisions of this Privacy Policy please feel free to contact us via the following: privacy@qualsights.com.

Please review this policy (“Privacy Policy”) carefully. This policy is designed to explain: (1) how our service works; (2) the kinds of personal data that we and our customers may collect and process via this service, and (3) how we manage those data.

Before you read this policy, please understand that we are committed to respecting the privacy rights of all individuals, wherever located.


Privacy Shield

QualSights complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. QualSights has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.

To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

In compliance with the Privacy Shield Principles, QualSights commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact QualSights at: privacy@qualsights.com.

If a privacy complaint arises and cannot be resolved through QualSights’s internal processes, QualSights has agreed to participate in the VeraSafe Privacy Shield Dispute Resolution Procedure. Subject to the terms of the VeraSafe Privacy Shield Dispute Resolution Procedure, VeraSafe will provide appropriate recourse free of charge to you. To file a complaint with VeraSafe under the Privacy Shield Dispute Resolution Procedure, please submit the required information to VeraSafe here: https://www.verasafe.com/privacy-services/dispute-resolution/submit-dispute/


CCPA and ‘Do Not Sell’

All data collected or processed by QualSights will be processed in accordance with our “Do Not Sell” policy statement. For specific information relating to our practices regarding the collection and sale of personal information and the principles of the CCPA, please review the policy statement at: https://www.qualsights.com/do-not-sell/.


If you are an Individual and You Have Privacy Questions or Concerns

If you are an individual (whereever located) and you have concerns or questions about QualSights’ privacy practices, or if you want to understand how you can limit the use or disclosure of your personal information, please contact us at privacy@qualsights.com..


1. The Scope of this Policy

This Privacy Policy applies to our website (www.qualsights.com); to all web-based and mobile applications that are a part of our platform (hereafter “Applications”); and to all data and/or information collected via our website or the Applications. For the purposes of this policy we refer to the website and the Applications collectively as the “Site” or “Sites”, as applicable.

This Privacy Policy may change from time to time; and any changes will be effective immediately upon the posting of the revised Privacy Policy.

2. How our Service Works

QualSights provides a unique online service which allows our customers (which are generally businesses) to observe and understand how consumers shop for, use, consume, and/or experience products, services and related items (e.g. groceries, packaging, marketing materials) in a variety of real-world environments.

To make this possible, our platform provides several interrelated features that allow our customers (again, businesses) to initiate and engage in live or recorded interview sessions and activities with research participants using any of a variety of possible devices (e.g. smartphones, cameras, etc.) in any of a variety of contexts (e.g. video/photo/audio activities, video/audio interviews & focus groups, surveys, in-person fieldwork). All participation by research participants is entirely voluntary.

All of the features of our platform can be fully configured by our customers, and as such, any given research project may include audio recording, recorded videos or photographs, screen captures, video live feed and recording, and collection of surveys and text/written comments/responses. QualSights’ platform then allows customers to process the raw data resources so gathered using a variety of technologies, to generate highly-focused insights into research subjects’ behavior. Examples of such processing technologies include machine transcription, identification of keywords & topics, sentiment analysis, etc.

3. QualSights is Usually a Data Processor/Service Provider

For the vast majority of our engagements we operate as a data processor (under the GDPR) or as a service provider (CCPA). This is because our customers choose which data to collect and process, and how; and as such our customers function as data controllers and/or covered businesses.

Important:

  • If you are a customer of QualSights (not a research participant), you should understand that you are a data controller and must be in compliance with the requirements of applicable privacy laws.
  • If you are a research participant who is engaged by a customer of QualSights, you should understand that all of the research data generated by or through our platform will be available to and controlled by that customer; and if you have any concerns or questions regarding your privacy rights, you should contact the customer directly.
  • Because we can only access a customer’s data with that customer’s direct authorization, if we receive a direct request for information or assistance from a research participant (data subject) relating to data collected by a customer, we will refer the request to the customer that such individual specifies in their request (or the research participant can identify the research project). QualSights will not respond directly to a research participant’s request without the prior consent of our customer.

4. Occasionally, QualSights Is a Data Controller/Covered Business

In certain circumstances QualSights may enter into engagements directly with research subjects (individuals) in order to allow such individuals to participate in research studies that are intended to reveal broad consumer or market insights that may be shared with one or more of our customers. We refer to these as “Direct Engagements”. For Direct Engagements, QualSights acknowledges that it may be functioning as a data controller (GDPR) or covered business (CCPA) for that portion of an engagement in addition to its role as a data processor/service provider overall.

In order to protect the interests of our Site users and to comply with the requirements of relevant laws for personal data that may be collected during Direct Engagements, we have implemented a series of technical and organizational measures, as described below in Section 8, as well as the other measures described in this Privacy Policy.

Important:

  • If you are a research participant who is engaged by QualSights for a Direct Engagement, you should understand that the primary research data generated/captured by our platform (e.g. videos, comments, pictures, etc.) and certain limited demographic information (age, gender, geographic region) will be shared with one or more customer(s); however, we will not share personal contact information (name, email, telephone number) with customers.
  • Remember that participation in this kind of project is strictly voluntary. If you have any concerns or questions regarding your privacy rights, you should contact us directly. If you wish at any time to review the data that have been collected, or to withdraw your consent, you may do so (our contact information is below).

5. Overview of The Personal Data That We Process; and The Legal Basis for Such Processing

A. Customer Account Information:

In order to operate our service, we collect basic account information from our customers. That information includes personal data such as employee names, business contact information (e.g. address, phone number, e-mail address), employment titles/roles, the employment status of certain individuals. Payment processing data is addressed as set forth in Section 6, below.

QualSights acts as a data controller for all such data; and we process all such data on the basis of the express consent of the customers and individuals involved and our legitimate interests in operating our business.

B. General Browsing Data/Site Usage Data:

We collect general browsing and/or usage data from individuals who visit the Sites; however, all such data are fully anonymized for internal research purposes. In this activity, QualSights acts as a data controller; and we process these data on the basis of our legitimate interests in understanding and improving our services.

In addition, we reserve the right to use certain information (e.g. IP addresses) that may be collected in order to identify a visitor when we feel it is necessary to enforce compliance with our Terms or to: (i) fulfill a government request; (ii) conform with the requirements of the law or legal process; (iii) protect or defend our legal rights or property, our Site, or other users; or (iv) in an emergency to protect the health and safety of our Site users or the general public.

C. Research Participant Data:

Depending on the options selected by a customer, the personal data that may be collected by a customer using our platform may include the following: names, age information, geographic information (e.g. city, country) and other account-related information (e.g. telephone number, email address). In addition, the service may capture audio recordings, photographs, screen captures, video recordings (including faces), survey responses and written comments. And the service tracks a limited amount of information to verify which activities a research participant has completed during a research session. Further, the platform can be configured by our customers to substitute a unique identifier (a number or alphanumeric code) for account information. We refer these data collectively as “Participant Personal Data”.

We process Participant Personal Data based on the express consent of research participants and as required in order to fulfil our contractual obligations with our customers. We may also use Participant Personal Data to communicate directly with research participants, if requested or necessary.

We also process Participant Personal Data in accordance with our “Do Not Sell” policy statement (see https://www.qualsights.com/do-not-sell/).

Important:

  • Individuals who have been engaged directly by a customer, and who have provided data based on consent, may have the right to withdraw such consent. Such individuals should contact the customer directly for this purpose.

6. Cookies

We may, from time to time, use cookies (small text files placed on your computer or device, which help our Site or Applications function better) in connection with our Sites; and we may analyze the information derived from these cookies for the same purposes as set forth elsewhere in this Privacy Policy. You may be able to limit the use of cookies on your computer or mobile device in general by modifying the settings of your web browser (e.g. Internet Explorer, Chrome, etc.).

We may use the following types of cookies on the Sites:

  • Convenience” cookie: We use a single cookie to store certain registration information. You may be able to configure your browser to block/delete these cookies; but if you do, you will have to input the account-related information every session.
    • You have the option to opt out of convenience cookies (if applicable) when you visit our website.
    • If you do not opt out, and you would like to delete any account information we may store via convenience cookies, you can take the following actions: (1) you can delete your QualSights cookies (via your browser); and/or (2) you can reach out to us as specified in this Privacy Policy.
  • Analytics” cookies which help us to determine usage patterns of our web pages by collecting information about how visitors use our Site.
    • More specifically, we use Google Analytics for aggregated, anonymized website traffic analysis. In order to track your session usage, Google places a cookie with a randomly generated Client ID number in your browser. This ID number is anonymized and contains no identifiable information like email, phone number, name, etc. Google also has access to your IP address. We use Google Analytics to track aggregated website behavior, such as what pages you looked at, for how long, and so on. This information is important to us for improving the user experience and determining site effectiveness.
    • If you would like to understand what Google Analytics-derived browsing information we may have and/or want to delete any Google Analytics data, you can take the following actions: (1) you can delete your cookies (via your browser);(2) you can reach out to us as specified in this Privacy Policy, and/or (3) you can install the Google Analytics Opt-Out Browser Add-On.

You can change your Internet browsers’ preferences (whether computer or mobile device) to disable or delete non-necessary cookies, although that may affect certain functions on the Sites. To learn how to manage your cookies, please follow the instructions from your specific browser. If you wish to opt out of any cookies on our Sites, and need additional assistance, please contact us.

7. Third Parties with Whom We May Share Personal Data

In addition to the sharing of the personal data of Research Participants with applicable Customers, by necessity, QualSights may share certain personal data with third party service partners which are under contract with us and which perform Site-related functions on our behalf. These service partners are sub-processors under the GDPR; and they include certain cloud-based service providers (listed below) which provide aspects of the Sites’ functionality (e.g. cloud-based application hosting, cloud-based storage).

We share data with our service partners on the basis of our users’ express consent and our legitimate interests in operating our business. We maintain written contracts with these third parties and require that these third parties provide at least the same level of privacy protection and security as required by the Privacy Shield Principles.

In addition, please understand that these disclosures are to third parties which are providing services to QualSights, in connection with the operation of our business, and we will only make such disclosures as are consistent with the purpose for which the personal information was collected. To the extent provided by the Privacy Shield Principles, QualSights remains responsible and liable under the Privacy Shield Principles if a third-party that it engages to process personal information on its behalf does so in a manner inconsistent with the Privacy Shield Principles, unless Qualsights proves that it is not responsible for the matter giving rise to the damage.

Third Party Service Partners include: Microsoft Azure, Amazon Web Services, Digital Ocean, Google Cloud, IBM Cloud, VoiceBase, Rev, GoTranscript.

In addition, we may now or in the future allow or facilitate payment processing functions via our Sites. QualSights has no access to, and does not retain or record, any payment processing information.

8. Measures Adopted by QualSights to Protect Privacy Interests

A. Data Mapping; and Data Protection by Design and Default:

We build data maps to ensure that we understand what personal data may be collected via our Sites and how it may flow through our services. We have adopted internal policies that require us to prioritize privacy concerns in the design phase of all new features for our platform. And (when we are the data collector) we only collect and process those data that we need to perform the processing that we have disclosed to research participants.

B. Data Minimization; Data Disposal:

Where possible, we minimize the personal data being processed. And we have adopted policies that require us to delete or anonymize all data that are no longer required for research purposes.

C. Security of Data and Processing:

We have implemented technical and organizational measures that are designed to limit access to personal data to authorized individuals (either our team or customer representatives, as applicable), including multiple levels of authorization, audit trails, security monitoring tools, and procedures designed to limit and remove access when no longer required.

We have also implemented data security technologies designed to preserve the security of all data collected and/or processed on our platform, including encryption for all such data in transit, and also encryption of sensitive data at rest within our platform.

We have also implemented technological and administrative controls designed to prevent the loss or corruption of data.

9. Other Terms

A. Geographic Aspects of our Privacy Practices; International Transfer:

QualSights is based in Chicago, IL, USA; we have significant operations in India; and we serve customers and research participants who are located throughout the world. Please be aware that your personal data may be transferred to, and be processed in, countries other than the country in which you are a resident. These countries may have data protection laws that are different to the laws of your country.

Further, please understand that elements of our service platform (including servers) are located in the United States, Europe and Asia, and our third-party service providers (including cloud service providers and partners) operate around the world. This means that when we collect personal information, we or our customers may process it in foreign jurisdictions.

We have implemented measures (including Privacy Shield certification) to assure that transfers of data between us and our customers are compliant with applicable laws. If you have concerns, please contact us.

B. Transfer of Assets:

As we continue to develop our business, we may sell or purchase assets. If another entity acquires us or acquires all (or substantially all) of our assets, the personal data in our platform will be transferred to and used by this acquiring entity. Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such information may be considered an asset of ours and as such may be sold or transferred to third parties.

C. Children, Parental Consent, and Privacy:

The Sites are not directed toward individuals under age 18; we do not knowingly collect information from anyone under age 18 (a “Minor”); and if we find out that we have collected information from a minor under age 18, we will delete that information immediately.

The only exception to the preceding statement may arise if a parent voluntarily consents to the participation of a Minor (child) in a research study. In such circumstances the parent will be deemed to have provided express and informed consent to the participation of such Minor in such capacity; such parent is responsible for communicating with QualSights about the interests of such Minor; and the parent must remain with the Minor at all times that the Minor participates in the relevant project. In no event may a Minor create an account or use the Sites on an individual basis.

D. Third Party Sites and Links:

We are not responsible for the privacy practices and/or security practices employed by any third-party website or service, including but not limited to any such sites or services that may be linked to or referred to in any way on the Sites.

E. Do Not Track:

The Site itself may not respond to web browser-based “do not track” signals.

F. Biometric ID Processing:

QualSights does not use any technologies (e.g. face recognition) that are designed to identify an individual based on data (e.g. photogaphs) collected/processed by the system, and we prohibit our customers from doing so as well.

G. Legally Required Disclosures, Investigatory Power of FTC:

Notwithstanding anything herein to the contrary, we reserve the right to disclose any personal data if we are required to do so by law, in order to assert or defend copyright or other intellectual property infringement claims, or if we believe that such action is necessary to: (1) fulfill a government request; (2) conform with the requirements of the law or legal process; (3) protect or defend our legal rights or property, our Sites, or other users; or (4) in an emergency to protect the health and safety of our Sites’ users or the general public.

In addition, QualSights and the Sites are fully subject to the investigatory and enforcement power of the Federal Trade Commission (FTC).

10.Dispute Resolution; Binding Arbitration

Upon receipt of any claim or complaint (hereafter a “Claim”) based on any matter addressed by or arising under this Privacy Policy, QualSights will (if necessary) investigate and respond to the Claim within a reasonable time period. QualSights will attempt to resolve any Claim, in good faith, to the satisfaction of the individual submitting the Claim.

If a Claim relates to a Privacy Shield principle, and the Claim is not resolved by QualSights to the satisfaction of the individual who submitted the Claim, and the Claim is not otherwise resolved by any other Privacy Shield mechanism, then the individual may initiate binding arbitration under provisons of Annex I to the Privacy Shield. Annex I is available at: https://www.privacyshield.gov/article?id=ANNEX-I-introduction.

10. Contact Information

You may contact us as provided below if: (a) you have questions or comments about our Privacy Policy, or your personal data; (b) you wish to make corrections to any personal data you have provided; (c) you have voluntarily submitted your contact information to us, and you want to opt-out from receiving future correspondence, including emails, from us; (d) you wish to withdraw consent for any ongoing data processing activity; and/or (d) you otherwise wish to contact us in connection with any provision set forth in this Privacy Policy or the Terms:

privacy@qualsights.com

We will respond to your request and, if applicable and appropriate, make the requested changes as soon as reasonably practicable. Please note that fulfilling certain requests may have an impact on your use of the Sites.